### Before the United States Department of Transportation February 15 , 2013

Proposal to Provide Essential Air Service at

KINGMAN, ARIZONA PAGE, ARIZONA PRESCOTT, ARIZONA SHOW LOW, ARIZONA

Under 49 U.S.C. 41731 et seq. Docket OST

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# Proposal of SeaPort Airlines, Inc. to Provide Essential Air Service at the Arizona Communities of

Kingman, Page, Prescott, and Show Low

In response, SeaPort Airlines, Inc. (“SeaPort”) respectfully submits this timely proposal to provide subsidized EAS at each of the above named communit ies. The proposals herein contemplate service connecting each community with the national air transportation system via Phoenix Sky Harbor International Airport (PHX), a major connecting hub for both US Airways and Southwest Airlines, the nation’s largest low

- fare carrier.

 At Prescott, SeaPort proposes to operate 30 nonstop roundtrips each week to Phoenix, of which 18 would originate or terminate at Kingman, providing that community with 18 one

stop roundtrips to Phoenix each week. If SeaPort is not selec ted to provide EAS at Kingman, a standalone proposal to provide EAS at Prescott is also included that offers 26 weekly nonstop roundtrips between Prescott and Phoenix.

 At Page, SeaPort proposes to operate 32 weekly roundtrips to Phoenix during peak touri sm months reduced to 18 weekly roundtrips during off

- peak months.

 At Show Low, SeaPort proposes to operate 26 nonstop roundtrips to Phoenix each week

. Each community is provided the option of flights operated with single

- engine turboprop aircraft or ai rcraft w ith two piston

- engines (“piston

- twin”), should a community not wish to waive its right to Essential Air Service with twin

- engine aircraft. The aircraft will seat 8 or 9 passengers and all flights will be operated with two pilots.

With the exceptio n of Kingman being t ied to Prescott, the EAS proposals at each community are submitted on a “stand alone” basis. If selected to provide EAS at all of t he communities and using the same type of aircraft, SeaPort expects to realize economies of scale to lower operating costs. Accordingly, there is also a contingent proposal with a reduced subsidy request that SeaPort offers should it be selected to serve all four of the Arizona communities using the same type of aircraft.OST

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February 15 , 2013 Page | 2 On a standalone basis SeaPor t is requesting a total of $ 8,170,022 to provide EAS at all four communities using single

- engine turboprops, or $ 7,621,564 if flow n using piston

- twins. The reduced request ed subsidy amount contingent on being selected to provide service to all for communities using Cessna Caravan single

- engine turboprops is $7,485,287 , saving the Department $ 684,775 per year

. The reduced requested subsidy amount contingent on being selected to provide service to all fo u r communities using piston twins is $ 7,116,626 , saving the Department $504,938 on an annual basis.

After this proposal is docketed, SeaPort Airlines will contact the Airport Manager at each airport to schedu le a meeting with the communities to explain our proposal in detail, and answer any questions. In the interim and throughout the carrier selection process, questions regarding this proposal should be directed to:

Timothy Sieber Vice President

– Commercial SeaPort Airlines , Inc. 7505 NE Airport Way Portland, OR 97218 (971) 340

- 1716 tsieber@seaportair.comOST

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February 15 , 2013 Page | 3 

# Introduction to SeaPort Airlines

Scope of Operations

SeaPort Airlines, Inc. is a FAA certified scheduled airline based in Portland, Oregon with 30 years of experience in commercial aviation . In addition to Portland, the company has operational bases at Memphis (MEM) and Juneau (JNU). Service from a fourth operational base located at San Diego (SAN) is scheduled to be gin on May 1, 2013 with service to Imperial/El Centro, California.

Our approximately 185 professionals operate a fleet of 14 aircraft on an average of 90 scheduled departures each day, increasing to over 100 each day during the peak tourist season in Sout heast Alaska. 1 Including new service to Imperial/El Centro, the company serves 2 1 cities in nine states as illustrated on the map below.

1 SeaPort Airlines operate in Southeast Alaska branded as “Wings of Alaska .” The company operates an additional 8

- 10 “ flightseeing ” tours each day during the summer, which are marketed by major cruise lines such as Princess

, Carnival, and Royal Caribbean directly to their passengers onboard the ships. These flights, which offer views of Alaska landscape and wildlife , are not included in the count of scheduled departures

.OST

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February 15 , 2013 Page | 4 A Track Record of Building Partnerships With Our EAS Communities

Service to eight of the communities on SeaPort ’s route map is provided under the EAS program : Athens, Georgia ; Pendleton, Oregon; El Dorado, Hot Springs, and Harrison , Arkansas; Salina, Kansas; Jackson, Tennessee; and Imperial/El Centro, California.

The primary focus of SeaPort Airlines is to provide air service to small and rural communities across America that is affordable , customer

- centric, and reliable . Many of the communities we serve w ere
on ce on the route map of one or more major airlines not too long ago. However, with the business models of big airlines focused on global alliances and the cost of typical 100

- 150 seat aircraft hovering around $50 million, service to these communities was entrusted to regional airlines that, in many cases, operated with an affiliate brand such as American Eagle, US Airway s Express, or Delta Connection. Today, many of the first generation regional airlines are facing similar rising costs and migrating to larger aircraft (i.e., 75 seaters replacing 50 seaters), meaning that revenues in the se market s are insuffi cient to be served profitably even with a reasonable level of subsidy. For small er
or rural communities that remain on a major airline’s map, a lack of attention or specific operating strategies such as reasonably timed flights, competi tive fares, and/or a policy of first cancelling small er markets during weather events. Frequently , the major airlines are re focus ing their resources

on grab bing an extra one

- percent of market share at Shanghai or spiffing up the premium passenger lounge at Paris Charles DeGaulle Airport . SeaPort fills this void by focusing on providing service to markets such as the se four Arizona communities with air service that is reliable, customer

- centric, and affordable.

