April 17 , 2014

Kevin Schlemmer Office of Aviation Analysis US Department of Transportation 1200 New Jersey Avenue SE Washington, DC 20590

RE: EAS at Altoona, PA (“AOO”) Docket DOT

- OST

- 2002

- 11446 EAS at Johnstown, PA (“JST”) Docket DOT

- OST

- 2002

- 11451 EAS at Greenbrier/White Sulphur Springs, WV (“LWB”) Docket DOT

- OST

- 2003

- 15553 EAS at Beckley, WV (“BKW”) Docket DOT

- OST

- 1997

- 2761 EAS at Clarksburg/Fairmont, WV ( “CKB”) Docket DOT

- OST

- 2005

- 20736 EAS at Morgantown, WV (“MGW”) Docket DOT

- OST

- 2005

- 20735 EAS at Staunton, VA (“SHD”) Docket DOT

- OST

- 2002

- 11378

EAS at Du B ois, PA (“DUJ”) Docket DOT

- OST

- 2004

- 17617 EAS at Parkersburg, WV / Marietta, OH (“PKB”) Docket DOT

- OST

- 2005

- 20734

Dear Mr. Schlemmer:

Silver Airways is pleased to provide to the Department of Transportation our response to the Request for Proposals for Essential Air Service to the nine communities listed above. Our proposal is designed to be a single, comprehensive response which we believe will best meet the needs of each community and the Department of Transpor ta tion

. We believe we meet all regulations and guidelin es issued by the department with our response.

Silver Airways proposes to maintain service at all nine cities with service operated in cooperation with
United Airlines from our hub at Dulles International Airport (“IAD”) in Washington, D.C. on board 34

- seat Saab 340 B plus aircraft. Flight frequency levels at six of the nine communities would remain similar to the levels Silver has provided since August 1, 2012. The growing Du B ois, PA and Parkersburg, WV/Marietta, OH markets would see significant improvements to service levels, as flights would be
shifted from Cleveland to Washington (Dulles) and operated with larger aircraft featuring more customer appeal. We propose to reduce Altoona from three peak

- day r oundtrips to two in response to the Department’s concerns over traffic levels and the amount of subsidy per passenger. We propose to continue our pattern of operating one

- stop flights to maximize frequency and access to the hub for each community. We pro pose an annual subsidy of $2 3

, 610

, 300 in order to provide service to all nine cities.We believe the Silver Airways bid will be superior to others the Department may receive for several

reasons:

 Access to a global network

o In order to maximize the effecti veness of air service, i t is very important to provide access to a large airline hub. As such, Silver Airways intends to connect these nine
communities to United’ s Dulles hub, which has over 2 50 daily departures to over 1 0 0
destinations worldwide.

 Frequency and Schedule

o By combining flights of neighboring communities, we believe Silver Airways can offer
the best combination of frequency and departure times from each community. We
believe we can offer more frequency through this method, which increases the utility of our flights to the passen gers and communities we serve.

 Saab SF 340 B

plus

o Our Saab 340 B plus aircraft offer a superior passenger experience, strong economics, and outstanding safety. There are several passenger friendly amenities onboard Silver’s proposed flights, including a lav atory, flight attendant, beverage service, and cabin noise reduction system.

 Washington, DC

o The nine communities within this proposal have strong ties to the capital region. For example, the FBI’s National Crime Information Center is located near Clarksburg and the Treasury Department’s Bureau of the Public Debt has operations in Parkersburg. Additionally, the Metro Silver line , once completed, will enhance the ability for passengers to use Dulles International Airport as their gateway to Washington.

For the reasons outlined above, we believe that Silver Airways’ proposal to continue providing Essential Air Service to Altoona, Johnstown, Greenb rier/White Sulphur Springs, Beckley, Clarksburg/Fairmont, Morgantown, Staunton, Du B ois, and Parkersburg will be the best proposal for each community. We look forward to continuing to work with each community on ensuring its air service needs are met
throu gh the Essential Air Service program.

Sincerely,

Travis Christ
Chief Commercial Officer Silver AirwaysApril 17 , 2014 Silver Airways Essential Air Service Propos al Page | 3

The terms associated with our proposal are below. 

# Proposal TermsApril 17 , 2014 Silver Airways Essential Air Service Propos al Page | 4

Below, we have summarized our proposal for each community. Additional details can be found in the appendices on pages 11

– 14

. 

# Proposal Summary by CityApril 17 , 2014 Silver Airways Essential Air Service Propos al Page | 5

The proposed schedule is outlined below. It is subject to change. 

