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## Great lakes Airlines to Suspend Air Service at Devils lake and Jamestown, North Dakota; Fort Dodge and Mason City, Iowa; Ironwood, Michigan; and Thief River Falls, Minnesota. CHEYENNE, Wyo., January 27,2014 - Great Lakes Aviation, Ltd. (OTC Bulletin Board: GLUX.OB - news) Effective February 1,2014, Great Lakes Airlines will be suspending service from Devils Lake and Jamestown, ND; Fort Dodge and Mason City, IA; Ironwood, MI; and Thief River Falls, MN due to the severe industry-wide pilot shortage and its relative acute impact on Great Lakes. Charles Howell, CEO released the following statement: "Due tothe unintended consequences of the new congressionally mandated pilot regulatory requirements, the Company feels it is inthe best interest of our customers, communities, and employees to suspend service from these stations until we are able to rebuild our staff of pilots in order to provide reliable service. We deeply regret and apologize for this inconvenience." All customers with future fiights in any ofthese stations will be given refunds. Please begin your refund efforts with your initial booking source. For more background information regarding how the regulatory changes have affected Great Lakes' unique role inthe airline industry, please visit ourwebsite atwww.FlyGreatLakes.com
### Great LakesAirlines providesscheduledpassengerairservicewithafieetofEmbraerEMB-120 Brasilia's and Beechcraft 19000 regionalairliners.Acurrentroutemapmaybeviewedat: http://www.fiygreatlakes.com/route_map/Oocs/route_map.pdf Additional information isavailableonthe Companyweb sitethat maybeaccessedat www.flygreatlakes.com

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### The Honorable Michael Huerta Administrator Federal Aviation Administration 800Independence Avenue, SW Washington, DC 20591 Dear Administrator Huerta: 

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# ~cnatt WASHINGTON, DC 20510-1502 

### April 15,2013 (202) 224-3254 FAX: (202) 224-S369 TTY: 12021 22&-9810 http://harkin.senBte,gov COMMrt1'£ES: HEALTH, EDUCATION, LABOR, AND PENSIONS. CHAIR APPROPRIATIONS AGRICULTURE SMALL BUSINESS



### Iwrite to express my concemregarding theFAA's proposed 1,500flight hour requirement forco-pilots, which is scheduled totake effect inAugust 2013, because itwill likely disrupt the ability ofsmall andregional airlines toretain adequate numbers ofpilots for scheduled flights. According topeople withknowledge oftheindustry, the memes ofhours spent inclassroom instruction andinflight simulators are superior tothe flight time requirement. Iurge theFAA tomove forward with regulatious which would allow the use ofthese alternative training methodologies inlieu offlight hours. This burdeusomerequirement comes atatime when the availability ofneWpilots to small andregional airlines isincreasingly constrained bymarket factors. Rapid growth inthe global aviation sector has lured significant numbers ofU.S. pilots towork forforeign carriers. Furthermore, the supply ofnew pilots has also declined asthenumber ofpilots leaving the military has dropped inrecent years andthenumber ofnew commercial pilot certificates awarded has declined by almost 50percent inthe last20years. Enrollment inaccredited aviation and commercial flight schools has alsodeclined, perhaps partly duetothe expectation of the increased cost oftraining associated the 1,500hour flying time requirement. Oneregional airline has reported tome thatthey areexperiencing asharp drop inapplications despite offering significant signing bonuses. The supply ofnew pilots has been further restricted as aresult of new flight and duty time regulations thathave forced airlines toincrease the number of employed pilots needed tomaintain their current flight schedules. The combination ofthese factors will result inanespecially severe shortage ofpilots available toregional and smaller airlines. Larger carriers, who areable to offerbetter compensation, will recruit more pilots from regional carriers. These carriers will, inturn, ramp uptheir recruitment ofpilots from smaller carriers. There are already signs thatthis issue isbeginning tohave adeleterious impact onthe ability ofsmall carriers tomaintain service atcurrent levels. For example, Iknow ofatleast one small carrier that isstarting theprocess ofusing Part 135rules ineXpeCtationofashortage ofco111 7TH AVENUE SE, BOX 16

