RICHARD A. HENSON FIELD 

COMMERCIAL & COMMUTER AIRSERVICE I AVIATION MAINTENANCE I AIRSIDE SERVICES 

July 18, 2014 

Mr. Dennis J. DeVany, Chief 

EAS & Domestic Analysis Division 

Office of Aviation Analysis 

United States Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

REFERENCE: Docket DOT -OST -2006-25228 

SUBJECT: Petition ofHagerstown Maryland for Waiver from the 10-Enplanement Statute 

Dear Mr. DeVaney: 

The Hagerstown Regional Airport on behalf of Hagerstown Maryland hereby requests a waiver 

to Order 2014-6-6, issued June 24, 2014, terminating the eligibility of Hagerstown, Maryland 

under the Essential Air Service (EAS) program based on requirements passed by Congress in the 

FAA Modernization and Reform Act of2012 (Public Law No. 112-95). The Hagerstown 

Regional Airport requests an exemption from 49 U.S.C. § 41731(a) (1) (B) and as such submits 

the following information to support its petition for waiver: 

ABILITY TO MEET STANDARDS 

The Hagerstown Regional Airport has historically demonstrated its ability to meet or exceed the 

10-enplanement requirement. As recently as 2012 before the transition to the current carrier Sun 

Air, the previous carrier Cape Air with service to Baltimore International Airport had a two year 

average of 10.5 passengers per day. Prior to Cape Air's service, Air Midwest averaged 18.6 

enplanements per day with service to Pittsburgh International Airport. 

The Hagerstown Regional Airport is fully confident that the required number of enplanements 

can be met and exceeded if Essential Air Service is continued with Sun Air or other airlines at 

Hagerstown. 

OBSTACLES TO MEETING EAS STANDARDS 

The Hagerstown Regional Airport would like to cite the following facts that proved to be 

considerable obstacles to the EAS air carrier Sun Air's ability during the 313 day evaluation 

period to meet the 1 0-enplanement requirement during its startup of service at Hagerstown: · 

18434 Showalter Road 1 Hagerstown, MD 21742 1 P: 240.313.2777 1 F: 301.791.2590 I Hearing Impaired: 7-1-1 

flyhagerstown.com 
Dennis De Yaney 

July 18, 2014 

Page 2 of3 

• Sun Air CEO was averse to adequately marketing the Sun Air product. 

• Sun Air started service with unreliable aircraft that decimated dispatch numbers. 

• Sun Air had aircraft not equipped to operate in winter weather conditions. 

At the start ofEAS service by Sun Air, its CEO at the time did not engage in a robust marketing 

campaign to promote the service. Passenger counts lagged for lack of public awareness of the 

service. This persisted despite the efforts of the Hagerstown Regional Airport and the 

Washington County Department of Community Relations and Community Affairs to assist with 

the marketing effort. 

During the startup period, Sun Air did not have an adequate maintenance facility established or 

contractors in place to respond in a timely manner to aircraft discrepancies that time and again 

delayed or cancelled departure times. 

During the first winter of its operation, Sun Air utilized aircraft that were not equipped with any 

anti-ice or de-ice capabilities. This resulted in numerous cancellations due to weather. 

SEQUESTRATIONS NEGATIVE IMP ACT ON MEETING EAS STANDARDS 

Sequestration came into full force as Sun Air was commencing its entry into the new market. 

This had a significant negative impact on Sun Air's startup efforts at Hagerstown. The 

sequestration imposed the mandatory reduction ofF AA resources. This forced the agency to 

redirect its resources, from the activities needed by Sun Air to start operations in a timely and 

efficient manner, to enforcement and monitoring. 

• Sun Air had a shortage of route qualified pilots. 

• Sun Air had difficulty getting aircraft approved on its Operating Certificate 

• Sun Air's cold weather operations manual revisions (for ground de-icing and related 

activities) did not get reviewed and approved for the 2013 winter season. This caused 

significant flight disruptions and a major loss of customers. 

Sun Air had difficulties in securing route checks and other required FAA check rides for its pilot 

staff. There was one period in excess of nine months in which Sun Air did not accomplish one 

successful check ride. 

