Order: 2015-1-6

Served: January 5, 2015

 UNITED STATES OF AMERICA

 DEPARTMENT OF TRANSPORTATION

 OFFICE OF THE SECRETARY

 WASHINGTON, D.C.

Issued by the Department of Transportation

on the 5th of January, 2015

ORDER SELECTING AIR CARRIER

Summary

By this Order, the Department is re-selecting Kalinin Aviation, LLC d/b/a Alaska Seaplanes, 

(Alaska Seaplanes) to provide Essential Air Service (EAS) at Elfin Cove, Pelican, Angoon, and 

Tenakee, Alaska for the four-year term from February 1, 2015, through January 31, 2019, at the 

specified annual subsidy rates below:

Community 2015 2016 2017 2018

ELFIN COVE $118,970 $119,652 $122,142 $124,795

PELICAN $293,606 $308,790 $327,997 $348,103

ANGOON $231,794 $253,430 $275,900 $303,298

TENAKEE $133,501 $139,783 $145,794 $152,127

Essential Air Service at

ELFIN COVE, ALASKA

PELICAN, ALASKA

ANGOON, ALASKA

TENAKEE, ALASKA

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

DOT-OST-2002-11586

DOT-OST-2002-11586

DOT-OST-2006-25542

DOT-OST-2006-25542
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Background 

By Order 2011-3-11, issued on March 9, 2011, the Department selected Alaska Seaplanes at Elfin 

Cove and Pelican, to provide EAS for an annual subsidy of $75,391 at Elfin Cove, and $185,721 at 

Pelican, from June 1, 2011, through January 31, 2015. At Elfin Cove, the service consists of 5 

weekly round trips to Juneau in the 18-week peak period and 2 weekly round trips in the 34-week 

off-peak period. At Pelican, the service consists of 6 weekly round trips, year-round.

Also, by Order 2010-12-7, issued on December 3, 2010, the Department selected Alaska Seaplanes 

to provide EAS at Angoon and Tenakee, for an annual subsidy of $145,734 at Angoon and 

$135,576 at Tenakee, from February 1, 2011, through January 31, 2015. At Angoon, the service 

consists of 10 weekly round trips to Juneau in the 18-week peak and 5 weekly round trips in the 

34-week off-peak period. At Tenakee, the service consists of 7 weekly round trips to Juneau in the 

18-week peak period and 3 weekly round trips in the 34-week off-peak period.

Summary of Proposals

Alaska Seaplanes

Alaska Seaplanes submitted a proposal for Elfin Cove, Pelican, Angoon, and Tenakee for a fouryear term, continuing their service to Juneau. Their proposal consists of using 9-passenger Cessna 

Caravans, 6-passenger Cessna 206s and 6-passenger DeHavilland DHC-2 Beaver aircraft to 

Juneau at the annual subsidy rates shown in the table shown in the summary section on page 1. 

At Elfin Cove, the airline would provide 5 weekly round trips during the 18-week peak period, and

2 per week in the 34 week off-peak period; at Pelican, 6 weekly, year-round, round trips; at 

Angoon, 10 weekly round trips in the 18-week peak period, and 5 weekly round trips in the 34 

week, off-peak period; and at Tenakee, 7 weekly round trips in the 18-week peak period, and 3 per 

week in the 34-week off-peak period. See Appendix C for the dates that define the peak and offpeak periods.

Harris Air

Harris Air submitted a proposal for Pelican, Angoon, and Tenakee for a two-year term with 

service to Sitka, without subsidy. The carrier did not submit a bid for Elfin Cove. Their proposal 

consists of utilizing 6-passenger, DHC-2 Beaver aircraft. During the 18-week peak season, from 

May through September, the carrier proposed 10 weekly round trips at Angoon, 7 at Tenakee. 

During the 34-week off-peak season, Harris Air proposed 5 weekly round trips at Angoon, and 3

at Tenakee. The carrier proposed 6 weekly round trips, year-round, at Pelican. Harris Air plans to 

meet or exceed the Department’s needs by offering 2 scheduled flights daily during the peak 

season, and 1 flight daily in the off-peak season at Angoon and Tenakee.

Community Comments

On October 24, 2014, the Department solicited comments from the communities and the State of 

Alaska regarding this air carrier-selection case. 

