DEPT.OFTRANSPORTATiON
DOCKETS
BEFORE THE
UNITED STATES DEPARTMENT OF TRANSPORTATIO&£38 AUG I 8 A 10 22
WASHINGTON, D.C.
In the matter of the Ninety-Day Notice of
Horizon Air Industries, Inc.
Of intent to terminate service at North
Bend/Coos Bay, Oregon, pursuant to 49
U.S.C. §41731etseq.
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Docket DOT-OSTAug. _ 1 2 _ , 2008
OBJECTION TO TERMINATION,
SUSPENSION OR REDUCTION OF
AIR SERVICE
OBJECTION TO NOTICE OF TERMINATION
Pursuant to 14 CFR §323.9, the undersigned hereby objects to the Ninety-Day Notice of
Horizon Air Industries, Inc. dated June 27, 2008, of intent to terminate service at North
Bend/Coos Bay, Oregon (Southwest Oregon Regional Airport). It is the objector's
opinion that the proposed termination of service would leave North Bend/Coos Bay and
the surrounding community with less than the minimum level of basic essential air
service needed for the community, pursuant to 14 CFR Part 398 and CAB/DOT Order
84-12-137.
1. Identification of Objector:
Melody Gillard-Juarez
PO Box 397, Bandon, OR 97411
541 347-9105
2. DOT Action Requested
The Objector requests that the DOT, by order, prohibit the requested termination of
service by Horizon Air Industries, Inc. In addition, or in the alternative, the objector
requests that the DOT determine and/or affirm its prior EAS determination set forth in
CAB/DOT Order 84-12-137, which designated Portland as the hub for North Bend/Coos
Bay's essential air service. Finally, the DOT should amend its Order 84-12-137 to
guarantee increased capacity with direct flights for North Bend to Portland.
3. Level of Service Remaining After Proposed Termination
The proposed termination of service would leave the community with no direct air
service to any other airport within the State of Oregon. Currently, Horizon Air provides
between two and four daily nonstop flights from North Bend/Coos Bay to Portland,
Oregon, depending on the day and the season. If this service is terminated, the only
remaining air service to the community would be twice daily flights by SkyWest Airlines
to San Francisco, California, which is a new service that began on July 7, 2008.
4. Suggested Reasonable Level of Essential Air Service
A reasonable level of essential air service to the community is not less than twice daily
direct flights to Portland, regardless of any additional flights that may exist to San
Francisco.
5. Justification of Suggested Level of Essential Air Service
Portland has been designed by the DOT as a medium hub and it should continue to be
considered the primary hub for the entire South Coast of Oregon, for the purposes of
Horizon's planned termination of service. The total population^ for the State of Oregon
is approximately 3.63 million. The Portland airport serves the primary population
centers of Oregon: Multnomah, Clackamas, and Washington Counties, as well as Clark
County, Washington, with a combined population of 1.94 million. The Portland region
also represents the economic heart of the State. In addition, the State capital is located
in Salem, Oregon, which is less than an hour drive from the Portland airport.
Although San Francisco is a major hub and would provide the community with access to
the national air transportation system, the termination of service to Portland, Oregon,
would cause the community to be cut-off from the geographic, commercial, and political
heart of the State. In addition, the distance differential between a direct flight to
Portland, and a connecting flight to Portland through San Francisco, makes such air
travel impracticable, as shown in the following table:
Origin Airport
OTH
OTH
SFO
OTH
Intermediate Airport
SFO
Destination Airport
PDX
SFO
PDX
PDX
Air Miles Distance
170
410
550
960
SOURCE: Measurements taken from Google Earth.
Airport Codes: OTH -North Bend/Coos Bay; PDX - Portland; SFO - San Francisco
The increased distance between a direct flight to Portland and a connecting flight
through San Francisco is an additional 790 miles or 565%.
The Southern Oregon Coast community is geographically isolated from the remainder of
the State. The nearest access to the Interstate Highway System is approximately 2
hours drive from Coos Bay/North Bend and up to four hours from Gold Beach and
Brookings through the Oregon Coast Mountain Range along 2-lane highways that are
vulnerable to closures from snow, flooding and landslides from late October to early
April.
The people of Bandon, myself included, depend upon air travel to Portland for business
and pleasure. Connections are good to Seattle and eastbound routes. Loss of this
service would heavily impact our mobility and business relations. I believe we should
help Horizon continue to serve our area and promote their service. I believe traffic has
Population data is for 2005.
been substantial and the area's growth will prove that both southbound and northbound
services are sustainable. A subsidy should be considered, and Oregon Tourism or other
money added to help promote the northbound flights as we are currently doing for
United. Horizon has provided very pleasurable, dependable service for more than 20
years with nice planes, friendly crew, good partnerships with Alaska and NW for easy
and affordable connections. We on the South Coast of Oregon do not want to lose
them.
I do not have ready access to information related to traffic levels to Portland or San
Francisco, or enplanement data for North Bend/Coos Bay. I request that DOT consider
such data as it may receive from other sources in consideration of this objection.
6. Additional Considerations
In its Notice of Termination, Horizon asserts that the retirement of the Dash-8-200 from
its fleet is one of the reasons why Horizon must terminate air service to the community.
It is my understanding that Horizon initially announced its intent to phase out the Q200 a
few years ago in favor of the Q400, a larger aircraft. It is further my understanding that
the Southwest Oregon Regional Airport is near completion of a runway expansion
project that was initiated, in large part, to accommodate the larger Q400 airplane and as
a result, there are no technical reasons that the Q400 would be unable to land at the
airport.
In its Notice of Termination, Horizon asserts that its termination of service to Portland
will not reduce levels of service below the level set forth in the essential air service
determination Order 84-12-137. In that order, the Civil Aeronautics Board specifically
determined that Portland, not San Francisco, would be the only hub airport designated
for EAS to North Bend/Coos Bay. In addition, that Order describes the minimum level
of EAS service as being twice daily round-trip flights to Portland. Therefore, Horizon's
assertion that the EAS levels set forth in the 1984 Order would be maintained after its
termination of service is not correct.
I understand that Horizon Air currently serves the Southwest Oregon Regional Airport in
a subsidy-free basis. I encourage the payment of a subsidy to Horizon, or any other
certified air carrier, and a state funding of advertising to promote both routes in order to
maintain essential air service in the form of direct flights to Portland.
Submitted Aug. 12, 2008
[Name]
[Title]
CERTIFICATE OF SERVICE
I hereby certify that I have on the / Z - ^ o f August, 2008, served the foregoing Objection
to Termination, Suspension or Reduction of Air Service upon those persons listed below
in accordance with 14 CFR §323.9(b)(7).
Dan Russo
V.P. of Marketing and Communications
Horizon Air
PO Box 68977
Seattle. WA 98168
Mr. Dennis DeVany
Chief, EAS & Domestic Analysis
U.S. Department of Transportation
1200 New Jersey Ave. SE
Washington, D.C. 20590
Mr. Rick Wetherell
Mayor, City of North Bend
835 California Street
North Bend, OR 97459
Mr. Jeff McKeown
Mayor, City of Coos Bay
500 Central Ave.
Coos Bay, OR 97420
Governor Kulongoski
160 State Capitol
900 Court Street
Salem, OR 97301 r4047
Mr. Gary LeTellier
Executive Director
Southwest Oregon Regional Airport
2348 Colorado
North Bend, OR 97459
"Docket Management Facility
U.S. Department of Transportation
1200 New Jersey Ave. SE
Washington, D.C. 20590
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