Detailed Information on the
Essential Air Service Assessment

Develop legislative reforms to better align program design and more effectively target resources.

Implement long term and annual performance measures.

Review previous year's performance data and establish ambitious performance targets for the performance measures that the program exceeded.

Measure: Maintain continuous air service at 98% of eligible, subsidized communities

Explanation:In order to attain the long-term goal of continuous air service to nearly every eligible community, EAS must establish and maintain air service at as many eligible communities as possible each year.

Measure: Percentage of renewal contracts that are established before the existing contract expires.

Explanation:For communities that are already receiving subsidized EAS, we generally establish two-year contracts with a regional air carrier to provide a prescribed level of service. In order to maintain smooth, uninterrupted air service, as those contracts near the end of the term, we establish new, two-year contracts, either with the incumbent carrier, or with another carrier before the existing contract expires.

Measure: Percentage of new contracts processed within 160 days of carriers' notices to suspend service at EAS communities.

Explanation:This measure tracks the amount of time it takes EAS to establish a new contract for subsidized service once a carrier notifies the Department it will be pulling out of a community. Tracking this process reduces the risk of interrupting service for communities.

Measure: Percentage of payments to air carriers that are processed within 15 business days

Explanation:Because air carriers are reimbursed for their flights, it's critical that EAS process payments as soon as possible. Because so many of the small regional carriers operate on such a thin margin, a carrier may be at risk of having to discontinue service to a community if it does not receive prompt payment from EAS.

Is the program purpose clear?

Explanation: The authorizing statutes clearly state that the Secretary must ensure, by providing subsidies to air carriers when necessary, that most every community that received scheduled air service during regulation continue to receive at least a minimum level of scheduled service. The law specifies which communities are covered by the EAS program and the minimum service levels that they are guaranteed. Specifically, Congress included in the EAS program all communities that were receiving scheduled air service from a certificated carrier on the date of enactment of the Airline Deregulation Act (October 24, 1978).

Evidence: http://www.law.cornell.edu/uscode/html/uscode49/usc_sec_49_00041732----000-.html Sec 332 of: http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=106_cong_public_laws&docid=f:publ069.106

Does the program address a specific and existing problem, interest, or need?

Explanation: Yes. Congress targeted those communities for inclusion in the EAS program that were receiving scheduled air service by one or more certificated air carriers on the date of enactment of the Airline Deregulation Act of 1978 (October 24, 1978). Of the some 700 communities that are guaranteed air service under the program (roughly 200 in Alaska and 500 in the rest of the country) the Department is paying carriers to serve 38 in Alaska and 114 in the rest of the country. All, or virtually all, of those communities would lose all scheduled air service without the EAS payments to the carriers. In addition, since September 11, airline revenues are down and expenses are up, making service to many small communities less commercially viable and further increasing the number of communities relying on the EAS program to maintain service.

Evidence: http://straylight.law.cornell.edu/uscode/html/uscode49/usc_sec_49_00041731----000-.html According to GAO Report January 2003 "Factors Affecting Efforts to Improve Air Service at Small Community Airports," small communities lack the population base and level of economic activity that generates sufficient passenger demand to make them profitable to air carriers and thus these communities are having a hard time keeping air service. GAO Report March 2003 "Issues Regarding Federal Assistance for Enhancing Air Service to Small Communities." On pg 4 explains that fundamental economic principles work against small communities when trying to attract and keep air service. 1987 DOT Report to Congress describes why continuous air service is vital to communities and the direct/indirect impacts involved if they lose air service.

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: The focus of the EAS program is to provide a safety-net level of connectivity to the national transportation system. The Small Community Air Service Development Program (SCASDP) is the only related Federal program and it differs significantly from EAS. SCASDP is targeted generally to communities with non-subsidized scheduled air service that want to enhance their existing services, frequently by attracting a second or third carrier, service to another hub, or service with larger/jet aircraft. The SCASDP differs from the EAS program in that the funds available are not limited to air carrier subsidy; the funding goes to the community rather than directly to air carriers; and, the focus of the SCASDP is air service "development". On a local level, the Illinois legislature has recently enacted "I-FLY", a state grant program similar to the SCASDP program.

