### Before the United States Department ofTransportation 

### June 6, 2014

Essential Air Service at KAKE,ALASKA 

### Under 49 U.S.C. 41731 etseq. Docket OST-2008-0217

MOTION OF SEAPORT AIRLINES, INC. dba WINGS OF ALASKA FOR LEAVE TO FILE AN UNAUTHORIZED DOCUMENT 

### SeaPortAirlines, Inc. dbaWings ofAlaska motionsfor leaveto file an authorized document inthe EAS docket of Kake, Alaska (DOT-OST-2008-0217) in response to afiling by Kalinin Aviation, Inc. dbaAlaska Seaplanes. By Order 2014-3-15, the Department requested proposals from carriers interested in providing Essential Air Service at Kake, Alaska due by April 28, 2014. Three carriers submitted timely proposals:Wings ofAlaska,Alaska Seaplanes,and HarrisAirService.
On May29,2014,AlaskaSeaplanesfileda responsetothe proposalsofWings ofAlaskaand Harris AirService.Wings ofAlaska is responding hereintoAlaskaSeaplanes and respectfullyasksthatthe Department includethisdocument in DocketOST-2008-0217.
Communicationswith respecttothesecommentsshould bedirectedto: Timothy Sieber ExecutiveVice President SeaPortAirlines, Inc. 7505 NEAirportWay Portland,OR 97218 (971)340-1716 tsieber@seaportair.com

### Before the United States Department ofTransportation June 6, 2014

Essential Air Service at KAKE,ALASKA Under 49 U.S.C. 41731 et seq. Docket OST-2008-0217

COMMENTS OF SEAPORT AIRLINES, INC. IN RESPONSE TO KALiNIN AVIATION, INC.
By Order 2014-3-15, the Department requested proposals from carriers interested in providing Essential Air Service at Kake, Alaska due by April 28, 2014. Three carriers submitted timely proposals: Wings of Alaska, Alaska Seaplanes (hereafter "Seaplanes"), and Harris Air Service ("Harris"). Communitycommentswere dueon May29,2014.
OnMay29,2014,AlaskaSeaplanesfiledaresponsetothe proposalsofWings ofAlaska and Harris Air Service that curiously provided no additive information to the docket. Rather, Seaplanes' response constitutes nothing more than supplemental narrative that Seaplanes should have been included in its proposal orduring the meetingwith community residentsand leaderswhere allthree carriers outlined their proposals. More egregious, however, the information provided bySeaplanes actually misrepresents some key facts that both the Department and community will presumably include intheirevaluation of respectivecarnerproposals.
In this document, Wings of Alaska clarifies the record and responds to specific statements by Seaplanes.
Medallion FoundationSafelv Program On page4ofitsresponse, Seaplanes providesatable comparing,eachofthecarrierproposalswith anabitraryand self-serving ratingsystem(see Figure 1).COMMENTS OF SEAPORT AIRLINES, INC.

OST-2008-0217 PAGE 2

FIGURE 1. EAS PROPOSAL RATING SYSTEM INCLUDED IN SEAPLANES RESPONSE

CAPSTONE X Turbine Aircraft 

### 0 Multi-Engine X IFR capability X Known Ice Capability 

### 0 Online Reservation X Online Payment 

### 0 Own Aircraft X DOT Certificate 

### 0 Medallion Safety X TOTAL BENEFITS 6 Benefit Harris Air 

### ALASKA SEAPLANES X X X 

## X X X X 

## X X X 

### 10 Wings 

### X X 

# o X 

# o X 

## X 

# o X 

## X 7

Of particular note isthe ambiguous category "Medallion Safety." Inthe table, Seaplanes claims that all three of the carrier's participate inthe Alaska Air Carrier Association's Medallion Foundation, a non-profit organization promoting aviation safety through systems enhancements by providing management resources, training, and support to the aviation community.
While it istrue that all three carriers participate inthis program, the table is misleading as the level of Medallion Safety certification by Seaplanes is not to the degree of that achieved byWings ofAlaska. As noted in our EAS proposal:


### "Ofthetwo 

### part 135 carriers withscheduledauthoritybasedatJuneau International Airport, only Wings of Alaska has earned the Medallion Shield indicating achievement of all five cornerstones of the Medallion program along with engagement and support of the company's safety culture among all employees, managementandfrontlinealike."
The distinction is an important one, yet one that Seaplanes chose for whatever reason to overlook in its response.COMMENTS OF SEAPORT AIRLINES, INC.