The Mayors of the Cities of Pelican, Angoon, and Tenakee, the Chair of the Community of Elfin 

Cove, multiple businesses and private citizens support the incumbent, Alaska Seaplanes, with its 
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service to Juneau. The Mayors in a jointly signed letter to the Department (October 27, 2014), 

stated that, “Juneau has been our communities’ air service hub and the hub for all communities in 

Northern Southeast Alaska for eighty years. Juneau is our state capital. Juneau’s population 

supports large scale grocery, equipment and supply businesses.” The State of Alaska did not 

submit any comments in response to the Department’s request. 

Decision

When selecting a carrier to provide EAS in Alaska, 49 U.S.C. §41733(c)(1) directs us to consider 

six factors: (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; (4) community views; (5) the 

carrier’s plan to market its service to the community; and (6) the experience of the applicant in 

providing scheduled air service or significant patterns of non-scheduled air service. In addition, 

the Continuing Appropriations Act, 2014, Public Law No. 113-46, provides that when selecting a 

carrier to provide EAS, the Department may consider the relative subsidy requirements, thus 

codifying a factor that we have considered since the inception of the program.

While Harris Air received favorable mention by the Mayor of Angoon, the carrier does not 

currently hold the requisite economic authority to provide subsidized EAS at the frequency levels 

offered at Angoon, Pelican and Tenakee in their proposal.1

 Additionally, the EAS determination 

of service for these communities (Order 80-1-167) designated Juneau as the hub to be served. As 

noted in Order 2014-9-13 (September 22, 2014), requesting proposals, Harris Air filed an 

application for a certificate of public convenience and necessity. As of the date of the Order, 

Harris Air’s application is still being processed. Alaska Seaplanes’ current rate expires 

January 31, 2015, and the Department must make a carrier selection at this time.

At Elfin Cove, only Alaska Seaplanes submitted a proposal and the Department finds the subsidy 

rates reasonable. Therefore, the Department will select Alaska Seaplanes for four more years.

Alaska Seaplanes has provided reliable service for many years. As described above, the 

communities fully support Alaska Seaplanes’ proposal to continue its service to Juneau. The 

service to Juneau will provide passengers with greater connecting opportunities and more 

destinations, which are served by Alaska Airlines and Delta Air Lines, than would Sitka. The 

carrier has requested reasonable subsidy rates and markets its service well throughout these 

communities. The Department makes its selection of Alaska Seaplanes at Pelican, Angoon, and 

Tenakee for a new four-year term, from February 1, 2015-January 31, 2019. 

This selection is contingent upon the Department’s receiving properly executed certifications from 

the air carrier that it is in compliance with the Department’s regulations regarding drug-free 

workplaces and nondiscrimination, as well as the regulations concerning lobbying activities.2

 1 Harris Air provides some service at Angoon, Pelican, and Tenakee as an Alaskan intra-state operator. Flights are 

operated to/from Sitka.

2 The certifications are available online under “Reports and Publications” at http://www.dot.gov/policy/aviationpolicy/small-community-rural-air-service/essential-air-service
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Carrier Fitness

49 U.S.C. §§ 41737(b) and 41738 require that we find an air carrier fit, willing, and able to provide 

reliable service before we may subsidize it to provide EAS. Alaska Seaplanes is subject to the 

Department’s continuing fitness requirements, and no information has come to our attention that 

would cause us to question the air carrier’s fitness at this time. We have contacted the Federal 

Aviation Administration, and it has raised no concerns that would negatively affect our fitness 

findings. We therefore conclude that Alaska Seaplanes is reliable and fit to conduct the operations 

proposed here.

This Order is issued under authority delegated in 49 CFR Part 1.25a(b).

ACCORDINGLY,

1. The Departments selects Kalinin Aviation, LLC d/b/a Alaska Seaplanes to provide Essential Air 

Service at Elfin Cove, Pelican, Angoon, and Tenakee, Alaska, and establish the annual subsidy 

rates as described in Appendix C. 