Evidence: http://www4.law.cornell.edu/uscode/html/uscode49/usc_sec_49_00041732----000-.html http://www.illinois.gov/PressReleases/ShowPressRelease.cfm?SubjectID=2&RecNum=4852 http://www.ilga.gov/legislation/ilcs/fulltext.asp?DocName=002039580K25

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: Given the Secretary's statutorily required mandate to ensure a minimum level of scheduled air service to approximately 700 communities, the current program is the most efficient and effective approach. If the program were static, it could perhaps be run at the state level through block grants. However, the program is fluid and the number of eligible communities receiving newly subsidized service increases each fiscal year and it cannot be predicted when or how much the subsidized service will cost. Moroever, it is unlikely that states would vigorously impose the eligibility standards such as the $200 per passenger cap since they want to preserve air service at their communities even if it would violate our eligibility criteria.

Evidence: August 2002, GAO Report examined alternate ways to do the program and probable negative effects. The end result being that none of the alternates proposed could guarantee continuous air service. (i.e. increased leakage, possible additional passenger inconvenience, impact on the economy of the affected communities is unknown, regionalizing air service would require some communities to give up their own service). DOT 1987 Report to Congress: looked at alternate ways to structure the program and why they wouldn't meet goal of ensuring continuous air service. GAO Reports of January and March 2003, state that the EAS program is meeting its statutory objective of ensuring air service to eligible communities, however, financial incentives by local communities aren't an effective long-term solution because the benefit only lasts as long as the subsidy.

Is the program design effectively targeted so that resources will address the program's purpose directly and will reach intended beneficiaries?

Explanation: The underlying EAS statutes have remained fundamentally unchanged in the more than 25 years since their inception, while the aviation landscape has changed dramatically, especially with respect to the development of the hub-and-spoke systems, the growth of regional jets, and the expansion of low-fare service by low-cost carriers. The EAS program's governing statutes require a one-size-fits-all approach, as virtually all communities are guaranteed two round trips a day with 15-seat or larger aircraft. The program should be targeted to only the most isolated communities, especially those that do not have highway access to air transportation. There are clearly some communities eligible for receiving subsidized service that are within easy driving distance of air service that do not require subsidies. Data show that passengers are especially willing to drive a couple hours to a nearby major hub with a low-fare carrier, such as JetBlue or Southwest. Also, some communities do not need 15-seat or larger aircraft to provide enough capacity to meet market demands.

Evidence: For example, Lancaster, PA, is 28 miles from significant levels of jet service at the Harrisburg Airport, and about 70 miles from the Philadelphia Airport and BWI, both of which are served by low-fare carriers. We are currently paying Air Midwest Airlines about $1.6 million a year to serve the Lancaster-Pittsburgh market. Lancaster is not "effectively targeted." Even the Harrisburg airport, with ample jet service, loses passengers who drive to Philadelphia or BWI for low-fare service. The "phenomenon" is so widespread that there is a term for it in the industry -- leakage. The Department has offered many legislative amendments over the years, but Congress has not adopted them: all communities would have to contribute some of the subsidy, with the most isolated paying the least and those within an easy drive of a major airport paying the least.

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: Program has developed one long-term measure so without additional long-term measures they will be unable to receive a "yes" on this question.

Evidence: The program has established one long term measure pertaining to providing service at 98% of eligible communities.

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: Program received a "no" for 2.1

Evidence: Program received a "no" for 2.1

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: The program's annual performance measures support achievement of the long-term goal of maintaining continuous air service at 98% of eligible, subsidized communities through 2011 by focusing on three key processes: establishing new contracts, renewing expiring contracts, and processing payments. These processes ensure that communities that were recently dropped by air carriers continue to have a safety net level of service through EAS, that long-time EAS-supported communities retain their air services without breaks, and that carriers receive timely subsidy payments so they may continue to provide service. With these three processes EAS ensures that 98% of eligible communities have air service. The annual achievement of this 98% rate ensures that the long-term goal is achieved.

Evidence: Annual performance measures were developed around, and will be measured by, tracking several functions of the program, e.g., maintaining continuous service at eligible, subsidized communities, and processing renewal contracts, new contracts, and payments to air carriers in a specific, alloted timeframe.

Does the program have baselines and ambitious targets for its annual measures?

Explanation: Program has developed baselines and targets for 3 out of the 4 annual performance measures.

Evidence: The Program has established FY 2005 as the baseline for the long-term performance measure, and for 3 out of the 4 annual performance measures. In addition, the Program has decided to collect historical data back to FY 2003 and set targets out to FY 2008. (See 'Performance Measures' link)

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: The Program has developed one long-term and 4 annual goals for the program. Without established goals, partners cannot commit to and work towards the goals of the program.

