BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Essential Air Sennce at 

EXCURSION INLET, ALASKA 

KAKE, ALASKA 

Under 49 U.S. C. 41731 et. Seq. 

October 2, 2012 

SUPPLEMENT NO. 1 

Docket DOT-OST-2002-12014 

Docket DOT -OST -2008-0217 

PETITION OF SEAPORT AIRLINES, INC D/B/A WINGS OF ALASKA 

FOR RECONSIDERATION OF THE SELECTION OF AIR EXCURSIONS TO PROVIDE 

ESSENTIAL AIR SERVICE AT KAKE AND EXCURSION INLET, ALASKA 

On September 8, 2012, the US Department of Transportation (hereafter referred to as 

"the Department") issued Order 2012-9-8 selecting Air Excursions, LLC (hereafter referred to as 

"Air Excursions") to provide Essential Air Service (EAS) at Excursion Inlet and Kake, Alaska. 1 

On September 21, 2012, SeaPort Airlines, Inc., and doing business in Southeast Alaska 

as "Wings of Alaska" (hereafter referred to as "SeaPort"), submitted a petition to the Department 

requesting that it reconsider its selection of Air Excursions and instead select SeaPort to provide 

EAS at these communities. 

In support of its request, SeaPort outlined in its petition what it believes are incorrect, 

incomplete, or mischaracterized facts cited by the Department in Order 2012-9-8. Also we 

discussed two accidents and one incident involving aircraft operated by Air Excursions which 

occurred after the RFP was issued by the Department and after the communities submitted 

comments, but before the Department's Order announcing its carrier selection. Given these 

significant events, and as stated in our petition, SeaPort believes that the communities should 

have be provided an opportunity to submit additional comments and that the Department 

reconsider its selection of Air Excursions to provide EAS at Kake and Excursion Inlet and 

instead selected SeaPort. 

1 Order 2012-9-8 
Supplement No. 1 to Petition of SeaPort Airlines, Inc. for Reconsideration 

Docket DOT-OST-2002-12014 & Docket DOT-OST-2008-0217 

Page2 

To supplement information provided in its petition, additionally SeaPort states the 

following: 

SeaPort Anticipates Finalizing An Interline Agreement 

With Alaska Airlines By The End of October 2012 

By October 31, 2012, SeaPort Airlines anticipates implementing an interline agreement 

with Alaska Airlines that includes interline electronic ticketing (lET) and baggage check-in to 

final destination. Necessary testing between the respective reservation systems of Alaska 

Airlines and SeaPort Airlines has been completed, with details of the interline agreement 

contract remaining to be completed prior to final signatures and implementation. 

When implemented, the agreement will represent a significant improvement to air 

service at rural communities in Southeast Alaska that are served by SeaPort. 2 Specifically, 

customers will be able to purchase and to travel on itineraries that include flights of both 

SeaPort Airlines and Alaska Airlines using a single-ticket. To a customer in Kake, for example, 

this means an itinerary to any destination in the Alaska Airlines network will be able to be 

purchased on a single ticket and baggage checked-in at the originating airport (i.e., Kake) 

through to the final destination. The agreement will also provide enhanced customer protections 

such as reaccommodation in the event of flight irregularities (i.e., "Rule 240).3 

For the tourism industry, this agreement will result in display of and ability to purchase 

connecting itineraries on major GDSs, including online travel retailers such as Orbitz, 

Travelocity, Expedia, Hotwire, Hipmunk, etc. This will make it easier for potential visitors to build 

vacation itineraries to the rural communities in Southeast Alaska served by SeaPort and, 

therefore, the ability of those communities to capture greater amounts of discretionary spending 

of Alaska vacationers. 

For the Southeast Alaska communities that SeaPort serves, the interline agreement 

between SeaPort Airlines and Alaska Airlines will result in true connectivity with the national air 

transportation system. SeaPort firmly believes the interline agreement should be factored 

alongside the information provided in its September 21, 2012 petition, as well as any community 

2 Connections between Alaska Airlines and SeaPort can made at Juneau International Airport providing single-ticket 

service to/from Gustavus, Haines, Hoonah, and Skagway. 

3 Neither the interline agreement or this filing is intended to infer support by Alaska Airlines for selection of SeaPort as 

the provider of EAS at Kake and Excursion Inlet. 
Supplement No. 1 to Petition of SeaPort Airlines, Inc. for Reconsideration 

Docket DOT-OST-2002-12014 & Docket DOT-OST-2008-0217 

Page 3 

comments, as the Department reconsiders its selection of Air Excursions to provide EAS at 

Kake and Excursion lnlet.4 In support of this view, we note 49 U.S.C. § 417~3(c)(1) which 

directs the Department to consider four factors when selecting a carrier to provide Essential Air 

Service: (1) service reliability; (2) contractual and marketing arrangements with a larger carrier 

at the hub; (3) interline arrangements with a larger carrier at the hub; and (4) community 

views. 

