Order 2011

- 2

- 4

Served: February 4, 2011

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY WASHINGTON, D.C.

Issued by the Department of Transportation

on the 4 th day of February , 2011

Application of

ALASKA CENTRAL EXPRESS , INC.

for reissuance of its certificate of public convenience and necessity under 49 U.S.C. § 41102 Docket DOT

- OST

- 1996

- 1657

ORDER TO SHOW CAUSE

PROPOSING RE ISSUANCE OF CERTIFICATE

Summary

By this order, we tentatively find that Alaska Central Express, Inc. (“ ACE ”)

, is a citizen of the

United States, is fit, willing, and able to provide interstate air transportation

, and should be issued

a n amended interstate scheduled certificate of public convenience and necessity to reflect the

removal of the condition that limits it to charter passenger operations, subject to conditions

.

Background

Section 41102 of Title 49 of the United States Code (“the Transportation Code”) directs us to

determine whether companies proposing to engage in interstate scheduled air transportation are “fit, willing, and able” to perform such service, and to comply with the Transportation Code and the regulations and requirements of the Department. In making fitness fin dings, the Department uses a

three

- part test that reconciles the Airline Deregulation Act’s liberal entry policy with Congress’ concern for operational safety and consumer protection. The three areas of inquiry that must be

addressed in order to determine a company’s fitness are whether the applicant: (1) will have the managerial skills and technical ability to conduct the proposed operations, (2) will have access to resources sufficient to commence operations without posing an undue risk to consumers, and (3) will comply with the Transportation Code and regulations imposed by Federal and State agencies.

We must also find that the applicant is a U.S. citizen.

On November 12

, 20 10 , ACE filed an application in Docket DOT

- OST

- 1996

- 1657 requesting that the Department reissue its certificate of public convenience and necessity to the extent necessary to permit ACE to engage in scheduled interstate air transportation of persons, property, and mail

, i.e.,

remove the condition that limits the air carrier to charter passenger air transportation

. A dditionally,

A CE supplemented its application with information notifying the Department of its plan to acquire

an additional Beech 1900C airc raft to conduct its proposed scheduled passenger operation s. ACE

accompan ied its application with information required by 14 CFR § 204.3 of our regulations for a2

re

- examination of its fitness and supplemented it with additional information on December 22,

2010. 1

No answers opposing ACE’s application were filed and no special issues regarding the applicant have come to our attention. Under these circumstances, we propose to decide the issue of the applicant’s fitness on the basis of the written record, and we tentatively conclude that ACE is a

U.S. citizen and is fit, willing, and able to operate its proposed service. However, we will give interested persons an opportunity to show cause why we should not adopt as final these tentative findings and conclusions.

FITNESS

The Company

ACE is incorporated under the law s of the State of Alaska, and holds a Part 135 Federal Aviation Regulation s (“FAR”) operating certificate from the Federal Aviation Administration (“ FAA ”)

. The air carrier is solely owned by Mr. Donald R. Swortwood , a U.S. citizen. ACE curre ntly provides scheduled cargo service to 21 destinations within the State of Alaska, offers passenger and cargo charter flights throughout Alaska, employs approximately 65 full

- time employees , and operates a

fleet of four Raythe on Beech 1900C aircraft

. By Order 87

- 8

- 46, issued August 21 , 1987, the air carrier was grant ed a certificate of public convenience and necessity to engage in interstate air transportati on of persons, property, and mail

. By Order 96

- 8

- 22, dated August 19, 1996, the Department reissued ACE’s certificate with a condition limiting it to operating cargo

- only air

service with small aircraft

. 2 Most recently, by Order 2008

- 12

- 17

, dated December 24, 2008, the Department re issued ACE’s certificate and removed the cargo

- only restriction , allowing ACE to

offer charter passenger air transportation utilizing small aircraft. If granted approval of the authority it now seeks , ACE intends to provide scheduled passenger air service between Anchorage, Cold Bay

, and Dutch Harbor

, Alaska

, utilizing small aircraft. In support of its scheduled passenger air service, t he air carrier also intends to add one additional Beech 1900C aircraft to its f leet.

Manag ement and Key Technical Personn el

ACE’s key management and technical personnel consists of the following U.S. citizens:

Michael A. Bergt President and Chief Executive Officer Kenneth D. Triplett Director of Maintenance

Harold W. Carter Chief Pilot Michael A. Murphy Director of Operations

John M. Seaman Controller Merlyn J. Parret Chief Inspector

Except as noted below , ACE’s management team will remain unchanged. The Department, in connection with an informal continuing fitness review concluded in April 2009 , has previously

reviewed b ackground information for Messrs. Bergt

, Carter, Murphy

, Seaman, and Triplett

. That review was satisfactory.