Sun Air had difficulty getting aircraft inspected by the FAA and placed into service as authorized 

by its Operating Certificate. This lack of aircraft for daily schedules and as maintenance spares 

adversely impacted Sun Air's dispatch reliability. 

There is no doubt that the sequestration was a tremendous burden on Sun Air as it started 

operations. This fact coupled to the others listed above conspired to make Sun Air's EAS debut 

and subsequent enplanement numbers dismal. 

REMEDIES TO OBSTACLES TO MEETING EAS STANDARDS 

The Hagerstown Regional Airport would like to describe the remedies that Sun Air has initiated 

to meet and exceed the 1 0-enplanement standard: 

• Sun Air has secured a new CEO and other senior management. 

• Sun Air has hired a Marketing Manager to develop the service at Hagerstown. 

• Sun Air has established a maintenance base in Lancaster, Pennsylvania. 
Dennis De Yaney 

July 18, 2014 

Page 3 of3 

Sun Air's new management team assumed control of operations in October 2013. They 

immediately set about to remedy the issues that had plagued Sun Air's prior performance. 

The new management increased qualified pilot numbers, improved the availability of aircraft for 

dispatch and worked tirelessly to improve local service at Hagerstown. 

The dispatch reliability factor rose from 20% at the start of service to a high of 99% today. Also, 

the increased emphasis on customer service has paid dividends by steadily increasing daily 

enplanements. Sun Air recently adjusted their schedule to better align with the United Airlines 

flight out of Dulles in an effort to increase the enplanements out of Hagerstown. 

The Marketing Director has been aggressive in promoting the Sun Air service. He has been 

working tirelessly with the local community to get passenger levels to increase and help business 

expand in this region which includes catchment area encompassing four-states. 

These aggressive tactics have been rewarded with a growing cadre of frequent flyers from 

several local companies and small business owners who rely on the Sun Air Service to meet their 

travel requirements. 

These efforts by Sun Air to market their product here at Hagerstown have been rewarded by a 

demonstrable growth in enplanements. The number of enplanements has steadily increased from 

3.9 as reported during the startup period to the current number of8 enplanements per day. We 

anticipate this growth to continue and the 10 enplanement per day statute of the EAS if our 

petition for waiver is granted. 

The Hagerstown Regional Airport knows that there is a broad customer base that will utilize a 

reliable air service product from Hagerstown to business and travel destinations both domestic 

and international. The EAS program at Hagerstown is meeting that demand and growing in 

visibility and popularity. It would be a tremendous detriment to air commerce in this region if the 

EAS program here at Hagerstown is allowed to go dark. 

Airport Director 

Cc: Kevin Schlemmer, Director of EAS 

Attachments 

Board of County Commissioners 

of Washington County, Maryland 

.J..,~.,. 

ohn F. Barr, Vice-President 

/2JA Cl,__ c~~ Ruth Anne Callaham, Commissioner 

issioner 
•••••••••• tiAGEKSTOWN - e e e e e e e e WASHINGTON COUN IV e e e. 

CHAMBER ·:· 

of ( om men e 

January 24, 2014 

Mr. David Hackett, CEO 

Sun Air International 

3201 Griffin Rd. Suite 202 

Fort Lauderdale, FL 33312 

Dear Mr. Hackett: 

The Hagerstown-Washington County Chamber of Commerce believes that local passenger air service 

is a critical transportation link for our membership and that it is important for the continued growth and 

prosperity of the quad-state region. For several decades, local air service has enabled our business 

community to foster and strengthen relationships around the world. This has allowed employers 

throughout our region- from Chambersburg, PA to the north, Frederick, MD to the east and 

Winchester, VA to the south- the ability to better compete and expand into new markets. 

Such high-profile and well-respected organizations as VOLVO, Manitowoc, Oshkosh, Meritus Health, 

Macy's, First Data, CSX and Citi, the U.S. National Park Service and the U.S. Army have a continued 

expectation that our transportation infrastructure can and will support their future business 

requirements. That infrastructure includes regularly-scheduled service to meet the air travel needs of 

staff, customers and management. 

Aviation in Hagerstown has a proud and rich heritage dating back nine decades and including such 

historically prominent names as Bellanca, Kreider-Reisner, Fairchild Industries and Henson Aviation. 