SUITE 480 CEDAR RAPIDS, IA 52401 (3191 365-4504 210WALNVT STREET 133 FEDERAL BUILDING DES MOINES, IA 50309 1515) 284-4574 1606BRAOY STREET SUITE 323 DAVENPORT. IA 52603 15631322-1338 350 WEST 6TH STREET 315 fEDERAL BUILDING DUBUOUE. IA 52001 15631 582-2130 320 6TH STREET 110 fEDERAL BUILDING SIOUX CITY. IA 51101 17121252-1550

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pilots resulting from Part 121 Ru1es. This process may involve capping the number of passengers atnine regardless ofthe size ofthe aircraft, anapproach the FAA will hopefully allow. Inthe case ofcarriers notreceiving Essential Air Service (EAS) subsidy, service onthese routes cou1deventually cease altogether. Forthose receiving anEAS subsidy, costs will likely increase andthe quality ofservice may decrease. While the initial impact ofthe shortage may be limited to smaller cities, asthe situation grows worse larger cities could experience major loss of service aswell. Inthe long term, we need abetter pipeline toencourage more individuals to choose the quality, high-paying jobs that acareer as apilot inthecommercial airline industry can offer. In order to accomplish this, however, Ithink itiscrucial forthe FAAto actas quickly and as broadly aspossible to mitigate theproblems that small andregional carriers will face asthe 1,500 hour requirement takes effect. Thank you for consideration ofthis matter. Ifyou have any questions regarding my request, please feel free to contact Richard ~ender onmy staff at202-224-7318 .


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Tom Harkin United States SenatorApril 8, 2013

Mr, Dale Ogden CMOManager Certificate Management Office 26805 East 68th Avenue Suite 234 Denver, Colorado 80249-6339 Mr, Ogden: In light ofthe pending regulatory changes forcrewmember qualifications and the uncertainty of any relief from the Administrator with regard to Airline Transport Pilot (ATP) certification requirements, the Company must address the pilot shortage that exists today. The supply, or lack thereof, ofqualified applicants is causing the Company to begin planning reductions incapacity tothe communities itserves, Great Lakes is essentially being forced to consider pursuing some "outside tbe box" options to maintain air service atmany points witbin the current route structure, One option wbicb the Company isconsidering is the development ofa "split operating certificate" whereby some operations would be performed under the current 121 certificate and others would be performed under a scbeduled "9 or less" 135 certificate. The Company previously utilized a split certificate from 1997 tbru June of2004 toprovide airmail and freight services inBeech 1900 aircraft. Currently all Great Lakes scheduled operations are conducted with aircraft having a seating capacity of nineteen or more passengers all of which are performed in accordance with Title 14CFR Part 121 (Part 121). An alternate method ofmaintaining community access totheNational Transportation System would be to operate aircraft having aseating capacity ofnine or less that would be conducted inaccordance with Title 14CFR Part 135 (Part 135). The operating rules for both Parts are quite, similar and in accordance with Title 14 CFR part 119.5 an operator authorized toengage incommon carriage under Part 121 and/or 135 shall be issued only one certificate regardless of tbe kind ofoperation, class, or size ofaircraft tobe operated. Atthis time Great Lakes would respectfully request theDenver Office to initiate the steps required to add aPart 135 authorization to its existing certificate. Great Lakes proposes to operate both flight operations (Part 121 and 135) with the same "highest degree of safety" and utilize common programs between the two operations making them as seamless as possible with the only visible difference being one operation would be conducted with an aircraft limited tono more than nine passengers, Great Lakes willblock ten (10) seats on its Beechcraft 19000 aircraft tobe incompliance with the nine seat limitation forscheduled 135nine orless operatioDS, With that in mind we have included a short list ofprograms with our thoughts on their applicability to a Part 135 Operation, This list is meant to initiate a discussion between our offices and should not be considered complete. We look forward toyour comments. 

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Tory A. Meisel Director ofOperations Enclosure: Programs and Manuals

### Pilot safety rules could cut flights -Jan. 9, 

### 2014 

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# Pilot safety rulescould cutflights By Chrts tsidore @CNNMoney J8r'lU8ry9, 2014: 10;01 AM ET

New rules to give pilots more rest could mean there aren't enough pilots to fly the regional jets that are used on about half ofthe nation's flights. 

