City of Alpena 

March 15,2012 -.; 

Mr. Dennis DeVany -^^ > ' — 

Chief, Essential Air Service Division "^ 7" 5^0 

Office of Aviation Analysis ^r, ":p§ ^ 

Department of Transportation -1^ s;^ 5 

1200 New Jersey Avenue SE, _ ^<5 Q 

Washington, D.C. 20590 2. £5'" ' 

CD 

Reference DOT-OST-2009-0300 

Dear Dennis, 

This letter is the response of the City of Alpena, Michigan to the Department's letter of February 

17, 2012. The Department letter does not ask Alpena for its comments at any point. The first 

paragraph says the letter is to "inform you of results...before we (DOT) submit a 

recommendation on the carrier-selection issue..." The last paragraph of the letter says "we will 

act as quickly as possible upon receipt of your letter". 

While the Department is apparently not asking for our comments, this letter will constitute our 

comments on the results of the third round of Essential Air Service (EAS) bidding to provide 

Alpena air sen/ice. 

As background, I will first offer that Alpena is a growing city, the largest in Northeast Lower 

Michigan. Our economy is diverse and numerous elements of that economy depend on effective 

air transportation in order to conduct on-going business operations. 

Alpena is also a very isolated city; 71 miles to the nearest Interstate Highway and 100 miles (all 

on two lane roads) to the nearest alternative airport (Pellston). It is 258 road miles to Detroit and 

its large hub airport. In other words, unlike many EAS cities, we do not have another airport 45 

minutes down the road. 

Our air service is currently prospering, with 2011 total traffic on our flights to and from Detroit of 

nearly 23,000 passengers. Detroit has been our hub for nearly five decades now and is the 

closest hub airport. 

The Department's February 17 letter briefly outlines the recent history of EAS at Alpena, the 

results of the first and second rounds of bidding and the results of the third round of bidding, 

including the five option bid of AirChoiceOne to provide Alpena EAS with either a Cessna 

Caravan or Piper Navajo on a route to Chicago O'Hare airport. 

ALPIMA 

ktlCHiGAH'S ADVEMSHORE 
While the February 17 letter never specifically asks Alpena for its comments we assume the 

request at the end for "our letter" means the Department wishes to know any comments the 

community may have on the AirChoiceOne bid. 

Our comments are as follows: 

> We reject options one, two and three, that use single engine Cessna equipment. 

> We reject option four in that it does not meet the minimum EAS service definition for that 

airplane type. The original DOT RFP for Alpena defined minimum bids as (appendix C) 

12 to 14 trips per week with a 34 or 30 seat aircraft and 18 to 24 trips per week with a 

19-seat aircraft. The Appendix C also noted that Alpena generates on average 31.5 

enplanements per day. While the RFP did not define any minimum service standard for 

smaller aircraft we do note that recent RFPs or awarded carrier bids for Burlington, lA, 

Decatur, IL and four Delta cities in the southeast all required a minimum of four trips a 

day with aircraft smaller than 19 seats. 

> We question the Navajo's capability to carry more than 4 passengers with the fuel 

required to travel from APN to ORD on days with less than perfect conditions. 

> Our research of AirCHoiceOne shows that the carrier appears to be on "probation" for 

lack of a better term regarding its current EAS operations at Burlington, lA, Decatur, IL 

and Jonesboro, AR. In Order 2011-12-17 the Department awards AirChoiceOne a new 

term at Burlington and Decatur but for only one year, with a proviso that the carrier must 

"fully implement an electronic ticketing and baggage agreement with a major airline with 

a hub operation at Chicago O'Hare and/or St. Louis by January 31, 2013." Apparently 

AirChoiceOne's recent award of EAS designation at Jonesboro contains a similar 

provision. 

> Research on AirChoiceOne also shows that the airline is based in St. Louis and owns or 

operates three Caravan aircraft and one Navajo aircraft. All current EAS services, 

including all flights at ORD, appear to be operated with Caravans, at least all were bid as 

Caravans and that is the airplane shown on the carrier's website. 

> All of the carrier's Alpena bids, either Caravan or Navajo, show a scheduled flight time in 

the representative schedule of 1:40 in both directions. Using publically available flight 

planning software we have found that an average flight time of 1:40 might be possible 

between the two cities under perfect weather conditions. However, as with all airline 

operations, southwest bound flights into predominate winds will take longer and 

northeast bound flights may take less time. Also, the flight time does not allow for taxi 

time in and out at ORD, which is a measurable addition. Thus we believe, despite the 

airline's "representative schedule" that flights from Alpena to Chicago will require more 

than a two hour scheduled time, and even more in winter. 