To serve these communities, SeaPort operates aircraft with operating costs and passenger capacity that are appropriate to a market’s true demand. This strategy allows us to offer higher frequencies and a greater choice of departure times than is possible with larger aircraft, including the next increment in plane size seating 19

- 30 passengers. The pricing strategy employed by SeaPort in our EAS communities is to incentivize use of the local airport so that enplanements maintain EAS program eligibility, but do not result in shifting the “true cost” of air travel to the Department’s EAS budget. Most importantly, we are focused on providing our customers with attentive and personal service that, in many of our markets, is commonly known as “The SeaPort Experience.”

Once SeaPort is awarded an E AS contract and service is launched, we develop a partnership wi th each community by participating in local events, donation of tickets, on

- going dialogue with airport management and community leaders, and presentations to civic clubs and other similar org anizations

. We also have a reputation of being responsive to community needs, affording them the opportunity to comment on schedule and fare changes before they become effective. It is SeaPort’s view that airlines and communities, who we view as our customer, need not be at odds with each other. To the contrary, we have a shared interest in fostering grass roots support for local air service and, as result, ensuring that enplanements maintain the level needed for continued eligibility in the EAS program.

Possibly the strongest indicator of the service we provide in communities similar to the four Arizona communities, is the fact that in every “Lower 48” markets where SeaPort has been selected to provide EAS, we have been re

- selected for subsequent terms at the end of the first contract period. This includes reselection during 2012 to four

- year contract renewals (rather than the standard two

years) at both Salina, Kansas and Pendleton, Oregon, aft er both communities voiced their overwhelming support for SeaPort Airlines.

Later in this document we have provided comments submitted by customers and airport managers that lend support to our commitment and capability to deliver outstanding customer se rvice. Nonetheless, we encourage each of the communities that SeaPort is proposing to provide EAS toOST

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February 15 , 2013 Page | 5 contact the airport manager in any of our EAS communities to discuss the responsive, reliable, and customer

- centric service that SeaPort Airlines consiste ntly provides their community

. Aircraft Type: Single

- Engine Turboprop OR Piston

- Twin Engine

In this filing, SeaPort is offering Kingman, Page, Prescott, and Show Low a single service pattern proposal but a choice of two aircraft with which the service pattern may be flown

. 2 Both aircraft types offered are described below, as is the rationale for providing a choice of aircraft types

. Single

- Engine Turboprop: Cessna Caravan

Currently, all SeaPort flig hts are flown with single

- engine aircraft, including flights to the eight communities served as part of the EAS program. It is our view that m odern single

- engine turboprop s
are the best platform for providing EAS at reasonable levels of subsidy, which is frequent, affordable, and reliable.

Specifically, SeaPort Airlines is proposing to provide EAS at Kingman, Page, Prescott, and Show Low using Cessna Caravans, a single

- engine turboprop that seats 9

- passengers

. 

### The Caravan is certified for single

- pilot operation , however SeaPort operates in the Lower 48 with both a Captain and First Officer. 3



### Produced in the USA, the “ Caravan ” was originally designed in the 1980’s to replace an aging fleet of piston

- powered aircraft, such as the De Havilland Otter and Piper Chieftain

. Over 2,000 Caravans have been built logging a total of over 12.5 million flight hours.

The Caravan is equipped with a large cargo pod, allowing it accommodate more baggage (both in volume and weight) tha n other 8/9 passenger aircraft, including the piston twin (i.e., Piper Chieftain and Cessna 402) offered as an option in our proposal

. Equally important, the large

2 A “back

- up” proposal for Prescott is also included that will allow for the selection of SeaPort to provide EAS to that community regardless of which carrier is selected to provide EAS at Kingman.

3 Presently, over half of SeaPort’s fleet is comprised of Cessna Caravans, with four additional aircraft deliveries planned for the balance of 20 13

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February 15 , 2013 Page | 6 

### cargo pod facilitates the segregation of passengers and baggage, important for security purpo ses. 4



### Based on our experience in other EAS markets, SeaPort expects there to be some questions regarding flights operated with single

- engine aircraft in each community. During the carrier selection process and, if selected, during presentations and events to promote the new service, we will expand upon the following reasons as how the Cessna Caravan allow s us to provide safe and reliable air transportation

, as we do every day on an average of 90 daily departures:

 The argument that single

- engine aircraft a re less safe than multi

- engine aircraft is based on the presumption of engine failure

. Failure of modern turbine engines is extremely rare and it is even more rare is engine failure being the primary c ause of an accident or incident.

 Multi

- engine aircraft experience asymmetric thrust and a rapid loss of climb performance of up to 80% . In contrast, s ingle

- engine aircraft don’t experience asymmetric thrust, and they typically have higher glide ratio s and can land at slower speeds.

 As reliability has improve d over the last 75 years, airlines have specified fewer engines on new aircraft designs

– “more motors is better” no longer applie s.

 Newer, modern technology single

- engine aircraft provide a better customer experience than older twins

. Finally, and as noted earlier, SeaPort Airlines has never lost an EAS contract renewal in the Lower 48 . While many factors contributed to this perfect record

, it is worth noting that these renewals have come following a period (and after proposing a subsequent period) of operations using single

- engine turboprops. While there may have been some trepidation early in a first contract term, it hardly gets a mention during the renewal process. We believe this reflects our community’s understanding and app reciation for the frequent, affordable, and reliable service we can offer with such aircraft

.
Combined, these factors all contribute to (and can even determine if) a community remains eligible for EAS subsidized flights.

Piston

- Twin Eng ine Aircraft: Pip er Chieftain or Cessna 402C

The definition of “Basic Essential Air Service” provided in 49 U.S.C. 41732(b)(5) states that EAS be

“ provided in aircraft with at least 2 engines and using 2 pilots, unless scheduled air transportation has not been provided to the place in aircraft with at least 2 engines and using 2 pilots for at least 60 consecutive operating days at any time since October 31, 1978.”

A community can waive their right to twin

- engine aircraft, as has been the case in nearly all EAS communities where SeaPort was selected to provide service

. 5 Notwithstanding our track record of success and belief that the Cessna Caravan is the best platform for serving EAS markets

, we recognize the possibility that a community may str ongly prefer the service pattern, pricing approach, etc. of SeaPort Airlines but prefers its service to be provided with twin

- engine aircraft.