2. The Department directs Kalinin Aviation, LLC d/b/a Alaska Seaplanes to retain all books, 

records, and other source and summary documentation to support claims for payment, and to 

preserve and maintain such documentation in a manner that readily permits its audit and 

examination by representatives of the Department. Such documentation shall be retained for 

seven years from the service date of this Order or until the Department indicates that the records 

may be destroyed, whichever comes first. Copies of flight logs for aircraft sold or disposed of 

must be retained. The carrier may forfeit its compensation for any claim that is not supported 

under the terms of this Order;

3. The Department finds that Kalinin Aviation, LLC d/b/a Alaska Seaplanes is fit, willing and able 

to operate as a certificated air carrier, and capable of providing reliable Essential Air Service at 

Elfin Cove, Pelican, Angoon, and Tenakee;

4. These dockets will remain open pending further Department action; and
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5. The Department will serve a copy of this Order on the Alaska Department of Transportation, 

the Mayors of Elfin Cove, Pelican, Angoon, and Tenakee, Kalinin Aviation, LLC d/b/a Alaska 

Seaplanes and Harris Aircraft Services. 

By:

BRANDON M. BELFORD

Deputy Assistant Secretary for

Aviation and International Affairs

(SEAL)

An electronic version of this document is available at

http://www.regulations.gov
Appendix A

AREA MAP

Maps generated by the Great Circle Mapper - copyright © Karl L. Swartz
Appendix B

Page 1 of 2

Alaska Seaplanes Proposal for EAS at Elfin Cove, Pelican, Angoon, and 

Tenakee
Appendix B

Page 2 of 2
Appendix C

Page 1 of 4

Kalinin Aviation, LLC d/b/a Alaska Seaplanes

Essential Air Service to be provided at Elfin Cove, Alaska

Docket DOT-OST-2002-11586

Effective Period: February 1, 2015, through January 31, 2019

Scheduled Service: Peak (18 weeks): Five weekly nonstop round trips to Juneau

 Off-peak (34 weeks): Two weekly nonstop round trip to Juneau. 

Aircraft: 9-passenger Cessna Caravans, 6-passenger Cessna 206s, and 6-passenger DeHavilland DHC-2 Beaver

Rate per Eligible Flight: $3761(Feb. 2015-Jan. 2016); $379 (Feb. 2016-Jan. 2017); $387(Feb. 2017-Jan. 2018); $395

(Feb. 2018-Jan. 2019)

Weekly Ceiling: 

Peak = $3,760 2 (May 10, 2015-Sep. 12, 2015); $3,790 (May 8, 2016-Sep. 10, 2016); $3,870 (May 7, 2017-Sep. 9, 

2017); $3,950 (May 6, 2018-Sep. 8, 2018)

Off-peak = $1,504 (Feb. 1, 2015-May 9, 2015); $1,516 (Sep. 13, 2015-May 7, 2016); $1,548 (Sep. 11, 2016-May 6, 

2017); $1,580 (Sep. 9, 2018-Jan. 31, 2019)

Note: The carrier understands that it may forfeit its compensation for any flights that it does not operate in conformance 

with the terms and stipulations of the rate Order, including the service plans outlined in the Order and any other significant 

elements of the required service, without prior approval. The carrier understands that an aircraft take-off and landing at its 

scheduled destination constitutes a completed flight; absent an explanation supporting subsidy eligibility for a flight that 

has not been completed, such as certain weather cancellations, only completed flights are considered eligible for subsidy. 

In addition, if the carrier does not schedule or operate its flights in full conformance with the Order for a significant period, 

it may jeopardize its entire subsidy claim for the period in question. If the carrier contemplates any such changes beyond 

the scope of the Order during the applicable period of this rate, it must first notify the Office of Aviation Analysis in 

writing and receive written approval from the Department to be ensured of full compensation. Should circumstances 

warrant, the Department may locate and select a replacement carrier to provide service on these routes. The carrier must 

complete all flights that can be safely operated; flights that overfly points for lack of traffic will not be compensated. In 

determining whether subsidy payment for a deviating flight should be adjusted or disallowed, the Department will consider 

the extent to which the goals of the program are met and the extent of access to the national air transportation system 

provided to the community.

If the Department unilaterally, either partially or completely, terminates or reduces payments for service or changes 

service requirements at a specific location provided for under this Order, then, at the end of the period for which the 

department does make payments in the stipulated service levels, the carrier may cease to provide service to that 

specific location without regards to any requirement for notice of such cessation. Those adjustments in the levels of 

subsidy and/or service that are mutually agreed to in writing by the Department and carrier do not constitute a total 

or partial reduction or cessation of payment.