ALPEU 

MCHIGAN'SADVENSHORE 
To further clarify this point; AirChoiceOne currently operates the following routes and 

published schedule times; 

AIRCHOICEONE SCHEDULED TIMES: MARCH 2012 

City 

BRL 

BRL 

DEC 

DEC 

J BR 

APN 

Hub 

ORD 

STL 

ORD 

STL 

STL 

ORD 

Distance 

187 

147 

157 

111 

176 

306 

Inbound 

1:40 

1:10 

1:20 

:55 

1:30 

1:40 

Outbound 

1:40 

1:10 

1:20 

:55 

1:25 

1:40 

BRL, DEC AND JBR times per AirChoiceOne website 

APN times per AirChoiceOne EAS proposal 

The proposed Alpena route, with either a Caravan or Navajo, has a schedule time of 

1:40 in the carrier proposal. Yet the carrier takes the same time, 1:40, just to cover the 

Burlington - Chicago route. Alpena is 64% further from ORD than Burlington is. The 

compass heading is similar. The carrier has clearly misjudged the realistic schedule 

time it will take to perform Alpena - Chicago ORD by a wide margin. The scheduled 

time Alpena to Chicago will have to exceed two hours. 

The Department reminds us in the February 17 letter that the Silver Ainways bid was 

rejected by the Department as "excessive". However, we cannot help but notice from 

reviewing AirChoiceOne's bids at Decatur and Burlington that in that bid process another 

carrier bid $1,802,939 less per year than AirChoiceOne and did not win. Thus we are 

confused as to when budget constraints apply and when they do not. We hope, and our 

congressional delegation shares our hope, that this is not a case where budget 

constraints apply in Michigan EAS but not in Iowa or Illinois EAS. In the 

Decatur/Buriington case the DOT said; "While we acknowledge that Cape Air requires 

fewer subsidies, both communities strongly support AirChoiceOne..." If community 

comments then do matter that much, we hope ours do too. 

The Department also reminds us in the February 17 letter that it is urgent to replace 

Delta. The four Delta EAS cities in the southeast; Greenville, Hattiesburg, Muscle Shoals 

and Tupelo, are moving to a fourth round of bidding. Delta remains in those cities with 

paired service patterns that allow two RJ's to serve four cities. We note that Delta has 

moved Alpena to a paired service pattern with Pellston, with DOT approval. We also 

note that Delta, when merging with Northwest, made many promises to retain Northwest 

Airlines service to small communities. While these promises were not apparently legally 

binding, the rush of Delta to abandon Alpena can perhaps take a pause while we find a 

replacement carrier. After the summer of 2012, Delta could revert to the current Pellston 

- Alpena - Detroit routing for the winter of 2012 - 2013 and use the same amount of 

aircraft to serve both cities as it would fly anyway with only Pellston. We understand that 

Delta is leaving us, we just need some time, measured in months, to find a replacement 

carrier. 

ALKNA 

ilCHIOAtfSAOVB^SHORE 
In summary, we are doing everything we can to find a suitable EAS carrier for Alpena. We have 

visited SkyWest Airlines (and they strongly considered bidding in the third round) and we have 

been in contact with American Eagle Airlines. We are in active discussions with Public Charters 

and are watching how the Department will respond to Manistee's proposal for "alternative EAS" 

using that carrier. 

At some point, legal definitions must give way to common sense. Perhaps in Alaska there are 

EAS routes where Piper Navajos or similar aircraft fly two hour flights. Alpena is not in Alaska. 

How the spirit and intent of the EAS program can be so turned as to define a two hour plus flight 

on a Piper Navajo on an airline lacking basic interline agreements as a "legal" bid escapes me. 

It would be short sighted of the Department to rush to a clearly inadequate bid by a carrier that 

is on some form of probation with the Department, with an implication that the entire 

AirChoiceOne route system might be re-bid in January of 2013. It would be short sighted to 

rush to this inadequate bid when the Manistee "alternative EAS" proposal is still pending. 

Perhaps the Manistee / Public Charters concept will allow a reasonable alternative to emerge 

for Alpena. 

The four Delta cities in the southeast are gaining a fourth bid cycle. Delta, with its fleet of over 

1,000 airplanes can continue to sen/e Alpena via pairing with Pellston (off season) and use the 

same number of aircraft as it would to serve Pellston alone. 

Thus, we reject all AirChoiceOne bids as inadequate, either by definition or by common sense. 

We appreciate the carrier's interest in Alpena. We request a fourth bid cycle and that the 

Department move as promptly as it can to clarify the status of the Manistee alternative EAS 

proposal. 

Best regards, 

Matthew J. Waligora 

Mayor 

ilPINli 

MICHK>A!f$ADVEN3mRE