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 REISSUANCE 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 

an 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 findings, 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, 2010, 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. Additionally, 

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

an additional Beech 1900C aircraft to conduct its proposed scheduled passenger operations. ACE 

accompanied its application with information required by 14 CFR § 204.3 of our regulations for a

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION
2

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 laws of the State of Alaska, and holds a Part 135 Federal Aviation 

Regulations (“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 currently 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 Raytheon Beech 1900C aircraft. By Order 87-8-46, issued August 21, 1987, the air 

carrier was granted a certificate of public convenience and necessity to engage in interstate air 

transportation 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 reissued 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, the air carrier also intends to add one additional Beech 1900C aircraft to its fleet.

Management and Key Technical Personnel

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 background 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 Airframe and Powerplant Mechanic, serves as ACE’s Chief Inspector,

replacing Mr. John Davis. Prior to being promoted to his current position, Mr. Parrett was 

employed 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 Alaska 

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),3Seair 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 aircraft 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 utilizing 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 frequencies 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 operating costs. Further, in calculating available resources, projected 

revenues may not be used.

ACE provided forecasts of its pre-operating costs and first-year operating expenses for scheduled 

passenger operations and the addition of the additional Beech 1900C aircraft. It 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 will need approximately $667,254.

5

 

3

While attending classes at Anchorage 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 qualifications 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-operating expenses and 

about $629,554, which is one-quarter of its estimated total 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 $1.02 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 Disposition 

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

Information available to the Department indicates that the company has one open enforcement case 

against it, involving proposed civil penalties of $7,500.8 Additionally, the air carrier had two

accidents in the last year9and no incidents since March 2002. The FAA has informed us that it has 

no objections to the Department amending the air carrier’s economic authority to include scheduled 

passenger operations. 

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. Swortwood, 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. GIC845934). 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 

(Case No. 2010NM730063). Final action by the FAA is pending.

9

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

experienced 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 lightning 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 injuries. (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 Directors 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 the 

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

As previously discussed, Mr. Swortwood, a U.S. citizen, owns ACE, a corporation organized under 

the laws of Alaska. Further, all of ACE’s key personnel are U.S. citizens, 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, 2010, ACE filed a motion for confidential treatment under 14 CFR § 302.12 

(“Rule 12”) of our rules to withhold from public disclosure: (1) revenue projections contained in its

forecast Profit and Loss Statement for combined passenger and cargo operations, and (2) a 

Statement of Cash Flows 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 and 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. Section 552(b)(4). Moreover, ACE 

states that the material contains 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 these documents are similar to that for which the Department has granted confidential 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. Section 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 competitive 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 usually 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. Regarding 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 revenues. With respect to the air carrier’s 

Statement of Cash Flows for combined passenger and cargo operations, this information is not 

required in the Department’s evaluation of this air carrier. Therefore, it is granted confidential 

treatment.

OBJECTIONS

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 expect 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 hearing 

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 procedures 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 unsupported 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 an 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 fitness 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 aircraft,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 provide 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 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.
7

Finally, we remind ACE of the requirements of 49 U.S.C. § 41110(e). Specifically, that section 

requires that, once an 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 subsequent 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 operations, 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 

out 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 an 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-1996-1657, and serve them upon all persons listed in Attachment A no later than 

14 days after the service date of this order. Answers 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 and we will enter an order making final our tentative findings and conclusions and will 

reissue Alaska Central Express, Inc. an amended certificate that will contain exact copies of the 

attached specimen Terms, Conditions, and Limitations. 

5. We will serve 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 July 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 demonstrate 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 authority. 

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 entertain 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.gov
Attachment 

 

 

SPECIMEN

Terms, Conditions, and Limitations

ALASKA CENTRAL EXPRESS, 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 authority 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, 

operating 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 reserve 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 operations 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) The 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 concerning 

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 will 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 authorized 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.

(10) The holder may not enter into any form of agreement or arrangement with Mr. Neil Bergt, 

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. 

(11) 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 operations, 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 Principal 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 SILVERBERG ESQ

ATTORNEY FOR ALASKA CENTRAL 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 EXPRESS INC.

5901 LOCKHEED AVENUE

ANCHORAGE ALASKA 99502

MR PETER J LYNCH

ASSISTANT CHIEF COUNSEL

FOR ENFORCEMENT AGC-300

FEDERAL AVIATION ADMINISTRATION 

800 INDEPENDENCE AVENUE SW

WASHINGTON DC 20591

MS DEE RICE

PRINCIPAL OPERATIONS INSPECTOR

FEDERAL AVIATION ADMINISTRATION

222 WEST 36TH AVENUE 

SUITE 101

ANCHORAGE ALASKA 99503

REGIONAL COUNSEL, AAL-7

FEDERAL AVIATION 

ADMINISTRATION

ALASKAN REGION HEADQUARTERS

222 WEST 7TH AVENUE SUITE 14

ANCHORAGE ALASKA 99513

MS. ANNE SUISSA 

OFFICE OF AIRLINE INFO

DOT/RITA/BTS E-36 - RTS-42

1200 NEW JERSEY AVENUE SE

WASHINGTON DC 20590