Subsidy contract are subject to, and incorporate by reference, relevant statutes and Department regulations, as they may be 

amended from time to time. However, any such statutes, regulations, or amendments thereto shall not operate to controvert 

the foregoing paragraph.

Funds may not be available for performance under this order beyond January 14, 2015. The Government’s obligation for 

performance under this order beyond January 14, 2015, is subject to the availability of funds from which payment for 

services can be made. No legal liability on the part of the Government for any payment may arise for performance under this 

order beyond January 14, 2015, until funds are made available to the Department for performance. If sufficient funds are not 

made available for performance beyond January 14, 2015, the Department will provide notice in writing to the carrier.

All claims for payment, including any amended claims, must be submitted within 90 days of the last day of the 

month for which compensation is being claimed. For example, claims for service provided in July must be filed by 

October 31; August claims must be submitted by November 30, and so on.

 1 Annual compensation of $118,970 divided by 316 flights (10 weekly flights x 18 peak weeks + 4 weekly flights x 

34 weeks). 2 Peak: 10 flights x $376; Off-peak: 4 flights x $376.
Appendix C

Page 2 of 4

Kalinin Aviation, LLC d/b/a Alaska Seaplanes

Essential Air Service to be provided at Pelican, Alaska

Docket DOT-OST-2002-11586

Effective Period: February 1, 2015, through January 31, 2019

Scheduled Service: Six weekly nonstop round trips to Juneau, year-round 

Aircraft: 9-passenger Cessna Caravans, 6-passenger Cessna 206s, and 6-passenger DeHavilland DHC-2 Beaver

Rate per Eligible Flight: $4713(Feb. 2015-Jan. 2016); $495 (Feb. 2016-Jan. 2017); $526 (Feb. 2017-Jan. 2018); 

$558 (Feb. 2018-Jan. 2019)

Weekly Ceiling: 

$5,6524 (Feb. 2015-Jan. 2016); $5,940 (Feb. 2016-Jan. 2017); $6,312 (Feb. 2017-Jan. 2018); $6,696 (Feb. 2018-Jan. 

2019)

Note: The carrier understands that it may forfeit its compensation for any flights that it does not operate in conformance 

with the terms and stipulations of the rate Order, including the service plans outlined in the Order and any other significant 

elements of the required service, without prior approval. The carrier understands that an aircraft take-off and landing at its 

scheduled destination constitutes a completed flight; absent an explanation supporting subsidy eligibility for a flight that 

has not been completed, such as certain weather cancellations, only completed flights are considered eligible for subsidy. 

In addition, if the carrier does not schedule or operate its flights in full conformance with the Order for a significant period, 

it may jeopardize its entire subsidy claim for the period in question. If the carrier contemplates any such changes beyond 

the scope of the Order during the applicable period of this rate, it must first notify the Office of Aviation Analysis in 

writing and receive written approval from the Department to be ensured of full compensation. Should circumstances 

warrant, the Department may locate and select a replacement carrier to provide service on these routes. The carrier must 

complete all flights that can be safely operated; flights that overfly points for lack of traffic will not be compensated. In 

determining whether subsidy payment for a deviating flight should be adjusted or disallowed, the Department will consider 

the extent to which the goals of the program are met and the extent of access to the national air transportation system 

provided to the community.

If the Department unilaterally, either partially or completely, terminates or reduces payments for service or changes 

service requirements at a specific location provided for under this Order, then, at the end of the period for which the 

department does make payments in the stipulated service levels, the carrier may cease to provide service to that 

specific location without regards to any requirement for notice of such cessation. Those adjustments in the levels of 

subsidy and/or service that are mutually agreed to in writing by the Department and carrier do not constitute a total 

or partial reduction or cessation of payment.

Subsidy contract are subject to, and incorporate by reference, relevant statutes and Department regulations, as they may be 

amended from time to time. However, any such statutes, regulations, or amendments thereto shall not operate to controvert 

the foregoing paragraph.

Funds may not be available for performance under this order beyond January 14, 2015. The Government’s obligation for 

performance under this order beyond January 14, 2015, is subject to the availability of funds from which payment for 

services can be made. No legal liability on the part of the Government for any payment may arise for performance under this 

order beyond January 14, 2015, until funds are made available to the Department for performance. If sufficient funds are not 

made available for performance beyond January 14, 2015, the Department will provide notice in writing to the carrier.

