BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

v'RTMENTOF 

•vS?CRIATICM 

:n !.zp o n A i I - "^ I 

Application of 

SUN AIR EXPRESS, LLC d/b/a SUN AIR 

INTERNATIONAL 

For authority to conduct scheduled passenger 

operations as a commuter air carrier under 49 

U.S.C. 41738 

Docket OST-2011-0169 

SUPPLEMENT NO. 3 TO THE APPLICATION OF 

SUN AIR EXPRESS, LLC d/b/a SUN AIR INTERNATIONAL 

AND OPPOSITION TO SEAPORT AIRLINES. INC.'S MOTION AND COMMENTS 

Communications with respect to this Application should be sent to: 

Thomas L. Cooper 

Chief Executive Officer & President 

SUN AIR EXPRESS, LLC d^/a 

SUN AIR INTERNATIONAL 

3201 Griffm Road 

Suite 100 

Fort Lauderdale, FL 33312 

(954) 660-9865 

FAX: (954)359-9502 

tlcooper(g)gosunair.net 

Lormie Anne Pera 

ZUCKERT, SCOUTT & RASENBERGER, 

L.L.P. 

888 Seventeenth Street, N.W. 

Suite 700 

Washington, D.C. 20006 

(202) 973-7913 

FAX: (202)342-0683 

lapera@zsrlavy.com 

Counsel for Sun Air Express, LLC d/b/a Sun 

Air International 

Dated: February 28, 2012 
BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

Application of 

SUN AIR EXPRESS, LLC d/b/a SUN AIR 

INTERNATIONAL 

For authority to conduct scheduled passenger 

operations as a commuter air carrier under 49 

U.S.C. 41738 

Docket OST-2011-0169 

Dated: February 28, 2012 

SUPPLEMENT NO. 3 TO THE APPLICATION OF 

SUN AIR EXPRESS, LLC d/b/a SUN AIR INTERNATIONAL 

AND OPPOSITION TO SEAPORT AIRLINES, INC.'S MOTION AND COMMENTS 

Sun Air Express, LLC d/b/a Sun Air International ("Sun Air" or the "Company") hereby 

submits this Supplement No. 3 to its previously filed Application for Commuter Air Carrier 

Authority (the "Commuter Air Carrier Application" or the "Application"). Sun Air filed the 

Application on September 9, 2011. This Supplement No. 3 updates Sun Air's management team. 

Sun Air also responds to the Motion and Comments of SeaPort Airlines, Inc. ("SeaPort"), 

requesting that the Department suspend further review of the Application. SeaPort apparently 

objects to the Application because it is under the impression that Sun Air (a) has not advised the 

Department of its plans to seek authority to provide service between Memphis and three 

Essential Air Service ("EAS") communities' and (b) is not complying with Part 204 

' On January 18, 2012, Sun Air submitted a proposal to provide service between Memphis 

on the one hand and Greenville, Muscle Shoals, and Tupelo on the other hand. This EAS 

proposal is still pending before the Department's EAS and Domestic Analysis Division (the 

"EAS Division"). 
SUPPLEMENT NO. 3 TO APPLICATION OF 

SUN AIR EXPRESS, LLC d^/a 

SUN AIR INTERNATIONAL 

Page 2 

requirements to provide updated financial information. Nothing could be further from the truth. 

For the reasons set forth below. Sun Air requests that the Department deny SeaPort's Motion and 

conclude its review of the Commuter Air Carrier Application. 

Sun Air is anxious to commence commuter air carrier services. It respectfully requests 

that the Department process its Application promptly. 

I. Supplement No. 3 to Application 

1. In the Commuter Air Carrier Application, Sun Air noted that it was located on the 

fourth floor of 3201 Griffin Road, Fort Lauderdale, Florida. It has since moved to a different 

suite in the same building. The new address is: 

Sun Air Express, LLC d/b/a Sun Air International 

3201 Griffin Road 

Suite 100 

Fort Lauderdale, FL 33312. 

2. The Application also identified Robert Booth as Director of Operations and 

Lahouari Otmane as Chief Pilot. The resumes of these two key personnel were enclosed in 

SUN-Exhibit 604 and SUN-Exhibit 606, respectively. 

2. Since the Application was filed, Mr. Booth has departed the Company. Sun Air 

has replaced Mr. Booth by promoting Mr. Otmane to Director of Operations. Sun Air also has 

hired Mark D. Reichard as the new Chief Pilot. Sun Air has not made any other changes to its 

management team. 

3. Sun Air encloses Revised SUN-Exhibit 601 to identify its current management 

team. Sun Air, moreover, has enclosed an updated resume of Lahouari Otmane in Revised SUNExhibit 606. In SUN-Exhibit 608, Sun Air submits the resume of Mark D. Reichard, the Chief 
SUPPLEMENT NO. 3 TO APPLICATION OF 

SUN AIR EXPRESS, LLC d/b/a 

SUN AIR INTERNATIONAL 

Page 3 

Pilot. A revised SUN-Exhibit 607 states the business affiliation(s) of each management team 

member. 

