Before the United States Department of Transportation

Washington, DC

October 7, 2014

Essential Air Service at:

KEARNEY, NEBRASKA Docket OST-1996-1715

NORTH PLATTE, NEBRASKA Docket OST-1999-5173

SCOTTSBLUFF, NEBRASKA Docket OST-2003-14535

under 49 U.S.C. 41731 et.seq.

This document contains Great Lakes Aviation, Ltd.'s response to Order Requesting 

Proposals 2014-8-20.

Great Lakes Aviation, Ltd. is pleased to submit this proposal, as an inseparable package,

for all three of these Nebraska communities.

Our proposals contemplate conveniently timed connecting services to our Denver hub, whereby 

passengers may utilize our code-share agreements with United Airlines. Local service will be 

marketed and priced utilizing the Great Lakes (ZK) brand and reservations system. Additionally, 

Great Lakes maintains interline ticketing and baggage agreements with the majority of the other 

carriers serving Denver, including interline e-ticketing agreements with American Airlines, Delta 

Airlines (with the ability to earn Delta Skymiles) and United Airlines. All of which will offer 

passengers traveling to and from these communities supplemental access to the domestic and 

international air transportation system.

New FAA pilot qualification rules have created an industry-wide pilot shortage which has had an 

acute impact on Great Lakes. These new rules mandated that first officers obtain an Airline 

Transport Pilot certification (“ATP”) prior to being qualified to perform crewmember duties in 

scheduled airline passenger service under FAR Part 121 regulatory requirements. A key factor to 

enable a pilot to receive an ATP certificate is the accumulation of 1,500 flight hours. 

On March 18th of this year, Great Lakes received from the FAA new operations specifications 

allowing us to hire pilots under it's FAR Part 121 Certificate utilizing FAR Part 135 regulatory hiring 

requirements. This allows our new hire pilots to operate the Beech 1900D aircraft in a nine seat 

configuration and will enable Great Lakes to restore pilot staffing levels while maintaining FAR Part 

121 hiring, training and maintenance standards. 

Great Lakes is proposing three different service alternatives for all three communities. Service 

levels vary by equipment type, equipment configuration and frequency of service. In proposal A, 

Great Lakes is proposing three roundtrips per day operating Beechcraft 1900D aircraft configured 

for nine seats. Due to pilot supply, this is the current level of service we have been forced to offer 

Scottsbluff and North Platte. 
Questions and comments may be referred to:

Michael O. Matthews

Chief Financial Officer

Great Lakes Aviation, Ltd.

1022 Airport Parkway

Cheyenne, WY 82001

(307) 432-7000

It is Great Lakes' belief that regulatory relief for small community air service must be granted in the 

near future. Excessive subsidy requirements will force communities to loose EAS service eligibility 

as available seats are being dramatically reduced due to arbitrary limitations on aircraft seating 

configurations. Great Lakes’ stands ready to participate in creative solutions to assist small 

communities in their efforts to remain in the National Air Transportation System.

Additionally, for the same annualized subsidy requirements as our Beechcraft 1900D configured in 

nine seats proposal; we are prepared to commit, with the full marketing support of the communities, 

to upgrading the aircraft to 37 seat or larger regional jets operating two roundtrips per weekday and 

two roundtrips over the weekend period.

In proposal B, for illustrative purposes; we have provided a level of service that will lower subsidy 

requirements assuming that our Beechcraft 1900D aircraft can be returned to a 19 seat 

configuration. 

In proposal C, Great Lakes is proposing two daily roundtrips utilizing Brasilia EMB-120 aircraft 

configured with 30 seats. By operating the 30 seat Brasilia EMB-120 aircraft, Great Lakes believes 

that we will be enabled, with the support of the community, to stimulate traffic development by 

offering additional seats at discounted fares. Great Lakes currently owns six EMB-120 aircraft and 

has a 20 year history of operating this aircraft type.
Table of Contents:

Subsidy Passeng

Bid Service Point(s) Hub Served Round Trips Equipment Requirement Foreca

A1 Scottsbluff, Nebraska Denver 3 1900D - 9 seat $2,443,523 

10,000 

A2 Kearney, Nebraska Denver 3 1900D - 9 seat $2,993,938 

12,750 

A3 North Platte, Nebraska Denver 3 1900D - 9 seat $2,818,163 

10,000 

Total Cost of 9 Seat Beech 1900-D (1) $8,255,624 32,750 

(1) As a alternative to the nine seat aircraft EAS bid, Great Lakes would be prepared to commit to

upgrading the aircraft to a 37 seat or larger Regional Jet that would provide two round trips perweekday and over the weekend period for the same total annualized subsidy amounts.