All claims for payment, including any amended claims, must be submitted within 90 days of the last day of the 

month for which compensation is being claimed. For example, claims for service provided in July must be filed by 

October 31; August claims must be submitted by November 30, and so on.

 3 Annual compensation of $293,606 divided by 624 flights (12 weekly flights x 52 weeks). 4 12 weekly flights x $471 per eligible flight.
Appendix C

Page 3 of 4

Kalinin Aviation, LLC d/b/a Alaska Seaplanes

Essential Air Service to be provided at Angoon, Alaska

Docket DOT-OST-2006-25542

Effective Period: February 1, 2015, through January 31, 2019

Scheduled Service: Peak (18 weeks): Ten weekly nonstop round trips to Juneau

 Off-peak (34 weeks): Five weekly nonstop round trip to Juneau. 

Aircraft: 9-passenger Cessna Caravans, 6-passenger Cessna 206s, and 6-passenger DeHavilland DHC-2 Beaver

Rate per Eligible Flight: $3315(Feb. 2015-Jan. 2016); $362 (Feb. 2016-Jan. 2017); $394 (Feb. 2017-Jan. 2018); 

$433 (Feb. 2018-Jan. 2019)

Weekly Ceiling: 

Peak = $6,620 6 (May 10, 2015-Sep. 12, 2015); $7,240 (May 8, 2016-Sep. 10, 2016); $7,880 (May 7, 2017-Sep. 9, 

2017); $8,660 (May 6, 2018-Sep. 8, 2018)

Off-peak = $3,310 (Feb. 1, 2015-May 9, 2015); $3,620 (Sep. 13, 2015-May 7, 2016); $3,940 (Sep. 11, 2016-May 6, 

2017); $4,330 (Sep. 9, 2018-Jan. 31, 2019)

Note: The carrier understands that it may forfeit its compensation for any flights that it does not operate in conformance 

with the terms and stipulations of the rate Order, including the service plans outlined in the Order and any other significant 

elements of the required service, without prior approval. The carrier understands that an aircraft take-off and landing at its 

scheduled destination constitutes a completed flight; absent an explanation supporting subsidy eligibility for a flight that 

has not been completed, such as certain weather cancellations, only completed flights are considered eligible for subsidy. 

In addition, if the carrier does not schedule or operate its flights in full conformance with the Order for a significant period, 

it may jeopardize its entire subsidy claim for the period in question. If the carrier contemplates any such changes beyond 

the scope of the Order during the applicable period of this rate, it must first notify the Office of Aviation Analysis in 

writing and receive written approval from the Department to be ensured of full compensation. Should circumstances 

warrant, the Department may locate and select a replacement carrier to provide service on these routes. The carrier must 

complete all flights that can be safely operated; flights that overfly points for lack of traffic will not be compensated. In 

determining whether subsidy payment for a deviating flight should be adjusted or disallowed, the Department will consider 

the extent to which the goals of the program are met and the extent of access to the national air transportation system 

provided to the community.

If the Department unilaterally, either partially or completely, terminates or reduces payments for service or changes 

service requirements at a specific location provided for under this Order, then, at the end of the period for which the 

department does make payments in the stipulated service levels, the carrier may cease to provide service to that 

specific location without regards to any requirement for notice of such cessation. Those adjustments in the levels of 

subsidy and/or service that are mutually agreed to in writing by the Department and carrier do not constitute a total 

or partial reduction or cessation of payment.

Subsidy contract are subject to, and incorporate by reference, relevant statutes and Department regulations, as they may be 

amended from time to time. However, any such statutes, regulations, or amendments thereto shall not operate to controvert 

the foregoing paragraph.

Funds may not be available for performance under this order beyond January 14, 2015. The Government’s obligation for 

performance under this order beyond January 14, 2015, is subject to the availability of funds from which payment for 

services can be made. No legal liability on the part of the Government for any payment may arise for performance under this 

order beyond January 14, 2015, until funds are made available to the Department for performance. If sufficient funds are not 

made available for performance beyond January 14, 2015, the Department will provide notice in writing to the carrier.

All claims for payment, including any amended claims, must be submitted within 90 days of the last day of the 

month for which compensation is being claimed. For example, claims for service provided in July must be filed by 

October 31; August claims must be submitted by November 30, and so on.

