### BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

_________________________________________ ) Application of ) ) CARIBBEAN SUN AIRLINES, INC. D/B/A ) WORLD ATLANTIC AIRLINES ) DOCKET OST

- 20 14- ) for a Certificate of Public Convenience ) and Necessity ( Interstate Passenger ) Charter Service) ) _________________________________________ )
APPLICATION OF CARIBBEAN SUN AIRLINES, INC. D/B/A W ORLD ATLANTIC AIRLINES FOR A CERTIFICATE OF P UBLIC CONVENIENCE AND N ECESSITY Communications with respect to this document should be sent to: John R. Mietus, Jr. L aw Office of John Mietus, LLC 6701 Democracy Blvd., Suite 300 Bethesda, MD 20817

- 7500 (202) 747

- 5212 j ohn@mietuslaw.com C ounsel for CARIBBEAN SUN AIRLINES, INC. d/b/a WORLD ATLANTIC AIRLINES
APPLICANT REQUESTS THAT THIS APPLICATION BE PROCESSED THROUGH EXPEDITED, NON

- HEARING PROCEDURES PURSUANT TO SUBPART B OF THE DEPARTMENT’S PROCEDURAL REGULATIONS. NOTICE: Any person may support or oppose this application by filing an answer no later than September 23 , 2014 and serving a copy of the answer on counsel for Applicant and upon persons served with this application. September 2 , 2014

### BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

_________________________________________ ) Application of ) ) CARIBBEAN SUN AIRLINES, INC. D/B/A ) WORLD ATLANTIC AIRLINES ) DOCKET OST

- 2014 - ) for a Certificate of Public Convenience ) and Necessity (Interstate Passenger ) Charter Service) ) _________________________________________ ) APPLICATION OF CARIBBEAN SUN AIRLINES, INC. D/B/A WORLD ATLANTIC AIRLINES FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY

Pursuant to 49 U.S.C. § 41102, parts 201 and 204 of the Department’s Economic Regulations, subpart B of the Department’s Procedural Regulations, and the Department’s Streamli ning Initiative in Docket OST

2005

- 22228, Caribbean Sun Airlines, Inc. d/b/a World Atlantic Airlines (“World Atlantic”) respectfully applies for a certificate of public convenience and necessity authorizing World Atlantic to engage in interstate charter ai r transportation of persons, property, and mail. World Atlantic requests that the Department process this application expeditiously and proceed directly to
a final order

. In support of its application, World Atlantic states as follows:
1. World Atlantic, based in Miami, Florida, has been operating passenger charters with its fleet of MD

- 80 type aircraft since its certificate authorizing foreign charter air transportation of persons, property, and mail

### World Atlantic Certificate Application Page 2 was made effective in September 2010. See Orders 2009

- 12

- 8 ( s how c ause),
2010 -3- 7 ( f inal) , and 2010 -9- 34 ( e ffective c ertificate)

. 1 

### With the approval of the Air Carrier Fitness Division, most recently in August 2014, t he airline has expanded its fleet from one to five aircraft. Its operations for the U.S. government, several licensed operators of U.S.

- Cuba charters, and public charter operators have been well

- received. The requested interstate certificate will permit World Atlantic to expand its services within the United
States.

2 . Under 49 U.S.C. § 41102(b)(1), the Department may issue interstate authority if the applicant is a U.S. citizen and meets the Department’s fitness requirements ; no findings as to public convenience and necessity or the public
interest are required

. In the course of requesting fleet increases, t he carrier has provided the Department with information , for the most pa rt confidential, demonstrating its continuing fitness. S ince World Atlantic’s proposed interstate charter operations are not a “substantial change” from its existing foreign charter operations, it submits that the Department has sufficient information to act on this application 2 

### and to proceed directly to a

1/ World Atlantic held interstate charter authority when its current owner purchased it, but because there were then no firm plans for interstate service, the Department revoked the authority. Order 2009

- 10

- 12.
2/ See 14 C.F.R. § 204.6; Atlas Air, Inc. , Or der 2011 -5- 18 (adding interstate authority) ; Private Jet Expeditions, Inc. , Order 89 -7- 29 ( same ). Cf. Southwest Airlines Co. , Order 86 -5- 60 (adding mail authority to existing interstate authority).