4 The cargo pod on the Cessna Caravan has a maximum capacity of 111 cubic feet and 1,090 pounds. In comparison, the Piper Chieftain has a maximum capacity of 65 cubic feet and 700 pounds in its nose compartment and two wing lockers.

5 Exception s are Jackso n, TN and Athen, GA, where the community had already waived its right to twin

- engine aircraft when selecting the carrier that SeaPort would later replace.OST

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February 15 , 2013 Page | 7 To address this, each proposal also provides the option of service flown by piston

- twin aircraft, specifically the Cessna 402C or Piper Chieftain. These aircraft, which would be flown by two pilots and carry 8

- passen gers , offer virtually identical customer experiences with the physical similarity between the two airplanes evident in the phot os below.

The aircraft offer similar operating capabilities and have comparable operating economics. To calculate the requested level of subsidy with piston

- twins

, operating and anticipated acquisition costs of the Piper Chieftain were used. Based on operating costs of the Piper Chieftain being marginally higher than the Cessna 402C, offset by acquisition costs for a Chieftain generally below (and in some cases, sign ificantly lower) than those of a Cessna 402C, we believe this provides reasonable foundation for requested subsidy level. 6

Pricing Strategy & Fare Structure

In all markets, whether served with subsidy or entirely at our own risk, SeaPort employs a fare structure that offers a range of price points intended to make our service attractive across the entire spectrum of potential customer s , including low fares that stimulate additional traffic volume , either through net

- new customers who previously would not travel by air or at all and/or more travel by existing customers. O ur highest price point (still reasonable compared to “walk

- up” fares typical of other airlines) allows a customer to change the ir travel itinerary or obtain a refund without incur rin g a service charge.

A ll of SeaPort’s fares are priced on a one

- way basis, including all taxes and fees, and structured as follows:

 The highest price point (branded as “FullFlex”) provides our customers with total flexibility to change their travel p lans up until departure time or, if they choos e , obtain a full refund without incurring a ny service charge. Reservations not cancelled prior to scheduled departure prevent SeaPort reselling the seat to another customer. In such instances, customers holding FullFlex tickets are charged a $50 no

- show fee.

 The lowest price point (branded as “NoFlex”) targets customers who are certain about their travel plans. This fare requires an advance purchase of 21

- days, is non

- refundable, and does not permit any changes from the original booked itinerary.

6 If SeaPort is selected to provide EAS using piston

- twin aircraft, we believe carrier selections by the Department granting discretion to schedule EMB

- 145s instead of CRJ

- 200s, and vice versa, provides precedent for a selection that permits service to be provided with t he Chieftain and/or Cessna 402C.



### Piper Chieftain Cessna 402COST

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February 15 , 2013 Page | 8  In between, SeaPort offers a range of fares (“Free2Flex” and “Flex4Fee”) with price points based on how much flexibility a customer has in their travel plans. Except for the two highest price points, fares are also su bject to capacity controls meaning that the farther in advance a reservation is made, the more likely a customer is to get a lower fare.

The table below summarizes ticket prices (and rules and restrictions applicable to each price point) that would be ch arged by SeaPort at the Arizona communities of Kingman, Page, Prescott, and Show Low, assuming a service start of approximately May 1, 2013

.



# SeaPort Airlines Illustrative Fares at Kingman, Page, Prescott, and Show Low, Arizona

NOTE: Listed price points include Federal Excise Tax , segments fee

, and 9/11 security fee

The level s of requested subsidy in this filing are based on calculations that include the projected average fare illustrated next to each city name. Based on limited ava ilable data, we have assumed no local passengers or revenue between Kingman and Prescott, or passengers traveling between the EAS communities via connection at Phoenix.

During the first 30 days of service, SeaPort would offer an introductory fare of $49 (including taxes and fees) on every seat, on every flight between Phoenix and each community where SeaPort is selected to provide EAS. Our experience in other communities indicates that introductory fares are effect ive in building a local customer base that can speak with genuine k nowledge abou t SeaPort’ s service and, depending on which carrier we replaced, an opportunity to demonstrate the higher service standards of SeaPort, and to draw back customers who may have stopped using their local airport during the tenure of the previous carrier. 7

This pricing strategy and fare structure as outlined above has proven effective in SeaPort’s other EAS markets. Specifically, it allows us to stimulate demand and help s increase enplanement levels to th e level need for continued EAS eligibility, but the higher price points ensure we do so without unduly shifting the “true cost” of air transportation to the Department. We are confident that this fare structure will be similarly ef fective in the Arizona communities.

7 This discussion should not be viewed as a commentar y on the level of service currently provided by Great Lakes Airlines. Rather, and as alluded to above, SeaPort has replaced a number of airlines in EAS markets, including three where we reestablished service following an 18 month service gap due to previou s carrier ending all operations.OST

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February 15 , 2013 Page | 9 Interline Connectivity & GDS Availability

SeaPort Airlines tickets are available for purchase by calling our toll

- free reservation number, online at www.SeaPortAirlines.com, at any travel agent connected to the major global distribution systems (GDS), and all of the major online travel agencies and meta

- searchers such as Orbitz, Travelocity, Exped ia, Kayak, Hipmunk, and CheapoAir.

SeaPort is working toward implementation of an interline agreement with a major airline in the second quarter of 2013 which includes E

- ticketing and thru baggage check

- in. We are in discussion s with two other major airl ines and anticipat es beginning implementation of our next agreement shortly after completing the current implementation

.

