June 6, 2019

Michael D. Gormas United States Department of Transportation Room W86-487 1200 New Jersey Avenue, SE Washington, DC 20590

Dear Mr. Gormas:

My Name is Ron Philemonoff, the CEO of Tanadgusix Corporation (“TDX”), The Alaska Native Village Corporation, established pursuant to the Alaska Native Claims Settlement Act, (ANCSA) for St. Paul Island, Alaska. TDX, as provided for by ANCSA, is a major economic driver for St. Paul and its residents. I am in support of and a signatory to the Community Leadership letter, by these comments we are reaffirming our support of the points in the Community letter. However, we are providing these additional comments out of great concern for the issues of Air Service to and from St. Paul Island. These written comments are in support of the Request for Proposals to provide St. Paul Island with EAS. While we highly support DOT providing EAS subsidy for St. Paul Island; the parameters of U.S. DOT’s request for proposals, and the application by Ravn Alaska as the passenger carrier, fail to meet the basic passenger air service needs of St. Paul Island and the suggested basic outline of service stated in the DOT RFP for passenger service to St. Paul Island is itself inadequate. Therefore, we recommend that U.S. DOT either uses whatever flexibility it has to provide for adequate service under the current, pending RFP, or that it rejects the current RFP and Ravn proposal, and goes out to rebid the EAS, telling bidders to sharpen their pencils to recalculate their costs of their roundtrip tickets, and to address the capacity need for increased frequency of flights to 4 times a week during peak summer season and during the peak Crab fishing season. Also, we support and recommend the approval of the Northern Air Cargo, “NAC,” EAS air cargo proposal.

As you may know, SNP is 400 miles from the mainland of Alaska proper, in the middle of the Bering Sea. We have no roads or marine highway links or service to St. Paul. Our only life line is access to mainland Alaska by air service and we depend on air service to sustain our community, our people, our economic viability, and access to emergency medical care. Today, I see the EAS as only a small and temporary step to achieve what we believe is needed to provide for not only our basic community needs, but to support economic development (jobs) and growth for our people.

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How has air service to SNP evolved? As background, I would take you back to the end of WWII, when St. Paul Island discovered the importance of air service when Reeve Aleutian Airways pioneered the 800-mile route to St. Paul Island from our Alaskan Hub city, Anchorage. At the peak of Reeve’s service to St. Paul, they were flying a 60-passenger Super Electra propjet, and a combination “combi” 65 passenger Boeing 727 jet. Later, St. Paul was served by Mark Air with their Boeing 737 jet. The St. Paul airport was expanded and paved to safely handle 727 and 737 jets, and the airport was then a Part 139 certified airport. Because of its route being over 400 miles of open ocean; a long-range larger aircraft such as the Super Electra or Boeing 737-type aircraft, with over water certification, is really the minimum size and long- range aircraft needed to safely and efficiently serve St. Paul Island in the longer term.

Regarding the application of Ravn Alaska, I offer the following comment on what I consider important considerations prior to approval of an award of EAS to Ravn Alaska.

1. Ravn Alaska Dash-8 Aircraft. While we support the idea of Ravn Alaska’s request for U.S. DOT to provide Ravn with EAS subsidy; Ravn Alaska’s proposed plane is too small, does not have the capacity and when fully loaded only marginally has the range for this long range 400-mile over-water route, it’s only a little bigger than the smaller “puddle jumper” planes, such as those used by part 135 carriers ACE and Grant air. We need to get back to the historical and right sized, large, long range aircraft with which Reeve Aleutian and Mark Air properly sized and serviced St. Paul. Prior to its acquisition by Ravn, Old Pen Air’s plans for use of the SABB 2000 for St. Paul was the right idea along these lines. We understand that the Dash 8 is the only type aircraft Ravn Alaska may have certified for now, and therefore can support this aircraft for the next two to three years as a temporary fix. However, in the meantime, to address the peak loads and having no other plane of the right size available, we recommend Ravn be required to increase their scheduled frequency of flights to St. Paul to 4 times a week, see note below.