4. The Federal Aviation Administration has authorized these changes. The 

Department should have the necessary information to complete its review of the Application. 

II. Answer to SeaPort Airlines' Motion and Objection 

1. More than a month after Sun Air filed a proposal to provide service between 

Memphis and three EAS communities, SeaPort has filed a motion for leave to file a very late 

objection to Sun Air's Commuter Air Carrier Application. Importantly, SeaPort does not object 

to Sun Air's proposal to provide daily commuter air carrier services between Miami, Florida and 

Bimini, the Bahamas.^ Nor does SeaPort apparently object to Sun Air's forecast and financial 

data submitted in connection with that service proposal. See SeaPort Comment at 3 (stating that 

Sun Air's available capital "may be sufficient to meet the Department's financial fitness criteria 

based on the operating plan that Sun Air described in its Application"). While SeaPort states that 

it is not objecting to competition in the Memphis market (SeaPort Comment at 6), this is exactly 

what SeaPort is doing. By objecting to the Application pending before the Department's Air 

Carrier Fitness Division, SeaPort is hoping to stop Sun Air from offering any commuter air 

carrier services whatsoever -just so that a different Department division will never consider Sun 

Sun Air notes that SeaPort's comments relate to the initial service between West Palm 

Beach and Freeport. As the Department knows. Sun Air filed an amended application on 

September 23, 2011, changing its service proposal to daily roundtrip service between Miami and 

Bimini. 
SUPPLEMENT NO. 3 TO APPLICATION OF 

SUN AIR EXPRESS, LLC d/b/a 

SUN AIR INTERNATIONAL 

Page 4 

Air's EAS proposal. If SeaPort has concerns about Sun Air's EAS proposal, it should have 

provided those comments to the EAS Division. 

2. SeaPort, moreover, suggests that Sun Air has not communicated with the 

Department about its plans to submit the EAS proposal. This simply is not the case. Sun Air 

confirmed with the Air Carrier Fitness Division that it could submit an EAS proposal to the EAS 

Division while the Commuter Air Carrier Application was pending and that it did not need to 

provide updated financial information unless and until the EAS Division selected Sun Air as the 

carrier for the proposed EAS service. Sun Air, moreover, confirmed with the EAS Division that 

it could submit the EAS proposal while the Application was pending. Sun Air submitted the 

EAS proposal on January 18, 2012 only after ensuring that it was complying fully with 

Department requirements. It is not appropriate to suggest, as SeaPort did, that Sun Air has done 

anything improper. 

3. The Department's EAS Division is still considering Sim Air's EAS proposal as 

well as other competing proposals. If the EAS Division selects Sun Air to provide service 

between Memphis and the EAS communities. Sun Air will submit the required updated forecast 

and financial information to the Air Carrier Fitness Division. In the meantime, the Department 

can proceed with its review of the Commuter Air Carrier Application. 

4. The Air Carrier Fitness Division has a separate review process fi-om that of the 

EAS Division. There is no reason for this division to delay processing of Sun Air's Conmiuter 

Air Carrier Application, an application that has been pending since September 2011. Sun Air 

has provided complete data in accordance with the Regulations relating to its proposed 

commuter air carrier services between Miami and Bimini. SeaPort has not raised any objection 
SUPPLEMENT NO. 3 TO APPLICATION OF 

SUN AIR EXPRESS, LLC d/b/a 

SUN AIR INTERNATIONAL 

Page 5 

to the proposed Miami-Bimini service or to the financial information provided in connection 

with that service proposal. The Department, therefore, has all of the information it needs to 

conclude its review of the Application. 

WHEREFORE, Sun Air Express, LLC d/b/a Sim Air International respectfully requests 

that the Department authorize it to conduct scheduled commuter air transportation services under 

49 U.S.C. § 41738 and 14 C.F.R. Part 298. Sun Air also requests such fiirther, different, and 

additional relief as the Department may deem to be appropriate. 

Respectfully submitted, 

ZUCKERT, SCOUTT & RASENBERGER, L.L.P. 

By: 

Lonnie Anne Pera 

David M. Endersbee 

888 Seventeenth Street, N.W. 

Suite 700 

Washington, D.C. 20006 

(202)973-7913 

Counsel for Sun Air Express, LLC d/b/a Sun Air 

International 

Dated: February 28, 2012 
VERIFICATION 

This Third Supplement to the Commuter Air Carrier Application and the information 

therein, including the Exhibits attached hereto, are true and correct to the best of my knowledge 

and belief. Pursuant to Title 18, United States Code section 1001,1, Thomas L. Cooper, 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 cormection with the preparation, filing or prosecution of the Amended Application 

or the initial Application. I understand that an individual who is found to have violated the 

provisions of 18 U.S.C. § 1001 shall be fined or imprisoned not more than five years, or both. 