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NEW YORK (CNNMoney) 

### New safety rules that played apart inJetBlue Airways' epic meltdown this week could further stretch the industry's supply of pilots, and cause problems at local airports nationwide. That's because busy regional airlines, which carry abig chunk of all U.S.passengers, are particularly vulnerable to the same rules that felled JetBlue ( JBLU, Fortune 500). At issue isan FAA policy that went into effect on Saturday requiring more rest for pilots. Experts saythe rules will mean more flight cancellations inbadweather, since weather-related delays will eat upthe fixed number of hours that pilots areallowed to beon duty. More downtime will alsoexacerbate anexisting shortage of pilots, which could eventually cost some cities service altogether. Many major airlines are not really affected bythe rules becausetheir union contracts already require similar rest periods for pilots. But JetBlue's pilots are not inthe union, sothe carrier hadto make adjustments when badweather backed upflights. And many regional carriers might have to follow suit. While many ofthem are unionized, their pilots don't have the same strong contracts asthose atthe major carriers. Sothey too will have to start giving pilots bigger breaks.

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### Pilot safety rules could cutflights

-Jan. 9,2014 Page 3of3 Darby said it's too soon to saywhich cities are at risk of losing air service altogether. He believes eventually the airlines will have to decide which cities are no longer profitable enough to justify using the limited supply of pilots. "It's not something that typically happens the day the rule takes effect," hesaid. "But itwill happen when the regionals run out of pilots." •

First Published:January 9.2014: 9:58AM ETUS Senate - Committee on Commerce, Science and Transportation Great Lakes Aviation - Pilot Shortage background material - 12-11-13 On April 8th of this year, Great Lakes submitted awritten proposal to the FAA which would enable Great Lakes to operate Beechcraft 1900-D aircraft limiting the number of passengers carried to nine passengers under FAR 135 (see attached letter to the FAA). Our proposal was then specifically targeted to provide Essential Air Service at the Minneapolis/St. Paul (MSP) hub whereby all segments ofthe operation would remain in compiiance with FAR 121 operational standards with the exception being our need to be able to use FAR 135 piiot hiring standards. This proposal would enable Great Lakes to access to a highly qualified, well trained pool of pilots that do not possess the 1,500 hour Airline Transport Pilot FAR 121 credentials. A pool of Pilots that the company has historically had over 32 years of access to. In July of this year, Great Lakes met with representatives of all the EAS communities served by Great Lakes into its MSP hub. The meeting served as a multi-faceted communication forum addressing the unintended consequences of the implementation of the 1,500 hour ATP rule. At the time of the meeting, the FAA had yet to release the long anticipated exemption rules that were to be set to facilitate exceptions to the 1,500 hour ATP rule. Great Lakes had been confronting asharp reduction in its eligible pilot hiring pool availability that was a byproduct effective ofthe August 1, 2013 1500 hourATP rule implementation date. In anticipation ofthe new rule, inthe fall of 2012, the company had hired a significant number of pilots that became qualified under our then current FAR part 121 training process. 

### Itwas believed then that these Pilots would have received enough flight time experience to become eligible to fly beyond August 1" under the anticipated new exemption rules. The FAA released the exemption rules two days after this community meeting. Unfortunately, the design of the exemption rule procedures did notfacilitate for all pilots on staff to be eligible to fly on August 1'I. The delay inthe release ofthe rules and the corresponding certification process postponed completion of recertification for many pilots that had been flying for the airline under Part 121 for many months in advance of the August 1" transition date. No grandfathering relief for on staff FAR 121 pilots was granted bythe FAA. These events forced Great Lakes to remove asignificant amount of capacity from its system inthe early days ofAugust. The company had substantially over staffed its pilot requirements prior tothe rule change and still came up short on the transition date. As the airline industry transitioned through the August 1" 1,500 ATP rule change, the industry refocused on preparing for the FAR part 117 flight duty time rule change to be implemented on January 4,2014. Due to the lack of qualified pilots outside ofthe existing FAR part 121 air carrier staffing levels, Great Lakes pilots became immediate targets for aggressive hiring by other regional and major air carriers. Pilot attrition rates have exceeded new hire piiot recruiting capabilities by more than 20 fold. The attrition rates have resulted in aggressive near term capacity reductions that have been and will continue to be required to be made bythe company. Further planned system wide schedule reductions have now placed Great Lakes in a position whereby it is being forced to reduce EAS flying below traditional EAS community capacity expectations.