# Proposed ScheduleApril 17 , 2014 Silver Airways Essential Air Service Propos al Page | 6

Silver Airways Corporation (IATA: 3M) is a U.S. owned and operated regional airline based in Fort Lauderdale, Florida, operating approximately 150 daily scheduled flights throughout the eastern United
States and The Bahamas

. Offering more flights within Florida and to T he Bahamas than any other U.S. airline, Silver also provides global access to passengers by operating in cooperation with United Airlines
from Wa shington (Dulles) and partnering with the world ’s largest network carriers through interline e

ticketing agreements

. The Silver fleet is largely comprised of Saab 340B Plus turboprop aircraft , as well

as Be echcraft 1900D aircraft in the Cleveland network.

Silver is a 2013 two

- time award winner, having been recognized in February 2013 as the recipient of Air Transport World’s (ATW) 2013 Regi onal Airline of the Year Award

– the first U.S. airline to win regional
aviation’s to p honor since 2008. In October 2013, Silver was named one of the Top 10 “Best U.S. Airlines” in the prestigious Condé Nast Traveler’s 26th annual 2013 Readers’ Choice Awards.

Focus Cities Atlanta, Cleveland, Fort Lauderdale, Washington, DC (Dulles)

Code Share Partner United Airlines

Interline E

- Ticketing Partners American Airlines, Delta Airlines, JetBlue Airways, United Airlines, Bahamasair, and All Nippon Airways

Crew Domiciles 5

Maintenance Bases Gainesville, FL and Du B ois, PA

Line Maintenance Stations Atlanta, Cleveland, Fort Lauderdale, Orlando, Tampa, and Washington (Dulles)

Cities Currently Served Total: 38 (8 states in the U.S., Washington, DC and 7 destinations in The Bahamas)

Employees 920 total; 770 FTEs

Average Scheduled Departures 147 per day (based on March 2014 schedule)

Passengers Carried in 2013 805,316 passengers

Total Revenue Passenger Miles

Flown in 2013 158.3 million revenue passenger miles*

(*A revenue passenger mile is equal to one fare

- paying passenger flown one mile)

Total Aircraft in Operating Fleet 33 aircraft

Saab Aircraft 28 Saab 340B Plus turboprops

Beechcraft Aircraft 5 Beech 1900D aircraft (all will be exited/replaced with more Saabs) 

# Silver Airways Fact SheetApril 17 , 2014 Silver Airways Essential Air Service Propos al Page | 7

Silver Airways currently flies to 38 airports over a diverse network spanning the Eastern United State s and The Bahamas.

Operations from Washington (Dulles) and Cleveland are operated in cooperation with United Airlines

. Operations from Atlanta, within Flor ida, and to The Bahamas are operated under the Silver Airways brand. All flights within this network are available for interline e

- ticketing with our partner carriers, which include United Airlines, JetBlue Airways, Delta Airlines, and American Airlines. Additionally, all flights in Florida and The Bahamas are sold via a code share arrangement with United Airlines.

Although the company has filed a termination notice with the Department for the Cleveland network, it seeks in this application to maintai n service to Du B ois and Parkersburg to Dulles, continuing as part of
the United Airlines n etwork. The company has also filed a termination notice on most of the Atlanta network. These changes will allow Silver to focus our resources on the remai ning Washington and Florida networks to ensure operational reliability and financial success. 

# Silver Airways Route MapApril 17 , 2014 Silver Airways Essential Air Service Proposal for Washington, DC (Dulles) Page | 8

There are over 300 scheduled departures per day from Washington Dulles International Airport for July 2014 to 87 nonstop destinations throughou t North America. United and its partners operate nearly 250 of those departures and serve 82 destinations nonstop. 

# Washington (Dulles) Route Map : North AmericaApril 17 , 2014 Silver Airways Essential Air Service Proposal for Washington, DC (Dulles) Page | 9

In July 2014, Washington Du lles International Airport has 52 scheduled departures to 40 destinations beyond North America. United and its partners have scheduled over 20 departures per day to 25 international destinations 

# Washington (Dulles) Route Map : Beyond North AmericaApril 17 , 2014 Silver Airways Essential Air Service Proposal for Washington, DC (Dulles) Page | 10

Source: Saab Aircraft Leasing. 