B1 Scottsbluff, Nebraska Denver 3 1900D - 19 Seat $1,765,849 

20,000 

B2 Kearney, Nebraska Denver 3 1900D - 19 Seat $2,034,866 

27,000 

B3 North Platte, Nebraska Denver 3 1900D - 19 Seat $2,117,119 

20,000 

Total Cost of 19 Seat Beech 1900-D $5,917,834 67,000 

(2) $2,337,789 - 

34,250 

(2) Cost of 1,500 hour ATP to EAS program due to pilot supply 

and the loss of 10 available seats in the Beechcraft 1900D

C1 Scottsbluff, Nebraska Denver 2 EMB-120 $1,764,806 

22,000 

C2 Kearney, Nebraska Denver 2 EMB-120 $1,998,178 

24,000 

C3 North Platte, Nebraska Denver 2 EMB-120 $1,995,396 

22,000 

Total Cost of 30 seat - EMB-120 $5,758,381 68,000 
Great Lakes Aviation, Ltd.

Annual Compensation Requirements for Essential Air Service at

Scottsbluff, Nebraska to Denver (DEN)

Three Round Trips - B1900 (9 Seats)- current schedules should be used as sample pattern of service

(at 98 percent completion)

Departures: 1,840

Block Hours: 1,656

Revenue Passenger Miles: 1,500,000

Available Seat Miles: 2,484,000

Operating Revenues:

Passenger: BFF-DEN 10,000 psgrs at $104.98 $1,049,800

Other: (at 0.62% of passenger revenue) $6,509

Total Operating Revenues: $1,056,309

Operating Expenses:

Direct: Aircraft and Hull Insurance $365,710

Fuel and Oil $984,388

Flying Operations $326,629

Maintenance $613,112

Total Direct Expenses: $2,289,839

Total Indirect Expenses: $1,043,334

Total Operating Expenses: $3,333,173

Operating Loss ($2,276,864)

Profit Element (5.0% of Total Operating Expenses) $166,659

Annual Compensation Requirement: $2,443,523

 All Scottsbluff - Denver - Scottsbluff Service is Non-Stop

 This Proposal is submitted with no upline scheduling restrctions

As a alternative to this nine seat aircraft EAS bid Great Lakes would be prepared to commit to

upgrading the aircraft to a 37 seat or larger Regional Jet that would provide two round trips per

weekday and over the weekend period for the same total annualized subsidy amount.

Regional Jet service option to be offered at Great Lakes discretion and assumes full community

marketing support for the companys efforts to offer a minimum of 74 departing seats per day. 

RJ Subsidy 

per departure

$2,443,523 Regional Jet Subsidy 1,227 Departures $1,991.46
Great Lakes Aviation, Ltd.

Annual Compensation Requirements for Essential Air Service at

Kearney, Nebraska to Denver (DEN)

Three Round Trips - B1900 (9 seats) - current schedules should be used as sample pattern of service

(at 98 percent completion)

Departures: 1,840

Block Hours: 2,454

Revenue Passenger Miles: 3,660,000

Available Seat Miles: 5,050,800

Operating Revenues:

Passenger: EAR-DEN 12,750 psgrs at $119.02 $1,517,505

Other: (at 0.62% of passenger revenue) $9,409

Total Operating Revenues: $1,526,914

Operating Expenses:

Direct: Aircraft and Hull Insurance $365,710

Fuel and Oil $1,495,923

Flying Operations $484,027

Maintenance $750,982

Total Direct Expenses: $3,096,642

Total Indirect Expenses: $1,208,931

Total Operating Expenses: $4,305,573

Operating Loss ($2,778,659)

Profit Element (5.0% of Total Operating Expenses) $215,279

Annual Compensation Requirement: $2,993,938

 All Kearney - Denver - Kearney Service is Non-Stop

 This Proposal is submitted with no upline scheduling restrctions

As a alternative to this nine seat aircraft EAS bid Great Lakes would be prepared to commit to

upgrading the aircraft to a 37 seat or larger Regional Jet that would provide two round trips per

weekday and over the weekend period for the same total annualized subsidy amount.

Regional Jet service option to be offered at Great Lakes discretion and assumes full community

marketing support for the companys efforts to offer a minimum of 74 departing seats per day. 

RJ Subsidy 

per departure

$2,993,938 Regional Jet Subsidy 1,227 Departures $2,440.05
Great Lakes Aviation, Ltd.

