U.S. Department of 

Transportation 

Office of the Secretary 

of Transportation 

Aprill, 2015 

Mr. Paul A. Lange 

Law Offices of Paul A. Lange 

80 Ferry Boulevard 

Stratford, CT 06615 

Dear Mr. Lange: 

.. _J 1 .• 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

We have completed our initial review of the 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 revealed the need for additional and/or clarifying information before we can complete 

processing of Liberty's application. The attached Information Request lists the areas where further 

and/or clarification information is necessary. I ask that you respond fully to this request within 30 days 

of the date of this letter. You may upload your response via web at www.regulations.gov, or you may 

mail your response to U.S. Department of Transportation, Docket Operations, West Building, Ground 

Floor, (M-30, Room W12-140), 1200 New 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 of Liberty'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 

application is under review by the Department. 

Thank you for your cooperation in this matter. If you have any questions regarding this letter or the 

requested information, please feel free to contact me at (202) 366-9721 or shabu.thomas@dot.gov. 

Sincerely, 

Shabu 

w~ Thomas 

Transportation Industry Analyst 

Air Carrier Fitness Division 

Office of Aviation Analysis 

cc: Docket DOT-OST-2015-0037 
Information 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 arrangement will operate. 

2. Please list subsidiaries, if any, of Sightseeing Tours of America, Inc. ("STA), and include a 

description of each organization's principal business. 

Ownership and Key Personnel 

1. · Resume for Mr. Drew Schaefer does not have description of responsibilities handled at each 

place of employment. Please submit a complete resume, including a brief description of 

responsibilities held at each place of employment and provide compliance information as 

required by sections 204.3 (1), (m), (o), (p), and (q) of our rules. Since Mr. Schaefer holds 

multiple positions within STA and subsidiaries, please indicate how much time he will 

devote to 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 

An applicant for commuter authority is expected to be prepared to fully prosecute its application 

at the time it is filed. With respect to financial fitness, the applicant is required to provide 

current financial data, 1 and three years of historic 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 of operations. In 

addition, the company must demonstrate that it has obtained all of the 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 accompanying the financial statement 

were provided. Therefore, please provide the following information: 

1. Please provide balance sheet and income statements, for the years 2012, 2013 and 2014 

along with their explanatory footnotes. 

2. Please submit a current (within 3 months of the date of the request is filed) balance sheet 

and income statement of Liberty along with the accompanying explanatory footnotes. 

1 The balance sheet and income statement supplied must be for a period ending no more than three months prior to 

the date of filing. 
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 of the 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 of the proposed operations. If certain of the 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, and those which remain to be paid. 

5. Generally, the air carrier must demonstrate that it will have available funding sufficient to 

cover any current working capital deficit and any pre-operating expenses, as well as an 

average of three months of the 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 of this application and the attached exhibit (s) are true and correct to the 

best of my knowledge and belief. Pursuant to Title 18 United States Code Section 1001, I [the 

individual signing the application, who shall be a principal owner, senior officer, or internal 

counsel of the applicant], in my individual capacity and as the authorized representative of the 

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 of the 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.