# Saab 340B Plus FAR Aircraft SpecificationsApril 17 , 2014 Silver Airways Essential Air Service Proposal for Washington, DC (Dulles) Page | 11

The revenue and expenses associated to each city is calculated as follows:

 Clarksburg/Fairmont (CKB), Morgantown (MGW), and Parkersburg/Marietta (PKB)

o Clarksburg/Fairmont (CKB) service consists of 36 flights operating to/from IAD (18 each way) per week. 14 flights will be operated nonstop to/from IAD. 12 flights per week are operated CKB

- MGW as a tag flight continuing to/from IAD. 10 flights per week are operated as wraps, 5 via MGW and 5 via PKB. The wrap flights provide nonstop service to/from IAD in one direction
and one

- stop service to/from IAD in the other direction. The nonstop flights and 12 CKB

- MGW flights are allocated 100% to CKB.
Th e 5 CKB

- MGW and 5 CKB

- PKB wrap flights are allocated 50% to CKB.

o Morgantown (MGW) service consists of 36 flights operatings to/from IAD (18 each way) per week. 12 flights per week are operated as nonstop to/from IAD with a tag flight to CKB. 5 flights pe r week are operated as a wrap with CKB and 7 flights per week wrap with PKB, providing nonstop service in one direction and one

- stop service in the other driection. The nonstop flights to/from IAD are allocated 100% to MGW, while the 5 CKB

- MGW and 7 MGW

- P KB wrap flights are allocated 50% to MGW.

o Parkersburg/Marietta (PKB) service consists of 36 flights operating to/from IAD (18 each way) per week. 24 flights are opera ted nonstop to/from IAD. 5 flights are wrapped via CKB

- PKB and 7 flights are wrapped via MGW

- PKB, creating nonstop flights in one
direction and one

- stop flights in the other. 100% of the nonstop segments and 50% of the wrap segments are allocated to PKB.

 Altoona (AOO), DuBois (DUJ), and Johnstown (JST)

o Altoona (AOO) service consists of 24 fl ights operating to/from IAD (12 each way) per week. One nonstop to/from IAD operating 14 times per week and one tag flight via JST operating 10 times per week. 100% of the revenue and expenses of each of these is
associated to AOO. The AOO

- DUJ segment i s a tag flight associated 100% to DUJ.

o DuBois (DUJ) service consists of 36 flights operating to/from IAD (18 each way) per week. One tag flight operates via AOO 10 times per week and two flights wrapped with JST which 11 flights nonstop to/from IAD per we ek and 15 flights per week which stop in JST. 100% of the AOO

- DUJ tag and DUJ

- IAD flights are associated to DUJ. 50% of the DUJ

- JST segment is associated to

DUJ.

o Johnstown (JST) service consists of 36 flights operating to/from IAD (18 each way) per week. 25 weekly flights operate nonstop to/from IAD and continue as tags or wraps to AOO and/or DUJ. JST’s revenue and expenses are calculated as 100% of the nonstop IAD

- JST segments, 50% of the DUJ wraps, and 0% of the AOO tags.

 Beckley (BKW), Staunton (SHD) , and Greenbrier/White Sulphur Springs (LWB)

o Beckley (BKW) service consists of 24 flights operating to/from IAD (12 each way) per week. 12 flights are operated as nonsto p flights, while 12 flights are wrapped with SHD creating 6 nonstop flights from IAD a nd 6 flights to IAD which stop in SHD. BKW is allocated 100% of the 18 nonstop flights to/from IAD and 50% of the BKW

- SHD segment .

o Staunton (SHD) service consists of 36 flights operating to/from IAD (18 each way) per week. 24 flights are operated as non stop flights, while 12 are wrapped with BKW creating 6 nonstop flights to IAD and 6 flights from IAD which stop at BKW. SHD is allocated 100% of the 30 nonstop flights to/from IAD and 50% of the BKW

- SHD segment.

o Greenbrier/White Sulphur Springs (LWB) ser ivce consists of 14 nontop flights to IAD per week May 1 through October 31 and 12 flights nonstop to IAD November 1 though April 30. LWB is allocated 100% of all IAD

- LWB flights. 

# Appendix: Calculation of Subsidy Requirement by Airport from SegmentsApril 17 , 2014 Silver Airways Essential Air Service Proposal for Washington, DC (Dulles) Page | 12 

# Appendix: Clarksburg /Fairmont, Morgantown , and Parkersburg /MariettaApril 17 , 2014 Silver Airways Essential Air Service Proposal for Washington, DC (Dulles) Page | 13 

# Appendix: Altoona, DuBois, and JohnstownApril 17 , 2014 Silver Airways Essential Air Service Proposal for Washington, DC (Dulles) Page | 14 

# Appendix: Beckley

, Staunton , and Greenbrier /White Sulphur Springs