U.S. Department of 

Transportation 

Office of the Secretary 

Of Transportation 

October 1, 2012 

Mr. Robert E. Cohn 

Mr. Patrick R. Rizzi 

I? 

Counsel for Rhoades Aviation, Inc. d/b/a Transair 

Hogan Lovells US LLP 

555 Thirteenth Street, N.W. 

Washington, DC 20004 

Re: Docket DOT-OST-2011-0216 

Dear Messrs. Cohn and Rizzi: 

1200 New Jersey Ave., S.E. 

Washington, DC 20590 

By letter dated August 23, 2012, the Department issued its ruling on the request of Rhoades 

Aviation, Inc. d/b/a Transair ("Rhoades"), for confidential treatment of various documents filed 

in support of its application for certificate authority. · 

Under Rule 12, a Department ruling on motions for confidential treatment will not take effect if, 

within five business days after issuance, the person requesting confidential treatment files a 

petition for reconsideration of that decision, or files a statement that he or she in good faith 

intends to seek judicial review of the decision. Rhoades filed such a petition for reconsideration 

of our ruling on August 29, 2012. This petition was limited to our ruling on the confidentiality 

of certain information contained in Exhibit RDS-7, Page 1, and Exhibit RDS-7, Page 3, 

regarding projected net income as well as revenue and cost analysis statements for Rhoades' 

Boeing 73 7 aircraft. 

On September 19, 2012, the Department issued its ruling on Rhoades' petition for 

reconsideration. Specifically, the Department partially granted Rhoades' motion for confidential 

treatment of Exhibit RDS-7, Page 3. Under Rule 12, we gave Rhoades an additional five 

business days to file a petition for reconsideration of the decision or to file a statement of intent 

to seek judicial review of the decision. On September 21, 2012, Rhoades filed such a petition for 

reconsideration. 

Specifically, Rhoades asks the Department to reconsider its ruling with respect to two rows of 

the "Cost per Flight Miles for 12 months" section of Exhibit RDS-7, Page 3: the "Projected 

Annual Revenue" row and "Revenue per Mile" row. Rhoades states that public disclosure of this 

information could allow its projected first-year revenues to be calculated. Rhoades also points 

out that we granted confidential treatment to its projected revenue figures in our earlier rulings. 

In our ruling on August 23, 2012, we noted that "the Department typically grants confidential 

treatment to an applicant's projected revenues." Thus, we agree with Rhoades that the 

information contained in the "Projected Annual Revenue" row and "Revenue per Mile Row" of 

Exhibit RDS-7, Page 3, warrants confidential treatment. It is thus granted. 
2 

Upon reconsideration of our September 19, 2012, ruling, we have decided to grant Rhoades' 

request with respect to the information noted in its September 21, 2012, petition for 

reconsideration. 

Under Rule 12, the information identified above for which confidential treatment is not granted 

will be released to any person requesting it unless, within 5 (business) days from the date of the 

receipt of this letter, the applicant files with this office a petition for reconsideration or a written 

statement in good faith of its intent to seek judicial review of this decision. Please inform us if 

Rhoades wishes to pursue either option. If reconsideration or judicial review of this decision is 

not sought, Rhoades should immediately resubmit the redacted exhibits and those for which 

confidentiality has been denied to the appropriate docket for placement on the public record. 

In the meantime, as is the Department's practice, further processing of your application will be 

deferred pending receipt of this material. Thank you for your cooperation in this matter. If you 

have any questions regarding this letter, please feel free to contact Reese Davidson of my staff at 

(202) 366-8161 or via e-mail at Reese.Davidson@dot.gov. 

Chief, Air Carrier Fitness Division 

Office of Aviation Analysis 

cc: Docket DOT-OST-2011-0216 

Ms. Mary Ballard 

POI for Rhoades Aviation, Inc. 

FAA Indianapolis FSD0-11 

1201 Columbia Road, Suite 101 

Plainfield, IN 46168 

Mr. Teimour Riahi 

Chief Executive Officer 

Rhoades Aviation, Inc. d/b/a Transair 

1 00 Iolana Place 

Honolulu, HI 96819