DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

June 26, 2013

Essential Air Service at

EL DORADO, HARRISON, HOT SPRINGS,

ARKANSAS

Under 49 U.S.C. 41731 et. Seq.

Docket DOT-OST-1997-2935

SECOND COMMENTS OF SEAPORT AIRLINES, INC IN RESPONSE TO 

SUPPLEMENTAL INFORMATION SUBMITTED BY BOUTIQUE AIR

By Order 2013-4-6 issued on April 12, 2013, the Department requested proposals from 

air carriers interested in providing Essential Air Service at the Arkansas communities of El 

Dorado, Harrison, and Hot Springs for a new term to begin on November 1, 2013. By the 

deadline of May 16, 2013, valid proposals were submitted by SeaPort Airlines, Boutique Air, and 

Air Choice One.

On May 31, 2013, Boutique Air sent an email to the Department’s EAS division

“clarifying” the amount of subsidy per passenger it was requesting for each service option in its 

proposal that included Hot Springs.

On June 6, 2013, SeaPort Airlines submitted comments to the Department showing that 

Boutique Air’s earlier Docket filing incorrectly calculated of the amount of the subsidy per

passenger the carrier is requesting at Hot Springs. Specifically:

Service Option As Presented by 

Boutique Air

As Calculated by 

SeaPort Airlines

#1 $132 $408

#2 $126 $338

#3 $132 $263

On June 18, 2013, the president of Boutique Air responded by stating its calculations 

assumed a change in flight numbers at Hot Springs and, therefore, connecting passengers 
Comments of SeaPort Airlines, Inc.

Docket DOT-OST-1997-2935

Page 2

should be counted as enplanements as Hot Springs.

1 Boutique also asserted that that SeaPort 

included Memphis – Kansas City passengers in its proposal to serve Harrison and, therefore, 

was engaging in the same practice as Boutique Air.

In response, SeaPort states the following:

Connecting Passengers Are Not Indicative of Market Demand for EAS

As noted, Boutique Air states that each aircraft stop in Hot Springs would result in a 

change of flight number and, therefore, passengers traveling to or from another EAS point could 

be counted as a Hot Springs enplanement at Hot Springs for the purpose of calculating subsidy 

requirements. 

First, nowhere in the proposal that Boutique Air submitted on May 16, 2013 is it indicated 

that passengers would be required to “connect” at every intermediate aircraft stop. To the 

contrary, in its narrative Boutique Air describes such routings as “one-stop” and footnotes 

illustrative schedules for each such options with “all DFW flights have a quick stop in Harrison.”2

The requirement that Harrison - Dallas passengers make a “connection” at Hot Springs 

represented in June 18, 2013 filing is a vastly different value proposition than the quick one-stop 

flight itinerary represented in its proposal filed on May 16, 2013.

Second, counting Harrison to Dallas passengers as indicative of demand at Hot Springs

simply attempts to “game” the EAS program. This is no more valid than, for example, counting 

Shreveport to New York passengers that connect in Memphis as indicative of the demand for 

travel between Shreveport and Memphis or between Memphis and New York. As SeaPort 

outlined in its June 6, 2013 filing, we believe that Boutique Air is confusing “true market 

demand” (i.e., that found in O&D traffic data) with onboard passengers (i.e., that found in T-100 

data). 

Boutique’s Assertion That SeaPort Included Memphis - Kansas City Passengers Is False 

In its filing of June 18, 2013, Boutique Air states that SeaPort Airlines has engaged in 

the same practice we describe above:

 

1

Actual submission from Boutique Air was noted dated, however June 18, 2013 is the date the filing appeared on 

Regulations.gov.

2

Proposal of Boutique Air, page 9.
Comments of SeaPort Airlines, Inc.

Docket DOT-OST-1997-2935

Page 3

We are actually quite surprised by this objection from SeaPort, as it 

appears they count through traffic on their direct MCI-MEM flight, which stops in 

Harrison, as Harrison passengers. We are not questioning this practice; just why 

the carrier would feel it is a suitable practice for Harrison, but not for Hot Springs,

if indeed those through passengers are being counted.3

As the table below indicates, Boutique Air’s claim is incorrect:

HRO-MEM 

O&D

HRO-MCI 

O&D

TOTAL

As presented in SeaPort’s proposal 11,001

Forecast Detail 6,401 4,600 11,001

Summation

As SeaPort has shown in this filing, Boutique Air either (1) continues to confuse “O&D 

demand” with “onboard passengers” or (2) understands the difference but is attempting to 

“game” the EAS program which hides the true level of service it would provide at another EAS 

community (Harrison). 

For these reasons, SeaPort asks the Department add these comments to Docket OST1997-2935 and carefully consider the information as it selects a carrier to provide Essential Air 

Service at El Dorado, Harrison, and Hot Springs, Arkansas. 

Respectfully submitted,

Timothy F Sieber

Executive Vice President 

SEAPORT AIRLINES, INC.

7505 NE Airport Way

Portland International Airport

Portland, Oregon 97218

(971) 340-1716

Email: tim@seaportair.com

June 26, 2013

 

3

Letter from Shawn Simpson to Dennis Devany, June 18, 2013.