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### Deterll~er 10, 2014

Mr. Brandon M. Belford Deputy Assistant Secretary for Aviation and International Affairs U.S. Department ofTransportation 1200NewJersey Ave., S.E Washington, DC 20590 RE: DOT-OST-1996-1899 Orderto Show Cause ProposingTermination ofEssential Air Service DearMr. Belford: 

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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 ofissues that have affected Kingman, Arizona's passenger numbers are a direct result, and the unanticipated consequences, related to Regulatory or Congressional Mandates ofthe DOTIF ederal AviationAdministration:
• Effective August 1, 2013 Congress and the FAA mandated that all co-pilots of an airlinehave a minimumof 1500total time hold anAirlineTransport Pilotcertificate. As a result ofthis mandate, Great Lakes Airlines lost a number ofco-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 ofthe 19 seats in the Beech 1900'sthat serve Kingman in orderto 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 enplanementsperday 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 thatcommunities exceed 10 enplanementsperday during eachfiscal year. ,t 

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Kingman Airport Authority, Inc. • 7000 flightline Drive
.. '""""'"' AZ 86401 • (928) 757-2134 " fAX (928) 757-9871Mr. BrandonM. Belford DOT-OST-1996-1899, Orderto ShowCause 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 theirFiscal Year2013 decline in enplanements." We objectto the orderbecause:
• 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% ofthe 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 extendingthe datacollectionperioduntil September 30, 2015. Ifyou have any questions regarding this position, or ifyou require additional information, please contactme, orRobert Riley, Director,Economic Development, atthis office. Sincerely,

David French Executive Director DF/br Cc: Richard Anderson, MayorCtty ofKingman Gary Watson, Mohave County SupervisorDistrict#1