Evidence: The EAS program has developed one long-term goal and 4 annual goals.

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: Program has had numerous evaluations over the last few years by GAO that have been of high quality, sufficient scope, unbiased and on a regular basis. GAO has conducted audits of the program and concluded, on balance, that the program is meeting its goals. GAO suggests that service should be targeted to more remote communities, that smaller aircraft are more appropriate in many cases, and that service should be consolidated from several nearby airports into one regional airport. The Department has proposed all of those legislative reforms, but none have been adopted. On page 12 of its report, GAO concludes, "The EAS program appears to be meeting its statutory objective -- to ensure continued air service to small communities....To the extent that the program must operate within certain fiscal constraints,, we identified some directions that the Congress (emphasis added) may wish to consider....The Congress (emphasis added) will need to weigh the effects of each option against the program's overall goal."

Evidence: http://www.gao.gov/new.items/d02997r.pdf, http://www.gao.gov/archive/2000/rc00034.pdf, http://www.gao.gov/new.items/d02432.pdf, http://www.gao.gov/new.items/d03330.pdf.

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: No, the EAS program is currently developing new annual and long-term performance goals.

Evidence: http://www.whitehouse.gov/omb/budget/fy2004/transportation.html

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: The Department has consistently requested authority from Congress to tighten standards. Except for the $200 subsidy-per-passenger ceiling and the 70-mile isolation standard, Congress has retained the requirement that service be provided and has not granted DOT any discretion to terminate or reduce service below statutory minimums. The Assistant Secretary for Aviation and International Affaires has delegated authority down to the Office Director level for a number of routine EAS orders, thus ensuring that cases are handled timely and that there are no service hiatuses. In addition, the program is working to develop performance measures that can be used to guide its operations.

Evidence: DOT Memo, dated September 2005. Subject: ACTION: Delegation of Authority for administering the Essential Air Service Program

Has the agency/program conducted a recent, meaningful, credible analysis of alternatives that includes trade-offs between cost, schedule, risk, and performance goals, and used the results to guide the resulting activity?

Explanation: In every carrier-selection decision, the Department balances the various statutorily mandated carrier-selection criteria with the subsidy amounts required. In addition, the Department established an alternate EAS and EAS buyout program in 2004. However, to date, no community has applied for either program. The EAS buyout program would allow communites a one-time grant, the value being twice the one year subsidy amount being currently paid for subsidized service. In exchange, the community would opt out of the EAS program for 10 years. The community may use the grant for any project that (a) is eligible for assistance under, and complies with the requirements of, the Airport Improvement Program, (b) is located on airport property, or (c) will improve airport facilities in a way that will enhance their usage for general aviation. Furthermore, based on findings and recommendations in recent GAO reports, the Department continues to advocate for change in the EAS program in its annual budget request to Congress.

Evidence: http://dmses.dot.gov/docimages/pdf95/383254_web.pdf http://dmses.dot.gov/docimages/p78/288626.doc http://dmses.dot.gov/docimages/pdf89/288625_web.pdf http://www.gao.gov/new.items/d03540t.pdf

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: Carriers submit monthly data regarding their completion performance. During the RFP process, we directly solicit community comments regarding the air carrier proposals, and communities frequently discuss their incumbent carrier's reliability. In addition, we are in regular contact with community and airport officials regarding service performance, among other things. Finally, the Department has established an internal tracking system that closely monitors the progress of all casework.

Evidence: Small subsidy example: Air Carrier's Claim for Subsidy submitted by 40-Mile Air. Large subsidy example: Air Carrier's Claim for Subsidy submitted by Big Sky Airlines. http://dmses.dot.gov/docimages/pdf95/383254_web.pdf

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: The Assistant Secretary for Aviation and International Affairs establishes a contract with the Secretary of Transportation outlining all major program objectives. (The portion relevant to EAS is copied verbatim below.) This contract is used as a benchmark to measure organizational and individual performance. The organization is reviewed annually by the agencies executive resource review committee required by the Office of Personnel Management to review the performance of Senior Executive Service members connecting individual performance to organizational success. Current standards require the performance objectives to cascade throughout the organization to General Schedule employees. As a result, the performance requirements established for the Assistant Secretary are mirrored by the standards set forth at the Director level as well as Division Chief level of the EAS program.

