U.S. Department of 

Transportation 

Office of the Secretary 

of Transportation 

April 28, 2015 

Mr. Samuel Raphael 

Managing Director 

Aviation Partners of Boynton Beach, LLC 

d/b/a Hummingbird Air 

Henry Rohlsen Airport 

RR 1 Box 9911 Kings Hill 

St. Croix, USVI 00850 

Re: Docket DOT-OST-2014-0116 

? 0 ~. "). , - ~· ; .i 

1200 New Jersey Avenue SE 

Washington DC 20590 

Application of Aviation Partners of Boynton Beach, LLC d/b/a Hummingbird Air, 

for authority to conduct operations as a commuter air carrier 

Dear Mr. Raphael: 

Thank you for the updated fitness information that you submitted on March 27, 2015, in 

support of the application filed by Aviation Partners of Boynton Beach, LLC d/b/a 

Hummingbird Air ("Hummingbird Air"), for the determination of its fitness to conduct 

scheduled passenger operations as a commuter air carrier under 49 U.S.C. § 41738. 

We have reviewed the information submitted and find that we continue to requi~e 

additional and/or clarifying information with respect to the applicant's financial fitness 

before we can completely process Hummingbird Air's application. 

First, we require that first-year projected operating expenses be submitted showing 

projected monthly or quarterly expenses. Therefore, we request that Hummingbird Air 

break down its first-year projected operating expenses by quarter or month. 

Second, in evaluating an applicant's financial fitness, the Department generally asks that 

the applicant have available to it resources sufficient to cover all pre-operating costs and 

any negative working capital balance, plus a working capital reserve e~ual to the 

operating costs that would be incurred in three months of normal operations. Assuming 

no change in the total projected first-year operating expenses, Hummingbird Air expects 

Because projected expenses during the first several months of operations frequently do not include all 

of the costs that will be incurred during a "normal" period of operations, it is our practice to base our threemonth standard on one quarter of the first year's operating cost forecast. In calculating ·available resources, 

projected revenues may not be used. 

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to incur first-year expenses of $2.8 million. In order to meet the Department's financial 

fitness test, Hummingbird Air would need to show that it has access to $702,822, which 

is one quarter of its first-year projected expenses. Hummingbird Air's balance sheet as of 

December 31, 2014, shows the company having positive working capital of $306,514. 

Thus, it does not appear that Hummingbird Air has financial resources sufficient to meet 

the Department's requirements. We request that Hummingbird Air submit a more recent 

balance sheet along with third-party verification of any and all funds available to 

demonstrate its financial fitness. 

Last, the third-party verification of funds submitted by Hummingbird Air in support of its 

application does not indicate the actual amount of funds on deposit at the Bank of 

St. Croix. Also, it is the Department's policy that. applicants submit third-party 

verification of funds in the form of a letter from the financial institution or in the form of 

a regular periodic bank statement; balance snapshots printed from the Internet are not 

acceptable sources of fund verification. Please submit revised financial verification 

documents. 2 

I ask that you respond fully to this request within 30 days of the date of this letter. You 

may upload your response via the web at www.regulations.gov, or you may mail your 

response to U.S. Department of Transportation Dockets, West Building, Ground Floor, 

(M-30, Room Wl2-140), 1200 ·New Jersey Avenue SE, Washington, D.C. 20590. 

In either case, your response should be filed in Docket DOT-OST-2014-0116. 

As is the Department's practice, further processing of Hummingbird Air's application 

will be deferred pending receipt of this material. In addition, please remember that 

Hummingbird Air should promptly provide the Department with any information 

regarding changes it may undergo in areas affecting its fitness (i.e., management, 

operating plans or financial condition, compliance disposition, or ownership) while its 

application is under review by the Department. 

Thank you for your cooperation in this matter. If you have any questions regarding this 

letter or the requested information, please feel free to contact me at (202) 366-2999 

or vanessa.balgobin@dot.gov. 

~~-~~ Vanessa R. Balgobin 

Sr. Transportation Industry An 

Air Carrier Fitness Division 

Office of Aviation Analysis 

In general, the current asset section of a company's balance sheet reflects all of the cash held by the 

company. Therefore, we do not add the cash amount shown on a balance sheet to cash amounts shown in 

bank statements. Rather, we use bank statements to verify the cash amount reflected on the balance sheet. 

We also use bank statements to verify the availability of cash pledged to the applicant by an individual. 
cc: Docket DOT -OST -2014-0116 

Mr. Jorge Echegoyen 

Principal Operations Inspector 

Federal Aviation Administration 

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