Respectfully submitted by 

Thomas L. Cooper 

Chief Executive Officer and President 

Sun Air Express, LLC d/b/a 
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Lahouari Otmane 

5950 SW 172 Ave. 

Southwest Ranches, FL 33331 

Revised SUN-606 

Page 1 of 1 

Tel: (954) 880-0001 

Cell: (954) 806-2141 

Slcype: none 

LICENSES AND RATINGS 

FAA ATPL - Airplane ME Land 

FAA CPL - Airplane SE Land& SE Sea 

FAA - First Class Medical 

FCC - Restricted Radiotelephone Operator Permit 

FLIGHT TIME 

Total Time 5500 

PIC time 4500 hrs Xcountry 

Multi time 3950 hrs Turbine 

EMPLOYMENT INFORMATION 

Sun Air Express, LLC 

Du-ector of Operations 

3580 hrs 

1000 hrs 

Night time 565 hrs 

Instrument 440 hrs 

Dec 2011 -Prese 

Chief Pilot July 2011 - Dec 2011 

Part 135 Chief Pilot - Duties and responsibilities per FARs 61, 91, 135, 119. Rewrite company Pilot Traming 

Manual and develop a GPS Training Course in preparation of obtaining Ops. Spec 8034. 

Gulfstream Connection May 2008-June 20 li 

Chief Pilot 

Assistant Chief Pilot - PIC - Flying cargo and passengers to domestic and international destinations mcluding 

Diplomatic flights to Cuba and Haiti's disaster area. 

DayJet 

First Officer 

Eclipse 500 SIC Flying passengers. 

Air Flight 

Captain 

PIC - Flying passengers, domestic and international 

Mar 2008 - May 2008 

Dec 2007 - Mar 2008 

Ai Dec 2006 - Dec 2007 r Repair 

Assistant flight trainmg director 

Support the director of training - Conducting and scheduling ground and flight training. 

EDUCATION. AWARDS AND ACHIEVEMENTS 

Science & Technology - "Lycee Colbert" - Lorient, France 

ADDITIONAL SKILLS 

Languages: English - French - Spanish - Polish - Arabic 

Computer skills, customer services. 

PERSONAL INFORMATION 

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Exhibit SUN-608 

Page 1 of 2 

Mark D. Reichard 

43 Oregon Lane, Boca Raton, Florida 33487 - (561) 901-5876 - reichardmark@yahoo.com 

Software Applications 

- Microsoft Office - Microsoft FrontPage - Microsoft Project 

- Microsoft Visio - Adobe FrameMaker - Adobe Acrobat 

Microsoft Outlook 

Flight Time 

- Total Time - 9700 - PIC - 5000 - Turbojet -120 

- TurboProp - 5200 - instrument - 350 - SIC -150 

Flight Engineer - 850 

Type Ratings 

- BE-1900 - EMB -120 - EMB-145 

- EMB-170 

Experience 

SunAir Express, LLC d/b/a Sun Air International, Ft. Lauderdale, FL (Feb. 2012 - Present) 

- Chief Pilot 

CommutAIr, Cleveland, OH (Jan. 2011 - Dec. 2011) 

- Manage compliance with 14 CFRs, lOSA requirements, SAI requirements. Analyze and 

rewrite Company manuals to verify compliance. 

- Develop an Implementation Plan for Safety Management System (SMS) 

- Manage Compliance with OSHA Regulations and 

- Managed relationships with FAA, Department Heads and other personnel. 

Gulfstream Connection, Ft. Lauderdale, FL (Sept. 2010 -Jan. 2011) 

- Manage compliance with 14 CFRs for Part 135. Analyze and rewrite Company manuals to 

verify compliance. Oversight for Pilot training. Flight and duty time limitations and Company 

Training Records. 

- Managed relationships with FAA. Department Heads and other personnel. 

Gulfstream Intenrationai Airlines, Ft Lauderdale, FL (Sept 2009 - Dec. 2010) 

Director of Regulatory Compliance and Project Integration 

- Oversee company manual conversion from MS Word to Adobe FrameMaker 

- Rewrite company manuals to System Safety conformance 

- Manage compliance with 14 CFRs, lOSA requirements, SAl requirements. 

- Managed relationships with FAA, Department Heads and other personnel. 

- Instruct FAA personnel on the use of Adobe Acrobat "Sticky Notes" functionality 

CAVOK Group, Inc., Keller, TX (Apr. 2004 - Sept 2009) 

Certification Program Manager (November 2004 - September 2009) 

- Manage SME staff assigned to a client's project. 