• Adequate Flight Schedule. We request that the U.S. DOT require four passenger flights a week during the summer and crab seasons, and that the EAS for St. Paul is further supplemented by the NAC heavy capacity cargo jet proposal. The need for a both a Passenger and a separate Cargo only EAS service, is critical because Ravn does not currently have the capacity to meet the Community’s Air Cargo needs, and is Not addressing this need in their proposal. This economic growth during summer and the crab season cannot be hindered by inadequate air passenger and cargo service. As of today’s date, Ravn Alaska flights to SNP and vice versa are booked solid through the end of June this year! No extra flights are scheduled (nor can they be, as Ravn has their planes booked elsewhere), nor does Ravn Alaska permit anyone to book and standby for a flight if it is full. Furthermore, Ravn barely has the capacity for our luggage, we are seeing more and more of our luggage being left behind. Ravn has very little capacity

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and over water range with the dash8-100 to carry a full load of passengers and all their luggage, let alone with all the cargo needs of the Community. Therefore, we need for U.S. DOT to approve both EAS proposals for St. Paul, so that the limited 4 times a week passenger services can be further supplemented by the NAC heavy capacity cargo jet proposal.

2. Rising Airfare cost. The recent costs quoted by Ravn Alaska for SNP are exaggerated and are barely justified for the $1300 round trip ticket they are charging the Community. We pray, and hope U.S. DOT holds Ravn Alaska to their word, at their stated number in their EAS Bid, at the $400 one way - $800 round trip price tickets if they get a $2 million annual EAS subsidy. Old Pen air was selling round trip tickets for$ 650 to $780 with no EAS subsidy. The cost of ground operations to operate in and out of St. Paul has not gone up much more than 2 thousand dollars per month, compared to the proposed approximately $100,000 per month increased cost to the flying public, let alone Ravn’s requested $2 million subsidy they are asking DOT to provide them. Ravn states the “average ticket cost” in their EAS bid, at the $400 one way - $800 round trip price tickets if they get $2 million EAS subsidy. This seems to be some fancy wordsmithing to imply $800 RT tickets going forward; DOT needs to require Ravn lock this price down as being the true and accurate roundtrip ticket cost if they get the $2 million EAS subsidy.

3. Overstated Operational costs. We also need to clarify the record relative to ground operation costs at St. Paul’s terminal. In the rush by Ravn Alaska to get the EAS proposals to DOT in a timely fashion and to explain the urgent air carrier needs for EAS support, some of their information overstated the supposed expensive costs of operations on-Island. One case in point is Ravn Alaska’s overstated costs of the terminal space on Island. An error was made by the drafter of the Ravn Alaska EAS proposal by including apron and taxiway square footage in their square foot cost calculation, and implied that the terminal costs were more than $7,000 per month. This was an error on Ravn’s part and at best is mistakenly stated in their request for the EAS consideration. The true cost was not much more than the Old Pen Air cost, Ravn Alaska’s terminal cost is only $2,000 per month. It’s very likely that the cost of ground service provided by their contractor, APUN, may also be overstated.

Regarding a larger aircraft to serve SNP, we have discussed this with the State DOT managers, and we both agree and understand that once the air carrier proposes to fly the larger, more than 30-passenger, part 121 aircraft, i.e., the SABB 2000 or Dash 300; the Community and the State will begin the process of re-certification of the SNP Runway back to being Part 139. In the meantime, therefore, all we can do, and need to do, at this time, is to get Ravn to approved to provide reliable flights, four times per week (during peak times at least) with an airfare that our community can afford, and that U.S. DOT approves of the additional Cargo-only EAS to support and meet the needs of the basic Air Cargo service, as proposed by NAC. The NAC proposal

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will supplement the somewhat less than adequate proposal that Ravn did not expand on regarding the critical air cargo needs. The Cargo only EAS is one that should be only interim in nature, until Ravn or another carrier moves to the right size, the larger longer-range aircraft to adequately address the passenger capacity along with our mail and cargo needs from a range of 700 miles away, at 400 miles over water! and another 300 miles to the main HUB in Anchorage.

We appreciate DOT’s understanding and support of our passenger and cargo air service to SNP as an essential service.

Sincerely,

Ron Philemonoff Chief Executive Officer