1 ACE filed a motion for confidential treatment of certain documents on these same dates. This information is

discussed further in the REQUEST FOR CONFIDENTIAL TREATMENT section of this order.

2 Small aircraft is defined as any aircraft originally designed to have a maximum passenger capacity of less than 60 seats or a payload capacity of no more than 18,000 pounds.3

Mr. Merlyn J. Parret, an A irframe and P owerplant Mechanic, serves as ACE’s Chief Inspector

, replacing Mr. John Davis

. Prior to being promoted to his current position, Mr. Parrett w as emplo yed as ACE’s Lead Mechanic (1997

- 2010 ). Mr. Parret’s career in the aviation industry spans over thirty years, having served as an Aircraft Mechanic with various airlines , including Al aska Aircraft Sales (1996

- 1997), Ketchum Air Service (1995

- 1996), and Markair Express (1988

- 1995)

. Prior to that, Mr. Parrett served as a Mechanic with Aero Twin (1988), 3 Seair Alaska Airlines (1980

- 1985), and Robertson STOL Company (1978

- 1980). Between 1974 and 1978, Mr. Parrett

served in the U.S. Air Force as a Crew Chief

, maintaining KC

- 135 tankers

.

In view of the experience and background of the applicant's key personnel, we tentatively conclude

that ACE has demonstrated that it has the management skills and technical ability to conduct its proposed services

. 4

Operating Plan and Financial Condition

ACE currently conducts interstate scheduled and charter all

- cargo operations and charter passenger operations using four Raytheon Beech 1900C aircr aft and now proposes to expand its current operations to include scheduled passenger operations

. Specifically, ACE intends to provide scheduled passenger operations for an initial period of 6 months u tiliz ing one of its existing aircraft configured with 9 seats

. The air carrier intends to conduct four weekly flights between Anchorage

, Cold Bay , and Dutch Harbor, Alaska , with the intention of increasing f requencies to up to 6 weekly flights. To provide such additional frequencies, ACE intends to acquire an additional Beech 1900C

aircraft approximately 6 months after it commences scheduled passenger service.

In establishing financial fitness, the Department typically asks an applicant to demonstrate that it

has access to financial resources sufficient to cover its pre

- operating expenses and any negative working capital balance, plus a working capital reserve equal to the operating costs that are reasonably projected to be incurred during three months of “normal” operations. Because projected expenses during the first several months of air service frequently do not include all costs that will be incurred during a “normal” period of operations, it is our practice to base our three

- month test on

one

- quarter of the first year’s operatin g costs. Further, in calculating available resources, projected revenues may not be used.

ACE provided for ecasts of its pre

- operating costs and first

- year operating expenses for scheduled passenger operations and the addition of the additional Beech 1900C aircraft

. I t has projected that it

will incur approximately $ 37,700 in pre

- operating costs, and that its first

- year expenses for scheduled service will total approximately $2.51 million. Therefore, to meet the Department’s

financial fitness criteria, ACE w ill need approximately $ 667,254

. 5

3 While attending classes at Anc horage Community College, Mr. Parrett assisted his wife’s home

- based daycare

from 1985 to 1987.

4 Before authorizing an air carrier to conduct air transportation, the FAA evaluates certain of the applicant’s key personnel with respect to the minimum qual ifications for those positions as prescribed in the Federal Aviation Regulations. The FAA’s evaluation of these key personnel provides an added practical and in

- person test of the skills and technical ability of these individuals. The FAA has advised us that ACE’s key technical personnel are acceptable to that agency in their respective positions.

5 The $667,254 is comprised of the applicant’s forecast of approximately $37,700 in pre

- operatin g expenses and about $629,554, which is one

- quarter of its e stimated t otal first

- year expenses of $2.51 million

.4

In support of its fitness, ACE provided a balance sheet at September 30, 2010, showing total current assets of $ 3.44 million and total current liabilities of $ 1. 0 2 million

, giving the air carrier positive working capital of $ 2.42 million. In addition, ACE reported net income of $1.48 million on $11.4 million in revenues for the 9 months ended September 30, 2010.

