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Deterll~er 10, 2014 

Mr. Brandon M. Belford 

Deputy Assistant Secretary for Aviation and International Affairs 

U.S. Department of Transportation 

1200 New Jersey Ave., S.E 

Washington, DC 20590 

RE: DOT-OST-1996-1899 

Order to Show Cause Proposing Termination of Essential Air Service 

Dear Mr. Belford: 

• •• 

Please accept this letter as an objection to the tentative decision that the Department of 

Transportation proposes to terminate the subsidy eligibility of Kingman under the EAS 

Program. 

The majority of issues that have affected Kingman, Arizona's passenger numbers are a direct 

result, and the unanticipated consequences, related to Regulatory or Congressional Mandates 

of the DOT IF ederal Aviation Administration: 

• Effective August 1, 2013 Congress and the FAA mandated that all co-pilots of an 

airline have a minimum of 1500 total time hold an Airline Transport Pilot certificate. 

As a result of this mandate, Great Lakes Airlines lost a number of co-pilots needing more 

hours, and in addition lost captains to larger legacy airlines. This resulted in cancellations 

throughout the system because of "no crew" and for Kingman this amounted to 302 (25% of 

scheduled flights) canceled flights. 

To meet schedules, Great Lakes Airlines removed 10 of the 19 seats in the Beech 1900's that 

serve Kingman in order to allow lower time pilot/co-pilot crews to fly under the 10 seat rules. 

This made planes available for service, but at reduced capacity. Since the route structure 

including Kingman also includes the community of Page, and since Page has averaged 

occupying more than six seats daily to both Denver and Los Angeles over the last year, 

Kingman has been left with 4 seats per day to fill. It is mathematically impossible to meet 10 

enplanements per day when there are only 4 available seats. 

In Order 2014-9-21 dated September 26, 2014 it was stated: "We wish to make it clear that 

the statute requires that communities exceed 10 enplanements per day during each fiscal year. 

,t 

• • 

Kingman Airport Authority, Inc. • 7000 flightline Drive .. '""""'"' AZ 86401 • (928) 757-2134 " fAX (928) 757-9871 
Mr. Brandon M. Belford 

DOT -OST -1996-1899, Order to Show Cause 

December 1 0, 2014 

Page2 

Although these communities received a temporary waiver from this.requirement, their traffic 

will be reassessed based upon Fiscal Year 2015 data (October 1, 2014 through September 30, 

2015). We expect that these communities will work with their EAS carriers to address any 

issues that contributed to their Fiscal Year 2013 decline in enplanements." 

We object to the order because: 

• Passenger enplanements cannot reach 1 0 per day when only 4 seats per day are 

available. 

• Local confidence in the airline service will not be achieved when 25% of the flights 

are cancelled due to federal mandates. 

• It is difficult to produce FY 2015 enplanement numbers if the EAS Program is 

terminated in Kingman in April2015. 

• We are working with Great Lake Airlines to address issues that have contributed to 

their decline in enplanements, but they appear to be federal issues that the community 

has limited input. 

• As a community, it is difficult to implement any correction efforts when the U.S. 

DOT, controlling the program, in November issues an Order to Show Cause to 

Terminate the EAS Subsidy on April 30, 2015, when 60 days earlier there was an 

Order Granting Waiver extending the data collection period until September 30, 2015. 

If you have any questions regarding this position, or if you require additional information, 

please contact me, or Robert Riley, Director, Economic Development, at this office. 

Sincerely, 

David French 

Executive Director 

DF/br 

Cc: Richard Anderson, Mayor Ctty of Kingman 

Gary Watson, Mohave County Supervisor District #1