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ULS. Departmmit of 

Transportation 

Office of the Secretary 

of Transportation 

"PARTMENT OF 

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1 200 New Jersey Avenue, SE 

Washington, DC 20590 

September 13, 2010 

Mr. Gregory P. Cirillo 

Wiley Rein LLP 

7925 Jones Branch Drive 

McLean, VA 22102 

Re: Dockets DOT-OST-2010-0153 and DOT-OST-2010-0190 

Application of Aviation Services, Ltd., d/b/a Freedom Air 

for Section 41102 Certificate Authority 

Dear Mr. Cirilo: 

We have received the applications filed by Aviation Services, Ltd., d/b/a Freedom Air 

("Freedom Air") on June 14 and July 28, 2010, for a determination of its fitness to 

conduct interstate and foreign charter air transportation of person, property, and mail 

using large aircraft. 

We are currently reviewing the material filed by the applicant, and during the course of 

our review, we have found that we require additional and/or clarifying information before 

we can complete our processing of Freedom Air'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. The 

original plus 6 copies of your response should be filed in Dockets DOT-OST-2010-0153 

and DOT-OST-2010-0190. 

Since our review of the application remains ongoing, further information may be required 

before we are able to make a fitness determination. Please remember that Freedom Air 

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. 

Sincerely, 

Vanessa R. Balgobin 

Transportation Industry Analyst 

Air Carrier Fitness Division 

Enclosure 

cc: Docket DOT-OST-2010-0153 

Docket DOT-OST-2010-0190 

Mr. Tim McCarthy 

Honolulu Certificate Management Office 

Federal Aviation Administration 

135 Nakalo Place 

Honolulu, HI 96819 
INFORMATION REQUEST 

AVIATION SERVICES, LTD., d/b/a FREEDOM AIR 

MANAGEMENT AND KEY TECHNICAL PERSONNEL 

1. The resume of Mr. James Gazley, Director of Maintenance, indicates that he has 

some experience maintaining large aircraft. Please identify the type of large 

aircraft he has maintained. 

2. With respect to the resume for Mr. James Jamison, please provide a detailed 

listing of all previous employment (both aviation and non-aviation) and education 

and training, including FAA certifications and license numbers if applicable. The 

employment listing should include the name of employer, location (city, state), 

type of business, position(s) held, description of responsibilities, and dates 

employed. Further, if the employer held any aviation authority, the type of 

authority held should be noted. 

3. Based on the resume submitted for Mr. Cardiff Walker, Chief Pilot, it does not 

appear that he has any experience operating large aircraft. Please discuss 

Mr. Walker's qualifications for this position as it pertains to large aircraft 

operations. 

4. Please indicate if any of Freedom Air's current pilots are qualified to operate 

B737 aircraft. If not, please discuss the air carrier's plans to hire qualified pilots 

or further train its current pilots. 

OPERATIONS 

1. Please provide copies of all agreements between Freedom Air, WAI Asia, Ltd. 

("WAI"), and Fly Micronesia Limited that have not yet submitted to the 

Department. 

2. Please discuss Freedom Air's plans for maintaining the B737 aircraft. Will 

aircraft maintenance be performed in-house, or will it be contracted out. If the 

maintenance will be contracted out, please indicate who will perform the 

maintenance. 

3. Provide a copy of any lease and/or sublease agreements for the B737 aircraft 

Freedom Air intends to operate. 

4. Does WAI intend to market the foreign charter flights as "Freedom Air?" If not, 

please state that name under which the flights will be marketed. 
FINANCIAL POSITION 

1. What percentage of Freedom Air's annual revenues will come from business 

generated by WAI? 

2. Freedom Air proposes to conduct interstate charter flights using large aircraft, 

however, the applicant has not provided an operating proposal for such flights, 

nor has the applicant submitted forecast financial information. Generally, it is not 

the Department's practice to grant certificate authority for operations without a 

service proposal and corresponding fitness information. Therefore, we direct the 

applicant to provide such information. Failure to submit such information may 

result in denial of Freedom Air's request for authority to conduct interstate 

passenger charter flights using large aircraft. 

3. Please provide current (within 3 months) compiled balance sheets and income 

statements for Freedom Air. 

4. Freedom Air's February 28, 2010, balance sheet shows a liability of $1.6 million 

due to "ASLtd-CNMI." Please explain this liability. Also, state whether or not 

this is a current liability, that is, payable within the next 12 months. 

5. The forecast financial information that Freedom Air provided is somewhat 

unclear. Please provide a revised forecast of the air carrier's first year expenses 

associated with its large aircraft operations, by month, showing each expense 

category, such as fuel, maintenance, salaries, etc. Further, this information should 

be broken-down between interstate and foreign charter operations. 

6. Please identify which of the pre-operating costs have been paid to date and which 

costs remain outstanding. 

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.