We have reviewed the forecasts provided by ACE and find them to be reasonable. Based on our review of this information , we tentatively conclude that ACE will have access to sufficient financial resources to enable it to commence its proposed scheduled passenger service without posing an

undue risk to consumers or their funds. 6

Compliance D isposition

ACE states that there are no actions or outstanding judgments against it, its owner, or its key personnel, nor have there been any charges of unfair, deceptive or anti

- competitive business practices, or of fraud, felony or antitrust violations brought against any of these parties. The air carrier further states that there are no pending investigations, enforcement actions, or formal complaints filed by the Department against it, its key personnel, or persons having a substantial

interest in it with respect to compliance with the Transportation Code or the Department’s regulations. 7

I nformation available to the Department indicates that the company has one open enforcement case against it, involving proposed civil penalties of $ 7

, 5 00. 8 Additionally, the air carrier had two

accident s in the last year 9 and no incident s s in ce March 2002

. T he FAA has informed us that it has no objections to the Department amending the air carrier’s economic authority to include scheduled

passenger operati ons

.

There is no further information regarding ACE’ s owners or its key personnel that would reflect negatively on its fitness. In light of these circumstances, we tentatively conclude that ACE has the proper regard for the laws, rules, and regulations governing its services to ensure that its aircraft and personnel conform to applicable safety standards and that acceptable consumer relations practices

will be followed.

6 As is our practice, prior to making any authority awarded to ACE effective, we will require the company to

demonstrate that it continues to have the financial resources needed to meet our financial fitness criteria.

7 According to ACE, Mr. Donald R. Sw ortwood, trustee of the Donald R. Swortwood Trust, was a named subject in a lawsuit brought by taxi cab drivers against Yellow Cab of San Diego in 2005, seeking certain employee benefits ( Musse, et. al. v. Yellow Cab of San Diego Superior Court Case No. GI C845934). Mr. Swortwood settled the case for $125,000, and payment is expected to be distributed among the plaintiffs involved upon approval by the court. This case was closed on April 14, 2009, in San Diego Superior Court.

8 ACE was cited by the FAA on April 30, 2010, for improper handling of hazardous material shipment for transport (Ca se No. 2010NM730063). Final action by the FAA is pending.

9 On J anuary 21, 2010, ACE had a fatal accident involving two crew members. According to ACE, the aircraft

e xperienced complications during takeoff from Sand Point, Alaska. The National Transportation Safety Board ’s ( “ NTSB ”) review of the accident is ongoing (NTSB File No. ANC10FA014). Additionally, on October 18, 2010, an

all

- cargo aircraft was struck by ligh tning and suffered damage to the elevator. According to ACE, the Captain’s vision was impaired by lightning and the First Officer was forced to take over controls. There were no inju ries. (NTSB File

No. ANC11LA004 ).5

CITIZENSHIP

Section 41102 of the Transportation Code requires that authority to engage in air transportation be held only by citizens of the United States as defined in 49 U.S.C. § 40102(a)(15). That section also requires that the president and two

- thirds of the Board of Dir ectors and other managing officers be

U.S. citizens

, that at least 75 percent of the voting interest be owned by U.S. citizens , and that t he

air carrier must be under the actual control of U.S. citizens.

As previously discussed, Mr. Swortwood, a U.S. citi zen, owns ACE

, a corporation organized under

the laws of A lask a

. Further, all of ACE ’ s key personnel are U.S. citizen s, and the applicant has filed an affidavit attesting that it is a citizen of the United States within the meaning of the Transportation Code . Finally , we have found no information that suggests that non

- U.S. citizens

control ACE

.

In light of the foregoing, we tentatively find that U.S. citizens own and actually control ACE

, consistent with 49 U.S.C. 40102(a)(15) and that it is fit, willing, and able to provide its proposed operations, subject to conditions.

REQUEST FOR CONFIDENTIAL TREATMENT

On November 12

, 20 1 0, ACE filed a motion for confidential treatment under 14 CF R § 302.12 ( “ Rule 12 ” ) of our rules to withhold from public disclosure : (1) revenue p rojections contained in its

forecast Profit and Loss Statement for combined passenger and cargo operations, and ( 2 ) a Statement of Cash Flow s for combined passenger and cargo operations. On December 22 , 2010, ACE filed additional information in support of its application, and subsequently filed another motion for confidential treatment under Rule 12 to withhold from public disclosure revenue a nd net income projections for its proposed scheduled passenger operations. In support of both motions

, ACE states that the information at issue meets the requirements for exemption from public disclosure under the Freedom of Information Act, 5 U.S.C. Sect ion 552(b)(4). Moreover , ACE

states that the material contain s proprietary information that would not normally be provided to the public and that its release here would cause ACE serious competitive harm. Further , ACE notes

that th ese documents are simil ar to that for which the Department has grant ed co nfidential treatment in the past

.