OST-2008-0217 PAGE 2

"Modest" Ticketing Distribution Advantage The table also states that all three carriers have online reservation capabilities but that only Wings .of Alaska and Seaplanes have online payment capabilities. The key measurement that the table fails to include isthe capability to enter into interline e-ticketing agreements, one that Wings ofAlaska has and Seaplanes lacks. In its filing, Seaplanes down plays this advantage:

"Wings' modest ticket distribution advantages are the only component 

### ofits proposal that 

### is even marginally belter than Seaplanes. However, Seaplanes will soon have equal capability. ,,1
The "modest ticket distribution advantage" Seaplanes refers to isthe Amadeus AllEm reservation system. This isthe same platform used by leading global carriers such as Lufthansa, Air France, KLM, Emirates, TAM Brasil, and Alitalia, and which has been chosen by Southwest Airlines to become the single platform for both its domestic and international operations. Altea isthe most advanced reservation platform inthe world. To illustrate this point, only one airline in North America is presently fully compliant with lATA's Electronic Miscellaneous Document (EMD) mandate and that airline isWings ofAlaska: Seaplanes claims itwill "soon" have the same distribution capabilities as Wings ofAlaska has with Altea. This is a highly questionable claim, particularly given the number of times in its response that Seaplanes felt it necessary to state that it keeps its promises. Our questioning of this claim is based on the fact that virtually all attempts by "second-tier" reservation system providers to engineer lATA compliant bilateral interline e-ticketing capabilities have failed.' Based on this, unilateral interline ticketing (e.g., where the mainline carrier 

## can book on the regional carrier, but not vice versa) is likely the best that Seaplanes could achieve and that would not be "same" as Wings ofAlaska which is able to offer bilateral interline ticketing. •

1 Page 7

2 Electronic Miscellaneous Documents (EMDs) are intended to replace paper Miscellaneous Charge Orders (MCOs) that are used to collect payment for services and charges other than actual air transportation; The electronic format ofthis :}For purposes of this discussion, Wings of Alaska considers "first tier" reservation system providers to be Amadeus (Wings of Alaska's vendor), Sabre, and Travelport.COMMENTS OF SEAPORT AIRLINES, INC.

OST-2008-0217 PAGE 4

For example, Seaplanes would not be able t6 sell interline connections on its own website nor would its own airport personnel be able to electronically reissue tickets inthe event of aflight irregularity. Hardly the "same" as Wings ofAlaska. Additionally, Seaplanes ignores the most important fact of all: Wings of Alaska isthe only carrier among those that submitted proposals which offers full interline ticketing and through baggage check-in connecting service with Alaska Airlines at Juneau. Not "soon" as Seaplanes claims, but today.4 Comparisons with Athens Seaplanes attempts to make the issue of continued EAS eligibility atAthens, Georgia an issue relevant to Kake, Alaska. It is not. The EAS eligibility requirements that affect Lower 48 markets are not applicable)o EAS markets inAlaska and Hawaii. To raise this requirement in a discussion of EAS at Kake is nothing short of scare tactics by Seaplanes. Equally important, Seaplanes has chosen to hone in on the singular example of Athens where there are a litany of rnarket specific issues that are not relevant to Kakes What Seaplanes fails to point out, however isthat Athens is but one of 9 EAS markets that SeaPort Airlines, Inc. serves inthe Lower 486 Since 2012, in each ofthe Lower 48 markets where contracts came up for renewal, we have offered the communities the option of atwo or four year renewal.? In every case, not only did the community select SeaPort over competitive bids but they all selected afour year renewal term. We believe our record of community partnerships in EAS markets speaks for itself. Wings ofAlaska Historv at Kake In itsfiling Seaplanes, states:

4See discussion of "EAS Carrier Selection Criteria" below.

5 i.e., Replacement of EAS carrier that had an adversarial relationship with the community, proximity to Atlanta, failure of 'key community generators to utilize local airport, etc.

