May 12,2014 

Secretary Anthony Foxx 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, D.C. 20590 

RE: Docket DOT-OST-2008-0299 

Dear Secretary Foxx, 

CITY COUNCIL 

Geoff Dale- Mayor 

Mark Gran- Mayor Pro-Tern 

Rick Breland- Council Member 

Doug Cox - Council Member 

Betty Sampson- Council Member 

CITY CLERK 

Debra Jackson 

CITY TREASURER 

Stacy cox 

It has come to our attention that the Imperial County Airport "IPL" is one of thirteen airports that were 

notified by Tentative Order by the United States Department of Transportation that the community may 

lose Essential Air Service "EAS" eligibility due to the averages of fewer than ten enplanements per day. 

While we are not protesting the numbers, we look forward to petitioning for a waiver ofthese standards 

based on our position that these numbers are based on a temporary decline as allowed in the order. 

IPL is located in the Southeastern corner of California. It is bordered by Arizona and Mexico. Even 

though it is about 114 miles to San Diego, road access to the nearest large hub airport to Imperial 

County is made uniquely more challenging than distance alone due to congestion, unpredictable border 

crossings, and road closures due to weather conditions on all roadways leading out of Imperial County. 

This increases the amount of time that passengers need to travel to other airports, as well as increases 

the community's reliance on IPL for access to the international air transportation network to support 

economic growth in the area. 

IPL has been served by two carriers, United Airlines operated by SkyWest, which ceased service in April 

of 2013, and Seaport Airlines, which began service in May 2013 when the US DOT selected Seaport as 

the new EAS carrier. Seaport's service replaced flights to LAX with service to large-hub San Diego 

International Airport "SAN" and Burbank's Bob Hope Airport "BUR", a medium-hub airport North of LAX. 

Despite the advantage of having access to two airports, this federally mandated service attracted fewer 

passengers because it is flown on smaller aircraft, and Seaport did not initially have interline agreements 

in place to allow passengers to transfer at SAN and BUR to other airlines. In addition, SAN and BUR offer 

fewer connecting opportunities than LAX, because fewer airlines and routes are served from SAN and 

BUR. As a result of the smaller aircraft operated by Seaport, the number of daily seats offered from IPL 

was approximately half the number offered by United. 

IPL consistently generated approximately twenty passengers per day in 2009 through 2012. IPL 

passenger traffic peaked in 2007 when the airport had nearly twice daily service to LAX and YUMA, 

Arizona "YUM". United's service with online and interline connecting opportunities at LAX allowed both 

business and leisure travelers to travel globally and on a larger aircraft, the 30-seat Embraer 120. During 

420 SOUTH IMPERIAL AVENUE • IMPERIAL, CA 92251 • TEL (760) 355-4371 • FAX (760) 355-4718 • WWW.CITYOFIMPERIAL.ORG 
2007, IPL also reached its highest load factor of 52%. IPL was hit hard by the weak economy in 2008, 

2009 and 2010 with an immediate decline in traffic and load factor. As IPL started to emerge from the 

recession, air travel increased to 20.6 in 2012. In 2013, the US DOT selected a new airline, serving new 

markets and passenger traffic decreased. 

This temporary decline is because the community must adjust to the new air service patterns at IPL, and 

Seaport needed time to negotiate and interline agreements with other airlines at BUR and SAN. At this 

time Seaport is surpassing the required 10 enplanements per day. 

As such, it is certain that the passenger performance below US DOT minimum was a temporary decline 

related to the entrance of a new EAS carrier serving new markets from I PL. The City of Imperial and 

Imperial County are unified in its support of the Seaport service and look forward to petitioning a waiver 

of these standards listed in DOT-OST-2008-0299. 

Thank you for your consideration. Should you have any questions, please contact the City of Imperial at 

(760} 355-4373 or email mbest@cityofimperial.org. 

Geoff Dale 

Mayor 

City of Imperial 

cc. Susan Kurland, Aviation and International Affairs 

Rebecca Terrazas-Baxter, Office of Congressman Juan Vargas, CA-51 

Kevin Schlemmer, Essential Air Service & Domestic Analysis Division 

Jamie Jones, David Turch & Associates 

Marlene Best, City of Imperial