Rule 12 instructs us to evaluate requests for confidential treatment in accordance with the standards of disclosure found in the Freedom of Information Act (5 U.S.C. S ection 552). Information may be withheld from disclosure under 5 U.S.C. 552(b)(4) if it is (1) commercial or financial, (2) obtained from a person outside of government, and (3) privileged or confidential ( Gulf and Western Industries, Inc. v. United States , 615 F.2d 527, 529 (D.C. Cir 1979)).

There is no question that the information for which ACE seeks confidential treatment is financial or commercial in nature and that it was obtained from a person outside the government. The remaining question is whether the information is privileged or confidential

— whether “disclosure of the information is likely to have either of the following effects: (1) impair the Government’s ability to obtain necessary information; or (2) cause substantial harm to the compe titive position of the person from which the information was obtained” ( National Parks and Conservation Association v.

Morton , 498 F.2d 765, 770 (D.C. Cir 1974)). Further, to be privileged or confidential, the information must not be of the type that is u sually released to the public ( Gulf and Western Industries, Inc. v. United States , 615 F.2d 527, 530 (D.C. Cir 1979)).6

After careful review of the motion, we have decided to grant confidentiality to the information for which such treatment is sought . Reg arding the revenue projections contained in ACE’s forecast

Profit and Loss Statement for combined passenger and cargo operations and the revenue projections

contained in ACE’s forecast of stand

- alone scheduled passenger operations, the Department typically grants confidential treatment to an applicant ’ s projected revenues. We find that the release of this information could cause substantial harm to the competitive position of the applicant. Thus,

we will grant confidential treatment to ACE’s projected rev enues. With respect to the air carrier’s Statement of Cash Flows for combined passenger and cargo operations, t his information is not required in the Department ’s evaluation of this air carrier. Therefore, it is granted confidential

treatment.

O BJECTIONS

We will give interested persons 14 days following the service date of this order to show cause why the tentative findings and conclusions set forth here should not be made final; answers to objections will be due within 7 days thereafter. We ex pect that persons objecting to our tentative findings and conclusions will support their objections with relevant and material facts. If an oral evidentiary hearing or discovery procedures are requested, the objector should state in detail why such hearin g or discovery is considered necessary, and what material issues of decisional fact the objector would expect to establish through a hearing or discovery that cannot be established in written pleadings. The objector should consider whether discovery proce dures alone would be sufficient to resolve material issues of decisional fact. If so, the type of procedure should be specified ( see Part 302, Rules 19 and 20); if not, the reasons why not should be explained. We will not entertain general,

vague, or uns upported objections. If no substantive objections are filed, we will issue an order that will make final our tentative findings and conclusions with respect to certification and fitness and

will issue ACE a n amended certificate that will contain an exact copy of the attached Terms,

Conditions and Limitations.

CERTIFICATE CONDITIONS AND LIMITATIONS

If ACE is found fit and issued the certificate authority it seeks, its scheduled passenger authority

will not become effective until the air carrier has fulfilled all of the requirements for effectiveness
as set forth in the terms, conditions and limitations attached to its certificate. 10 Among other things,

this includes : (1) our receipt of evidence that ACE has been certified by the FAA to engage in the subject operations

, (2) a fully

- executed OST Form 6410 evidencing liability insurance coverage that meets the requirements of 14 CFR § 205.5(b) of our rules for all of its aircraft, (3) verification of available funding necessary to meet the Department’s f itness requirements, and (4) a statement of changes that ACE has undergone in its ownership, management, operations, finance or compliance disposition since the issuance of this order

. Additionally, should ACE expand its operations to include large aircra ft, 11 our fitness determination may no longer be valid. Therefore, ACE’s authority is limited to the use of small aircraft

.

10 The air carrier may continue to p rovide interstate scheduled air transportation of cargo and mail and charter passenger operations under its current certificate until its amended certificate is made effective to include scheduled passenger service.