In addition

, SeaPort presently has an interline paper ticketing agreement with US Airways , the dominant network carrier at Phoenix Sky Harbor Airport. If selected to provide EAS at the four Arizona communities

, SeaPort will seek to transition this agreement to a full interline agreement that includes e

- ticketing and through baggage check

- in. In making this case , we will point to the incr emental (but meaning ful ) passenger volumes and revenues that can be generated by the four Arizona EAS communities via connections at Phoenix, as well as by our new service at San Diego

. We will seek to accomplish this quickly , however due to the announced merger of US Airways and American we anticipate a period time during which the “new American” will not ent ertain additional agreements, instead focus ing resources on integration of existing IT platform s

. Staffing Plan & Airport Locations

SeaPort Airlines views the use of our own employees as a critical part of our formula to provide excellent customer service and build partnership s with our EAS communities. 8 If selected to provide EAS at the four Arizona communities , we would utilize our own personnel to provide customer service and ramp operations, and maintain the security screening of passengers and baggage performed by the Transportation Security Administration (TSA)

. SeaPort Airlines pla ns to establish a pilot base and maintenance ba se at P hoenix Sky Harbor International Airport that will ensure adequate staffing levels and spare parts inventory to achieve a high level of dispatch reliability. For unscheduled maintenance at the EAS communities , SeaPort Airlines plans to contract with an FAA certified Part 145 repair station for “on

- call” maintenance. We have had discussions with staff at Phoenix S ky Harbor International Airport and have been assured that

, if selected to provide EAS at the four Arizona communities, space will be available for our operations in the main terminal complex.

SeaPort Airlines operates a reservation call center at Memphis International Airport which is open from 5am ET (2am PT) until 11pm ET (8pm PT) Monday through Friday, with reduced hours on weekends . Th e call center is supported by airport ticket counters, which answer reservation calls during those periods when a station does not have any flight operations and which contributes to maintaining relatively short customer hold times

. Finally, beginnin g this summer SeaPort will provide an enhanced level of service to our Hispanic customers when we open a call center offering reservation and customer service staffed by

8 The exception to this is Jackson, TN where the FBO (owned and operated by the Jackson

- Madison County Airport Authority) has been contracted to provide passenger check

- in and aircraft ramp handling for a market

- standard fe e per departure. This agreement was only entered into after concluding the airport authority shared our view that exceptional customer service was a requirement to rebuild traffic following the previous EAS operator, and that its geographic position of our Mid

- South route system would allow us to maintain a community presence and be responsive in a timely manner to customer service issues.OST

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February 15 , 2013 Page | 10 Reservation Agents with fluent in both English and Spanish. Initially, this center will be open from 8am to 6pm (Pacific Time)

, every day except major holidays. As call volume data is monitored

, staffing levels and center hours m ay be adjusted to better align with c all volume patterns that emerge . The Spanish

- speaking call center will be supplemented in late 2013/early 2014 with a Spanish version of the company’s website.

Marketing & Public Relations Strategy

Recognizing the low volume of traffic under the current EAS provider and the requirement of at least 10 enplanements per day for continued EAS eligibility , SeaPort is prepared to implement a comprehensive marketin g and public relations strategy . In addition to advertising (primarily print but also lots of radio), activities include:

 Local Event Marketing: Recognizing that tactics which include high visibility in key markets has been effective for legacy and low

- cost airlines, SeaPort has implemented a similar strategy in all of its communities. Activities range from annual Easter egg hunts in selected communities, pres entations to civic groups, displays at local fairs and trade shows, Chamber of Commerce memberships, and “Food 4 Flight” food drives that benefit local food banks. SeaPort also makes “in kind” donations of tickets to be use d by local charities, either for their own travel needs or for

use in fundraising (i.e., raffles, silent auctions, etc.). This public outreach maintains awareness of the local airport, which is often on the edge of a small community and suffers from an “out of sight, out of mind” syndrome . It also helps to build the support that SeaPort enjoys in virtually all of our communities.

 Social Media: SeaPort has become very proficient in the use of social media to engage our customers in a two

- way conversation on sites such as Facebook, Twitter, and LinkedIn. S ocial media has proven to be an excellent tool for generating passenger referrals and informa tion sharing in our communities. If selected to provide EAS at the Arizona communities, similar success is expecte d

. An indicator of SeaPort’s success with s ocial media is the fact that only one U.S. regional airline has more “ Likes” on Facebook than SeaPort, and that airline carries seven

times more passengers each year.

 FlyerFlex Customer Rewards: To thank those c ustomer s who give us repeat business

, SeaPort offers a customer loyalty program called “ FlyerFlex .” This program provides a variety of benefits to our frequent flyers including free flights, waivers to excess baggage and ticket change fees , and

, coming in 2013, participation in the TSA’ s “Pre

- Check” program.

SeaPort has budgeted $ 25 ,000 per year for marketing and sales activity at each of the Arizona EAS communities . Th is budget is believed to be more than adequate when factoring the lower media costs in small markets , assuming continued success stretching paid media buys with trade agreements, and understanding that the majority of traffic in EAS markets originat es in the EAS communi ty, and leveraging our presence on social networking sites

, more frequen t and interesting blogging , opt

- in email program , etc.

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# What Our Customers & Community Partners Say

The tactics outlined to this point have proven successful in markets and are an integral part of the overall strategy that SeaPort will implement if selected to provide EAS at Kingman, Page, Prescott and Show Low. The most effective tactic at SeaPort’s dis posal, however, is to focus on what we do best by building a partnership with the community, operate safely and reliably, and provide customers with a great experience from their first visit to our website or call to our reservation call center through to baggage claim at the final destination.

Also to this point, SeaPort has not been anything but shy about touting our record of building partnerships with our EAS communities and providing consistently great service at affordable fares, We’re not the onl y ones who are talking. B elow is a small sample of the types of comments that our customers regularly take the time to submit, as well as from some of our EAS community partners:

Comments Submitted By EAS Communities

“Eastern Oregon Regional Airport at Pendleton had been struggling since schedule changes following 9/11 served by a carrier flying 37 seat aircraft. Low passenger count attributed to poor schedule, which then contributed to poorer passenger count. The ca rrier's solution was to bring in larger aircraft and fly to a different hub. The Airport and community balked at this suggestion and went in search of alternatives. The solution found through the EAS process was SeaPort Air flying a 9 passenger Pilatus. Th e passengers have welcomed the new service, much better schedule, and are elated with ‘no security check’ and stand by time. Passengers today will say, ‘I love the service’, ‘great customer service,’ and ‘I'm sure glad I finally tried it, cause I'll be bac k’

“In our particular market, the 9 passenger aircraft is perfect, and SeaPort Air provides the schedule, the professionalism, and customer service we need and desire.”