Annual Compensation Requirements for Essential Air Service at

North Platte, Nebraska to Denver (DEN)

Three Round Trips - B1900 (9 seats) - current schedules should be used as sample pattern of service

(at 98 percent completion)

Departures: 1,840

Block Hours: 2,024

Revenue Passenger Miles: 2,280,000

Available Seat Miles: 3,775,680

Operating Revenues:

Passenger: LBF-DEN 10,000 psgrs at $116.55 $1,165,500

Other: (at 0.62% of passenger revenue) $7,226

Total Operating Revenues: $1,172,726

Operating Expenses:

Direct: Aircraft and Hull Insurance $365,710

Fuel and Oil $1,257,454

Flying Operations $399,214

Maintenance $676,691

Total Direct Expenses: $2,699,069

Total Indirect Expenses: $1,101,778

Total Operating Expenses: $3,800,847

Operating Loss ($2,628,121)

Profit Element (5.0% of Total Operating Expenses) $190,042

Annual Compensation Requirement: $2,818,163

 All North Platte - Denver - North Platte Service is Non-Stop

 This Proposal is submitted with no upline scheduling restrctions

As a alternative to this nine seat aircraft EAS bid Great Lakes would be prepared to commit to

upgrading the aircraft to a 37 seat or larger Regional Jet that would provide two round trips per

weekday and over the weekend period for the same total annualized subsidy amount.

Regional Jet service option to be offered at Great Lakes discretion and assumes full community

marketing support for the companys efforts to offer a minimum of 74 departing seats per day. 

RJ Subsidy 

per departure

$2,818,163 Regional Jet Subsidy 1,227 Departures $2,296.79
Great Lakes Aviation, Ltd.

Annual Compensation Requirements for Essential Air Service at

Scottsbluff, Nebraska to Denver (DEN)

Three Round Trips - B1900 (19 seats) - current schedules should be used as sample pattern of service

(at 98 percent completion)

Departures: 1,840

Block Hours: 1,656

Revenue Passenger Miles: 3,000,000

Available Seat Miles: 5,244,000

Operating Revenues:

Passenger: BFF-DEN 20,000 psgrs at $97.77 $1,955,400

Other: (at 0.62% of passenger revenue) $12,123

Total Operating Revenues: $1,967,523

Operating Expenses:

Direct: Aircraft and Hull Insurance $365,710

Fuel and Oil $984,388

Flying Operations $326,629

Maintenance $613,112

Total Direct Expenses: $2,289,839

Total Indirect Expenses: $1,265,754

Total Operating Expenses: $3,555,593

Operating Loss ($1,588,070)

Profit Element (5.0% of Total Operating Expenses) $177,780

Annual Compensation Requirement: $1,765,849

 All Scottsbluff - Denver - Scottsbluff Service is Non-Stop

 This Proposal is submitted with no upline scheduling restrctions.
Great Lakes Aviation, Ltd.

Annual Compensation Requirements for Essential Air Service at

Kearney, Nebraska to Denver (DEN)

Three Round Trips - B1900 (19 seats) - current schedules should be used as sample pattern of service

(at 98 percent completion)

Departures: 1,840

Block Hours: 2,454

Revenue Passenger Miles: 8,235,000

Available Seat Miles: 10,662,800

Operating Revenues:

Passenger: EAR-DEN 27,000 psgrs at $108.21 $2,921,670

Other: (at 0.62% of passenger revenue) $18,114

Total Operating Revenues: $2,939,784

Operating Expenses:

Direct: Aircraft and Hull Insurance $365,710

Fuel and Oil $1,495,923

Flying Operations $484,027

Maintenance $750,982

Total Direct Expenses: $3,096,642

Total Indirect Expenses: $1,641,121

Total Operating Expenses: $4,737,763

Operating Loss ($1,797,978)

Profit Element (5.0% of Total Operating Expenses) $236,888

Annual Compensation Requirement: $2,034,866

 All Kearney - Denver - Kearney Service is Non-Stop

 This Proposal is submitted with no upline scheduling restrctions
Great Lakes Aviation, Ltd.