Over the years, whether via connections to Pittsburgh, Baltimore or Washington, daily passenger 

service has been a vital link for our Chamber members to connect to the world marketplace. The 

Chamber supports Sun Air in its efforts to further strengthen its commitment to providing daily local air 

service for Hagerstown. 
Gale 7 LLC 

1098 Armada Drive 

Greencastle. PA 17225 

USA 

Tel:+ 1 717 593 0204 

Fax: + 1 717 593 0208 

www.gate71/c.com 

sales@gotelllc.com 

Todd Willman 

Sun Air International 

Galct 7Ud 

Princes Park. Princesway, 

TVTE Galeshead, Tyne & Wear. 

NE 11 ONF, England. 

Tel: +44 (0) 191 487 8548 

Fax: +44 (0) 191 487 8547 

www.gate7.co.uk 

soles@gole7.co. uk 

65 Jeffries Court 

Chambersburg, PA 17202 

61

h May 2014 

Dear Todd, 

GATE7 

GROUP 

It was good to finally meet you on Thursday May rt, I know we have spoken a few times on the 

telephone and via email. 

We have found Sun Air to be a great link between Hagerstown and Dulles Airport both for domestic and 

International flights. Our CEO is from the UK and he uses Sun Air on all his return flights, he always 

states how very convenient it is to land in Terminal Bas his British Airways flight is also out of Terminal 

B. He therefore does not need to hire a car or have somebody drop him at Dulles and proceed with long 

security lines. We used to joke when we first started business in Shady Grove, PA, wouldn't it be great to 

fly from our local airport in the UK to Hagerstown, with Sun Air we now have that. 

I also use Sun Air to fly domestically, I now try to select flights from Dulles instead of BWI for the easy 

link with Sun Air, this actually saves me money as we have no airport parking or car hire to Dulles and in 

under 40 minutes we are landed and security side in Dulles. 

' 

Hagerstown and Greencastle and over an hour drive from Dulles, Baltimore, Reagan and Harrisburg, add 

in the fact you need to be at the airport at least an hour and a half before that to, get through security, 

park a car or return a hire car, you are basically setting off 3 hrs before your flight. I actually decide to 

drive to some appointments which are less than 8 hours, simply because it can take 6 hours with the 

commute to one of the regional airports. With Sun Air, I can take at least an hour out of this scenario. 

My company and work associates are great supporters of Sun Air, we promote Sun Air to anybody 

visiting our facility. 

Cc Keith Wickham (CEO & President) 

Innovative Print Solutions 
PlnSBURGH INSTITUTE OF AERONAUTICS 

P. 0. BoK 10897 • Pittsburgh PA 15236-0897 

(412) 346-2100 • (412) 462-9011 • FAX (412) 466-051 3 

July 17, 2014 

To Whom It May Concern: 

As a partner in the Hagerstown aviation community, the Pittsburgh Institute of Aeronautics (PIA) 

supports a local air service and believes the continuation of Sun Air in Hagerstown is a vital part of the 

Western Maryland community and economy. 

As Washington County Maryland continues to develop future business opportunities and promotes 

economic development, affordable air travel from Hagerstown to Washington Dulles will be critical for 

future opportunities. 

The Pittsburgh Institute of Aeronautics-Hagerstown Campus is celebrating its one year anniversary in 

their newly constructed building located on the grounds of the Hagerstown Regional Airport. As you 

may be aware, PIA's Aviation Maintenance Technology Program leads to testing for the Federal Aviation 

Administration's (FAA) Airframe and Powerplant (A&P) Certification. 

In 2013, PIA-Hagerstown placed 94% of graduates in the aviation field or related industries. PIA 

graduates are highly sought after due to their transferable skills in technical accuracy in hydraulics, 

electronics and pneumatics. This educated workforce in the technical fields will be a catalyst to attract 

future business to this region and daily air passenger service to serve the greater Hagerstown Maryland 

region will compliment any economic initiative. 

As our campus grows to serve Maryland, Virginia, West Virginia, Pennsylvania, the daily air passenger 

service Sun Air provides will support the aviation education and enhance the aviation industry. We look 

forward to your future support of growing the aviation opportunities in Western Maryland with the 

continuation of Sun Air at the Hagerstown Regional Airport. 