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The new regulatory requirements imposed on all FAR Part 121 air carriers regarding pilot training and

hiring eligibility requirements have dramatically accelerated a pilot shortage crisis that the airline industry has anticipated and has been allempting to address for several years. Capacity reductions following the events of September 11, 2001 had reduced pilot staffing demands in subsequent years, but the effects ofthis reduction in capacity has run its course relative to currently available qualified pilots. In the three years since the congressionally mandated hiring standards were established an inadequate numbers of pilots have been building the experience and skills necessary to meet the industry's future needs. Single pilot certified FAR part 135 operators are not required to staff copilots and hence do not provide the Industry a meaningful progression of pilot development out ofcollegiate accredited pilot training programs. The pilot has been left on his own to find the necessary additional 500 to 1,000 hours of flight experience that facilitates eligibility into the airline industry. Purchasing the additional time flying around the airport pallem in Cessna 150's does very lillie to advance safety standards inthe airline industry. The traditional pipeline of FAR part 121 nineteen seat turboprop aircraft operators' virtually no longer exists. We find it interesting that the NTSB is now focusing on hand flying skills while the regulatory environment has eliminated were these skills had historically been developed. FAR part 135 single pilot Instrument Flight Rule operations require the use ofan autopilot since no copilot is required and hence does nothing to assist in growing pilot hand flying experience levels within the industry. Most former operators of FAR part 121 nineteen seat aircraft recognized years ago that the pilot pool competing with regional jet equipment would not facilitate pilot retention under the same hiring standards. Congress must recognize that the unintended consequences of the new congressionally mandated hiring standards has been the virtual elimination ofthe traditional pilot career path. The combination of pilot allrition in past years and the new pilot hiring standards which established a 1500 hour experience standard along with Airline Transport Pilot Certification (ATP) for all FAR Part 121 operations has created a"perfect storm" within the airline industry relative to the availability of qualified pilots operating within a FAR Part 121 environment. Throughout the course ofthe last three years the company has repeatedly communicated with US DOT expressing our concern regarding our ability going forward to cover all EAS flying post implementation of the new rules. Our greatest fears have become realized. The pilot shortage threatens future EAS community eligibility by reducing enplanements as measured against time. As we pull down schedules seat capacity falls below traditional availability levels producing enplanement numbers that will trigger EAS eligibility reviews and subsequent removals from the program. The reduced enplanementlevels will also threaten Airport Improvement Program grants and entitlements. Communities will need waivers by Congress in order to maintain historical levels of Airport infrastructure investment support. This is not just a Great Lakes problem, our EAS capacity happens to be were the effects of the unintended consequences will be first seen. The cry for help from the Airline Industry regarding the pilot shortage is not being heard.1. Industry wide Pilot shortage exists today an~ crisis will dramatically be become more evident soon

a. 1500 hour/ATP (Airline Transport Pilot Rating) rule will significantly lamage Small Community Air Service Nationwide I. Will there be exemptions? il. Ifso, what will they be? 1. Knowing the exemptions allows Great Lakesto begin planning astrategy b. Number of student pilots registered with FAAhasdramatically decreased over the years and the 1500 rule will further exacerbate Airline Industry Pilot supply crisis. I. Typical student graduates 4year college with 350-400 hours - now they will have to more than double that amount prior to being hired bya Part 121 carrier 1. Cost-prohibitive for student 2. Credit /student loans not available for students to payfor increased number of hours required c. Great Lakestypically retains approximately 280 pilots on staff - losing significant percentage due to:

