BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

) 

Application of ) 

) 

HARRIS AIRCRAFT SERVICES, INC. ) Docket DOT-OST-2014-0145 

) 

for a certificate of public convenience and ) 

necessity pursuant to 49 U.S.C. §41102 ) 

to engage in interstate scheduled air ) 

transportation of persons, property and mail ) 

ANSWER TO MOTION OF AIR EXCURSIONS LLC 

Communications with respect to this document should be sent to: 

R. Scott Harris 

President 

Harris Aircraft Services, Inc. 

400 Airport Road 

Sitka, AK 99835 

November 5, 2014 

Pierre Murphy 

Law Offices of Pierre Murphy 

1200 New Hampshire Avenue, NW 

Suite 590 

Washington, DC 20036 

Telephone: (202) 776-3980 

Facsimile: (202) 776-3975 

Email: pmurphy@lopmurphy.com 

Attorney for 

Harris Aircraft Services, Inc. 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

) 

Application of ) 

) 

HARRIS AIRCRAFT SERVICES, INC. ) Docket DOT-OST-2014-0145 

) 

for a certificate of public convenience and ) 

necessity pursuant to 49 U.S.C. §41102 ) 

to engage in interstate scheduled air ) 

transportation of persons, property and mail ) 

ANSWER TO MOTION OF AIR EXCURSIONS LLC 

Pursuant to 14 C.F .R. §302.11 (c), Harris Aircraft Services, Inc. ("Harris Air" or 

"Applicant") respectfully submits this brief Answer to the most recent in a string of endless 

filings in various dockets1 against Harris Air filed by Air Excursions, LLC, d/b/a Alaska 

Seaplanes2 ("Air Excursions" or "lone Objector"). This latest filing is styled a Motion toReOpen the Record. 

Despite the title of its latest filing, it is patently clear that the lone Objector never regards 

1 In the past months, lone Objector or its sister company Kalinin Aviation have filed at least 8 pleadings in 

opposition to Harris Air. See: Docket DOT-OST-2014-0145 herein: 4 filings, so far. See also: Dockets DOT-OST2013-0089; 2008-0217 (EAS); and 2002-11586/2006-25542 (EAS). 

2 See: DOT Notice of Registration of Trade Name ("Alaska Seaplanes") by commonly-owned carriers Air 

Excursions and Kalinin Aviation, LLC. 
ANSWER OF HARRIS AIR 

TO MOTION 

any record involving Harris Air as ever being "closed", and Harris Air is obliged, once again, to 

respond to lone Objector's repeated attacks. 

In its latest blast at Harris Air, lone Objector attempts to make the case that Harris' 

service proposal in a pending EAS case is totally different from its service proposal herein, and 

that Harris Air has therefore improperly told the Department "different stories" in each 

proceeding thereby rendering Harris Air unfit to hold the certificate being applied for herein. 

Lone Objector is, once again, totally incorrect in its assertions. 

The Alaska EAS proceeding referenced by lone Objector in its latest filing relates to EAS 

service from 4 Alaska points3 (Dockets DOT-OST-2002-11586/2006-25542). The EAS office 

sent a copy ofEAS Order 2014-9-13 soliciting EAS service proposals to, inter alia, Harris Air. In 

that instituting Order, the Department specifically noted that Harris Air was, and is, currently 

providing air service meeting the EAS frequency minima from 3 of the EAS points4 at issue. 

See: DOT Order 2014-9-13, p. 2, n. 1. The Department also noted that if Harris Air's certificate 

application herein were approved, the issue of EAS subsidy at the 3 points at issue might have to 

be revisited. Id. In response to Order 2014-9-13, Harris Air submitted a service proposal 

3 Elfm Cove, Pelican, Angoon & Tenakee. 

4 Angoon, Pelican & Tenakee, AK. See: DOT Order 2014-9-13, p. 2, n. 1. 

2 
ANSWER OF HARRIS AIR 

TO MOTION 

without EAS subsidy. 

Therefore, contrary to lone Objector's arguments to the contrary, not only is Harris Air's 

current service in the 3 EAS markets reflected in its historic financial statement for its operations 

filed herein, this current service is also reflected in Harris Air's service proposed and the 

financial projections filed herein. Harris Air is therefore hardly telling "different stories" in the 2 

dockets. 

What is clearly motivating lone Objector in making its repeated filings, including its 

current Motion, against Harris Air in every docket available is not Harris Air's fitness to be a 

certificated air carrier since it is clearly fit; it is the fact of Harris Air's current operations from 

the 3 EAS points where lone Objector seeks subsidy for several years from 2015 onwards (and 

currently and since at least 2011 has received substantial EAS subsidy) and the possibility that 

because of the fact of Harris Air's current service in the 3 EAS markets, the need for EAS 

subsidy to lone Objector is rendered into question by the Department. Id. Lone Objector will 

therefore apparently do anything to prevent Harris Air from becoming a certificated air carrier 

holding the same authority lone Objector holds. 

In stark contrast to the multiple, repeated objections of lone Objector to Harris Air, there 

has been strong and overwhelming support for both Harris Air's existing services and its 

3 
ANSWER OF HARRIS AIR 

TO MOTION 

certificate application herein by the various relevant constituents, including: Alaska's 

Congressman, Rep. Don Young; the local representative to the Alaska Legislature, State Rep. 

Kreiss-Tomkins; plus the Alaska cities and communities Harris Air has been successfully serving 

for many years, 5 as well as various local businesses and the local school district, all of whom 

have for many years used and relied on the services that Harris Air provides. Lone Objector's 

Motion should be denied as a continuing misuse of the regulatory process. 

November 5, 2014 

Pierre urphy 

Law Offices of Pierre Murphy 

1200 New Hampshire Avenue, NW 

Suite 590 

Washington, DC 20036 

Telephone: (202) 776-3980 

Facsimile: (202) 776-3975 

Email: pmurphy@lopmurphy.com 

Attorney for Harris Aircraft Services, Inc. 

5 Cities of Pelican, Port Alexander and Klawock and the City & Borough of Sitka. 

4 
Certificate of Service 

I hereby certify that on November 5, 2014, a copy of the foregoing Answer of Harris Aircraft 

Services, Inc. was served via US Mail (and by electronic transmission where indicated) to the 

following persons: 

Attn: Terry L. Gordon 

Manager 

Attn: Troy McClanahan 

POI 

Juneau Flight Standards District Office (FSDO AL05) 

Federal Aviation Administration 

3032 Vintage Park Boulevard 

Suite 106 

Juneau,AK 99801 

Peter J. Lynch 

Assistant Chief Counsel for Enforcement AGC-300 

Federal Aviation Administration 

800 Independence A venue, SW 

Washington, DC 20591 

Regional Counsel, AAL-7 

Federal Aviation Administration 

Alaskan Region Headquarters 

222 West 7th Avenue, Suite 14 

Anchorage,AK 99513 

Office of Airline Info 

DOTIRIT AIBTS E-36-RTS-42 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Robert E. Cohn, Esq. (via email) 

Patrick R. Rizzi, Esq. 

Counsel for AIR E:XURSIONS, LLC/ALASKA SEAPLANES, LLC 

Hogan Lovells US, LLP 

Columbus Square 

555 13th Street, NW 

Washington, DC 20004 

robert.cohn@hoganlovells.com 

patrick.rizzi@hoganlovells.com 

Kristin Leake