11 Large aircraft is defined as any ai rcraft originally designed to have a maximum passenger capacity of more than 60 seats or a maximum payload capacity of more than 18,000 pounds.7

Finally , we remind ACE of the requirements of 49 U.S.C. § 41110(e). Specifically, that section requires that, once a n air carrier is found fit initially, it must remain fit in order to hold its authority. To be assured that certificated air carriers continue to be fit after effective authority has been issued to them, we require that they supply information describing any s ubsequent substantial changes it may undergo in areas affecting fitness. Therefore, if ACE is issued authority to conduct scheduled passenger air transportation and should it subsequently propose substantial changes in its ownership, management, or operat ions, it must first comply with the requirements of section 204.5

of our rules. 12 The compliance of the company with this requirement is essential if we are to carry

ou t our responsibilities under section 41110(e) of the Transportation Code

. 13

ACCORDINGLY:

1. We direct all interested persons to show cause why we should not issue an order making final the tentative findings and conclusions stated above and award a n amended certificate to Alaska Central Express, Inc.

, removing the condition in its interstate scheduled certificate that limits it to charter passenger operations , subject to the attached specimen Terms, Conditions, and Limitations.

2. We direct any interested persons having objections to the issuance of an order making final any of the proposed findings, conclusions, or the certificate award set forth here to file such objections

with the U.S. Department of Transportation, Docket Operations

, 1200 New Jersey Avenue, SE, West Building Ground Floor, Rm. W12

- 140, Washington, DC 20590, in Docket

DOT

- OST

- 199 6

- 1657 , and serve them upon all persons listed in Attachment A no later than

14 days after the service date of this order . A nswers to objections shall be filed no later than 7

business days thereafter.

3. If timely and properly supported objections are filed, we will accord full consideration to the matters or issues raised by the objections before we take further action. 14

4. In the event that no objections are filed, we will consider all further procedural steps to be

waived an d we will enter an order making final our tentative findings and conclusions and will

re issue Alaska Central Express, Inc. a n amended certificate that will contain exact copies of the attached specimen Terms, Conditions, and Limitations.

5. We will serv e a copy of this order on the persons listed in Attachment A.

12 ACE may contact our Air Carrier Fitness Division to report proposed substantial changes in its operations, ownership, or management, and to determine what additional information, if any, will be required under section 204.5. In addition, by Notice dated J uly 21, 1998, the Department requested air carriers to provide a 30

- day advance notification of any proposed change in ownership, restructuring, or recapitalization. If the air carrier fails to file the

information or if the information fails to demonstra te that the air carrier will continue to be fit upon implementation of the substantial change, the Department may take such action as is appropriate, including enforcement action or steps to modify, suspend, or revoke the air carrier's certificate authorit y.

13 We also remind ACE about the requirements of section 204.7 of our rules. This section provides, among other things, that (1) the certificate authority granted to a company shall be revoked if the company does not commence actual flying operations under that authority within one year of the date of the Department's determination of its fitness; (2) if the company commences operations for which it was found fit and subsequently ceases such operations, it may not resume certificated operations unless its fitness has been redetermined; and (3) if the company does not resume operations within one year of its cessation, its authority shall be revoked for dormancy.

14 Since we have provided for the filing of objections to this order, we will not entertai n petitions for reconsideration.8

6. We will publish a summary of this order in the Federal Register.

By :

SUSAN L. KURLAND Assistant Secretary

for Aviation and International Affairs

An electronic version of this document is available on the World Wide Web at http:// www.regulations.govAttachment



### SPECIMEN Terms, Conditions, and Limitations

ALASKA CENTRAL EXPRE SS, INC.

is authorized to engage in interstate air transportation of persons, property and mail between any point in any State, territory, or possession of the United States or the District of Columbia, and any other point in any of those entities.

This authorit

y is subject to the following provisions:

(1) The authority to operate under this certificate will not become effective until six (business) days after the Department has received the following documents; provided

, however

, that the Department may stay the effectiveness of this authority at any time prior to that date:

(a) A copy of the holder's Air Carrier Certificate and Operations Specifications authorizing such operations from the Federal Aviation Administration (FAA).

(b) A certificate of insurance on OST Form 6410 evidencing liability insurance coverage meeting the requirements of 14 CFR Part 205.5(b) for all of its aircraft.

(c) A statement of any changes the holder has undergone in its ownership, key personnel,

operat ing plans, financial posture, or compliance history, since the date of the Show Cause

Order in this case.

(d) A revised list of pre

- operating expenses already paid and those remaining to be paid, as well as independent verification that the holder has available to it funds sufficient to cover any remaining pre

- operating expenses and to provide a working capital re serve equal to the operating costs that would be incurred in three months of operations.

(2) Pending receipt of effective passenger authority, the holder may not accept payment of any kind (i.e., cash, check, or credit card), issue tickets for the opera tions proposed under this certificate, or enter into contracts for the operations proposed under this certificate, and any advertisement by the holder must prominently state: "This service is subject to receipt of government operating authority."