### World Atlantic Certificate Application Page 3
fin al order using simplified, non

- hearing procedures

. 3 

### Key, public information concerning World Atlantic’s updated fitness is set forth below.

3. World Atlantic remains privately and wholly

- owned by a U.S. citizen, Tomas Romero, and managed by a Board of Directors and key personnel who are all U.S. citizens and listed below

. 4 

### K ey personnel not
named in the earlier World Atlantic orders cited above are shown with an asterisk, and capsule biographies are provided below; WAA has previously provided the Department with their resumes.

B oard of Directors
Tomas E. Romero President and CEO Florentino L. Gonzalez Executive V.P. & CFO John R. Rupert V.P. & Director of Operations Key Management Personnel
Tomas E. Romero President and CEO Florentino L. Gonzalez Executive V.P. & CFO Ray Bradley V.P. & Director of Technical Operations John R. Rupert V.P. & Director of Operations Capt. Thomas B. Van Halm Chief Pilot Patrick Joseph* Director of Safety John Barnes* Director of Q.C. & Chief Inspector Pedro Ruiz* Director of Maintenance

3/ See 14 C.F.R. §§ 302.15, 302.207 ; KaiserAir , Inc. , Order 2013 -5- 8 at 2; and cases cited in note 2.
4/ Chief Pilot Captain Van Halm holds dual Dutch/U.S. citizenship.

### World Atlantic Certificate Application Page 4 Patrick Joseph, Director of Safety Mr. Joseph, most recently World Atlantic’s Manager of Dispatch, began his airline career at Fine Airlines and served in management positions at BW IA West Indies Airways and Falcon Air Express before joining World Atlantic in 2009. He holds a degree from the University of the Virgin Islands. John Barnes, Director of Quality Control and Chief Inspector Mr. Barnes has held maintenance positions of increasing responsibility at such carriers as Batch Air, Arrow Air, and Miami Air before joining World Atlantic in 2010. He began his aircraft maintenance career in the U.S. Navy and holds an FAA airframe and powerplant l icense. Pedro (Pete) Ruiz, Director of Maintenance Mr. Ruiz joined World Atlantic from Falcon Air Express, where he once held the Director of Maintenance position, and has been involved in airline maintenance since 1984. He holds an FAA airframe and powerplant license. 

### 4. World Atlantic anticipates that new interstate operations – expected to include sports team operations, occasional private charters, and
subservice for other carriers – would account for no more than 10% of its total operations. As a proxy for the forecast incremental cost of those new operations, World Atlantic is attaching as an exhibit a summary of its recent submission to the Department estimating costs associated with adding an
aircraft to its fleet

. 5 / 

### Confidential financial statements and personal asset

5/ World Atlantic anticipates that it will continue to offer most charters as "ACMI" contracts, under which charterers will be contractually responsible for fuel costs; in such a case, the Department does not consider those costs in calculating financial requ irements. See, e.g., Dynamic Airways, LLC, Order 2010 -9- 17 at 5 -6.
The carrier does not anticipate the first full year of operations under the requested authority would result in a near

- term net annual change in aircraft fuel consumption of 10 million gallons or more, and it has determined that adequate fuel is available for this service. To the extent the Department nonetheless concludes that grant of the requested authority would constitute a major regulatory action, it requests that the Department waiv e the requirement that an Energy Statement under 14 C.F.R. Part 313 be prepared.World Atlantic Airlines Assumptions Financial Forecast 12 months period Based on the marginal revenue and cost of a sixth (one) aircraft