 5 Annual compensation of $231,794 divided by 700 flights (20 weekly flights x 18 peak weeks + 10 weekly flights x 

34 weeks). 6 Peak: 20 flights x $331; Off-peak: 10 flights x $331.
Appendix C

Page 4 of 4

Kalinin Aviation, LLC d/b/a Alaska Seaplanes

Essential Air Service to be provided at Tenakee, Alaska

Docket DOT-OST-2006-25542

Effective Period: February 1, 2015, through January 31, 2019

Scheduled Service: Peak (18 weeks): Seven weekly nonstop round trips to Juneau

 Off-peak (34 weeks): Three weekly nonstop round trip to Juneau. 

Aircraft: 9-passenger Cessna Caravans, 6-passenger Cessna 206s, and 6-passenger DeHavilland DHC-2 Beaver

Rate per Eligible Flight: $2937(Feb. 2015-Jan. 2016); $307 (Feb. 2016-Jan. 2017); $320 (Feb. 2017-Jan. 2018); 

$334 (Feb. 2018-Jan. 2019)

Weekly Ceiling: 

Peak = $4,1028 (May 10, 2015-Sep. 12, 2015); $4,298 (May 8, 2016-Sep. 10, 2016); $4,480 (May 7, 2017-Sep. 9, 

2017); $4,676 (May 6, 2018-Sep. 8, 2018)

Off-peak = $1,758 (Feb. 1, 2015-May 9, 2015); $1,842 (Sep. 13, 2015-May 7, 2016); $1,920 (Sep. 11, 2016-May 6, 

2017); $2,004 (Sep. 9, 2018-Jan. 31, 2019)

Note: The carrier understands that it may forfeit its compensation for any flights that it does not operate in conformance 

with the terms and stipulations of the rate Order, including the service plans outlined in the Order and any other significant 

elements of the required service, without prior approval. The carrier understands that an aircraft take-off and landing at its 

scheduled destination constitutes a completed flight; absent an explanation supporting subsidy eligibility for a flight that 

has not been completed, such as certain weather cancellations, only completed flights are considered eligible for subsidy. 

In addition, if the carrier does not schedule or operate its flights in full conformance with the Order for a significant period, 

it may jeopardize its entire subsidy claim for the period in question. If the carrier contemplates any such changes beyond 

the scope of the Order during the applicable period of this rate, it must first notify the Office of Aviation Analysis in 

writing and receive written approval from the Department to be ensured of full compensation. Should circumstances 

warrant, the Department may locate and select a replacement carrier to provide service on these routes. The carrier must 

complete all flights that can be safely operated; flights that overfly points for lack of traffic will not be compensated. In 

determining whether subsidy payment for a deviating flight should be adjusted or disallowed, the Department will consider 

the extent to which the goals of the program are met and the extent of access to the national air transportation system 

provided to the community.

If the Department unilaterally, either partially or completely, terminates or reduces payments for service or changes 

service requirements at a specific location provided for under this Order, then, at the end of the period for which the 

department does make payments in the stipulated service levels, the carrier may cease to provide service to that 

specific location without regards to any requirement for notice of such cessation. Those adjustments in the levels of 

subsidy and/or service that are mutually agreed to in writing by the Department and carrier do not constitute a total 

or partial reduction or cessation of payment.

Subsidy contract are subject to, and incorporate by reference, relevant statutes and Department regulations, as they may be 

amended from time to time. However, any such statutes, regulations, or amendments thereto shall not operate to controvert 

the foregoing paragraph.

Funds may not be available for performance under this order beyond January 14, 2015. The Government’s obligation for 

performance under this order beyond January 14, 2015, is subject to the availability of funds from which payment for 

services can be made. No legal liability on the part of the Government for any payment may arise for performance under this 

order beyond January 14, 2015, until funds are made available to the Department for performance. If sufficient funds are not 

made available for performance beyond January 14, 2015, the Department will provide notice in writing to the carrier.

All claims for payment, including any amended claims, must be submitted within 90 days of the last day of the 

month for which compensation is being claimed. For example, claims for service provided in July must be filed by 

October 31; August claims must be submitted by November 30, and so on.

 7 Annual compensation of $133,501 divided by 456 flights (14 weekly flights x 18 peak weeks + 6 weekly flights x 

34 weeks). 8 Peak: 14 flights x $293; Off-peak: 6 flights x $293.