Evidence: Excerpt from the Accountability Contract of the Assistant Secretary for Aviation and International Affairs: Fulfill the Department's Mandate to Afford Rural and Lesser-Served Communities Access to the Aviation System -- Through careful analysis, sound decision-making and targeted reform, seek to promote efficiency and equity in administration of the Department's programs (Essential Air Services and Small Community Air Service Development Pilot Project) to promote access by lesser-served communities to the country's air transportation system, consistent with the Department's statutory mandate. The Executive Performance Plan of the Director of the Office of Aviation Analysis requires him to a) administer the EAS program to ensure that all communities statutorily entitled to air service receive such service within the budgetary constraints of the funds appropriated for the program and that program funds are administered consistent with governing statutes and appropriate financial management practices; b) as appropriate, propose reforms designed to improve the efficiency of the EAS program; and c) promote awareness and understanding of the program to facilitate a greater understanding by small communities, Congress, other elected officials and the airlines of the statutory intent and restrictions of the EAS program.

Are funds (Federal and partners') obligated in a timely manner, spent for the intended purpose and accurately reported?

Explanation: Funds are obligated as service orders are awarded based on the maximum amount of subsidy allowable as identified in the order. For service orders that span the full fiscal year, the full year's worth of funds are obligated at the beginning of the fiscal year. For those that expire during the fiscal year, only funds necessary for the duration of the contract are obligated, until a new contract is let at which time the balance is obligated. Each order specifies the service level to be provided and a weekly subsidy ceiling, a level above which the carrier cannot be paid. These controls ensure that the correct level of subsidy is paid to the recipient based on the service provided to a community. Payments to carriers are made monthly, in arrears, within 15 days after the air carrier submits an invoice describing the service provide, i.e., the number of flights, aircraft type, etc, to ensure that the service levels are in accordance with the service order. The invoices are reviewed and approved in the program office for payment by OST's accounting service provider The monthly SF-133 is reviewed by the OST Budget Office and provided to the EAS program office for further review.

Evidence: Excel Spreadsheet (containing two worksheets) demonstrating that obligations are made in concert with the overall program plan and that funds are obligated on a schedule that corresponds to the resource needs of the program plan.

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: The Department uses a bid process to attract proposals from carriers interested in providing EAS. In addition, our RFPs make clear that we retain the right to reject all proposals if we find them to be too expensive, and to re-solicit another round of proposals. We also retain the right to negotiate the subsidy amounts if we find a meritorious proposal that is just too expensive. However, the program does not have an established efficiency measure but it is under development.

Evidence: http://dmses.dot.gov/docimages/pdf92/335815_web.pdf http://dmses.dot.gov/docimages/pdf92/337636_web.pdf

Does the program collaborate and coordinate effectively with related programs?

Explanation: The only related program is the Small Community Air Service Development Program (SCASDP), which was created by Congress several years ago. However, that program has a different set of goals and is targeted generally to communities with non-subsidized scheduled air service that want to enhance their existing services, frequently by attracting a second or third carrier, service to another hub, or service with larger/jet aircraft. The programs share staff and line-management who coordinate regularly. Both programs are managed within the Office of Aviation Analysis under the Assistant Secretary for Aviation and International Affairs, thus ensuring that the programs compliment each other rather than conflict. Within the last couple years, Cedar City, Utah, and Manhattan, Kansas, among others, received subsidized EAS and a SCASDP grant.

Evidence: http://dmses.dot.gov/docimages/pdf90/301897_web.pdf, http://dmses.dot.gov/docimages/pdf89/273449_web.pdf, http://dmses.dot.gov/docimages/pdf85/242366_web.pdf, http://ostpxweb.dot.gov/aviation/X-50%20Role_files/Order%202002%20Grant%20Award.pdf, http://ostpxweb.dot.gov/aviation/X-50%20Role_files/2003%20Grant%20Award%20Order.pdf, http://ostpxweb.dot.gov/aviation/X-50%20Role_files/2005%20Grant%20Selection%20Order.pdf http://ostpxweb.dot.gov/aviation/index.html, http://dmses.dot.gov/docimages/pdf95/389886_web.pdf (footnote 2) http://dmses.dot.gov/docimages/pdf95/383254_web.pdf (page 4)

Does the program use strong financial management practices?