Sincerely, 

4~<-V" 

Bernard Adams 

Campus Director, Hagerstown 

Pittsburgh Institute of Aeronautics 

14516 Pennsylvania Ave. 

Hagerstown, MD 21742 
CONVENTION AND VISITORS BUREAU 

July 17, 2014 

To Whom It May Concern: 

As the official tourism office for Washington County Maryland, we wish to assure the 

U.S. Department of Transportation how much we value the service of Sun Air between 

Dulles International Airport and Hagerstown Municipal Airport. 

Washington County is home to five National Parks, eight State Parks, 35 county and city 

parks, and more than 30 museums. We have an award-winning Arts & Entertainment 

District, and as part of the Heart of the Civil War Heritage Area are home to some of the 

most iconic American Civil War locations in the country and world-class recreation 

opportunities. 

We have competitively priced meeting and conference facilities that offer attendees an 

excellent choice of local attractions and the convenience of making day-trips to the 

Washington, DC and Baltimore metro areas. 

Sun Air's convenient service to a major international airport is considered a significant 

asset to the tourism industry here. With four round-trip flights on weekdays and two on 

weekends, business and tourism travelers appreciate reaching their destination via a 

location that is a hub of two major interstate highways; offering easy access to a 

multitude of attractions, and our regional residents enjoy the ease of originating their 

air trips from our smaller airport with free parking. 

The positive economic impact of these flights is considered of high value to the CVB and 

losing the Sun Air service from Hagerstown Municipal Airport is not a future we wish to 

envision. 

Sincerely, 

Julie M. Rohm 

Board Chair 

16 Public Square Hagerstown, Maryland 21740 301-791- 3 246 fax 301-791-2601 

w w w . mary I an d memories . com 
To Whom It May Concern: 

I am a contractor for the U.S. Department of Energy in Germantown, MD. Myself, and several other co-workers 

live in Hagerstown or Waynesboro. 

We have started to use the Sun Air flights to/from Hagerstown/Dulles as schedules permit for our work travel. 

#1, it's much more convenient than driving to Dulles (or other DC area airports) 

#2, it's cheaper for the government than paying for the mileage, parking, etc 

#3, it's much more relaxing than the drive to a DC area airport. 

I and my co-workers intend to continue to utilize this service as often as we can (as I have previously said) as 

schedules permit. 

The staff at Hagerstown is courteous and friendly. We would surely hate see anything happen to this service and 

strongly urge it's continuance. 

Sincerely, 

John c. MiLLs 

TeLecommunications Security SpeciaList I COMSEC Custodian 

Advanced Resource TechnoLogies~ Inc. (ARTI) Contractor to the US Department of Energy 

AU-1.2; MS:D-315/GTN 

1666 Independence Ave. SW 

Washington DC 26585 

361-963-8837 (desk) 

361-963-9661 (fax) 

"Twenty years from now you wiLL be more disappointed by the things that you didn't do 

than by the ones you did do. So throw off the bowLines. SaiL away from the safe harbor. 

Catch the trade winds in your saiLs. ExpLore. Dream. Discover." 

-- Mark Twain 
July 16, 2014 

To Whom It May Concern: 

We are writing this letter to encourage you to support Sun Air's continuing daily 

service from Hagerstown, MD to Dulles International Airport ( HRG to lAD). 

We live in Shepherdstown, WV, 14 miles from Hagerstown and 58 miles from lAD. 

And 80 miles from BWI. We use HRG's daily service to lAD whenever we fly. The 

25 minute flight is much more convenient and cost effective than driving to lAD, 

which takes 90 minutes each way. Also, we go through security and check bags at 

HRG, thereby avoiding the long lines at lAD. We have ample free parking in 

Hagerstown, or we simply have a friend drop us off, which takes about 30 minutes 

round trip. 

We have found Sun Air to be reliable and affordable, and more and more people from 

our area have recently come to depend on this service. 

Again, we encourage you to continue Sun Air's important route round trip from 

Hagerstown MD to Dulles. 

