From: Doug Voss [mailto:dvoss@f1ygreatlakes.com]

Sent: Wednesday, February 12, 2014 5:57 PM

To: Schlemmer, Kevin (OST)

Cc: Devany, Dennis (OST); Adams, Kevin (OST); Chuck Howell

Subject: Kansas EAS

Hello Kevin

Pursuant to our phone conversations Monday and Tuesday please consider this e-mail

acknowledgement that Great Lakes is willing to remove its all or nothing language from it KansasEAS

bids.

As is obvious, the willingness on part of Great Bend to accept single engine aircraft for its EASto Wichita

as a EAShub renders cost savings for DOTthat we certainly cannot compete with. The demand for our

Turbo Prop, pressurized, twin engine and two pilot crew aircraft is such that keeping them utilized at

communities where there is greater passenger usage makes a great deal of sense.

On October za" of last year when you, Dennis and I visited with Susan Kurland and Bob Goldner

regarding the Pilot Shortage, we had discussed the possibility of flying Beech 1900's with nineteen seats

installed under FARpart 135 supplemental. Under current regulations FARpart 135 supplemental

operators are limited to only four scheduled round trips per week between any two city pairs. Do you

believe that there would be any receptivity to restarting that conversation in the near future?

As a FARpart 121 Beech 1900 operator with all new hire pilots being trained and tested to FARpart 121

standards it appears to us that EASperformed by our Pilots, who while being hired to FARpart 135

standards for the FARpart 121/135 split certificate operations certainly can perform EASas well as FAR

part 135 Single Pilot/Single Engine nine seat operators, yet we can do it with an aircraft that can carry 19

passengers.

The state of denial regarding the scope of the nationwide Pilot shortage problem is crying out for

creativity and we at Great Lakesare dedicated to finding solutions so as to not leave our communities

removed from the national transportation system due to "unintended consequences" ofthe regulatory

process.

Since we have not had a follow up conversation with Susansince the October meeting, we would

appreciate it if we could arrange a meeting with her to provide an update to all that was then discussed.

I am attaching a copy of a Senate Commerce staff/Great Lakesbriefing document that could potentially

help with providing background information.

As always Kevin - we appreciate your support.

<Dougf4s q. %ss

Chairman and President

Great Lakes Aviation, Ltd.

1022 Airport Parkway

Cheyenne, WY 82001

Office: (307) 432-7010
Fax: (307) 432-7001
US Senate - Committee on Commerce, Science and Transportation

Great Lakes Aviation - Pilot Shortage background material - 12-11-13

On April 8th of this year, Great Lakes submitted a written proposal to the FAA which would enable Great

Lakes to operate Beechcraft 1900-0 aircraft limiting the number of passengers carried to nine passengers

under FAR 135 (see attached letter to the FAA). Our proposal was then specifically targeted to provide

Essential Air Service at the Minneapolis/St. Paul (MSP) hub whereby all segments of the operation would

remain in compliance with FAR 121 operational standards with the exception being our need to be able to

use FAR 135 pilot hiring standards. This proposal would enable Great Lakes to access to a highly

qualified, well trained pool of pilots that do not possess the 1,500 hour Airline Transport Pilot FAR 121

credentials. A pool of Pilots that the company has historically had over 32 years of access to.

In July of this year, Great Lakes met with representatives of all the EAS communities served by Great

Lakes into its MSP hub. The meeting served as a multi-faceted communication forum addressing the

unintended consequences of the implementation of the 1,500 hour ATP rule. At the time of the meeting,

the FAA had yet to release the long anticipated exemption rules that were to be set to facilitate exceptions

to the 1,500 hour ATP rule.

Great Lakes had been confronting a sharp reduction in its eligible pilot hiring pool availability that was a

byproduct effective of the August 1, 2013 1500 hour ATP rule implementation date. In anticipation of the

new rule, in the fall of 2012, the company had hired a significant number of pilots that became qualified

under our then current FAR part 121 training process. It was believed then that these Pilots would have

received enough flight time experience to become eligible to fly beyond August t" under the anticipated

new exemption rules.

The FAA released the exemption rules two days after this community meeting. Unfortunately, the design

of the exemption rule procedures did not facilitate for all pilots on staff to be eligible to fly on August 1st.

The delay in the release of the rules and the corresponding certification process postponed completion of

recertification for many pilots that had been flying for the airline under Part 121 for many months in

advance of the August 1

51 transition date.

No grandfathering relief for on staff FAR 121 pilots was granted by the FAA. These events forced Great

Lakes to remove a significant amount of capacity from its system in the early days of August. The

company had substantially over staffed its pilot requirements prior to the rule change and still came up

short on the transition date.

As the airline industry transitioned through the August 1st 1,500 ATP rule change, the industry refocused

on preparing for the FAR part 117 flight duty time rule change to be implemented on January 4,2014.

Due to the lack of qualified pilots outside of the existing FAR part 121 air carrier staffing levels, Great

Lakes pilots became immediate targets for aggressive hiring by other regional and major air carriers.

Pilot attrition rates have exceeded new hire pilot recruiting capabilities by more than 20 fold. The attrition

rates have resulted in aggressive near term capacity reductions that have been and will continue to be

required to be made by the company. Further planned system wide schedule reductions have now placed

Great Lakes in a position whereby it is being forced to reduce EAS flying below traditional EAS

community capacity expectations.
Prior to the October 1st, 2013 federal government shutdown, Great Lakes had submitted revised

operating procedures manuals to the FAA for final approval of our proposed nine seat configured Beech

1900 operation. Post the reopening of the FAA offices there seems to be hesitancy by the FAA to move

forward with the split certificate process. This delay in developing the nine seat alternative will in the near

future require US DOT to help the company determine which communities would potentially need to be

completely shut down. Picking the winners and losers from should not be the companies' responsibility.

