BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

) Application of ) ) AVIATION SERVICES, LTD. ) DOCKET DOT-OST-2010-0190* (d/b/a FREEDOM AIR (Guam)) ) ) for a Certificate of Public Convenience ) and Necessity (Foreign Passenger ) Charter Service) )

REPLY OF AVIATION SERVICES, LTD. (d/b/a FREEDOM AIR (Guam))

Communications with respect to th is document should be sent to:

Gregory P. Cirillo Wiley Rein LLP 7925 Jones Branch Drive McLean, Virginia 22102 Ph: 703-905-2800 Fx: 703-905-6701 E: GCirillo@wileyrein.com

March 9, 2011

* A substantively identical Reply has been filed in the related docket DOT-OST-2010- 0153.1 BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

) Application of ) ) AVIATION SERVICES, LTD. ) DOCKET DOT-OST-2010-0190 (d/b/a FREEDOM AIR (Guam)) ) ) for a Certificate of Public Convenience ) and Necessity (Foreign Passenger ) Charter Service) ) )

REPLY OF AVIATION SERVICES, LTD . (d/b/a FREEDOM AIR (Guam))

By letter of February 14, 2011, the Air Li ne Pilots Association (“ALPA”) sought

to bring certain facts to the attention of the Department of Transportation that ALPA

thought relevant to the applications of Aviation Services, Ltd. (d/b/a/ Freedom Air

(Guam)) (“Freedom Air”) in the above-captione d matter. A substantially similar filing

was made by Cape Air on March 7, 2011.

As further explained and established by the attached Affidavit of fact, the

operations that were the subject of the fore going filings were unrelated to Freedom Air

and therefore unrelated and irrelevant to the pending applications that are the subject of

this docket. While Freedom Air would in tend to employ the d/b/a “Fly Guam” when

authorized, that d/b/a is not owned by nor ex clusive to Freedom Air and can, and will, be

employed in other contexts in compliance with applicable law.

Freedom Air trusts that the Department wi ll not permit further delay as a result of

these filings, and will issue its Order to Show Cause promptly (whereupon interested2 parties may bring such other information to the Department’s attention as they deem

appropriate).

Respectfully submitted,

Gregory P. Cirillo Wiley Rein, LLP 7925 Jones Branch Drive McLean, VA 22102 703-905-2800 703-905-7601 (fax) gcirillo@wileyrein.com Counsel for Aviation Services, Ltd.

March 9, 20113 CERTIFICATE OF SERVICE

I hereby certify that I have, this 9t h day of March, 2011, caused the attached

Reply on the following persons:

Vanessa R. Balgobin Air Carrier Fitness Division U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, DC 20590

Stanley C. Chuck Principal Maintenance Inspector FAA-HNL CMO 135 Nakolo Place Honolulu, HI 96819

Tim McCarthy FAA-HNL CMO 135 Nakolo Place Honolulu, HI 96819

Lisa Kiele, Vice President Business Development & Distribution Cape Air 660 Barnstable Road Hyannis, MA 02601 John R. Byerly Deputy Assistant Secretary, Transportation Affairs U.S. Department of State 2201 C Street, NW Washington, DC 20520

R. Bruce Keiner, Jr. Crowell & Moring LLP 1001 Pennsylvania Avenue, NW Washington, DC 20004-2595 rbkeiner@crowell.com

Russell Bailey David Semanchik Air Line Pilots Association, Int’l 1625 Massachusetts Ave., NW Suite 800 Washington, D.C. 20036

______________________________ By:

for Aviation Services, Ltd. (d/b/a Freedom Air (Guam))