Respectfully, we understand that the law is the law. And, it is very important for a 2 engine plane to have 2 pilots per this rule.
If the incumbent EAS air carrier is not operating according to the rule: operating 2 engines and 2 pilots, then the rule has not been followed since April 5, 2020. That is over 4-years since RAVN left the market and far exceeding the rule's 60-consecutive operating days allowance.
Since the rule has not been adhered to for over 4-years, it allows an opportunity to select another air carrier option based on merit versus the 2 engines and 2 pilots rule. In our case, it allows the option to choose a pressurized IFR rated turboprop plane with a better safety record and at least 500-pounds greater payload per flight to serve the community. Again, respectfully, the rule does not state anything about losing the future right to choose an aircraft with 2 engines and 2 pilots.
49 U.S. Code § 41732 - Basic essential air service
U.S. Code
Notes
(5) service provided in aircraft with at least 2 engines and using 2 pilots, unless scheduled air transportation has not been provided to the place in aircraft with at least 2 engines and using 2 pilots for at least 60 consecutive operating days at any time since October 31, 1978.
The EAS solicitation states the following which allows us to make a more competitive bid:
"Air carriers may propose more than one service option. They can also propose service options different from what the community currently receives—lengths of contract terms or airports, for example. However, proposals should have at least one option that complies with the weekly capacity described below and all legal requirements."
In our bid, we offer the community of McGrath up to 10 direct flights per week and will add flights during times of greater demand such as hunting season. Our proposal is based on the the US DOT's data for passenger, cargo and first class mail.
If selected to serve McGrath EAS, we will be proud to provide safe, reliable service for McGrath!
Respectfully,
Josie & Team AAT
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