Before the United States Department of Transportation

June 6, 2014

Essential Air Service at

KAKE,ALASKA

Under 49 U.S.C. 41731 et seq.

Docket OST-2008-0217

MOTION OF SEAPORT AIRLINES, INC. dba WINGS OF ALASKA

FOR LEAVE TO FILE AN UNAUTHORIZED DOCUMENT

SeaPort Airlines, Inc. dba Wings of Alaska motions for leave to file an authorized document in the

EAS docket of Kake, Alaska (DOT-OST-2008-0217) in response to a filing by Kalinin Aviation, Inc.

dba Alaska 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 of Alaska, Alaska Seaplanes, and Harris Air Service.

On May 29, 2014, Alaska Seaplanes filed a response to the proposals of Wings of Alaska and Harris

Air Service. Wings of Alaska is responding herein to Alaska Seaplanes and respectfully asks that the

Department include this document in Docket OST-2008-0217.

Communications with respect to these comments should be directed to:

Timothy Sieber

Executive Vice President

SeaPort Airlines, Inc.

7505 NE Airport Way

Portland, OR 97218

(971) 340-1716

tsieber@seaportair.com
Before the United States Department of Transportation

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"). Community comments were due on May 29,2014.

On May 29, 2014, Alaska Seaplanes filed a response to the proposals of Wings of Alaska 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 or during the meeting with community residents and leaders where all three

carriers outlined their proposals. More egregious, however, the information provided by Seaplanes

actually misrepresents some key facts that both the Department and community will presumably

include in their evaluation of respective carner proposals.

In this document, Wings of Alaska clarifies the record and responds to specific statements by

Seaplanes.

Medallion Foundation Safelv Program

On page 4 of its response, Seaplanes provides a table comparing,each of the carrier proposals with

an abitrary and self-serving rating system (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 is the ambiguous category "Medallion Safety." In the table, Seaplanes claims that

all three of the carrier's participate in the 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 is true that all three carriers participate in this program, the table is misleading as the level of

Medallion Safety certification by Seaplanes is not to the degree of that achieved by Wings of Alaska.

As noted in our EAS proposal:

"Of the two part 135 carriers with scheduled authority based at Juneau 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,

management and frontline alike."

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 is the capability to enter into interline e-ticketing agreements, one that Wings of Alaska has

and Seaplanes lacks. In its filing, Seaplanes down plays this advantage:

"Wings' modest ticket distribution advantages are the only component of its proposal

that is even marginally belter than Seaplanes. However, Seaplanes will soon have

equal capability. ,,1

The "modest ticket distribution advantage" Seaplanes refers to is the Amadeus AllEm reservation

system. This is the 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 is the most

advanced reservation platform in the 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 is Wings of Alaska:

Seaplanes claims it will "soon" have the same distribution capabilities as Wings of Alaska 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 of Alaska 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 of this

:} 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 in the event of a flight irregularity.

Hardly the "same" as Wings of Alaska.

Additionally, Seaplanes ignores the most important fact of all: Wings of Alaska is the 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 at Athens, 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 in Alaska 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 is that Athens is but one of 9 EAS markets that SeaPort Airlines, Inc. serves in the

Lower 486Since 2012, in each of the Lower 48 markets where contracts came up for renewal, we

have offered the communities the option of a two or four year renewal.? In every case, not only did

the community select SeaPort over competitive bids but they all selected a four year renewal term.

We believe our record of community partnerships in EAS markets speaks for itself.

Wings of Alaska Historv at Kake

In its filing Seaplanes, states:

4 See 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 Hot Springs, EI Dorado, and Harrison, Arkansas; Jackson, Tennessee; Pendleton, Oregon; Salina and

Great Bend (effective June 16, 2014), Kansas; and Imperial/EI Centro, 9alifomia.

7 Note the contrast of SeaPort offering communities the "option" of a fOUf year 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, or its record of actual service at Kake. 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 of Alaska today is a very 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 of Air Excursions should not be an issue during this carrier selection process as it was during

the 2012 EAS proceedings at Kake.

Finally, when criticizing Wings of Alaska's "actual record of service at Kake," Seaplanes opts to

ignore the fact that Wings of Alaska entry into Kake was with only a few 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 of Wings of Alaska 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. It would 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 a color graph.
COMMENTS OF SEAPORT AIRLINES, INC.

OST -2008-0217

PAGE 6

(1) service reliability;

(2) contractual and marketing arrangements with a larger carrier at the 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. If the

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 of Alaska is confident in the 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, if the Department determines that Harris does not presently have the necessary

authority to operate EAS and/or scheduled air service and if the 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 in the most ex1reme circumstances.

Summation

As we have outlined herein, the response by Seaplanes to Harris and Wings of Alaska 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 of Wings 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