I. Higher than normal attrition rates in last 30 days- unpredictable going forward ii. Approximately 20 pilots with total hours of 1400+ (but lessthan 1500 hrs) on August 1, 2013 will be lost due to new 1500 hour rule and lackof exemption relief 2. Part 135 operations - 9seats or less

a. Great Lakes had requested a Part 135 certification in addition to their 121 cert - exhibits -April 8, 2013 Letter to FAAand June 18th response from FAA i. Part 135 allows Great Lakesto employ pilots (First Officers) with lessthan 1500 hours 1. Would operate in Minneapolis hub while first officers increase their time to 1500 hours in order to move into Part 121 operation b. Great Lakes needs the ability to block seats asopposed to removing seats

I. Great Lakeswas denied their request to block seats by Denver FAA ii. Removing seats impedes our ability to rotate aircraft between our MSPand DENoperations 3. Great Lakeswill not have enough pilots to staff Minneapolis operation

a. Reduction in flight schedules inthe Minneapolis hub will be required soon

i. Change of flighttimes ii. Discontinue flights that are above & beyond EA5contract iiI. Issue of survival for EAScommunities who already struggle to maintain their presence in the National Transportation System 

## In Summary: 

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# = Noservice These two issues need immediate attention of Congressional members.
• Need immediate administrative response by FAAasto what the exemptions to the 1500hr /ATP rule will be?
• Need the FAAto allow seat blocking (down to nine seats) versus removing 10 seats from the plane thus not allowing for aseamless pooling / swapping of aircraft for maintenance and reliabilityApproved and Accepted Programs and Manuals:

• Flight Operations Manual -GLA would propose toissue asecond FOM oraPart 135FOM
• Inflight Services Manual-Not applicable as only Beecb 1900's would be utilized
• Station Operations Manual-Potential updates fordifferences inoperations and seating capacity
• Dispatcb Procedures Manual-Appropriate cbanges as tbey would pertain toflight following and services provided to the 135operations
• CrewmemberlDispatcher Training Manual-Training appropriate to 135regulations and any differences in tbe operation. Systems would remain uncbanged and flight training would remain by inlarge unchanged with different regulatory references. Separate section for 135training but this would primarily be regulatory references onthetraining forms. Maneuvers and requirements are essentially the same. • General Maintenance Manual-No appreciable changes planned. Aircraft would be maintained under one CAMP
• Aircraft Fueling Manual-regulatory references added, but no appreciable cbanges
• Emergency Response Manual -No changes required
• Aircraft Inspection Manual-potential regulatory references but no appreciable changes, See GMM
• Safety Program -No appreciable changes
• Internal Evaluation Program -No appreciable cbanges
• 1900 Flight Standards Manual-No appreciable changes operations should beconducted utilizing the same SOP forboth types ofoperations
• E120Flight Standards Manual -Not applicable, EI20 operations would be conducted inaccordance witb Part 121
• Manager's Manual forOperations -Applicable 135references and minor changes with the operating 

### certificate.

• Dangerous Goods/Hazardous Materials Manual- No appreciable cbanges
• EI20 MEL-No changes
• Ground Deicing Manual-no appreciable changes, regulatory references to include 135
• Aircraft Weight and Balance -no appreciable cbanges, regulatory references to include 135
• No Carry-on Baggage Program Manual-no appreciable cbanges, regulatory references to ioclude 135
• 1900 MEL -Changes asapplicable for 135operations perMMEL
• Exit Row Seating Program Manual -no appreciable cbanges, regulatory references to include 135
• Maintenance Control Procedures Manual-no appreciable changes, regulatory references
• Crew Scheduling Manual-No appreciable changes, duty and rest requirements are currently bandIed under Part 135per Ops Spec A033, 121.470(b), 121.480(a), and 121.500(a).
• Documents Department Mauual-No appreciable changes, regulatory references and checkride references, however little cbange tothe Training isanticipated
• Aircraft Records Department Manual-Unchanged inpractice. Aircraft will be maintained under one program.
• Aviation Safety Action Program Manual-no appreciable changes anticipated.
• Cargo Services Manual-no appreciable changes anticipated.
• EWINS Manual-No appreciable changes required.
• 1900 APG Manual-takeoff and landing data/performance should be able toutilize thePart 12Istandards which are very similar to the 135standards. -regulatory references may have tobe modified.
• E120 APG Manual -Not Applicable.