6 Other EAS markets are HotSprings, EI Dorado, and Harrison,Arkansas; Jackson,Tennessee; Pendleton, Oregon;Salina and Great Bend (effective June 16, 2014), Kansas; and Imperial/EI Centro, 9alifomia. 7Note the contrast ofSeaPort offering communities the "option"ofafOUfyear renewal to Seaplanes EAS proposal at Kake \Nhich includes only a four year term.COMMENTS OF SEAPORT AIRLINES, INC.

OST-200B-0217 PAGE 5

"All the color graphics in the world cannot overcome the basic inadequacy 

### of the Wings/SeaPort service proposal, orits record 

### ofactual service 

### atKake. B The record of service at Kake which Seaplanes refers to was four years ago and, as our growing operations across the country, investments in distribution technology, and bilateral interline agreement with Alaska Airlines illustrate, the Wings ofAlaska today is avery different airline from that of four years ago.
As an example, Seaplanes response went on at length explaining how it has been "upgrading safety and reliability of its aircraft." We commend Seaplanes for these activities and, as result, the safety record ofAir Excursions should not be an issue during this carrier selection process as itwas during the 2012 EAS proceedings at Kake. Finally, when criticizing Wings ofAlaska's "actual record of service at Kake," Seaplanes opts to ignore the fact that Wings of Alaska entry into Kake was with only afew days notice following the FAA certificate revocation of LAB Flying Service. When the community needed air service, Wings of Alaska stepped up and restored connectivity.
EAS Carrier Selection Criteria As we have outlined above, the response of Seaplanes to the proposals ofWings ofAlaska and Harris added nothing of substance that would be of use to either the Department or community of Kake as they undertake each carrier's bids. To the contrary, the response appears to be nothing more than a distraction from the key criteria upon which the DOT is required to evaluate proposals.
As footnoted in our EAS proposal, Wings of Alaska believes that the benefits of our interline agreement with Alaska Airlines to Kake residents should result in favorable consideration of our proposals. Itwould also be consistent with 49 U.S.C. ~41733 (c) (1) which directs the Department to consider four factors when selecting a carrier to provide Essential Air Service:

8 Ironically, the EAS proposal of Seaplanes included color photographs and on the page before this statement the response of Seaplanes includes acolorgraph.COMMENTS OF SEAPORT AIRLINES, INC.

OST-2008-0217 PAGE 6 (1) service reliability; (2) contractual and marketing arrangements with a larger carrier atthe hub; (3) interline arrangements with a larger carrier at the hub; and (4) community views.
That being said, we have no desire to be forced upon the residents of Kake, Alaska. Ifthe community prefers another carrier's proposal, we will fully respect the community's decision. Regarding Harris Air Service With respect to the proposal of Harris, Wings ofAlaska is confident inthe ability of the Department to determine whether each entity that submits a proposal has the requisite authority to operate scheduled air service and, as a result, ability to meet the minimum service levels as requested by the Department in Order 2014-3-15.
That being said, ifthe Department determines that Harris does not presently have the necessary authority to operate EAS and/or scheduled air service and ifthe community demonstrates a preference for Harris over Seaplanes, we urge the Department to award the EAS contract for no longer than two years (and preferably only one) thus allowing for a new round of proposals in reasonable time frame during which Harris would have the opportunity to obtain necessary certificates.
As noted above, we do not wish to be, nor do we believe any EAS carrier should be, forced upon a community against its will except inthe most ex1reme circumstances.
Summation As we have outlined herein, the response by Seaplanes to Harris and Wings ofAlaska provided no substantive or new information and, to the contrary, was nothing more than an attempt to restate information provided in its proposal and subsequent community presentation or, in some cases, to distract the community's and Department's attentions from the key advantage ofWings of Alaska with respect to interline connectivity.COMMENTS OF SEAPORT AIRLINES, INC.

OST

### -2008-0217 PAGE 7

We trust that both the Department and community will make their respective choices based on the merit of each carrier's proposal and in manner consistent with criteria setforth in

### 49 U.S.C. 

### S41733 (c) (1). Respectfully submitted,
Timothy F. Sieber Executive Vice President June 

### 6,2014