U.S. Department of Transportation Office ofthe Secretary OfTransportation
January 31,2013 Malcolm L. Benge 1200 NewJerseyAve., S.E. Washington, DC 20590

Zuckert, Scoutt& Rasenberger, L.L.P. 888 Seventeenth Street,N.W., Suite 600 Washington, DC 20006-3939

Dear Mr. Benge: Re: Dockets DOT-OST-2012-0180 and DOT-OST-2012- 0181, Applications of Gama Charters, Inc., for certificates ofpublic convenience and necessity under 49 U.S.C. § 41102 to engage in interstate and foreign charter airtransportation

We have completed our review of the applications filed by Gama Charters, Inc. ("Gama"). Based on our initial review ofthis information it appears that Gama does not have access to suff:J.cient funds to meet our financial fitness criteria. As you may know, the Department generally ask that new entrant applicants have access to resources sufficient to cover all pre-operating all ofits pre-operating costs (i.e., all ofthe costs incuned priorto the actual commencement offlight operations) plus the operating expenses that are reasonably projected to be incurred by the applicant during three months of ''normal" operations. 1 In addition, ifthe applicant's most recent balance sheet shows a negative working capital balance for any ongoing operations (e.g., air taxi, aircraft leasing, or fixed base operations), the amotmt of that working capital deficit will be considered a pre-operating expense·in calculating the amount offunds that the applicant must have available to meet the financial fitness criteriaforthe proposedoperations. Information Gama provided in support ofits application for certificate authority indicates that the air carrier expects pre-operating and first-year operating expenses of $75,000 and $5.52 million, respectively. In addition, the air carrier's most recent balance sheet dated June 30, 2012, indicates that the air carrier has a negative working capital balance of $242,416. Therefore to meet our financial fitness criteria, Gama would need to provide evidence that it has access to approximately $1.69 million, which is one-quarter of the applicant's t1rst-year operating expenses, plus pre-operating expenses and negative working capital. While Gama

Because projected expenses during the first several months ofoperations do not include all costs that will be incurred during a "nonnal'' or average period ofoperations, the three-month standard is calculated by dividing the applicant's estimated total first year operatingexpensesby four.2

notes in its applicationthat is has available cash of$276,000, this will notbe enough to offsetits negative working capital balance orto meet ourfinancial fitness criteria. Therefore, in light ofthe above, it does not appear that Gamahas access to funding sufficient to meet the Depatiment's financial fitness requirements. However, we will provide Gama with an additional 30 days to supplement the record with information evidencing that it has access to funds sufficient to meet our financial fitness criteria. If Gama is unable to provide such verificationwithin this timeperiod we intend to dismiss its application for material deficiency. As is the Depmtment's practice. further processing of Gama's application will be deferred pending receipt ofthis information. In addition. please remember that Gama should promptly provide the Department with any information regarding changes it may tmdergo in areas affecting its fitness (i.e., management, operating plans or financial condition, compliance disposition, orownership) while its application is underreviewbythe Department. Thankyou for your cooperation inthis matter. Ifyouhave any questionsregardingthis letter or the requested information, please feel free to contact Katy O'Toole of my staff me at (202) 366-9721.

Damon D. Walker Acting Chief, Air CarrierFitnessDivision Office ofAviationAnalysis

cc: Docket**DOT-OST~2012-0180** and DOT-OST-2012-0181 Beth Babb, Manager FAAFSDO #63 Bradley InternationalAirpmi WindsorLocks, CT 06096