Order 201 3

- 1

- 12

Served: January 18 , 2013

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY WASHINGTON, D.C.

Issued by the Department of Transportation

on the 18 th day of January

, 2013

Application of

SCOTT AIR

, LL C

d/b/a ISLAND AIR EXPRESS

d/b/a DESERT SPLASH ADVENTURES

f o r a certificate of public convenience and necessity under

49 U.S.C. § 41102 to engage in interstate scheduled air transportation of persons, property, and mail Docket DOT

- OST

- 2012

- 0178

Docket DOT

- OST

- 2012

- 0179

ORDER TO SHOW CAUSE

Summary

By this order, we tentatively find that Scott Air, LLC d/b/a Island Air Express (“ Scott Air ”)

, is a

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

persons
, property, and mail utilizing small aircraft. 1 In addition, we register the trade name s “Island Air Express” and “Desert Splash Adventures ” for use in certain of Scott Air’s operations.

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 ensure that all operations relating to this authority 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.

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

On October 22

, 20 1 2

, Scott Air , an intrastate scheduled air carrier holding a Part 135 Federal

Aviat ion Regulations (“FAR”) operating certificate from the Federal Aviation Administration (“FAA”) and serving southern Alaska, filed an application in Docket DOT

- OST

- 2012

- 0178 requesting a certificate of public convenience and necessity to the extent necessar y to permit it to
operate interstate scheduled air transportation using small aircraft. Scott Air accompanied its application with information required by 14 CFR § 204.3 of our regulations

. On t he same date, Scott Air also applied for a pendente lite exemption to operate as an interstate air carrier while its application was pending. 2

No answers opposing Scott Air’ s application were filed

. Under these circumstances and because of the findings made below , we propose to decide the issue of the applica nt’s fitness on the basis of the written record, and we tentatively conclude that the air carrier 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

Scott Air originated as a charter air carrier in 1998 and was organized as a limited liability corporation under the law s of the State of Alaska in 200 1

. It currently provides scheduled intrastate

air service between the island communities of Klawock and Ketchikan, Alaska

, using three Cessna

aircraft. The air c arrier is equally owned by Mr . Scott Van Valin

, a U.S. citizen

, and Ayer Track,

LLC (“Ayer Track”)

, a Delawar e limited liability company owned by the Currier Family Trust. 3 If granted approval of the authority it now seeks

, Scott Air intends to operate the same service it currently provides today.

Manag ement and Key Technical Personnel

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

S co tt E. Van Valin Owner, Managing Member

, and Director of Operations

Scott A. Currier Owner

Patrick Goodrich Chief Pilot

Chad S. Russell Director of Maintenance David R. Seay Chief Financial Officer (“CFO”)

Mr. Scott E. Van Valin serves as Scott Air’ s Manager, Director of Operations and Pilot and has

owned the air carrier since 1998

. He is also the owner of El Capitan Lodge, having purchased it in September 2001 , and previously served as its Manager and a Guide (May 1994

- September 2001).

Mr. Van Valin holds a n FAA Commercial Pilot License.

Mr. Scott A. Currier indirectly holds a fifty percent ownership interest in Scott Air through his company, Ayer Track . He is also the President and Chief Operating Officer of Currier

2 See Docket DOT

- OST

- 2012

- 0179.

3 The Trustees of the Currier Family Trust are Mr. Scott A. Currier and his wife, Mrs. Laura C. Currie, each of which is a U.S. citizen. The Trust’s beneficiaries are the Currier’s three children, all U.S. citizens.3

Construction, In c. based in Phoenix, Arizona (1992

- present). Mr. Currier was previously a Senior Project Manage r with MGC Contractors (1984

- 1992).

Mr. Patrick Goodrich has been Scott Air’s Chief Pilot and Check Airman since October 2011 and has over 9,500 flight hours. He was previously the Chief Pilot for Alaska Seaplane Service (2006

- 2011), a Line Pilot for Wi ngs of Alaska (2006), a First Officer with Arctic Circle Air (2004

- 2006)

, and a Line Pilot for Skagway Air Service (2001

- 2004).

Mr. Chad S. Russell has been Scott Air’s Director of Maintenance since June 2011. A licensed Airframe and Powerplant Mechanic, h e has held similar Director of Maintenance positions with Grant Aviation (September 2008

- June 2011) and Evergreen Helicopter of Alaska (January 2008

- September 2008 and August 2004

- January 2007). He was also the Site Maintenance Manager and Inspector for Aero Air LLC (January 2007

- January 20 08), Chief Inspector for Grant Aviation (March 2006

- July 2006), Iraq Site Lead for Duncan Aviation (July 2004

- August 2005) , and was the Owner of Precision Aircraft Maintenance (October 2001

- December 2011 ).

Mr. David R. Seay is the air carrier’s CFO, a position he has held since 2010. He is also the CFO for Currier Construction, Inc., and was previously the CFO for Caviness Construction Company, Inc. (2002

- 2010).

