From: jptgilmore@hotmail.com

To: george.wellington@dot.gov

CC: pat.snyder7@verizon.net

Subject: RE: Airone Ventures Limited : Application For An Exemption Under 

49 U.S.C. § 40109(c) - (U.S.- Barbados) - Docket DOT-OST-2010-0134

Date: Tue, 25 May 2010 20:11:45 +0100

Mr. Wellington:

Further to Ms. Snyder's E-Mail to you (below) I will post my initial 

E-Mail (also below), her response and this follow up on the Docket

as a single document.

I would appreciate a response to the procedural question raised

and apologise for my submission as to the substantive standards

for proceedings of this type which should more appropriately

have been reserved for my Answer to the Application.

Sincerely,

John P.T. Gilmore

205 – 4250 St. Ambroise

Montreal, Quebec

Canada H4C 3R4

Telephone: 514 716 7665

E-Mail : jptgilmore@hotmail.com

Date: Tue, 25 May 2010 14:10:08 -0400

Subject: FW: Airone Ventures Limited : Application For An Exemption Under 49 

U.S.C. § 40109(c) - (U.S.- Barbados) - Docket DOT-OST-2010-0134

From: pat.snyder7@verizon.net

To: George.Wellington@dot.gov

CC: jptgilmore@hotmail.com

Dear George:

Mr. Gilmore has kindly alerted us to an undocketed proceeding involving Air 

Jamaica, an Airone competitor, which has not been made public and of which 

we were previously unaware. We would be interested in knowing how the 

Department finally determines that matter, particularly since Mr. Gilmore 

has raised questions of U.S. international aviation policy vis-à-vis the 

Caribbean in response to the Air Jamaica application. 
Regardless of how the Department chooses to proceed with that matter, we 

support the Department’s policy of openness and transparency to the extent 

possible. We would therefore be most grateful if the Department would 

ensure that any correspondence from the public responding to our 

application were filed in the docket. Although we are grateful to Mr. 

Gilmore for sending us a copy of his email, it should have been placed in the 

docket, particularly since the email does not ask a simple procedural 

question. Rather, it contains argument on the merits regarding the 

substantive standards to be applied to an application for exemption by a 

foreign air carrier. 

Best Regards,

Pat Snyder

Patricia N. Snyder

Of Counsel

Troutman Sanders LLP

Pat.Snyder7@verizon.net

703-615-8853 (mobile)

202-654-6664 (fax)

www.troutmansanders.com

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From: JOHN P.T. GILMORE <jptgilmore@hotmail.com> 

To: George Wellington <george.wellington@dot.gov> 

Cc: Hunnicutt, Charles A.; Snyder, Patricia N.; Connor, Brent 

Sent: Mon May 24 10:54:31 2010

Subject: AirOne Ventures Limited : Application For An Exemption Under 49 U.S.C. § 

40109(c) - (U.S.- Barbados) - Docket DOT-OST-2010-0134 
AirOne Ventures Limited : Application For An Exemption Under 49 

U.S.C. § 40109(c) - (U.S.- Barbados) - Docket DOT-OST-2010-0134

Mr. Wellington:

I have a procedural question relative to the subject 

Application.

14 CFR 211.20 provides that ‘The Department may require an applicant 

to provide additional information as necessary.’

Is it the normal procedure for the Department to take steps 

to ensure that an Application is complete with respect to the 

requirements of 14 CFR 211.20 or are interested Parties 

required to request such completion by Motion under 14 CFR 

302.11?

While my concern relates principally to the incomplete 

nature of the application with respect to 14 CFR 211 (k), (n) 

and (p), a check list approach to 211.20 will reveal other 

missing elements.

Without an aircraft acquisition schedule, a balance sheet in 

the form specified, and monthly traffic forecasts and 

financial results (Income Statement and Balance Sheet) for 

the proposed services for the first full year of normal 

operations and the supporting data employed to calculate those financial 

forecasts, it is impossible to assess the applicant’s fitness; specified in the 

Department’s Foreign Air Carrier InfoPak (Page 5), as:

‘whether the air carrier is operationally and financially fit and has a positive 

compliance disposition. Here we look at whether the air carrier has experienced 

management, and whether its operating plan and financing appear reasonable. In 

this context, we are looking primarily at economic fitness, that is, whether the air 

carrier will be in a position to conduct its proposed operations without putting U.S. 

passengers’ and shippers’ funds at risk;’

Further, since in my submission, the financial requirements 

for an initial applicant for a foreign air carrier permit or 

exemption should not be any less demanding / more 

favourable than those applicable to a US applicant for an 
initial certificate for foreign passenger and/or cargo authority 

under section 49 USC 41102, the financing plan and 

financial forecasts required of the former should be at least 

as comprehensive and detailed as those required of the 

latter.

Those requirements are summarised in the Department’s 

May 2005 Information Packet on ‘How to Become a 

Certificated Air Carrier’.

Would you also please advise whether the time period for 

Answers to the Application would run from the day after the 

complete required information is filed by the Applicant or 

remain as at present with a further opportune ity to 

comment on the additional information when filed.

I have copied this to Counsel for the Applicant but would be 

pleased to send copies to all those on the Service List and 

post this on the Docket should the Department so wish.

An early response would be appreciated as the final date for 

Answers to the Application is 15 days from the date posted 

on the DMS - May 18, 2010.

Sincerely,

John P.T. Gilmore

205 – 4250 St. Ambroise

Montreal, Quebec

Canada H4C 3R4

Telephone: 514 716 7665

E-Mail : jptgilmore@hotmail.com