There Is No Change To SeaPort's Reguest For Subsidy 

While an improvement to the narrative description as provided in SeaPort's EAS 

proposal, implementation of the interline agreement does not change the annual subsidy 

request of $364,506 at Kake and $33,537 at Excursion Inlet. 

At the time of the Kake and Excursion Inlet EAS proposal submission, SeaPort had 

verbally reached an agreement to enter into an interline agreement with Alaska Airlines but had 

not finalized commercial details or initiated data sharing tests between each carrier's respective 

reservation system. SeaPort determined that rather than risk failing to deliver as promised to the 

Department and communities, discussion of the interline agreement would not be included in 

the narrative of our proposal. 

Nonetheless, SeaPort was confident that even under our worst case scenarios the 

agreement would be implemented within a reasonable time period of the beginning of the new 

EAS contract, such that the subsidy request in our proposal included all of the expense and 

revenue assumptions with respect to incremental ticket revenue, higher distribution costs, 

interline revenue accounting settlement costs, etc. 

Other than revealing implementation of the interline agreement with Alaska Airlines 

which is additive in nature, SeaPort's proposal to provide EAS at Kake and Excursion Inlet 

remains unchanged. Specifically, this includes key components of our proposal that are typically 

important to both the Department and community, such as level of subsidy, aircraft type, 

preliminary flight schedules, average fares, and projected levels of passenger traffic. In this 

context, SeaPort's proposal is compliant with the Department's directive that "interested carriers 

4 SeaPort's research indicates that such connectivity has not existed for any of Southeast Alaska our communities, 

including Kake and Excursion Inlet, since the advent of electronic ticketing. 
Supplement No. 1 to Petition of SeaPort Airlines, Inc. for Reconsideration 

Docket DOT-OST-2002-12014 & Docket DOT-OST-2008-0217 

Page4 

should prepare their proposals with every expectation that their initial proposals will also be their 

final and only proposals. '

16 

Summation 

In its petition filed on September 21, 2012, SeaPort outlined what we believe are factual 

errors in Order 2012-9-8 that, including the recent operational issues at Air Excursions, more 

than adequately support our request that the Department to reconsider its EAS carrier selection 

at Kake and Excursion Inlet, Alaska. 

This supplement strengthens that request by notifying the Department and communities 

Kake and Excursion Inlet that SeaPort will be implementing an interline agreement with Alaska 

Airlines within the next couple of weeks, providing connectivity with the national air 

transportation system and described as "basic essential air service" in 49 U.S. C.§ 41733 (C). 

For the reasons provided in our September 21, 2012 petition as supplemented herein, 

SeaPort respectfully restates its request that (1) the Department reconsider its selection of Air 

Excursions, (2) that the communities be permitted to provide additional comments regarding 

their carrier preference, (3) that the interline agreement between Alaska Airlines and SeaPort be 

included as part of that reconsideration, and (4) that the Department instead select SeaPort to 

provide EAS at Kake and Excursion Inlet, Alaska. 

Respectfully submitted, 

Timothy F. Sieber 

Vice President- Commercial 

SEAPORT AIRLINES, INC. D/B/A WINGS OF ALASKA 

7505 NE Airport Way 

Portland International Airport 

Portland, Oregon 97218 

(971) 340-1716 

Email: tsieber@seaportair.com 

October 2, 2012 

5 Order 2012-4-13, p.2 
Supplement No. 1 to Petition of SeaPort Airlines, Inc. for Reconsideration 

Docket DOT-OST-2002-12014 & Docket DOT-OST-2008-0217 

PageS 

SERVICE LIST 

SUPPLEMENT NO. 1 

PETITION OF SEAPORT AIRLINES, INC D/8/A WINGS OF ALASKA 

FOR THE DEPARTMENT TO RECONSIDER SELECTION OF AIR EXCURSIONS TO 

PROVIDE ESSENTIAL AIR SERVICE AT KAKE AND EXCURSION INLET, ALASKA 

City Manager, City of Kake 

citymanager@cityofkake. org 

Organized Vilage of Kake 

gewilliams@kakefirstnation .org 

Kake Tribal Corporation 

vicki.wolfe@kaketribalcorp.com 

Mr. Bruce Gordon (representing Excursion Inlet) 

bruce@btpost. net 

Air Excursions, LLC 

kentcraford@hotmail. com 

Ward Air Inc. 

tom@WardAir.com 

U.S. Department of Transportation, Essential Air Service Division 

dennis.devany@dot.dov 

michael.f.martin@dot.gov 

Alaska Airlines 

kyle.levine@alaskaair.com