Historically, Great Lakes pilots have provided two to three week advance notices of resignation. The pilot

hiring and training process can conservatively require two to three months to complete line pilot

qualifications. Recovery from this pilot shortage will take many months, assuming relief that would enable

access to the more qualified pilots who possess the skill sets to meet Great Lakes hiring standards and

yet are unable to achieve the necessary 1500 flight hour requirement.

It is important to note that we are obligated to maintain standards higher than that of the FAA ATP

certification process. High quantities of pilots that have met FAA ATP certificate standards have not met

our more demanding hiring, training and employment standards. We as a part of the employment

process routinely test important pilot attributes like integrity every day. The assumption that we would

lower our standards just to maintain service is just not going to happen.

Under FAR part 117 duty time rules as originally written, Great Lakes had anticipated that it would

continue to be able to perform its operations in 19 and 30 seat aircraft under existing FAR 135 duty time

rules. On November 12, 2013, the FAA, with less than 60 day notification, published a technical

correction in the Federal Register (see attached Federal Register document) that now states, that the

company must also comply with the new pilot duty time rules. While Great Lakes has been asking for

relief from this requirement, it appears that the FAA is not inclined to provide such relief. This

requirement will further exacerbate future reductions in capacity to communities we serve do to a loss of

crew efficiency.

Great Lakes is obviously being forced by the new regulatory requirements to substantially reduce the

capacity it can provide to the communities we serve. Congressional intent and legislation provided the

authority for the DOT and FAA to grant exemptions to facilitate adjustments to the new rule requirements

that we certainly believed would maintain national transportation system connectivity for small

communities.

The alternative to Great Lakes twin engine, turbo prop, two pilot crewing and pressurized aircraft

capacity, would require communities to accept FAR part 135 single pilot, single engine or twin piston

engine nine seat aircraft to satisfy EAS service. This would result in an inherent reduction of safety of

flight margins which we do not believe was the intent of Congress.

Congress had instructed the FAA to engage the Industry in the rulemaking process as promulgated in the

Airline Safety and Federal Aviation Administration Extension Act of 2010. This legislation certainly

granted the latitude to facilitate the maintenance of commercial capacity without a reduction of historical

safety standards.

At the end of 2013 nearly 30% of Essential Air Service flying in the lower 48 states and Hawaii will be

provided by FAR 135 nine seat single engine and piston multi-engine equipment certified for single pilot

IFR (Instrument Flight Rule) operations.
The new regulatory requirements imposed on all FAR Part 121 air carriers regarding pilot training and

hiring eligibility requirements have dramatically accelerated a pilot shortage crisis that the airline industry

has anticipated and has been attempting to address for several years.

Capacity reductions following the events of September 11,2001 had reduced pilot staffing demands in

subsequent years, but the effects of this reduction in capacity has run its course relative to currently

available qualified pilots.

In the three years since the congressionally mandated hiring standards were established an inadequate

numbers of pilots have been building the experience and skills necessary to meet the industry's future

needs. Single pilot certified FAR part 135 operators are not required to staff copilots and hence do not

provide the Industry a meaningful progression of pilot development out of collegiate accredited pilot

training programs.

The pilot has been left on his own to find the necessary additional 500 to 1,000 hours of flight experience

that facilitates eligibility into the airline industry. Purchasing the additional time flying around the airport

pattern in Cessna 150's does very little to advance safety standards in the airline industry.

The traditional pipeline of FAR part 121 nineteen seat turboprop aircraft operators' virtually no longer

exists. We find it interesting that the NTSB is now focusing on hand flying skills while the regulatory

environment has eliminated were these skills had historically been developed. FAR part 135 single pilot

Instrument Flight Rule operations require the use of an autopilot since no copilot is required and hence

does nothing to assist in growing pilot hand flying experience levels within the industry.

Most former operators of FAR part 121 nineteen seat aircraft recognized years ago that the pilot pool

competing with regional jet equipment would not facilitate pilot retention under the same hiring standards.

Congress must recognize that the unintended consequences of the new congressionally mandated hiring

standards has been the virtual elimination of the traditional pilot career path.

The combination of pilot attrition in past years and the new pilot hiring standards which established a

1500 hour experience standard along with Airline Transport Pilot Certification (ATP) for all FAR Part 121

operations has created a "perfect storm" within the airline industry relative to the availability of qualified

pilots operating within a FAR Part 121 environment.

Throughout the course of the last three years the company has repeatedly communicated with US DOT

expressing our concern regarding our ability going forward to cover all EAS flying post implementation of

the new rules. Our greatest fears have become realized.

The pilot shortage threatens future EAS community eligibility by reducing enplanements as measured

against time. As we pull down schedules seat capacity falls below traditional availability levels producing

enplanement numbers that will trigger EAS eligibility reviews and subsequent removals from the program.

The reduced enplanement levels will also threaten Airport Improvement Program grants and entitlements.

Communities will need waivers by Congress in order to maintain historical levels of Airport infrastructure

investment support.

This is not just a Great Lakes problem, our EAS capacity happens to be were the effects of the

unintended consequences will be first seen. The cry for help from the Airline Industry regarding the pilot

shortage is not being heard.