(3) T he holder shall at all times conduct its operations in accordance with the regulations prescribed by the Department of Transportation for the services authorized by this certificate, and with such other reasonable terms, conditions, and limitations as the Department of Transportation may prescribe in the public interest.2

(4) The holder's authority under this certificate is effective only to the extent that such operations are also authorized by the FAA, and comply with all U.S. Government requirements conce rning security, including, but not limited to 49 CFR Part 1544. *

( 5 ) The holder may not operate aircraft originally designed to have a maximum passenger capacity of more than 60 seats or a maximum payload capacity of more than 18,000 pounds.

( 6 ) The holder shall at all times remain a "Citizen of the United States" as required by

49 U.S.C. 40102(a)(15).

( 7 ) The holder shall maintain in effect liability insurance coverage as required under

14 CFR Part 205. Failure to maintain such insurance coverage w ill render a certificate ineffective, and this or other failure to comply with the provisions of Subtitle VII of Title 49 of the United States Code or the Department's regulations shall be sufficient grounds to revoke this certificate.

( 8 ) The holder is a uthorized to conduct charter flights in interstate and/or foreign air transportation in accordance with the provisions of 14 CFR Part 212.

( 9 ) Should the holder propose any substantial changes in its ownership, management, or operations (as defined in 14 CFR Part 204.2(l)), it must first comply with the requirements of

14 CFR Part 204.5.

( 1 0 ) The holder may not enter into any form of agreement or arrangement with Mr. Neil B ergt, any member of his family, excluding Mr. Michael A. Bergt, or any entity owned or controlled by

Mr. Neil Bergt or a member of his family

, excluding Mr. Michael A. Bergt

, without obtaining prior approval from the Department.

( 1 1 ) In the event that the holder does not commence actual flying operations under this certificate within one year of the date of the Department's determination of its fitness, its authority shall be revoked for dormancy, unless the holder is conducting operations under another type of certificate authority. Further, in the event that the holder commences operations for which it was found "fit, willing, and able" and subsequently ceases all such o perations, its authority under all certificates held shall be suspended under the terms of 14 CFR Part 204.7 and the holder may neither recommence nor advertise such operations unless its fitness to do so has been redetermined by the Department. Moreover, if the holder does not resume operations

within one year of its cessation, its authority shall be revoked for dormancy

.

* To assure compliance with all applicable U.S. Government requirements concerning security, the holder shall, before commencing any new service (including charter flights) to or from a foreign airport,

contact its Princi

pal Security Inspector (PSI) to advise the PSI of its plans and to find out whether the Transportation Security Administration has determined that security is adequate to allow such airport(s)

to be served.Appendix A

SERVICE LIST FOR ALASKA CENTRAL EXPRESS, INC.

MR ROBERT P SILVERBE RG ESQ

ATTO RNEY FOR ALASKA CENT RAL EXPRESS INC

SILVERBERG GOLDMAN & BIKOFF LLP

1101 30TH STREET NW

SUITE 120

WASHINGTON DC 20007 MR WILLIAM J WEBER

CSET ASSISTANT MANAGER

FEDERAL AVIATION ADMINISTRATION

45005 AVIATION DRIVE AFS

- 900

SUITE 131

DULLES VA 20166

MR MICHAEL BERGT

PRESIDENT

ALASKA CENTRAL EXPRE SS INC.

5901 LOCKHEED AVENUE

ANCHORAGE ALASKA 99502 MR PETER J LYNCH

ASSISTANT CHIEF COUN SEL

FOR ENFORCEMENT AGC

- 300

FEDERAL AVIATION ADM INISTRATION

800 INDEPENDENCE AVENUE SW

WASHINGTON DC 20591

MS DEE RICE

PRINCIPAL OPERATIONS INSPECTOR

FEDERAL AVIATION ADMINISTRATION

222 WEST 36 TH AVENUE

SUITE 101

ANCHORAGE ALASKA 9950 3 REGIONAL COUNSEL, AA L

- 7

FEDERAL AVIATION

ADMINISTRATION ALASKAN REGION HEADQ UARTERS

222 WEST 7 TH AVENUE SU ITE 1 4

ANCHORAGE ALASKA 99513

M S. ANNE SUISSA

OFFICE OF AIRLINE INFO

DOT/RITA/BTS E

- 36

- RTS

- 42

1200 NEW JERSEY AVENUE SE

WASHINGTON DC 20590