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

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

. 4

Operating Plan and Financial Condition

Scott Air currently conducts schedule d and charter passenger operations using two Cessna Caravan aircraft configured for 9 passengers, and a Cessna Stationair, configured for 3 passengers. Its main revenue source is passenger travel between Klawock and Ketchikan, Alaska. Scott Air intends to

pro vide up to four daily roundtrip flights between the two locations, which is the same service it currently provides as an intrastate air carrier

, but the air carrier now seeks authority to operate as an

interstate certificated air carrier.

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 e qual 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.

In its application, the air carrier st ates that “pre

- operating costs were already incurred at the time [Scott Air] received its FAA Part 135 authority” and provided first

- year operating expenses for

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 Scott Air ’s key technical personnel are acceptable to that agency in their respective positions.4

scheduled passenger operations

. I t has projected that its first

- year expenses for scheduled service will total approximately $ 1

. 859 million. Therefore, to meet the Department’s financial fitness
criteria, Scott Air w ill need approximately one

- quarter of its estimated first

- year expenses, or $ 464,995

.

In support of its fitness, Scott Air provided a balance sheet at September 30, 201 2

, showing total current assets of $ 820,078 and total current liabilities of $ 39,540

, giving the air carrier positive working capital of $ 780,538. In addition, the applicant reported net income of $1 0 6,371 on $ 1.19 million in revenues for the 7 months ended July 31 , 201 2

. Further, Scott Air provided a letter from the Arizona Business Bank indicating it has a line

- of

- credit for $500,000 to be used for working capital purposes as needed.

We have review ed the forecasts provided by Scott Air and find them to be reasonable. Scott Air is not expanding its current operations and is instead requesting an interstate certificate to continue its scheduled and charter operations between two points within the State of Alaska. Therefore, we agree with the company that no pre

- operating costs will be incurred and that its first

- year operating expenses are sound based on Scott Air’s past experience. In light of the above, we tentatively

conclude that the air carrier 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. 5

Complianc e Disposition

In July 2012 the Department ’s Office of Aviation Enforcement and Proceedings (“Enforcement Office”) conducted an investigation into whether Scott Air violated 49 U.S.C. § 41101 and § 41712 by offering for sale and operating interstate air service between the Ketchikan International and the Klawock Airports in Alaska without certificate authority under 49 U.S.C. § 41101 or registration as

an air tax i under 14 CFR Part 298

. As a result of th is investigation , the Enforcement Office and

Scott Air agreed to a cease and desist order which assessed the air carrier a $20,000 civil penalty. 6

In response to the Enforcement Office’s investigation and resulti ng Consent Order, Scott Air states that it has taken action to prevent any further violations of the Transportation Code. Specifically,

Scott Air states that it has amended its website to indicate clearly that it is an intrastate carrier, that

is has file d the subject application to become an interstate air carrier, and that during the winter season, it is only carrying local Alaska traffic. Upon review of the air carrier’s actions to address the Department’s concerns, we find Scott Air is in compliance w ith the applicable statutes and regulations governing its current operations. Additionally, we have been informed that the Enforcement Office does not object to Scott Air being found fit.

Other than the above

- stated compliance issue, Scott Air states tha t 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 the se 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

5 As is our practice, prior to making any authority awarded to Scott Air effective, we will require the company to

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

6 See Order 2012

- 12

- 16, issued on December 28 , 2012.5

personnel, or persons having a substantial interest in it with respect to compliance with the Transportation Code or the Department’s regulations

.

T he FAA has informed us that Scott Air ’s compliance and safety record is excellent, and that the air

carrier is proactive i n addressing any issues that have come up during site visits.

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

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 t he

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

As previously discussed, M r. Van Valin , a U.S. citizen, and Ayer Track , ultimately owned by

Mr. Currier, a U.S. citizen, equally own Scott Air. The air carrier is a limited liability company organized under the laws of A lask a

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

non

- U.S. citizens control Scott Air

.

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

, 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.

TRADE NAME REGISTRATION

In its application, Scott Air requested th at the Department register the trade names “Island Air Express” and “Desert Splash Adventures” for use in certain of its air transportation operations. Part

215 (14 CFR Part 215) of the Department’s regulations provides that any air carrier wishing to use an alternative trade name must first register that name with the Department. The rule further states that the Department may register such name s after the air carrier gives notification to similarly

named air carriers of the proposed use of the trade nam e. In this case, Scott Air filed notice of its intent to register the above trade names on Hawaii Island Air, Inc. d/b/a Island Air; Island Airlines, LLC d/b/a Nantucket Air Shuttle; and Redemption, Inc. d/b/a Island Air Service.

Since Scott Air compli ed with the requirements of Part 215, we acknowledge the registration of the trade names “Island Air Express” and “Desert Splash Adventures” by Scott Air for use in certain of its air transportation operations.6

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 expect that p ersons 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 discov ery 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 Scott Air a certificate that will contain an exact copy of the attached Terms, Conditions

and Limitations.

CERTIFICATE CONDITIONS AND LIMITATIONS

If Scott Air 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. Among other things,

this includes : (1) our receipt of evidence that Scott Air 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 Scott Air has undergone in its ownership, management, operations, finance or compliance dis position since the issuance of this or der

.

