BEFORE THE

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY

WASHINGTON, DC

_______________________________

) 

In the matter of the application of ) 

) 

WINGS AIRWAYS INC. ) DOCKET DOT-OST-2010-0023 

) 

For a certificate of public convenience ) 

And necessity under 49 USC 41102 ) 

_______________________________) 

REPLY OF WINGS AIRWAYS INC.

TO CORRESPONDENCE OF ALASKA SEAPLANE SERVICE, LLC 

DATED FEBRUARY 16, 2010

Communications with respect to this document should be addressed to: 

Holly Johnson

Wings Airways

2 Marine Way #175

Juneau, AK 99801 

(907) 586-6275 

holly@wingsairways.com

February 26, 2010
BEFORE THE

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY

WASHINGTON, DC

_______________________________

) 

In the matter of the application of ) 

) 

WINGS AIRWAYS INC. ) DOCKET DOT-OST-2010-0023 

) 

For a certificate of public convenience ) 

And necessity under 49 USC 41102 ) 

_______________________________) 

REPLY OF WINGS AIRWAYS INC.

TO CORRESPONDENCE OF ALASKA SEAPLANE SERVICE, LLC 

DATED FEBRUARY 16, 2010

Wings Airways hereby replies to the correspondence of Craig Loken, owner of Alaska Seaplane 

Services dated February 16, 2010. The reasons listed below will prove all claims are erroneous. 

Aircraft

The five aircraft listed in the Wings Airways application are currently in lease negotiations 

between Wings Airline Services and Alaska Juneau Aeronautics, Inc. with no settlement at this 

time. Wings Airways is not privy to copies of current lease agreements, as they are between two 

private entities. Wings Airways has shown an interest in leasing the aircraft if they become 

available. In the case that aircraft owned by Wings Airlines Services would not be available 

other options are available for lease or purchase from numerous sources. The aircraft market is 

currently saturated with options. Wings Airways current financial fitness allows an array of 

options. The costs would be similar either through an agreement with Wings Airline Services or

other outside entities. 

Facilities

Wings Airways holds a concrete lease with Fountain Village Development to occupy a hangar

facility located at the Juneau International Airport. The lease is valid through 2013. Appendix A 

highlights the lease that allows “unrestricted shared space on the 16,800 square foot ground 

floor. 2,688 square feet of storage on the 2nd floor, of the two story hangar building”. The large 

hangar includes extensive office space, facilities for cargo and maintenance operations, offices, 
meeting space and parking as well as convenient runway access for the aircraft. Options to 

extend the lease are available. 

Land at the Juneau International Airport is available for the option to build a hanger if the desire 

of the company would be to do so in the future. 

Ticket counter space is routinely available at the Juneau International Airport. Currently the 

space of a former airport tenant has not been occupied.

Rental space is available in each of the outlying communities and towns. 

Employees

The majority of pilots flying for Wings Airways during the summer months are current in both 

types of aircraft proposed for service. Wings Airways receives applications from qualified 

pilots on a daily basis. Pilots would be accessible if needed per the application.

Unemployment rates are at an all time high creating a positive climate for obtaining employees. 

Prior to our application submission, conversations took place with potential employees from 

each community. Wings Airways holds an esteemed reputation within the industry and the 

communities of Southeast Alaska fostering a desire for others to become part of the team.

Market Focus

Wings Airways has clearly proven to operate a successful tourist floatplane business with 

exclusive use of a downtown floatplane base. The Wings Airways shareholders have had a 

dynamic seventeen-year relationship with the owners of the Taku Glacier Lodge, the cornerstone 

of the floatplane operation. The value of that relationship is immeasurable and is further proof of 

honesty in the application. Our intentions to only begin a scheduled wheeled service are clear 

and truthful.

In Addition

As stated in the narrative history from the Wings Airways application an additional motivation 

was to provide defensive strategy to protect the current markets served by Alaska Juneau 

Aeronautics if a disruption of service should occur. If this were to happen Wings Airways would 

attempt to recover any and all of the current office space, employees, ground equipment, etc. 

from Alaska Juneau Aeronautics. Wings Airways has sufficient funds to purchase any additional 

equipment needed. As shown in our application the owners and managers of Wings Airways 

have extensive expertise and the knowledge of what would be necessary to begin operations

immediately. 
WHEREFORE, Wings Airways Inc. recasts the principal thrusts of Alaska Seaplane Service

objection with explanation of cause, intent, resources and feasibility. A clear case has been

presented and substantiated.

Respectfully submitted,

Holly A. Johnson, President

Wings Airways Inc

2 Marine Way, Suite 175

Juneau, Alaska 99801

(907) 586-6275

holly(a),wingsairways.com
CERTIFICATE OF SERVICE

I hereby certify a copy of the foregoing reply of Wings Airways Inc has been served this 26th day

of February 2010, upon all persons listed on the Certificate of Service within the Wings Airways

Inc. application.

j1~/C/~~~- ....-

Holly A. Johnson