U.S.Departmentof Transportation OfficeoftheSecretary ofTransportation Aprill, 2015 Mr. Paul A. Lange LawOffices ofPaul A. Lange 80 Ferry Boulevard Stratford, CT06615

DearMr. Lange: .. _J 1.• 1200 NewJersey Avenue, SE Washington, DC 20590

We have completed our initial review ofthe application filed by Liberty Helicopters, Inc. ("Liberty") for the determination of its fitness to conduct scheduled passenger air transportation as a U.S. commuter air carrier. This review has revealedthe need for additional and/or clarifying informationbefore we cancomplete processing ofLiberty's application. The attached Information Request lists the areas where further and/or clarificationinformationis necessary. I askthatyourespondfully to this requestwithin 30 days ofthe date ofthis letter. You may upload your response viaweb at www.regulations.gov, oryoumay mail your response to U.S. Department ofTransportation, Docket Operations, West Building, Ground Floor, (M-30, Room W12-140), 1200New Jersey Avenue, S.E., West Building Ground Floor, Washington, D.C. 20590. In either case, your response should be filed in Docket DOT-OST-2015- 0037. As is the Department's practice, further processing ofLiberty's application will be deferred pending receipt of this material. In addition, please remember that Liberty should promptly provide the Department with any information regarding changes it may undergo in areas affecting its fitness (i.e., management, operating plans or financial condition, compliance disposition, or ownership) while its applicationis underreviewby theDepartment. Thank you for your cooperation in this matter. Ifyou have any questions regarding this letter or the requested information, pleasefeel free to contactme at (202) 366-9721 or shabu.thomas@dot.gov. Sincerely,



# w~ ShabuThomas TransportationIndustry Analyst Air CarrierFitnessDivision Office ofAviationAnalysis

cc: DocketDOT-OST-2015-0037Information Request

General Information 1. In its application, Liberty states that flights operated under the proposed commuter operations will be predominantly arranged via software applications that allow customers to crowdsource charter flights. Please provide detailed information on how the proposed crowdsourcing arrangementwill operate. 2. Please list subsidiaries, ifany, ofSightseeing Tours ofAmerica, Inc. ("STA), andinclude a descriptionofeachorganization'sprincipalbusiness. Ownership and Key Personnel 1. · Resume for Mr. Drew Schaefer does nothave description ofresponsibilitieshandled ateach place of employment. Please submit a complete resume, including a brief description of responsibilities held at each place ofemployment and provide compliance information as required by sections 204.3 (1), (m), (o), (p), and (q) ofour rules. Since Mr. Schaefer holds multiple positions within STA and subsidiaries, please indicate how much time he will devoteto Liberty's operations. 2. Resume provided for Mr. Steve Brown identified no employment between June 2008 and October 2009. Please explain the gap in of employment. If he was unemployed, please state. Financial Position Anapplicant for commuter authority is expectedto be preparedto fully prosecute its application at the time it is filed. With respect to financial fitness, the applicant is required to provide currentfinancial data, 1andthree years ofhistoric financial data, together with a detailed forecast of its pre-operating costs and a pro-forma forecast profit and loss statement reflecting all revenues and expenses the applicant expects to earn/incur during its first year ofoperations. In addition, the company must demonstrate that it has obtained all ofthe funding needed to meet our financial fitness test or, at a minimum, that it has a reasonable plan for doing so. In its request, Liberty submitted its balance sheet and income and expenditure statement for the years 2012, 2013, and 2014. However, no explanatory footnotes accompanyingthe financial statement wereprovided. Therefore, pleaseprovidethe following information: 1. Please provide balance sheet and income statements, for the years 2012, 2013 and 2014 alongwith their explanatoryfootnotes. 2. Please submit a current (within 3 months ofthe date ofthe request is filed) balance sheet andincome statement ofLiberty along withthe accompanying explanatory footnotes.

1 The balance sheet and income statement supplied mustbe for a period ending no more thanthree months prior to the date offiling.2

3. The first year forecast profit and loss statement does not appear to include significant expense categories such as aircraft lease and hangar expenses. In other. words, insufficient detail was provided on the expense categories shown and, as a result, we cannot determine whether these expenses are reasonable. In light ofthe foregoing, we ask that you provide a new first year profit and loss forecast (broken down by month or by quarter) which, at a minimum, provides details by expense category (direct and indirect) for all expenses that will be incurred in conducting the proposed commuter operations, indicating how the amounts were computed. These expenses should include all cash and non-cash (i.e., aircraft or facilities depreciation or lease expense) items that are related to the provision ofthe proposed operations. Ifcertain ofthe expenses will be assumed by a third-party, Liberty should include footnotes to this effect and provide independent third-party verification supporting its statements. If certain expenses normally associated with air transportation operations will not be incurred, please explain. 4. Please provide a detailed pre-operating expense forecast for the proposed commuter operations. This forecast should include, among other things, lease deposits and rents, legal expenses, station expenses, facility deposits and rents, training, insurance, general, administrative, and employee expenses, and expenses related to FAA certification. Additionally, such list should distinguish between pre-operating expenses that have been paid, andthose whichremain to bepaid. 5. Generally, the air carrier mustdemonstrate that it will have available funding sufficientto cover any current working capital deficit and any pre-operating expenses, as well as an average ofthree months ofthe additional operating expenses that would result from the expanded operations. Please provide third party verification of all available funds, together with a summary of all plans for additional funding required to meet the Department's financial fitness test. Certification The information provided pursuant to this Information Request should be accompanied by the following certification: The contents ofthis application and the attached exhibit (s) are true and correct to the best ofmy knowledge and belief. Pursuant to Title 18 United States Code Section 1001, I 

### [the individual signing the application, who shall be aprincipal owner, senior officer, or internal counsel ofthe applicant], in my individual capacity and as the authorized representative ofthe applicant, have not in any manner knowingly and willfully falsified, concealed or failed to disclose any material fact or made any false, fictitious, or fraudulent statement or knowingly used any documents which contain such statements in connection with the preparation, filing or prosecution ofthe application. I understand that an individual who is found to have violated the provisions of 18 U.S.C section 1001 shall be fined or imprisoned not more than five years, or both.