U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, DC 20590 

RE: Request for Expedited Treatment of Exemption Request in Docket FAA-2015-4903 

Dear Secretary Chao, 

Congratulations on your appointment as Secretary of Transportation. I join millions of Americans who are 

excited about the prospect of the U.S. Government's renewed commitment to regulatory relief and to fostering 

better economic conditions that will create jobs and allow companies to thrive. 

Great Lakes is a 35 year old regional airline that operates under 14 CFR Part 121 regulations and provides 

scheduled passenger and charter services with a fleet of six Embraer EMB 120 Brasilia' and 28 Beechcraft 1900-

D aircraft. The company has long been an important DOT partner by having provided small community Essential 

Air Service (EAS) throughout the Midwest and Western United States since 1985. 

We are headquartered in Cheyenne, Wyoming and currently have a meaningful presence at three national 

transportation system hubs. We have been utilizing Denver as a hub since 1991, Phoenix since 1993 and Los 

Angeles since 2008. 

Our airline, since inception, has focused on developing and maintaining interline relationships with various large 

U.S. network airlines by providing convenient passenger and baggage interline connectivity. The interline 

products in recent years have all transitioned to electronic processing (£-ticketing with American, Delta and 

United). The company has for 25 years also been providing United codeshare connectivity to small communities. 

As you are likely aware, in August of 2013, Flight Officer Qualification (FOQ) regulations took affect that 

required FAR Part 121 First Officers to have a minimum of 1500 hours of flight time (a six fold increase above 

the previous requirement) and hold an Airline Transport Pilot (ATP) certificate. 

With the inclusion of 19 and 30 seat turbo prop aircraft that traditionally served EAS and short haul markets these 

new regulations have produced many damaging unintended consequences for small community air service. A 

regulatory system that had historically allowed Great Lakes to safely and successfully operate for three decades 

was upended. The new regulations, along with rapidly accelerating mandatory pilot retirements, are contributing 

to a severe airline industry pilot shortage. The initial2013 ripple effects on the regional airline industry is about to 

tum into a tsunami on the entire airline industry. 

Since the regulations took effect in August of 2013, Great Lakes' has been forced to reduce and discontinue air 

service to more than 30 communities; all due to pilot shortage. The company had a well established 30 year 

history of providing reliable Essential Air Service that exceeded congressionally mandated service statutes. 

As a creative pilot supply solution, Great Lakes removed 10 seats from most of its 19-seat Beechcraft 1900 fleet. 

The nine seat aircraft are then operated under FAR Part 121 regulations with part 135 flight crew qualifications 

enabled through an Operations Specification approval that the company received from the FAA in March of2014. 

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Great Lakes pilot training program that is viewed by major carriers to be among the best in the industry. 

As you can imagine, arbitrarily removing more than 50% of the seat capacity in our 19 seat aircraft greatly 

impacted our ability to generate enplanements for the communities we were serving. Maintaining EAS eligibility 

for the communities requires minimum levels of passenger usage to remain in the program. 

The communities historically participating in the EAS program have been seeing explosive increases in subsidy 

requirements while also, in many cases, being asked by DOT to waive their statutory right to twin engine aircraft 

piloted by a two pilot crew. DOT has, since the onset of the regulatory change that generated the nationwide pilot 

shortage, been effectively forced to grant waivers of EAS subsidy caps in order to sustain some level of service to 

these communities. This regulatory consequence has been a major contradiction to congressional intent of the 

FOQ statutes. 

On October 9, 2015, Great Lakes filed a petition for an exemption with the F AA. 1 The exemption would allow us 

to operate our existing fleet of 28 Beech 1900 turboprop aircraft in the FAA certified 19 seat configuration. The 

petition documents why an exemption grant is in the public interest and not only facilitates an equivalent level of 

safety but will provide small communities the opportunity to remain in the nation's air transportation network. 

The FAA published our exemption request in the Federal Register for public comment on December 9, 2015. 

Great Lakes' petition request was extensively documented and received tremendous support from elected city, 

state and federal government representatives. 

I write now to urgently request expedited treatment of the exemption and to ask that the FAA issue a decision 

supporting our request. The FAA has complied with all procedural due process requirements and there is no 

reason for continued delay in reaching a decision. Our request has been pending with the FAA for over 16 

months and is overdue for an affirmative response. 

Great Lakes' looks forward to continuing to assist the airline industry in redeveloping a professional pilot career 

path. Removing the arbitrary regulatory and financial barriers that have severed the pathway for the energetic 

youth of this great country in order to find a rewarding aviation opportunity, is passion we both can share. 

Sincerely, 

Douglas G. Voss 

Chief Executive Officer 

1 See Docket FAA-2015-4903. 

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