Sincerely, 

Mary C. Bell 

Sandra L. Jenkins 

35 Red Blossom Circle 

Shepherdstown, WV 25443 
From: thelmas@aol.com [thelmas@aol.com] 

Sent: Friday, July 18, 2014 5:42 AM 

To: Robin Livingston 

Subject: Hagerstown HGR service 

Have utililized Sun Air to visit aging mother and family in 

nearby areas. Have done this for years and do appreciate 

the SUNAIR service to HGR. Please continue for passengers. 

Realize that numbers may be small at times, but 

outstandingly important to us. 

Thank you SUNAIR for your service, excellent employees, and 

continued good will. 

Sincerely, Thelma Sanborn 

Thelmas 

thelmas@aol.com 
SUN AIR SUMMARY- HAGERSTOWN REGIONAL MARKETING 

EXHIBIT "A" 

Digital and Web Advertising 

Herald-Mail Media - Hagerstown, MD 

Web banner, Home Page of www.herald-mail.com 

Placements: August, September, 2013 

Late April, May, June, 2014 

, . - i ... ~ FLY ABOVE THE BUSY TRAFFIC· SIT BACK AND RELAX! 

~ ~· .. AIR CAf!~ ,; ~- f25 '-:-' I " M CLICK H£R£ • - T E R N /1 T 0 N ,, L - . -·..,. _, 

~ . ,,., ~ HH ~ !'"'-''"'""'' Cll/(81111149-49~. 01 loc.orlr I lOI J !JJ }020 

r..ir .-- FlY ABOVE THE TRAFFIC- FLY THE 'NEW' SUN AIR! 

~ II'J -::AIR , ; ' 0 ., " ' ( 0 .. A L CARRY-ON ,fARES JUST $25 • f. '). 1: ., 4 C ?Sl.Jf.'~:r, '~M CLICK HERE 

Go Hot. Topics 

,. HeW> Sports (~"'"'" I tie llMlV6 l'holos & VIdeos Calend3! 4bou1 r:la"IIIP.rls 'luluanes )IIDSI>II" Wealhe· 

CURRENT CONDITIONS 

Comcast xfinity On-Line- southern Franklin County, PA 

E-Mail Log-In Message Center- 300x250 digital ad with link to www.gosunair.com 

Placements: Late March, April, May, June, 2014 

(FLASH animated 3-panel ad, depicts SUN AIR logo, aircraft, special pricing, 

Hagerstown Regional Airport mention and web address for SUN AIR} 
SUN AIR SUMMARY- HAGERSTOWN REGIONAL MARKETING 

EXHIBIT"B" 

Outdoor and Billboard Advertising 

Kegerreis Inc.- Chambersburg, PA 

Digital outdoor billboards, 1-81/U.S. 30, also 1-81/PA Route 994 Chambersburg Mall/Chambersburg PA 

Placements: April, May, June, 2014 

Current Display: K-aerreis Panel 0 -997-1N 
SUN AIR SUMMARY- HAGERSTOWN REGIONAL MARKETING 

EXHIBIT "C" 

Newspaper Print Advertising 

The Record-Herald -Waynesboro, PA 

4x12" print ads, run-of-site web ad, lSK impressions at Yahoo.com and Ontarget.com 

Placements: September, 2013 

May, 2014 

:©~SUN AIR 

S ~ INTERNATIONAL 

Fly From Nearby 

Hagerstown MD Regional Airport 

FREE Parking until your return! 

Convenient flights every day, 

to Dulles International 

Fares under $60 each way 

- call SUN AIR for details 

Fly above the busy traffic 

- sit back and relaxl 

Arrive just ONE HOUR prior to your departure time 

get more done at home, and at work! 

Sun Air is your closest air connection 

to anywhere in the world! 

Book your next flight at 

(877) 849-4998, or 

on-line at www.gosunair.com 

or orbitz.com 

Questions? Call our local counter at: 

(301) 733-3020 

LICK HERE TO BOOK NOW! 

Or Call 1877J 849::4998 

* Fare special of $25 each way not reflected in the above- these are samples of previous 2013 ad 
Mobile Advertising 

Downtown Taxi! 

