Rutland State Airport - State of Vermont

FAA-2004-17385 - FAR Part 139 Exemption

March 12, 2004

Re: Part 139 Exemption

The new Aircraft Rescue and Fire Fighting requirements would place severe economic burden and unreasonable personnel requirements on an airport that currently operates over ($328,000) in deficit yearly. The result of any significant increase in ARFF operating expenses would be the loss of the airport's airport operating certificate and subsequent loss o' air service for the community.

The Rutland State Airport currently maintains a FAR Part 139 limited operating certificate. The airport provides 4 daily week-day departures (2 departures on week-ends) to Boston and Albany on Continental Connection (CommutAir) with B 1900 aircraft and has the ability to accommodate 139 aircraft on an unscheduled basis. Operating under the Essential Air Service Program, the airport recorded 1812 passenger enplanements in 2003 (see enclosures 3A, 3B, 3C). CommutAir started service in October 2003 and has indicated to the airport that they do not anticipate any significant schedule or aircraft type changes in the near future.

With the anticipated June 9, 2004 implementation of the new FAR 139 rules, the airport finds itself in a situation that is both economically and practically unsustainable. The minimum increase in operating costs to provide the required level of ARFF protection required in the new rule is projected to be $294,448. This expense will increase the current total operational deficit by 90%, bringing the total deficit to approximately ($623,000). Also, the Rutland City Fire Department may not be able to adequately staff the airport due the voluntary nature of the overtime required to support the airport. Furthermore, due to the instability of the air carrier service (EAS Program), lack of reliable state funding and internal Rutland City policies the hiring of additional fire personnel is not feasible.

In conclusion, the State of Vermont and the surrounding community can not support the financial and human resource needs required to provide the on‑site fire fighting capability requirements of the new 139 rule. As outlined in this letter, the ARFF requirements of the 139 rule will place such economic and practical burdens on the airport that the State of Vermont's only option would be to discontinue air service to the community. Safety is of course paramount. The State feels that given the size and frequency of air carrier operations and the exceptional safety history of the airport, the airport's current and future level of safety is equal to or exceeds that, of many larger airports

By: Thomas Trudeau, Rutland Airport Manager