Additionally, we propose to limit any authority issued to Scott Air to operations using aircraft that can be operated under FAR Part 135 (that is, aircraft with no more than 9 seats in scheduled

pas senger operations). Should Scott Air desire to ac quire and operate larger aircraft that would require certification from the FAA under 14 CFR Part 121, our fitness findings might no longer apply. Therefore, should Scott Air desire to operate aircraft that would require certification from

the FAA under P art 121, it must first provide the Department with at least 45 days advance notice of such plans and provide updated information establishing its fitness for such expansion.

Finally , we remind Scott Air of the requirements of 49 U.S.C. § 41110(e). Speci fically, 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 requi re that they supply information describing any subsequent substantial changes it may undergo in areas affecting fitness. Therefore, if Scott Air 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 204.57

of our rules. 7 The compliance of the company with this requirement is essential if we are to ca rry

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

. 8

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 certificate of public convenience and necessity to Scott Air, LLC to engage in interstate scheduled air transpor t ation of persons, property, and mail, subject to the attached specimen Terms, Conditions, and Limitations.

2. We di smiss as moot Scott Air, LLC’s request for a pendent e lite exemption from the provisions of 49 U.S.C § 41102 to engage in interstate scheduled air transpor t ation in Docket DOT

- OST

- 2012

- 0179

.

3 We register the trad e names “Island Air Express” and “Desert Splash Adventures ” for use in Scott Air, LLC’s air transportation operations.

4. 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

- 2012

- 0178 , 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.

5

. 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. 9

6

. 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 issu e

7 S cott Air 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 da ted 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 demo nstrate 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 aut hority.

8 We also remind Scott Air 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 operati ons 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.

9 Since we have provided for the filing of objections to this order, we will n ot entertain petitions for reconsideration.8

to Scott Air, LLC a certificate that will contain exact copies of the attached specimen Terms, Conditions, and Limitations.

7

. We will serve a copy of this order on the persons listed in Attachment A.

8

. 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

SCOTT AIR, LLC

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 insura nce 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 po sture, 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 concerning security, including, but not limited to 49 CFR Part 1544. *

(5 ) The holder’s authority is limited to operations conducted pursuant to Part 135 of the Federal Aviation Regulations. In the event that the holder wishes to institute operations that would require Part 121 certification from the FAA, it must first be determ ined fit for such operations.

( 6 ) 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.

( 7 ) The holder shall at all times remain a "Ci tizen of the United States" as required by

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

( 8 ) 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.

( 9 ) 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.

( 10 ) 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 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 rev oked 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 operatio ns, 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

SCOTT AIR

, LL C

MR PIERRE MURPHY

ATTO RNEY FOR SCOTT AIR LLC

1200 NEW HAMPSHIRE A VE NW

SUITE 800

WASHINGTON DC 2000 36 CSET ASSISTANT MANAGER

FEDERAL AVIATION ADMINISTRATION

45005 AVIATION DRIVE AFS

- 900

SUITE 131

DULLES VA 20166

MR SCOTT VAN VALIN

SCOTT AIR LLC

PO BOX 1174

CRAIG ALASKA 9 9921 MR PETER J LYNCH

ASSISTANT CHIEF COUNSEL

FOR ENFORCEMENT AGC

- 300

FEDERAL AVIATION ADM INISTRATION

800 INDEPENDENCE AVENUE SW

WASHINGTON DC 20591

M R TROY MCCLANAHAN

PRINCIPAL OPERATIONS INSPECTOR

FEDERAL AVIATION ADMINISTRATION

3032 VINTAGE PARK BO ULEVARD

SUITE 10 6

JUNEAU ALASKA 99 801

MARK ATWOOD

HAWAII ISLAND AIR IN C

THE ARMY AND NAVY BU ILDING

1627 I STREET NW

SUITE 1100

WASHINGTON DC 20006

GARY GAROFALO

ISLAND AIRLINES LLC

GAROFALO GOERLICH & HAINBACH

1200 NEW HAMPSHIRE A VE NW

SUITE 800

WASHINGTON DC 20036

MICHAEL CARNEY

KETCHIKAN INTL AIRPORT

1000 AIRPORT TERMINAL WAY

KETCHIKAN AK 99901 REGIONAL COUNSEL, AA L

- 7

FEDERAL AVIATION

ADMINISTRATION ALASKAN REGION HEADQ UARTERS

222 WEST 7 TH AVENUE SU ITE 1 4

ANCHORAGE ALASKA 99513

OFFICE OF AIRLINE INFO

DOT/RITA/BTS E

- 36

- RTS

- 42

1200 NEW JERSEY AVENUE SE

WASHINGTON DC 20590

ROBERT SANFORD

PRESIDENT

REDEMPTION INC

D/B/A ISLAND AIR SERVICE

PO BOX 125

KODIAK AK 99615

TIM LACOUR

AIRPORT MANAGER

KLAWOCK AIRPORT

PO BOX 91

CRAIG AK 99921