− Larry Dalrymple (Retired) Airport Manager Pendleton Regional Airport

“I understand the importance of having dependable, reliable air service with an affordable cost. Not only will SeaPort Airlines meet these needs, but excel by providing great customer service, a high level of community involvement, and an eagerness to become a communit y partner”.

− Luci Larson Former Mayor of Salina & Owner of Action Travel Salina, KS

“South Arkansas Regional Airport and the entire South

- central Arkansas region suffered from the loss of air service previously provided by Mesa Airlines in the Spring of 2008. Unreliable service and a poor schedule were already negatively impacting enplanements before Mesa pulled out, but at that point, the nearest option for air service of any kind was almost a two hour drive away. After sorting through applications fro m many different interested carriers, the El Dorado Airport Commission, along with El Dorado’s Mayor, chose SeaPort to restore air service to South Arkansas. This was the beginning of a great partnership between SeaPort and our local community.OST

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February 15 , 2013 Page | 12 “Working with SeaPort has been nothing but a pleasure from the bottom to the top of their organization, and their commitment to excellence shines through the glowing comments that I hear from people who fly with them. In addition to hearing comments from others, I have flown SeaPort on several occasions, and have come away from the experience thinking ‘This is how all air service should be.”

− Josh Zylks Airport Manager South Arkansas Regional Airport (Goodwin Field)

Customer Comments (Submitted via Letter, Comment Card, or via Website)

“I'm a SeaPort MKL

- BNA commuter. My job is on the 5 day 4 night plan and I head out to work sites across the nation on Monday and fly home in time for dinner on Friday. Thanks Seaport for the service it beats using a car and parking at the airport.”

─ Calvin Phillips

We needed to change our reservation with SeaPort after having booked with priceline.com. Priceline was less than helpful. Frustrated I emailed SeaPort with our needs a bout 10:30PM. The next morning at 9:00 we got a call from Cindy in reservations advising that our request had been taken care of and was already booked. I NEVER EXPECTED THIS LEVEL OF SERVICE! We are satisfied and grateful for the intense personal attent ion we received.

─ Michael McDonell

“My husband and I recently had to make a fast trip to Dallas for the funeral of a dear friend. I was not interested in making that drive over a fast weekend. Then I remembered that SeaPort had recently started flights between Hot Springs and Dallas. I called SeaPort, Jim and Bob were so quick to get us booked, last minute so we could fly down and attend the funeral and visit with family and friends that we don't get to see very often.

Eve ryone was so friendly, helpful and professional. It was a dream trip, even to attend a funeral. The pilot going down was so kind. When he found out that my husband had been a ball turret gunner in WWII, he gave him a set of headphones so he could listen to the communication between the pilots and the air traffic controllers. To say the least, my husband was impressed. It was such a blessing to have been taken care of in such a kind and professional manner, especially under the circumstances of our trip. Tha nk you, Jim, Bob, Chris, Doug, Rodney and Michael.”

− Catherine Martin

“For two decades I have been picking my mother up at the airport and for two decades I have been met with the defeated, hang

- dog look that the ordeal of air travel has given her. I guess it pretty much does it to all of us, but (as she is well into her 80's) I worry about the toll it takes on her more and more lately.OST

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February 15 , 2013 Page | 13 “When I picked her up today from her SeaPort flight K52325 from Dallas and saw she was smiling, you could have knocked me over with a feather! She couldn't stop raving about how pleasant the flight was. Let me be clear. My mother is a tough

- as

- nails Mid

- western Yankee from the old school who has bee n around the world a couple of times since the late 1940's. She doesn't bestow idle praise and she seldom raves.

“I'm in the service industry myself and I know how often complaints come through. I just want to be sure to let you know how well everyone did on this flight. In the future, I will look to SeaPort first for my travel needs and will spread the good word to my friends.

“A smile and a kind word go a long way y'all. Thank you for getting this one so right.”

− Mark Davis Peterson

“I can not say eno ugh wonderful things about my experience with your company. My son, who is 7, flew for the first time as an unaccompanied minor. Let’s just say that my son and I were very

nervous.

On arrival to Kansas City I was welcomed with front row parking and an em ployee that was welcoming and reassuring. When his plane landed the pilot, Demetrius came and talked to me and my son for twenty minutes about safety and just reassuring me. He then allowed me to walk my son to the plane and see him off. Demetrius started buckling my son into his seat and my son started to cry, I could see him reassuring him that everything was going to be ok. All of your employees were wonderful and were conscious of safety and the well

- fare of my son. My son’s flights from Kansas City to Memphis were wonderful and because of the extra attention he feels comfortable and unafraid of flying by himself.

You have made me a lifelong customer. My son will be flying at least once a year to see his Grandparent. I have told all my friends, family and co

- workers about your company and how if they have an opportunity they should fly with SeaPort. Thank You again for making a nervous mother and a scared child feel comfortable.”

− Misty Strayhorn

“I would like to tell you of my recent experience at your airline in Memphis, TN. On the evening of September 25th I took my friend to the airport to catch her flight to Harrison, AR. I went inside to help her with her bags and to say goodbye. Returning to my car to leave it would not start. I went back to the waiting area to ask the lady at check in if someone that worked there might have jumper cables. Waiting a few minutes I saw a pilot friend of mine, Mark Emrath. He had jumper cables but could not get my car to start. He went for help and brought back three mechanics with tools. Mark finally left to go home after staying to help for over 30 minutes. The other men kept troubleshooting and finally removed the battery to have it tested first before making any diagnosis. My daughter had left work to come help me by this time and we went to AutoZone and purchased a replacement battery. When we returned to the airport the men put my new battery in and checked the car fluids and other parts letting me know I ne eded to have some things fixed. As a single lady it is always frustrating when I have car issues, so I was extremely grateful for the help I received at Seaport. The mechanics at the Memphis airline were so professional, courteous, and knowledgeable that I wanted to take the time to let you know how much I appreciated the SeaPort Airline employees helping me.”