- Manage relationships with internal and external clients 

- Work on-site to develop manual content. 

- Conversion of source documents from MS Word, Acrobat PDF, etc. into other approved 

templates. 

- Edit documentation according to approved writing standards, including grammar and 

formatting consistencies 
Exiiibit SUN-608 

Mark D Reichard. Page 2 of 2 Page 2 of 2 

- Edit and manipulate photos and diagrams for Company documentation. 

- Prepare airline carrier manuals for revision process 

- Prepare airline personnel for the requirements of FAA processes 

Subject Matter Expert (April 2004 - Nov. 2004) 

- Work on-site to develop manual content. 

- Conversion of source documents from MS Word, Acrobat PDF, etc. into other approved 

templates 

- Edit documentation according to approved writing standards, including grammar and 

formatting consistencies. 

- Edit and manipulate photos and diagrams for in documentation. 

USAirways, Inc., Pittsburgh, PA (Sept 2002 - April 2004) 

EMB-170 Fleet Manager 

- Develop Aircraft Operating Manuals, Normal Checklist and Quick Reference Handbook 

- Develop Training time line for the implementation of the Training program from initial training 

to Airline Launch 

- Managed relationships with Aircraft Manufacturer and other operators 

- Developed and tested all training curricula for accuracy 

Continental Express, Houston, TX (June 2000 - August 2002) 

Assistant EMB-145 Fleet Manager (Sept. 2001 - August 2002) 

- Managed relationships with FAA, Check Airman and Flight Instructors assigned to the aircraft 

- Developed manual content and bulletins 

- Develop and execute focused training for annual recun'ent Check Airman and Instructor 

Training 

EMB-120 Fleet Manager (June 2000 - September 2001) 

- Managed relationships with FAA, Check Airman and Flight Instructors assigned to the aircraft 

- Developed manual content and bulletins 

- Develop and execute focused training for annual recurrent Check Airman and instructor 

Training 

Guifetream International Airlines, Ft Lauderdale, FL (Aug. 1991 -June 2000) 

Vice President of Training / Chief Pilot (1997- 2000) 

- Managed relationships with FAA, Line Pilots, Management Personnel, Check Airman and 

Flight Instructors assigned to the aircraft 

- Managed Flight Crewmember Training and Qualification records Department personnel 

- Managed Crew Scheduling Department personnel 

Beechcraft 1900 Fleet Manager/ Clieck Airman (1995 - 7997) 

- Managed relationships with FAA, Check Ainnan and Flight Instructors assigned to the aircraft 

- Developed manual content and bulletins 

- Developed Standardization criteria among Check Airman and Instructors 

Line Pilot (1993 - 1995) 

- Operated aircraft on scheduled flight to destination throughout the system in various weather 

conditions 

Director of Maintenance (1993) 

- Managed relationships with FAA, Management Personnel, Maintenance Supen/isor and Line 

Mechanics 

- Developed a Reliability Program for submission dellivered monthly to the FAA 

- Organized aircraft records for New Aircraft going on the Airline Operating Certificate. 

Line Aircraft Meclianic (1992 -1993) 

- Maintained company aircraft in accordance with the approved inspection program. 

- Performed preventive and unscheduled maintenance on company aircraft. 
CERTIFICATE OF SERVICE 

I hereby certify that on this 28"' day of February, 2012, a copy of the foregoing 

SUPPLEMENT NO. 3 TO THE APPLICATION OF SUN AIR EXPRESS, LLC d/b/a SUN AIR 

INTERNATIONAL AND OPPOSITION TO SEAPORT AIRLINES, INC.'S MOTION AND 

COMMENTS was served by facsimile on the parties named below: 

Mr. Loftis J. Rollins 

Flight Standards District Office-17 

Federal Aviation Administration 

2895 S.W. 145* Avenue 

Suite 120 

Miramar, FL 33027 

Loftis.j.rollins@.faa.gov 

David M. Hernandez 

Counsel for Silver Airways Corp. 

f/k/n VPAA Co. 

VEDDER PRICE P.C. 

1401 I Street, N.W. 

Suite 1100 

Washington, D.C. 20005 

dhemandez@.vedderprice.com 

Ms. Laura Remo 

Air Carrier Fitness Division, X-56 

Office of Aviation Analysis 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E., 8"^ Floor 

Room W-86-306 

Washington, D.C. 20590 

Laura.remo(S)dot. gov 

Mr. Timothy F. Sieber 

Vice President, Strategy & Corporate 

Development 

SeaPort Airlines, Inc. 

7505 NE Airport Way 

Portland International Airport 

Portland, OR 97218 

tsieber(g),seaportair. com 

L «rvv%»„jL 4.-7^ 

Lonnie Anne Pera