Explanation: The EAS funds are apportioned by OMB through the OST Budget Office, allotted to the program office, and loaded into DOT's Delphi accounting system. The accounting system is accredited and is operated by the FAA's Enterprise Service Center (ESC) - a designated Center for Excellence. The Delphi system contains a funds control mechanism that prevents obligations from exceeding budget authority. Monthly reviews of obligations, expenditures and budget authority are conducted by multiple offices from information contained in the Delphi system and SF-133 Reports on Budget Execution. Obligations are established based on completed service orders and are verified against funds availability in the program office and by the OST Budget Office. Approved obligations are entered into the Delphi system by ESC. Payments to carriers are entered into an integrated electronic approval system (Markview), matched against existing obligations and approved by financial specialists within the program office. EAS funds and activity are included in the overall OST financial statements. No material internal control weaknesses were identified and OST's financial statements received a clean audit opinion - indicating that the financial information contained therein is accurate, timely and free of material internal control weaknesses.

Evidence: http://www.dot.gov/perfacc2005/auditreport.htm#audit http://www.dot.gov/perfacc2005/toc.htm

Has the program taken meaningful steps to address its management deficiencies?

Explanation: After a recommendation from the Office of the Inspector General, the EAS program established a separation of duties between staff who issue the service orders and staff who pay the resulting subsidy claims to improve financial management interal controls. This function was further separated in FY 2006, moving the payments function out of the program altogether and into a central financial management office with budgetary oversight provided by the OST Budget Office.

Evidence: DOT Memo dated March 10, 2005, Subject: Realignment of the OST Policy Management Staff

Is the program managed by maintaining clearly defined deliverables, capability/performance characteristics, and appropriate, credible cost and schedule goals?

Explanation: The Department uses a bid process to attract proposals from carriers interested in providing EAS, and our RFPs make clear that we retain the right to reject all proposals if we find them to be too expensive, and to re-solicit another round of proposals. In addition, all of the EAS contracts are fixed price, and they cannot exceed the established price. There are no provisions for cost escalations, fuel price adjustments, etc. In addition, consistent with recommendations by the Office of Inspector General, the personnel directly responsible for reviewing the invoices from carriers and ensuring that they conform to the contract do not work in the EAS office. The authorization of payments is done outside the EAS office as well.

Evidence: http://dmses.dot.gov/docimages/pdf92/335815_web.pdf http://dmses.dot.gov/docimages/pdf92/337636_web.pdf

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: Program is currently developing long-term performance goals.

Evidence:

Does the program (including program partners) achieve its annual performance goals?

Explanation: The program is in the process of developing baselines and targets for its performance measures.

Evidence:

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: Program is still developing program goals and has not been able to demonstrate improved efficiencies.

Evidence:

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: There are no comparable programs either in private or public sector, or in other parts of the world. The EAS program represents a highly regulated program within the broader context of a fully deregulated airline industry. The European Union is in the embrionic stages of developing some kind of protections for small communities to retain air service in a deregulated environment, but it is still in the formative stages, and does not allow for comparisons.

Evidence:

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: GAO has conducted multiple reviews of the EAS program and essentially concluded that the program meets its statuatory objective -- to ensure continued air service to small communities but in order for the program to remain viable it needs to be reformed. GAO has extensive suggestions on how to reform the program. In addition, GAO has commented that the program has not provided an effective transportation solution to most travelers to or from those communities. In 1989, the Office of Inspector General conducted an audit on the EAS program and found that while OAA had generally managed and controlled the program efficiently and economically, improved procedures were needed for obligating EAS funds and detailed guidance to air carriers was needed for their use in preparing their claims for losses in complying with hold-in orders. The audit also showed that final settlements of carriers' hold-in claims were reasonable, fully supported and documented, and made appropriate use of Office of Inspector General (OIG) audit reports. In addition, the audit found that determinations of eligible EAS points were in conformance with statutory criteria.

Evidence: http://www.gao.gov/new.items/d02997r.pdf December 1989 Inspector General Report on Audit of the EAS program

Were program goals achieved within budgeted costs and established schedules?

Explanation: The Department has maintained continuous service at virtually all of the EAS communities for more than 27 years, and we have been able to maintain service at an ever-increasing number of subsidized communities and stay within budget. In addition, the Department has terminated subsidy eligibility of 66 communities that have failed either the $200-subsidy-per-passenger cap or the 70-mile standard. Program is still developing goals so progress cannot be compared to annual or long-term goals.

Evidence: