I •'

THE**SPI~IT 0~**  AL.A...<:;;KA September 20, 2012
Dennis DeVany Chief, EAS and DomesticAnalysis Division U.S. DepartmentofTransportation 1200 NewJerseyAvenue, S.E. Washington D.C. 20590 RE: Essential AirService 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 August2, 2012, PenAirfiled a notice oftermination ofservice, in order to trigger the Departmenfs procedures to select a replacement carrier, in light of the new runway atAkun which was completed on September2, 2012. By Order2012-8-39, the Department prohibited PenAir from terminating service until a replacement carrier has commenced EAS at Akutan. PenAir understands its hold in obligations, but circumstances atAkutan have changed to make itdifficult, 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 

### Ianchorage alaska 99502 1\DC- 004721/000002 •3496725 v1 907.771.2500 

### Ifax 907.771.2661 

### Iinfo@penair.com 

### Ipenair.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 ofthe 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 byoperating 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 gearcomponents 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 ofthat 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 wayfor subsidyfree EAS to Akun.

cc: Kevin Adams Robert 

### E. Cot;ln

1\0C •0047211000002 •3496725v1 

### Daniel P. Seybert Chief Executive OfficerJ '



### 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, theDepartmentdoes notintendtoperform anyworkontheAkutan hovercrafttoaccommodate the Goose. The hovercraft rampwas notdesignedtoaccommodate Goose landingsandtheworkrequiredto modify the ramp mayormay notbesignificant, regardless itis neitherin the scope northebudget ofthe airport project. Further,ourcontractor has demobilizedfrom Akutan and we have no mechanism to assess the modifications required norcompletethework in the short term. · 

### Sean

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