U.S. Department of 

Transportation 

Office of the Secretary 

Of Transportation 

August 23, 2012 

Mr. Robert E. Cohn 

Mr. Patrick R. Rizzi 

Counsel for Rhoades Aviation, Inc. d/b/a Trans air 

Hogan Lovells US LLP 

555 Thirteenth Street, N.W. 

Washington, DC 20004 

Re: Docket DOT-OST-2011-0216 

Application of Rhoades Aviation, Inc. d/b/a Trans air 

for section 41102 Certificate Authority 

Dear Messrs. Cohn and Rizzi: 

1200 New Jersey Ave., S.E. 

Washington, DC 20590 

We have completed our initial review of the application filed on July 24, 2012, by Rhoades 

Aviation,' Inc. d/b/a Transair ("Rhoades") for the determination of its fitness to conduct 

certificated interstate charter air transportation. 

This review has revealed the need for additional and/or clarifying information before we can 

complete the processing of Rhoades application. The attached Information Request lists the 

areas where further and/or clarification information is necessary. I ask that you respond fully to 

this request within 30 days of the date of this letter. Your response should filed in Docket DOTOST-2011-0216. 

As is the Department's practice, further processing of Rhoades application will be deferred 

pending receipt of this material. In addition, please remember that Rhoades should promptly 

provide the Department with any information regarding changes it may undergo in areas 

affecting its fitness (i.e., management, operating plans or financial condition, compliance 

disposition, or ownership) while its application is under review by the Department. 
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Thank you for your cooperation in this matter. If you have any questions regarding this letter or 

the requested information, please feel free to contact Reese Davidson of my staff at (202) 366-

8161 or via e-mail at Reese.Davidson@dot.gov. 

Lauraly Remo 

Chief, Air Carrier Fitness Division 

Office of Aviation Analysis 

Enclosure 

cc: Docket DOT-OST-2011-0216 

Ms. Mary Ballard 

POI for Rhoades Aviation, Inc. 

FAA Indianapolis FSD0-11 

1201 Columbia Road, Suite 101 

Plainfield, IN 46168 

Mr. Teimour Riahi 

Chief Executive Officer 

Rhoades Aviation, Inc. d/b/a Trans air 

100 Iolana Place 

Honolulu, HI 96819 
INFORMATION REQUEST 

RHOADES AVIATION, INC. D/B/A TRANSAIR ("Rhoades") 

GENERAL INFORMATION 

1. Please provide a statement from the Office of the Secretary of State, or another agent of 

the State in which the application is incorporated, certifying that the applicant is in good 

standing. 

2. Please provide a brief narrative history of the company, including a detailed description 

of the company's current operations. Has Rhoades continued to operate since being 

acquired? 

3. Has Rhoades or Transair Holdings already entered into any charter agreements to provide 

lift using their 737 should Rhoades receive the economic authority it seeks? If so, please 

provide us with details of such agreements. 

4. How does Rhoades intend to operate solely in Hawaii if their FSDO is located in 

Indiana? Does Rhoades plan to switch FSDOs? If so, when? 

5. Please inform us of the status of adding the 737 aircraft to Ops Specs? 

MANAGEMENT AND KEY TECHNICAL PERSONNEL 

1. Please verify if Thomas Andino is serving as Rhoades' Director of Maintenance in a 

permanent capacity. The application indicated that his appointment would be effective as 

of August 1, 2012. 

2. It appears that most of Rhoades' key personnel reside outside of Hawaii. How does 

Rhoades propose to conduct operations with key management and technical personnel 

living in such various areas? 

3. The resumes provided for Messrs. Donald A. Whitcomb and Thomas J. Andino do not 

show the date that they became employed by Rhodes or the date that they resigned from 

their former positions. Please provide an updated resume for each of the above noted 

personnel indicating when each became employees of Rhodes and resigned from their 

former employmeht. 

4. Please provide updated fitness questionnaires and resumes for the following key 

personnel: Mr. Teimour Riahi, Mrs. Marjan Azimi, Mr. Raja Segaran, and Ms. Tracy 

Reasoner. 

FINANCIAL POSITION 

1. Please provide current (within 3 months) compiled balance sheets and income statements 

for Rhoades. Please provide the financial statements for Rhoades as a distinct entity from 

the holding company. Please also include current (within 3 months) compiled balance 

sheets and income statements for Trans Executive in addition to the statements of 

Transair Holdings. 

2. Please provide a statement indicating that Transair Holdings will financially support 

Rhoades proposed operation and working capital needs. 

3. According to the application, Transair Holdings, Inc. and Trans Executive Airlines are 

co-borrowers on a $2,000,000 line of credit from Central Pacific Bank. Please provide 
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the terms and conditions of the line of credit so that we can determine whether it can be 

extended directly to Rhoades. In addition, please inform us if any money has been drawn 

to date from the line of credit or if there are any conditions that must be met before funds 

will be advanced. 

4. Please provide a description of the operations of Transair Holdings. Does Transair 

Holdings engage in any other businesses in addition to acting as the holding company for 

Trans Executive and Rhoades? 

5. Exhibit RDS-7, Page 2 of 3 does not indicate any money allocated for costs associated 

with aircraft leasing, insurance, or hangar fees for Rhoades. Please elaborate with a more 

detailed expense breakdown. In addition, certain expense categories included in Trans 

Executives' income statement are not included in Rhoades'. Please elaborate with more 

detailed financial statements for Rhoades. 

6. Exhibit RDS-7, Page 1 of 3 indicates $4,209,263 as a note payable to Transair. Please 

explain this note. 

7. Footnote 6 of the application indicates that Trans Executive also owns Boeing 737-2B1C 

bearing Registration # N808T A but no longer plans to use that aircraft for Trans air's 

cargo operations. What is Trans Executive doing with this other 737? 

The information provided pursuant to this Information Request should be accompanied by the 

following certification: 

The contents of this application and the attached exhibit (s) are true and correct to the 

best of my knowledge and belief. Pursuant to Title 18 United States Code Section 1001, 

I [the individual signing the application, who shall be a principal owner, senior officer, 

or internal counsel of the applicant], in my individual capacity and as the authorized 

representative of the applicant, have not in any manner knowingly and willfully falsified, 

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

fraudulent statement or knowingly used any documents which contain such statements in 

connection with the preparation, filing or prosecution of the application. I understand 

that an individual who is found to have violated the provisions of 18 U.S.C section 1001 

shall be fined or imprisoned not more than five years, or both.