# GREAT LAKES AVIATION, LTD February 14,2017 The Honorable Elaine Chao Secretary ofTransportation 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. qreat £aR/s **~viation,** £'ltD.

• 1022 )f.irport IPfory.

• Cfieyenne, WY 82001This nearly three year old Operations Specification has allowed Great Lakes to hire well trained young commercial pilots and maintain

a pilot experience pathway that had served the industry well for many decades. The Operation Specification
has also produced
an originally unanticipated and previously untapped pilot supply. Pi lots over the age of 65 who were forced to retire from the major carrier jet jobs, but are proficient and easily capable of maintaining First Class medical status, are proving to be a great source of Captains, Pilot Training Instructors and line qualified management personnel for our Beech 1900

' s. Great Lakes believes that
a healthy passionate pilot over the age of 65 is just as qualified

in a 19 or 30 seat aircraft as he or she is in a nine seat Beech 1900. The pilot mentoring benefits are proving to be a terrific addition
to a 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. (}reat **£a~s** }f:viation

, £'1fD

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• Cfteyenne

, WY 8 2 001