Annual Compensation Requirements for Essential Air Service at

North Platte, Nebraska to Denver (DEN)

Three Round Trips - B1900 (19 seats) - current schedules should be used as sample pattern of service

(at 98 percent completion)

Departures: 1,840

Block Hours: 2,024

Revenue Passenger Miles: 4,560,000

Available Seat Miles: 7,970,880

Operating Revenues:

Passenger: LBF-DEN 20,000 psgrs at $107.97 $2,159,400

Other: (at 0.62% of passenger revenue) $13,388

Total Operating Revenues: $2,172,788

Operating Expenses:

Direct: Aircraft and Hull Insurance $365,710

Fuel and Oil $1,257,454

Flying Operations $399,214

Maintenance $676,691

Total Direct Expenses: $2,699,069

Total Indirect Expenses: $1,386,557

Total Operating Expenses: $4,085,626

Operating Loss ($1,912,838)

Profit Element (5.0% of Total Operating Expenses) $204,281

Annual Compensation Requirement: $2,117,119

All North Platte - Denver - North Platte Service is Non-Stop

 This Proposal is submitted with no upline scheduling restrctions
Great Lakes Aviation, Ltd.

Annual Compensation Requirements for Essential Air Service at

Scottsbluff, Nebraska to Denver (DEN)

Two Round Trips - EMB-120 - Overnight Aircraft

(at 97.5 percent completion)

Departures: 1,420

Block Hours: 1,278

Revenue Passenger Miles: 3,300,000

Available Seat Miles: 6,390,000

Load Factor 51.64%

Operating Revenues:

Passenger: BFF-DEN 22,000 psgrs at $69.38 $1,526,360

Other: (at 0.62% of passenger revenue) $9,463

Total Operating Revenues: $1,535,823

Operating Expenses:

Direct: Aircraft and Hull Insurance $337,960

Fuel and Oil $866,226

Flying Operations $303,231

Maintenance $572,524

Total Direct Expenses: $2,079,941

Total Indirect Expenses: $1,063,516

Total Operating Expenses: $3,143,457

Operating Loss ($1,607,634)

Profit Element (5.0% of Total Operating Expenses) $157,173

Annual Compensation Requirement: $1,764,806

 All Scottsbluff - Denver - Scottsbluff Service is Non-Stop

 This Proposal is submitted with no upline scheduling restrctions.

Overnight Aircraft - Midday trip scheduled in coordination with community input
Great Lakes Aviation, Ltd.

Annual Compensation Requirements for Essential Air Service at

Kearney, Nebraska to Denver (DEN)

Two Round Trips - EMB-120 - Overnight Aircraft

(at 97.5 percent completion)

Departures: 1,420

Block Hours: 1,905

Revenue Passenger Miles: 7,320,000

Available Seat Miles: 12,993,000

Load Factor 56.34%

Operating Revenues:

Passenger: EAR-DEN 24,000 psgrs at $97.99 $2,351,760

Other: (at 0.62% of passenger revenue) $14,581

Total Operating Revenues: $2,366,341

Operating Expenses:

Direct: Aircraft and Hull Insurance $337,960

Fuel and Oil $1,279,067

Flying Operations $451,999

Maintenance $705,912

Total Direct Expenses: $2,774,938

Total Indirect Expenses: $1,381,747

Total Operating Expenses: $4,156,685

Operating Loss ($1,790,344)

Profit Element (5.0% of Total Operating Expenses) $207,834

Annual Compensation Requirement: $1,998,178

 All Kearney - Denver - Kearney Service is Non-Stop

 This Proposal is submitted with no upline scheduling restrctions.

Overnight Aircraft - Midday trip scheduled in coordination with community input
Great Lakes Aviation, Ltd.

Annual Compensation Requirements for Essential Air Service at

North Platte, Nebraska to Denver (DEN)

Two Round Trips - EMB-120 - Overnight Aircraft

(at 97.5 percent completion)

Departures: 1,840

Block Hours: 1,562

Revenue Passenger Miles: 5,016,000

Available Seat Miles: 9,712,800

Load Factor 51.64%

Operating Revenues:

Passenger: LBF-DEN 22,000 psgrs at $82.98 $1,825,560

Other: (at 0.62% of passenger revenue) $11,318

Total Operating Revenues: $1,836,878

Operating Expenses:

Direct: Aircraft and Hull Insurance $337,960

Fuel and Oil $1,103,911

Flying Operations $370,616

Maintenance $632,942

Total Direct Expenses: $2,445,429

Total Indirect Expenses: $1,204,356

Total Operating Expenses: $3,649,785

Operating Loss ($1,812,907)

Profit Element (5.0% of Total Operating Expenses) $182,489

Annual Compensation Requirement: $1,995,396

 All North Platte - Denver - North Platte Service is Non-Stop

 This Proposal is submitted with no upline scheduling restrctions.

Overnight Aircraft - Midday trip scheduled in coordination with community input