I •' 

THE SPI~IT 0~ AL.A...<:;;K A 

September 20, 2012 

Dennis DeVany 

Chief, EAS and Domestic Analysis Division 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington D.C. 20590 

RE: Essential Air Service at Akutan, Alaska 

Dear Dennis: 

en 

Peninsula Airways, Inc. ("PenAir"} is sending this letter to advise the Department of 

significantly changed circumstances at Akutan, Alaska, over which PenAir has no 

control, that are impeding PenAir from fulfilling its obligations to provide essential air 

service at that community. 

PenAir is the designated EAS carrier for Akutan, having served that community for 

many years. On August 2, 2012, PenAir filed a notice of termination of service, in order 

to trigger the Departmenfs procedures to select a replacement carrier, in light of the 

new runway at Akun which was completed on September 2, 2012. By Order 2012-8-39, 

the Department prohibited PenAir from terminating service until a replacement carrier 

has commenced EAS at Akutan. PenAir understands its hold in obligations, but 

circumstances at Akutan have changed to make it difficult, if not impossible, for PenAir 

to continue to fulfill its EAS service obligations . 

. PenAir's operates service to Akutan with a Grumman Goose G21_ amphibious aircraft, 

the only aircraft in our fleet that can serve Akutan. That aircraft had been using a 

seaplane ramp located on Akutan to land and pick up passengers, freight and mail. It is 

important to note that the original seaplane ramp was developed to accommodate 

PenAir's Goose landings, because beach landings subjected the Goose to potential 

damage and, depending on water conditions (swells/waves), raised safety issues. 

The State of Alaska recently completed construction of a new ramp to replace the 

seaplane ramp used by PenAir. The new ramp was designed to accommodate the 

hovercraft that intends to transport passeng~rs, freight and mail operate between 

Akutan and the new runway at Akun, which is located approximately 6 miles by water 

peninsula airways inc. 16100 Boeing avenue I anchorage alaska 99502 

1\DC- 004721/000002 • 3496725 v1 907.771.2500 I fax 907.771.2661 I info@penair.com I penair.com 
' ' 

from Akutan. The new ramp cannot accommodate the Goose. That has forced PenAir 

to resume beach landings. . 

PenAir asked the State to modify the ramp to accommodate the Goose. That request 

was rejected. See attached email which states: · 

"The hovercraft ramp was not designed to accommodate Goose landings and the 

work required to modify the ramp may or may not be significant, regardless it is 

neither in the scope nor the budget of the airport project. Further, our contractor 

has demobilized from Akutan and we have no mechanism to assess the 

modifications required nor [sic] complete the work in the short term." 

Because the new ramp is unusable for the Goose aircraft, the only way PenAir can 

serve Akutan is by operating beach landings. That has two serious adverse impacts on 

PenAir's ability to provide EAS to Akutan. First, depending on water conditions, i.e., 

swell heights, PenAir is often forced for safety reasons to cancel flights. That is a 

determination that .PenAir and the pilot-in-command make on a flight-by-flight basis. 

Second, the beach .is very rocky, and beach landings a're causing PenAir to suffer 

increased damage to main and tail landing gear components and to tires. It is important 

to note that if a main gear is damaged beyond repair, there are no units available to 

· replace it If a tail wheel assembly is damaged it will likely be ripped from· the fuselage 

resulting in potentially extensive structural damage. 

PenAir has made diligent and good faith efforts to provide safe and reliable EAS to 

Akutan under difficult conditions. We continue to monitor conditions on a flight-by-flight 

basis. However, we must advise you that PenAir may have to terminate service if it 

determines that the conditions discussed above, over which we have no control, 

effectively foreclose our ability to safely provide service EAS to Akutan without risking 

further damage to the Grumman Goose aircraft. 

We understand that Grant is ready, willing· and able to begin EAS service to Akun 

without subsidy, but will not do so until arrangements are made for the carriage (and 

payment of that carriage) of mail between Akutan and Akun. PenAir strongly urges the 

Department to work with the U.S. Postal Service and the other affected parties to 

·quickly resolv~ that issue and pave the way for subsidy free EAS to Akun. 

cc: Kevin Adams 

Robert E. Cot;ln 

1\0C • 0047211000002 • 3496725 v1 

Daniel P. Seybert 

Chief Executive Officer 
J ' 

Scott Bloomquist 

From~ 

S~nt:"' 

To: 

Cc: 

Subj~: 

Hey Scott, 

Holland, Sean l (DOT) <sean.holland@alaska.gov> 

Wednesday, September 19, 2012 10~5 AM 

Scott Bloomquist 

Bustamante, linda (DOT) 

Akutan Hovercraft Ramp 

Per our conversation, the Department does not intend to perform any work on the Akutan hovercraft to accommodate 

the Goose. The hovercraft ramp was not designed to accommodate Goose landings and the work required to modify 

the ramp may or may not be significant, regardless it is neither in the scope nor the budget of the airport 

project. Further, our contractor has demobilized from Akutan and we have no mechanism to assess the modifications 

required nor complete thework in the short term. · 

Sean 

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