─ Nita CarrOST

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February 15 , 2013 Page | 14 On Saturday June 11, 2005, 17

- year

- old Theo Allen died after his glider crashed north of Pangborn Memorial Airport in Wenatchee, Washi ngton. The following letter was received from his mother in June 2012:

“I wanted to thank your airline and pilots for one of the most amazing Mother’s Day gifts. On the flight from Yakima to Wenatchee they diverted from the typical route and flew over the ridge my son’s plane went down in hopes of finding a marker. To see the world from ‘Theo’s’ viewpoint that day was extremely healing. I will never forget this kindness and have told many of my friends about your airline.”

─ Susan AllenOST

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# Service Proposal Details

Service Pattern & Frequency Levels

Provided over the following pages are specific details of the E AS service that SeaPort proposes to provide on a subsidized basis at Kingman, Page, Prescott, and Show Low.

Service Focus: Phoenix

T he proposals of SeaPort to provide EAS at the Arizona communities of Kingman, Page, Prescott and Show Low focus on service to Phoenix Sky Harbor International Airport (PHX), w here customers will be provided excellent connectivity with the national air transportation system.

Phoenix Sky Harbor International Airport is served by 15 scheduled airlines that collectively operate an average of more than 1,000 departures to over 100 nonstop destinations, including nonstop flights to London where a single onward connection provides access to a ll of the major government and business centers of Europe

. 9

9 The following airlines present ly serve PHX: Aeromexico, Air Canada, Alaska Airlines, American Airlines, British Airways, Delta Air Lines, Frontier Airlines, Great Lakes Airlines, Hawaiian Airlines, JetBlue Airways, Southwest Airlines, Sun Country Airlines, United Airlines, US Airways, and WestJet.OST

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February 15 , 2013 Page | 16 A major strength of Phoenix in its role as an access point to the national air transportation system results from th e nearly three decade long, back and forth battle between Southwest Airlines and US Airways (including predecessor America West Airlines) for control of the Phoenix market

. Th is seemingly permanent escalation of the competitive environment has resulted in fares at Phoenix being consistently below the national average and among the lowest in its peer group of Top 20 U.S. A irports. These data points on illustrated on the following table:

The large number of flights and nonstop destinations , along with relatively easy access to low fares that results from very strong competition , positions Phoenix Sky Harbor International Airport as an ideal point for providing EAS communities connectivity to the national air transportation system.

Equally important, however, is that Phoenix is the capitol city of Arizona

, creating demand for government related travel. As the largest metropolitan area in Arizona and among the largest in the Southwestern United States, Phoenix is also a major center for banki ng, medical services, legal services, higher education, and arts, entertainment and cultural activities.

SeaPort Airlines understands that flight routings and schedules designed to serve demand for travel to/from state capitol s is not a primary objec tive of the EAS program. However, in two of the Arizona markets

– Kingman and Show Low

– there exists a DOT requirement to increase average d aily enplanements and/or lower the level of subsidy as measured on per passenger basis in order to maintain eligib ility for the EAS program. SeaPort believes that the additional passenger s travel ing to/from the state capitol can be served without any negative impact on connectivity to the national air transportation system via PHX and could play a significant role (an d possibly determining role) in ensuring that flights subsidized under the EAS continue at each community.OST

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February 15 , 2013 Page | 17 Frequency Levels an d Impact s on Traffic

In Order 2013

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- 8, the Department directed that carrier “proposals should provide sufficient capacity to accommodate historical levels of traffic.” The less er number of seats on SeaPort’s aircraft relative to those of the current EAS operator

, results in a higher number of frequencies than historically provided

. Specifically, SeaPort proposes the following se rvice patterns and frequency levels at the four Arizona communities:

 Kingman: 18 weekly roundtrips to Phoenix operated on one

- stop basis over Prescott.

 Page: 18 weekly roundtrips to Phoenix for 38 w eeks each year, increasing to 32 roundtrips for 14 week s each year in response to demand from seasonal tourism.

 Prescott: 30 weekly roundtrips to Phoenix, of which 18 are shared with upline service to Kingman.

 Show Low: 26 weekly roundtrips to Phoenix.

SeaPort’s strategy to focus service on Phoenix creates the opportunity to satisfy demand for travel to and from the state capitol, a specifically a schedule that allows for a morning flight in, a full day of business, and return home the same evening. Current schedules in the Arizon a markets do not allow for such trip and it is the belief of SeaPort that this (currently unmet) demand f or business travel to and from Phoenix could produce additional passenger traffic which, in the case of Kingman and Show Low, could prove to be that wh ich assures the community’s continued participation in the EAS program.

Capacity Levels Sufficient to Meet Historical and Projected Traffic Levels

In Order 2013

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- 8, the Department dire cted that “proposals should provide sufficient capacity to accommodate historical levels of traffic.”

The table on the next page compares traffic over the past three years at Kingman, Page, Prescott, and Show Low to SeaPort’s projections of traffic at each of the EAS communities. In all markets, SeaPort projects traffic levels higher than in the most recent year of historical data

. 10 This is directly attributable to the higher flight frequencies in SeaPort’s proposal relative to those currently provided and changes to patterns which focus on service to Phoenix pro viding 1 ) improved connectivity via PHX with the national air transportation system, and 2) ability to complete a same

- d ay return business trip to Phoenix and vice versa

.

10 Historical year data was provided by the Department in Appendix B t o Order 2013

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# Historical Traffic Levels v Project ed T raffic Levels Proposal of SeaPort Airlines to Provide EAS at Kingman, Page, Prescott, and Show Low, AZ

The bar graph below provides a side

- by

- side comparison of projected traffic levels and the number of seats that SeaPort’s EAS proposal provides in each market , and clearly illustrates that the proposed service levels provide sufficient capacity to meet anticipated demand. In addition:

 The projected number of passengers and available seats in each market was calculated on a bi

directional basis when preparing the g raph on the next page, and equate s to twice the omnidirectional projection s on the table above

.

