u.s. Department of 

Transportation 

Office of the Secretary 

of Transportation 

April·19, 2012 

Mr. Robert Cohn 

Mr. Jonathan Echmalian 

Counsel for People Express Airlines, Inc. 

Hogan Lovells US LLP 

555 Thirteenth St. NW 

Washington, DC 20004 

Re: Docket DOT-OST-2012-0042 

Application of People Express Airlines, Inc. 

,_:t-PARTMENT OF 

;'; iJ:J~SPORTATION 

::·JCKET OPERATIONS 

for a Certificate of Public Convenience and Necessity 

Dear Sirs: 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

We have completed a review of the application filed on March 19, 2012, by People Express 

Airlines, Inc. ("PEX"),. for a certificate of Public Convenience and Necessity to conduct 

scheduled interstate air transportation of persons, property, and mail. 

We have determined that we will need additional and/or clarifying information before we may 

complete our review. The attached Information Request lists the areas where further information 

and/or clarification is necessary. I ask that you respond fully to this request within 30 days ofthe 

date of this letter. 

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 or the requested information, please feel free to contact 

me at (202) 366-9721. 

Sincerely, 

Catherine O'Toole 

Air Carrier Fitness Division 

Office of Aviation Analysis 

Enclosure 
cc: Docket DOT -OST-2012-0042 

Mr. William Dusold 

Washington Dulles FSDO 

13873 Park Center Road 

Suite 475 

Herndon, VA 20171 

2 
INFORMATION REQUEST 

PEOPLE EXPRESS AIRLINES, INC. 

GENERAL INFORMATION 

1. Please provide a copy of PEX's Articles of Incorporation and by-laws. 

2. Section 41113(c) prohibits the Department from approving an application for a 

certificate unless the applicant has filed an accident plan that meets the requirements 

of section 41113(b). As a result, the Department will not be able to issue a final order 

regarding PEX certification until this requirement has been met. Therefore we ask 

that PEX promptly file a copy of its accident plan in the public docket established for 

these plans (Docket OST-96-1960), submit the required copy of this plan to the 

National Transportation Safety Board, and, at the same time, file a notice in DOTOST-2012-0042 stating that it has complied with the Accident Plan requirements. 

3. Please provide a status update of P.EX's Part 121 certification process with the 

Federal Aviation Administration. 

,MANAGEMENT AND KEY TECHNICAL PERSONNEL 

1. Please provide an updated resume for Mr. Douglas Allington that accounts for his 

employment history from 2006-2012. 

2. For Mr. Bryan Thompson: 

a. His resume indicates that he was employed with Global Airline Services, 

Inc. during the time that the Department issued Consent Order 2011-6-3 

against Global Airline Services, Inc. and Mr. Harold Pareti, concerning 

unauthorized air transportation. Please fully describe Mr. Thompson's job 

responsibilities, whether he was involved in any of the particular 

transactions covered by the Consent Order, and his relationship to Mr. 

Harold Pareti. 

b. His resume and Key Personnel questionnaire indicates two different start 

dates for his position of Vice President of Operations with Glqbal Airline 

Services, Inc. Please provide updated information or an explanation of this 

discrepancy. 

3. Please provide fitness questionnaires and resumes for PEX's Chief Executive 

Officer, Director of Safety, and Chief Inspector at your earliest convenience. 
2 

4. The resume of Mr. Jose M. Pereira contains a gap in employment history from 

December 2007 -July 2008. Please explain and provide an updated resume to 

account for this gap. 

OPERATIONS AND FINANCIAL POSITION 

1. Page 8 of PEX's application states it plans a pre-launch offering of common 

stock. Please provide information, such as a prospectus, about this plan. 

2. Please provide a detailed explanation of the agreements to finance the acquisition 

and/or lease of aircraft and provide copies of the agreements. 

3. Please provide documents related to the funding of the applicant, including any 

commitment letters, stockholder agreements, and financing agreements. 

4. Please provide third-party verification of all lines-of-credit available to support 

PEX's proposed operations. This verification should include the total line-ofcredit ·being made available, the amount such credit line has been drawn down to 

date, any conditions that must be met before funds will be advanced, the terms of 

repayment, and the expiration date. Further, if the line-of-credit is being supplied 

by an individual or organization (other than a recognized financial institution) 

copies of the personal or corporate financial statements of the individual· or 

organization should also be provided. 

5. Please clarify the amount of shares of company stock that is owned or to be 

acquired by Ms. Brittany Colberg. 

COMPLIANCE DISPOSITION 

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.