Hpr 19 2010 5:24PM RLflSKH SEflPLflNE SERVICE 9077905506 P-1 

Alaska Seaplane Service, L.L.C 

PO Box 33179 

Juneau, AK 99803 

(907) 789-7880 

www.flyalaskaseaplBiiAS.coin 

April 19, 2010 

Docket Section 

U.S. Department of Transportation 

1200 New Jersey Avenue. SE 

Washington, D.C. 20590 

Re: Certificate Application of Wings Airways 

Gentlemen.: 

Alaska Seaplane Service, LLC hereby answers the Response of Wings Airways dated 

April 1,2010. We are filing this on our letterhead and fiom our facsimile machine in 

order to show beyond any doubt the source of this answer. Alt previous Slings made by 

Alaska Seaplane Service were prepared at our direction, with specific review and 

approval before each document was filed. All issaes raised now and in the previous 

filings are of concern to AlasJca Seaplane Service and not initiated by any third party. 

We became involved in this application because it was clear to us fiiom the start that the 

Wings Airways application seemed to assert things that were clearly untrue or without 

necessary foundation. The pivotal question is \«diiether Wings Airways had the aircraft it 

proposed to operate over the routes. To see if Wings Auivays "ever claimed it had^' 

possession or control of the two Cessna Caravans and three Cessna 207 aircraft in 

dispute, one simply has to read the original application. On page 3 of the application, at 

item j. . Wings Airways states, "A description of tlie fleet of aircraft available to Wings 

Airways is attached as Appendix F," On Appendix F, Airways lists the five aircraft 

under the heading "Proposed List of Commute Aircraft". Ttw status of the five aircraft 

is listed as 'To Be Leased'\ In fact, these five aircraft were not **available" to Airways at 

the time of the application because they were under lease from Wings Airline Services to 

Alaska Juneau Aeronautics. These aircraft are not available to Airways today because 

they remain xmder lease to Alaska Juneau Aeronautics under a renewed lease. 

Airways protests that Seaplanes did not have any knowledge of the lease negotiations, so 

our assertions are without merit. In fact, as soon as the Airways application was filed, we 

contacted senior managers of Alaska Juneau Aeronautics and asked directly about the 

status of the leases. AJA's managers volunteered that there was no intention to return the 

aircraft before the end of the existing term, that AJA intended to renew the leases, and in 

&ct were in negotiations to that end. We now know that, as stated by Seaplanes, AJA did 

mm 
Rpr 19 2010 5:24PM RLflSKfl SEflPLRME SERVICE 907790550G p. 2 

renew the leases on the five aircraft, and the aircraft are not now "available" to Wings 

Airways. 

We have carefully reviewed the original a{^lication narrative and cannot find the word 

"contingent" anywhere. While Airways spoke of the deteriorating relationship between 

Wings Airways and AJA, and the possibility that shareholders of Airways might lose 

their jobs at AJA, there was no representation that its application was "contingent" on the 

cessation of Juneau based service by AJA, or return of the aircraft fiom lease. One must 

question whose interests are primary if a reason given for the "reason and purpose behind 

4iis application..." is *\, .to keep the five Wings Airline Services Capstone equipped 

aircr«Et serving the markets should a disruption [of AJA service] occur...". Airways 

provided detailed financial mformation about Wings Airline Services, but now objects to 

providing a shareholder list of this obviously affiliated company. 

Seaplanes became concerned with the application precisely because it knew that the five 

claimed aircraft were not available to Airways. Airways does have a large fleet of float 

aircraft, however, and Seaplanes is in the scheduled float aircraft business. We want to 

make sure that If Airways decides to offer seaplane service instead, that its application 

will be fully vetted. 

In summaiy, the one fact that is very clear is that the five aircraft proposed for service, 

and which were used for all market and financial projections, are NOT ''available to 

Wings Airways", and never have been. Seaplanes knows of no precedent for an air 

carrier being certificated contingent on the cessation of service by a supposedly unrelated 

and rival third party, Our concerns about the actual intentions of Wings Airways remain, 

as do the questions concerning the veracity of the application and fitness of Airways. 

CERXmCATION 

The contents of this E^>plication and the attached exhibits are true and correct to the best 

of my knowledge and belief. Pursuant to title 18, United States Code section 1001,1, in 

my individual c^)aclty and as the authorized representative of the applicant, have not hi 

any manner knowingly and willfully &lsified, concealed or failed to disclose any material 

&ct or made any false, fictitious, or fiaudulmt statement or knowingly used any 

documents which contain such statements in connection with the preparation, filing or 

prosecution of the application. I undosland that an individual who is found to have 

violated the provisions of 18 U.S.C. section 1001 shall be fined not more than $10,000 or 

imprisoned not more than five years, or both. 

Sincerely, 

rice, LLC 

;ra>gdioken' 

General Partner