 Data in Page

- Phoenix market is presented on the average daily basis over a full calendar year and includes increased frequencies during the peak demand summer tourism months

.

 Calculations of traffic onboard Prescott

- Phoenix flights include s traffic originating or terminat ing at Kingma n and routed over Prescott with a service pattern that offers one

- stop service to Phoenix

. 

# SeaPort Airlines Projected Traffic and Capacity Proposal to Provide EAS at Kingman, Page, Prescott and Show Low, AZ

46 77

63 67

14 46 40 34

0 20 40 60 80 100

Kingman - Prescott Prescott - Phoenix Page - Phoenix Show Low - Phoenix

Avg Daily Seats Avg Daily Passengers Segment Load Factor = 30.2% Segment Load Factor = 59.6 % Segment Load Factor = 63.1 % Segment Load Factor = 50.8 %OST

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February 15 , 2013 Page | 19 Plans to Maintain Continued EAS Eligibility at Kingman and Show Low

In Order 2013

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- 8, the Department noted traffic levels at K ingman and per pa ssenger subsidies at Show Low represented threat s to continued EAS eligibility for these communities. As dire cted by the Department, the discussion below outlines how SeaPort intends to specifically address the challenges at Kingman and Show Low.

Kingman

S pecific to Kingman , the Department noted that as a result of its location “only about 121 miles from Las Vegas, the community must meet the 10

- enplanement

- a

- day threshold for EAS to continue after FY2013 or otherwise face termination of its eligibility to receive EAS, barr ing a waiver from the Secretary.” 11 The Department pointed to FY2012

, during which Kingma n generated 2,063 passengers ( average of 3 enplanements per day ) which is below the level ne eded to maint ain EAS eligibility

. The Department also noted that it “is prohibited from subsidizing air service at a community where the subsidy per passenger exceeds $200, unless the community is more than 210 highway miles from the nearest large or medium hub airport. Kingman’s subsidy per passenger is $566, well above t

he $200 ceiling.”

I nstead of terminating Kingman’s EAS eligibility , the Department solicit ed proposals that it will evaluate prior to comm itting to a two

- year contract or making a final determination regarding Kingman’s continued eligibility for EAS. In Order 2013

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- 8, the Department established the expectation that carriers “ detail in their proposals how they will work with the community in getting the subsidy p er passenger under the $200 cap” and that proposals “ provide a discussion on how they would attract enough passengers to meet the 10 enplanements per day statutory requirement in order for Kingman to remain eligible to continue receiving EAS after FY2013.

In response, SeaPort provides the following detail s of how we plan to bring subsidy levels at Kingman below $200 per passenger and increase traffic to meet statutory requirement of 10 enplanements per day:

 SeaPort’s service proposal at Kingman offers 18 weekly departures to Phoenix on a one

stop basis via with Prescott, with a well

- balan ced c hoice of departure times intended to improve access to the national air transportation system

.

 SeaPort’s 18 weekly departures represent a 38% increase over the 13 weekly departures that Great Lakes presently operat es to Los Angeles

.

 Focusing flights at Phoenix acknowledges the city’s role as the state capitol and major center of banking, medical, and legal activity , as well as for entertainment and cultural activities. The current service pattern to Los Angeles leaves this demand unmet.

 SeaPort ’s fares b etween Kingman and Phoenix will average $79.88 , with a range of $59 to $139

. These price points should provide sufficient motivation to residents and businesses in Kingman to show their support for local air service with the purchase of tickets . The fares are

11 Recent legislative amendments to EAS program require that each community receiving EAS subsidized flights maintain an average of 10 enplanements or more per service day during the most recent fiscal year. There are exemptions for commun ities in Alaska and Hawaii, as well as in the Lower 48 for communities more than 175 driving miles from the nearest large or medium hub airport. Additionally, the Secretary has the authority to waive the 10 passenger requirement, if a community can demonst rate that the reason passengers per day is less than 10 passengers is due to temporary market conditions. See 49 U.S.C. §41731(e)

.OST

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February 15 , 2013 Page | 20 not so low that they have the unintended consequence of holding subsidy levels above $200
per passenger.

 The pairing of Kingman with Prescott to provide one

- stop service to Phoenix allows EAS to be maintain ed at a lower level of required subsidy than would be required if nonstop service were offered. 12

 Recognizing the currently low enplanement levels generated at Kingman , SeaPort plans to implement an advertising and public relations strategy proven to be effective in rebuilding traffic at other EAS communities , such as at Jackson, TN and Athens, GA where it has fal len on SeaPort, to rebuild traffic after the previous carrier deci mated enplanement levels with poor service . Many of the se marketing and PR tactics were ou tlined earlier in this filing, including the importance of deve loping a partnership with each EAS community that results in a shared commitment to achieving specific service and enplanement levels to ensure continued eligibility for EAS.

While the above summary is responsive to DOTs request for explanation of how SeaPort intends to achieve an average of 10 enplanements per day and per passenger subsidy levels below $2 00

, we anticipate our experience at Kingman will mirror our e xperiences at other EAS communities . Simply put, i t will be a process and not an event. With this as a basis, SeaPort expects that :

 Kingman should generate an average of 7 daily enplanements by the end of the first year o f a two

- year contract. While this is more than double the current 3 daily enplanements that occur at Kingman , it is below the 10 daily enplanement average required to maintain the community’s EAS eligibility

. Nonetheless, in the second year SeaPort anticipates positive enplanement growth to continue, driven by greater brand awareness, positive “word of mouth” buzz as customers share their positive experiences, and enhanced connectivity as additional interline agreement s that inclu de e

- ticketin g and through b aggage check

- in are implemented, resulting in our achieving 10 enplanements per day.

