City of Alpena -RTMENTOF 

CITY HALL * 208 NORTH FIRST AVENUE ' ALPENA, MSGHIGAN 49707 ?385 

www.aipeRa.rni.us 

Aprils, 2012 

Mr. Dennis DeVany 

Chief, Essential Air Service Division 

Office of Aviation Analysis 

Department of Transportation 

1200 New Jersey Avenue SE, 

Washington, D.C. 20590 

Reference DOT-OST-2009-0300 

Dear Dennis, 

Alpena is very appreciative of the Department seeing the challenges of the air service situation 

in our City and issuing a fourth RFP for Alpena EAS service, per Order 2012-3-19. 

We do wish to make clear our strongest objection to one aspect of this process as it is 

unfolding. This is related to the level of service in an acceptable carrier bid proposing nine-seat 

or less aircraft. 

On page 5 of Order 2012-3-19 the Department states "We take this action notwithstanding that 

Air Choice One's Options 4 and 5 fully meet the requirement for basic EAS " 

While AirChoiceOne Option 5 offers four trips per day. Option 4 only offers three trips per day. 

We reference the following; 

• DOT Order 2011-9-5, the original RFP regarding Alpena and the other Delta cities, page 

6, "At all other communities (this includes Alpena) we are requesting two nonstop round 

trips per day (12-14 per week) at each community if 30-seat or larger equipment is 

proposed, two or three trips per day (12 - 18 per week) with 19-seat aircraft; and more 

frequencies with smaller aircraft" 

• Order 2011-11-20 requesting another round of bids at Alpena; page 4, "For example, we 

would entertain proposals with 8/9-seat aircraft and as many as four or five round trips 

per day (24 to 30 a week)" 

• Regarding the four Delta southeast U.S. cities that are also in the midst of a fourth RFP, 

the Department has specifically asked for four trip proposals if 8/9 seat aircraft are used, 

even though the Memphis hub to which such aircraft would typically be used only has 

three banks of Delta flights. 

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• AirChoiceOne operates EAS on a one year contract at Burlington, Iowa and Decatur, 

Illinois and in both cases the 9 seat service pattern requires four trips per day. 

• Cape Air EAS service at Marion, IL, Quincy, IL, and Cape Girardeau, Mo with 9-seat 

aircraft is subsidized at four or more frequencies, all of these cities board measurably 

less passengers than Alpena does. 

We are working very hard to gain an EAS bid from either a network associated regional jet 

operator or a thirty or nineteen seat operator. We have high hopes of gaining at least one bid 

from a carrier offering that type of service and the EAS definitions the Department has outlined 

are consistent on those types of bids. 

However, the Department is stating that AirChoiceOne Option 4, with only three round trips in 

an 8-seat (or 7 or less, depending on one's point of view) piston aircraft, is an acceptable bid. 

We strongly contest that conclusion. The Department's original Alpena solicitation and the follow 

up Order in November clearly state that 8/9 seat proposals should have four or more 

frequencies. RFPs for the four Delta cities with similar traffic histories in the southeast clearly 

state the same, AirChoiceOne service at Burlington and Decatur, two cities with measurably 

less traffic than Alpena, also is supported at a four flights per day level with a 9 seat aircraft. 

Cape Air service at three cities has four or more frequencies supported by subsidy. 

We respectfully request that the Department clarify Order 2012-3-19 in that AirChocieOne 

Option 4 is not a legal bid by the Department's own minimum service definitions for that bid. 

Further, in nine other city RFP instances that are recent or ongoing the Department has 

required four or more trips in 8/9 seat aircraft, not three. 

We hope to avoid seeing our air service shift from a 50-seat regional jet and 25,000 annual 

passengers (the traffic volume we are tracking at so far in 2012) to a 8/9 seat aircraft. If 

however, we have to make that transition, it must be accompanied by adequate frequency to 

attempt to compensate for the loss of capacity. The Department so noted the radical drop in 

capacity entailed in such a transition on page 5 of its recent Alpena re-bid order. 

Thank you again for the fourth bid cycle. We appreciate that the Department understands we 

are doing the best we can to find a good replacement service. However, we would very much 

appreciate a clarification that 8/9 seat bids should be at a four trip per day level, for all the 

reasons outlined above. 

Respectfu 

Matthew J. Waligora 

Mayor 

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