BEFORE THE

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY

WASHINGTON, D.C.

In the matter of the application of

ISLANDER ENTERPRISES SAMOA LTD.

d/b/a SAMOA AIR

for an exemption pursuant to 49 U.S.C 40109

and a foreign air carrier permit pursuant to

49 U.S. 41302

DOCKET OST-2012-0198

RESPONSE OF INTER ISLAND AIRWAYS, INC. TO APPLICATION

OF ISLANDER ENTERPRISES SAMOA LTD. D/B/A SAMOA AIR

FOR AN EXEMPTION AND FOREIGN AIR CARRIER PERMIT

Communications with respect to this document should be sent to:

Alex Sene, Jr.

President

P.O. Box 4929

Pago Pago, American Samoa 96799

Tel: 1+684+633-7002

Fax: 1+684+633-5727

Email: alex.sene@interislandair.com

December 5, 2012
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BEFORE THE

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY

WASHINGTON, D.C.

In the matter of the application of

ISLANDER ENTERPRISES SAMOA LTD.

d/b/a SAMOA AIR

for an exemption pursuant to 49 U.S.C 40109

and a foreign air carrier permit pursuant to

49 U.S.C. 41302

DOCKET OST-2012-0198

RESPONSE TO APPLICATION FOR AN EXEMPTION AND

FOREIGN AIR CARRIER PERMIT

Inter Island Airways, Inc. supports the request by Islander Enterprises Samoa Ltd. d/b/a

Samoa Air (“Samoa Air”) for exemptions from the provisions of 49 U.S.C. 41302 and any

other applicable statues and regulations of the Department of Transportation (the

”Department”) permitting Samoa Air to perform schedule and charter flights for the

following:

1. The Independent State of Samoa is a party to the Multilateral Agreement of the

Liberalization of International Air Transportation (“MALIAT”), broadening air

transport services between the United States and Samoa. This route is within the

scope of the MALIAT and is open to United States Carriers. 2. Inter Island Airways, Inc. supported Polynesian Ltd. application for exemptions

from 49 U.S.C 41302 and any other applicable statutes of the Department under

Docket OST-2004-19283, which was consistent with the scope of the MALIAT.

3. Inter Island Airways, Inc., a United States Carrier, is operating 19-seater Dornier

228-212 and 30-seater Dornier 328-100 aircrafts providing air service to the

Independent State of Samoa within the scope of the MALIAT.

In view of the above, Inter Island Airways, Inc. requests the Department to revisit these

Exemptions under Dockets OST-2004-19283 and OST-2012-0198 in the event Inter Island

Airways, Inc. is denied access to this route.
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Wherefore, Inter Island Airways, Inc. requests the Department that this application be

granted based on compliance with MALIAT Agreement including Exemption restrictions.

Respectfully submitted,

_________________________ ALEX SENE, JR.

President
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CERTIFICATE OF SERVICE

I hereby certify that I have on this 5th day of December 2012, the foregoing Response of

Inter Island Airways, Inc. to SAMOA AIR’s Application for an Exemption and a Foreign

Air Carrier Permit has been serviced on this day on each of the following individuals via

email.

_______________________ Alex Sene, Jr.

President

Christopher S. Langton

Chief Executive Officer

and Managing Director

ISLANDER ENTERPRISES

SAMOA LTD. D/B/A SAMOA AIR

APB Complex, Matafagatele Road

Apia Park, Box 2894, Samoa

Robert P.Silverberg, Esq.

L. Jeffrey Johnson, Esq.

SILVERBERG, GOLDMAN &

BIKOFF, L.L.P.

1101 30th Street, N.W.

Suite 120

Washington, D.C. 20007

Tel: (202)944-3300

Fax:(202)944-3306

Email: rsilverberg@sgbdc.com

jjohnson@sgbdc.com

Charles F. Donley II

Squire, Sanders, & Dempsey L.L.P

1201 Pennsylvania Avenue, NW

Washington, D.C. 20004

CDonley@ssd.com

Counsel for Polynesian Ltd.

Matagi R.M. McMoore, Director

Department of Port Administration

P.O. Box 1539

Pago Pago, American Samoa 96799