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u.s. Department of

Transportation

Office of the Secretary

Of Transportation

April 11,2014

1200 New Jersey Ave., S.E.

Washington, DC 20590

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Ms. JoAnn Wolters

GemAirLLC

31 Hamner Drive

Salmon, ID 83467

Dear Ms. Wolters:

We have completed our initial review of the information you filed on February 12, 2014, on

behalf of Gem Air LLC ("Gem Air"), for the determination of its fitness to conduct commuter

operations. We have determined that we will need the following additional information and/or

clarifying information before we may complete our review:

Ownership

1. Please clarify who will be Chief Executive Officer ("CEO") of Gem Air. FAA records

list Mr. Schroeder as CEO and the application lists you as CEO.

2. Please provide an affidavit of citizenship for Gem Air, the applicant.

Management

1. Mr. Schroeder's resume states that he was Director of Operations for Gem Air only from

2007 until 2008, though the application identifies him as currently serving as Gem Air's

Director of Operations and Chief Pilot. Please clarify and provide an updated resume

that includes the position(s) he currently holds with the applicant and the dates he has

served in that/those position(s).

Financial Position

1. Will Spirit Air, Inc. ("Spirit Air"), provide any funding to Gem Air? If so, please provide

a statement from Spirit Air stating this and third-party verification from the bank

confirming Spirit Air's ability to provide any financial support to Gem Air.

2. Please define "professional fees" and also explain the $107,927 sale of assets indicated

on page 3 of the "Statement of Revenues and Expenses December 31, 2013 and 2012" for

Spirit Air.

3. Please explain the large differences in expenses for repair and maintenance, shop

supplies, and contract work for Gem Air in the years 2012 and 2013 and why there were

no salary expenses in 2012.

Operations

1. When does Gem Air anticipate starting commuter operations?

2. Is Gem Air currently operating? If so, where? And, if currently operating, please

provide a forecast for the on-demand operations, a forecast for the proposed commuter

operations, and a consolidated forecast for both operations.
3. Please provide another Affidavit of Safety Compliance specifying either Part 121 or Part

135 operations.

4. When will the Kodiak 100 aircraft be added to the certificate?

5. How many other aircraft will have to go through the aging aircraft inspection?

Please 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, W12-140, 1200 New

Jersey Avenue SE, Washington, D.C. 20590. In either case, your response should be filed in

Docket DOT-OST-2014-0020.

Please include a statement signed by a representative of the air carrier [who shall be a principal

owner, senior officer, or internal counsel of the carrier] indicating that, pursuant to Title 18

United States Code Section 1001, the information provided in response to this letter is true and

correct and that the aforementioned individual has not knowingly and willingly falsified,

concealed or failed to disclose any material fact or made any false, fictitious, or fraudulent

statement in connection with the preparation or filing of the material submitted.

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

the requested information, please contact Barbara Snoden of my staff at (202) 366-9721 or via

email at Barbara.Snoden@dot.gov.

lyn J. Remo

Chief, Air Carrier Fitness Division

Office of Aviation Analysis

cc: Docket DOT-OST-2014-0020

Mr. Patrick Darling

POI for Gem Air LLC

FAA Boise FSDO

3295 Elder St. Suite 350

Boise, ID 83705

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