 SeaPort ’s subsidy request at Kingman approximate s $2 38 per passenger which, while substantially below t he $566 per passenger subsidy currently paid

, remains above the $200 ceiling. 13 As with daily enplanements, SeaPort expects continued growth during the second year of service that will result in Kingman satisfying all metrics use d to determine a community’s continued eligibility for EAS.

Show Low

With respect to Show Low , the Department again note d that it is “ prohibited from subsidizing air service at a community where the subsidy per passenger exceeds $200, unless the community is more than 210 highway miles from the nearest large or medium hub airport. Show Low is 154 miles from Phoenix and based on FY2012 data (October 1, 2011, through September 30, 2012), 8,360 passengers were enplaned and deplaned at Show Low. The annual subsidy amount for Show Low is $1,719,058. Therefore , the subsidy per passenger at Show Low is $206, just over the subsidy per passenger ceiling. ”

12 Ideally, this should be viewed as interim service pattern with the long

- term objective being building traffic to a level th at allows for either all nonstop service or combination of one

- stop and nonstop service at subsidy levels that are compliant with statutory limits and minimums required for continued participation in the EAS program.

13 Subsidy would be $215 per passenger assuming operations with piston

- twin aircraft.OST

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February 15 , 2013 Page | 21 Similar to Kingman, the Department included in Order 2013

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- 8 a request for EAS proposals at Show Low rather than terminate the community’s participation in th e program . The Department states that it will evaluate the proposals before deciding whether it will commit to a two year contract

or make a final determination with respect to Show Low’s EAS eligibility and, again similar to Kingman, reques ts that carriers explain how they intend to reach per passenger subsidy levels below the $200 ceiling

. In response to that request , SeaPort states that a strategy of higher frequencies and service focused at Phoenix ( both for the purpose of connecti vity with the national air transportation system and business travel to /from Phoenix ) will contribute to reasonable enplanement growth at Show Low

. This improved service pattern will be supported with many of the same marketing and PR strategies proven effecti ve in other EAS markets served by SeaPort, and as outlined earlier in this filing.

Based on t he improved service pattern supported with proven marketing tactics , SeaPort projects it will carry 10,617 passengers annually between Show Low and Phoenix, a 27% improvement over the 8,360 passengers carried in the YE 2Q2012 . Assuming an average fare of $74.99 , SeaPort is requesting annual subsidy at Show Low of $2,107,694 . This equates to $199 per passenger , just below the $200 ceiling, with the expectation of lower subsidy amounts in s ubsequent contract periods

. 14

Illustrative Flight Schedule s

I llustrative flight schedule s for each of the four Arizona communities are provided below

. If selected to provide EAS, SeaPort Airlines will solicit community comment on proposed schedules and, as much as practical, incorporate these comments into final schedule s which are published and offered for sale to the public.

Note that with the exception of Kingman , which is tied to Prescott, schedules for each community are presented on a standalone basis reflecting the standalone basis of our proposal to provide EAS at Kingman, Page, Prescott, and Show Low. In addition, an alternative schedule for Prescott is provided which would only be a valid option if SeaPort is not sele cted to provide EAS at Kingman. 15 Finally, for Page we have provided schedules that reflect an adjustment in frequency of 18 weekly roundtrips during the off

- peak seasons (38 weeks each year) to 32 weekly roundtrip during the peak tourism season (14 weeks e ach year).

The s chedules below assume operations with Cessna Caravans but are indicative of those that would be offered if selected to provide EAS with piston

- twins. 16 Block times to Page and Show Low would be marginally short er if flown wi th piston

- twins, and negligibly different on the Phoenix

Prescott

- Kingman routing.

We believe the schedule outlined for each community represent s a solid approach to provi ding of EAS through focused connectivity with the national air transportation system, capitalizing on potential local market demand to drive increased enplanements, and optimizing the benefits of greater frequencies with a well

- balanced choice of departure times

.

14 Subsidy would be $191 per passenger assuming operations with piston

- twin aircraft.

15 There is a service propos al and subsidy request in the next section for the same con tingency.

16 Subsidy requests specific to operations using piston

- twins are provided in the next section.OST

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February 15 , 2013 Page | 22OST

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February 15 , 2013 Page | 23 .OST

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February 15 , 2013 Page | 24 

# Subsidy Request & Supporting Calculations

The following pages contain service proposal s of SeaPort to provide EAS at the Arizona communities of Kingman, Page, Prescott, and Show Low, and include data to support the reques ted subsidy levels. Specifically:

 With the exception of Kingman tied to Pres cott each proposal is submitted on a standalone basis.

 An alternative proposal for Prescott is provided which allows for the selection of SeaPort in that community independent of selection at Kingman. However, as above bullet point indicates, service to K ingman is contingent on SeaPort being selected to provide service both there and at Prescott.

 For each community, we are offering a single service pattern. However, each service pattern has two proposals: one that assumes operations with the Cessna Carav an and one that assumes operations using piston

- twin aircraft (either Piper Chieftain or Cessna 402C). If a community recommends to the Department that SeaPort be selected to provide EAS, we respectfully request that the recommendation include aircraft typ e.

 While proposals are being submitted on a standalone basis, if selected to provide EAS at all four of the Arizona communities using the same type of aircraft, SeaPort will realize economic efficiencies which would result in a lower total subsidy request . A contingent subsidy request for this scenario is also provided herein.

We believe the service proposal s provide each of the Arizona communities the assurance of reliable, affordable, and customer

- focused air service , and look forward to partnering wi th the Department and community leaders in Kingman, Page, Prescott and Show Low to see that become a reality.

Respectfully submitted,

Timothy Sieber Vice President

– Commercial SeaPort Airlines, Inc.OST

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February 15 , 2013 Page | 26OST

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February 15 , 2013 Page | 27OST

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February 15 , 2013 Page | 28OST

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February 15 , 2013 Page | 29OST

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February 15 , 2013 Page | 30OST

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February 15 , 2013 Page | 31OST

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February 15 , 2013 Page | 32OST

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February 15 , 2013 Page | 33OST

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February 15 , 2013 Page | 34