SUN AIR SUMMARY- HAGERSTOWN REGIONAL MARKETING 

EXHIBIT "D" 

3 Cabs, a Sun Air rear or driver-side panel on each cab, daily service within Washington County, MD 

Placements: August, September 2013 

April, May, June, 2014 
SUN AIR SUMMARY- HAGERSTOWN REGIONAL MARKETING 

EXHIBIT "E" 

Public Events and Community Relations 

• Airport Open House at Hagerstown, September 22, 2013 

Booth at Open House to meet and greet potential local sir service customers (87 contacts) 

• Franklin County (PA) Business Expo, Chambersburg, October 19, 2013 

Worked with Allegiant and Airport staff, for annual Chamber Business Expo (25 contacts) 
Radio Advertising 

SUN AIR SUMMARY- HAGERSTOWN REGIONAL MARKETING 

EXHIBIT "F" 

Local Commercial Spots (:30s) 

• The Oldies Channels (96.3FM/1400AM/800AM - 3 stations) -Chambersburg PA, Hagerstown, MD 

Placements: August, September, 2013 

March, April, May, 2014 

• The Eagle (WWEG FM 106.9FM) - Frederick, MD (Washington County-centric) 

Placements: March, April, 2014 

• WJEJ Radio (1240AM) - Hagerstown, MD 

Placements: April, May, June, 2014 (Morning news sponsorships, etc.) 
SUN AIR SUMMARY- HAGERSTOWN REGIONAL MARKETING 

EXHIBIT"G" 

Television Advertising 

Local Station Advertising 

WHAG TV-25- Hagerstown, MD 

Broadcast sponsorship @ 5:00 PM newscast 

Placement: September, 2103 

Countywide Cable System Television Advertising 

'The Weather Channel' 

• Antietam Cable- Washington County, MD (72+ appearances per week) 

Placements: August, September, 2013 

March, April, May, 2014 

• Comcast Cable- southern Franklin County, PA (84+ appearance each week) 

Placements: August, September, 2013 

March, April, May, June, 2014 

HAGERSTOWN 

CLIENT NAME: SUN AIR 

ADDRESS: 3301 GRIFFIN ROAD- FT. LAUDERDALE, FL 

CONTACT: TODD WILLMAN- (717) 860.4011 

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SUN AIR SUMMARY- HAGERSTOWN REGIONAL MARKETING 

EXHIBIT"H" 

Media Information Releases 

Hagerstown Herald-Mail, other news outlets within the region 

April 3, 2014- Announcement of improved operations, better flight reliability, new special HGR Fares 

~@: SUN AIR 

$ '> INTERNATIONAL 

MEDIA INFORfMDON 

April3, 2014 

Contact: 

Todd Willman 

Regional Marketing Manager 

(717) 860-4011 

twillman@gosunair.com 

'It's a New Day, and it's a New Sun,' Notes Sun Air CEO; 

$25 On-Line Fare Special to and From Dulles Promotes Renewed Focus on Service 

HAGERSTOWN, MD- Sun Air, the area's only local daily passenger air service operating from Hagerstown's 

Regional Airport, has announced the availability of a low $25 on-line 'carry on' fare special, for travel between 

Hagerstown and Washington Dulles International Airport. No adyance purchase is required. 

To take advantage of the $25 fare special between Hagerstown and Dulles, tickets must be purchased on-line 

at www.gosunair.com. Pricing is valid for carry-on bags only, and does not apply to passengers heading 

onward from Dulles with checked-through bags. 

After beginning local Sun Air flights to Washington Dulles airport in late 2012, the company faced a 

number of operational challenges driven in part by the impact of the sequester on government resources, 

and resulting in a shortage of available pilots and aircraft. Sun Air introduced a new man21gement team in 

late 2013, and is achieving operational performance levels that now meet or exceed the major U.S. airlines. 

"With Sun Air's success in achieving recent reliability improvements, we are now moving forward with more 

aggressive marketing designed to promote the local Hagerstown airport, and the exceptional value it offers our 

customers," said Sun Air Director of Marketing, Todd Willman. 

Hi!lgerstown Regional Airport allows travelers to avoid the congestion and long lines of the major airports, while 

at the same time providing free parking. Boarding and security lines take minutes instead of hours, he noted.