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 CORRESP ON DENCE OF ALASKA SEAPLANE SERVICE, LLC DATED FEBRUARY 16, 2010

Communications with respect to this document should be addressed to:

H olly Johnson Wings Airways 2 Marine Way #175

Juneau, AK 99801 (907) 586

- 6275 holly@wingsairways



### . com

February 26 , 2010BEFORE 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 CORRESP ON DENCE 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

. T he reason s listed below will prove all claims are e rroneous.

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 o ptions 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 wou ld 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 June au 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 2 nd 

### 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 ha nger 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

.
R ental 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
p ilots 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 communi ties of Southeast Alaska fostering a desire for others to become part of the team.

Market Focus
Wings Air ways has clearly proven to operate a successful tourist floatplane b usiness 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 Glacie r Lodge, the corn erstone 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 se rvice should occur. If this were to ha ppen 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 applica tion the owners a nd 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 holl y(a ) ,wingsairw ay s

. comCERTIFICAT E OF SERVIC E

I hereby certif

y a cop y of the for eg oin g repl y of Win gs Air w a ys Inc h a s been served this 26 th da y of Februar y 2 010
, upon all p e r s ons li ste d on t h e Certi f icat e of S e r v ic e w ithin th e Wings Airwa y s Inc. application. 

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~ ~ ~ - .... - H o ll y A. Johnson