U.S. Department of 

Transportation 

Office of the Secretary 

Of Transportation 

January 31,2013 

Malcolm L. Benge 

1200 New Jersey Ave., 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-

0 181, Applications of Gama Charters, Inc., for 

certificates of public convenience and necessity under 49 

U.S.C. § 41102 to engage in interstate and foreign 

charter air transportation 

We have completed our review of the applications filed by Gama Charters, Inc. ("Gama"). 

Based on our initial review of this 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 of its pre-operating costs (i.e., all of the costs 

incuned prior to the actual commencement of flight operations) plus the operating expenses that 

are reasonably projected to be incurred by the applicant during three months of ''normal" 

operations. 1 In addition, if the 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 of funds that the applicant must have available to meet the 

financial fitness criteria for the proposed operations. 

Information Gama provided in support of its 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 of operations do not include all costs that will be 

incurred during a "nonnal'' or average period of operations, the three-month standard is calculated by dividing the 

applicant's estimated total first year operating expenses by four. 
2 

notes in its application that is has available cash of $276,000, this will not be enough to offset its 

negative working capital balance or to meet our financial fitness criteria. 

Therefore, in light of the above, it does not appear that Gama has 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 

verification within this time period 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 of this 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, or ownership) while its application is under review by the Department. 

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 Katy O'Toole of my staff me at 

(202) 366-9721. 

Damon D. Walker 

Acting Chief, Air Carrier Fitness Division 

Office of Aviation Analysis 

cc: Docket DOT-OST~2012-0180 and 

DOT-OST-2012-0181 

Beth Babb, Manager 

FAA FSDO #63 

Bradley International Airpmi 

Windsor Locks, CT 06096