### 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 Kansas EAS bids. As is obvious, the willingness on part of Great Bend to accept single engine aircraft for its EAS to 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 Lakes are 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 Susan since 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 Lakes briefing document that could potentially help with providing background information

. As always Kevin - we appreciate your support
. 

### <Dougf4s 

# q. %ss Chair man and President Great Lakes Aviation, Ltd
. 1022 Airport Par

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### Fax: (307) 432-7001US 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 1 st. 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 1 st 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 1 st, 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

.