1) The sixth aircraft will operate150 block hours a month (116 flight hours). Those 150 block hours will be sold on an ACMI basis. 2) Rent of aircraft will be based ona minimum of $95,000 rent up tp 120 flight hours a month. The lease payment includes power by the hour for engines, C Check, landing gears and APU. 3) Flying operations include rent of additional aircraft, insurance for the additional aircraft, salaries for additional cockpit crews and some incidental additional expenses related to the additional crews. 4) Maintenance include the actual salaries (cost) of additional maintenance personnel, plus 25% of the total monthly cost of maintenance for 4 A/C less salaries. 5) Passenger service include the cost of additional flight attendants plus some incidental additional expenses related to the additional flight attendants. 6) Aircraft and traffic expenses includes 25% of the total monthly expenses for a 4 A/C operation based on an ACMI operation only, without additional airport and handling service normal in a charter operation. 7) General and administrative expenses include the actual payroll taxes for all the additionl personnel requiered , plus 25% of the total 4 A/C expenses that would be increased as result of an additional aircraft. 8) Pre- operating expenses include mostlytraining of pilots, flight attendants and mechanics, plus additional expenses as result of adding the 6th A/C 

### World Atlantic Certificate Application (2 pages)World Atlantic Airlines Incremental Expense Forecast Sixth Aircraft 12 months period Sixth (6th) Sixth (6th) Sixth (6th) Sixth (6th) Sixth (6th) Sixth (6th) Sixth (6th) Sixth (6th) Sixth (6th) Sixth (6th) Sixth (6th) Sixth (6th) Total A/C A/C A/C A/C A/C A/C A/C A/C A/C A/C A/C A/C 12 months Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 forecast

Rent 95000 95000 95000 95000 95000 95000 95000 95000 95000 95000 95000 95000 1140000 Pilots and copilots 25450 25450 25450 25450 25450 25450 25450 25450 25450 25450 25450 25450 305400 PerDiem/Other Remuneration-Crew 2000 2000 2000 2000 2000 2000 2000 2000 2000 2000 2000 2000 24000 Travel expenses 500 500 500 500 500 500 500 500 500 500 500 500 6000 Flight crew meals 500 500 500 500 500 500 500 500 500 500 500 500 6000 Aircraft insurance 46000 46000 46000 46000 46000 46000 46000 46000 46000 46000 46000 46000 552000 Pre-operating expenses - training 64000 0 0 0 0 0 0 0 0 0 0 0 64000 

### Subtotal: Flying operations 233,450 169,450 169,450 169,450 169,450 169,450 169,450 169,450 169,450 169,450 169,450 169,450 2,097,400

Maintenance management and staff salaries 16425 16425 16425 16425 16425 16425 16425 16425 16425 16425 16425 16425 197100 Monthly maintenance cost (from current ops) 94661 94661 94661 94661 94661 94661 94661 94661 94661 94661 94661 94661 1135932 Pre-operating 60000 0 0 0 0 0 0 0 0 0 0 0 60000 

### Subtotal: Maintenance 171,086 111,086 111,086 111,086 111,086 111,086 111,086 111,086 111,086 111,086 111,086 111,086 1,393,032

Flight Attendand/PerDiem 2300 2300 2300 2300 2300 2300 2300 2300 2300 2300 2300 2300 27600 Other Supplies 1000 1000 1000 1000 1000 1000 1000 1000 1000 1000 1000 1000 12000 Flight crew meals 150 150 150 150 150 150 150 150 150 150 150 150 1800 Flight attendants for additional aircraft 22900 22900 22900 22900 22900 22900 22900 22900 22900 22900 22900 22900 274800 Travel expense and other expenses 1200 1200 1200 1200 1200 1200 1200 1200 1200 1200 1200 1200 14400 Pre-operating- Training 24200 0 0 0 0 0 0 0 0 0 0 0 24200 

### Subtotal: Passenger service 51,750 27,550 27,550 27,550 27,550 27,550 27,550 27,550 27,550 27,550 27,550 27,550 354,800

Travel Expenses 40 40 40 40 40 40 40 40 40 40 40 40 480 PerDiem/Other Remuneration 250 250 250 250 250 250 250 250 250 250 250 250 3000 Other Communications 845 845 845 845 845 845 845 845 845 845 845 845 10140 Weather Service 400 400 400 400 400 400 400 400 400 400 400 400 4800 Other expenses 5200 5200 5200 5200 5200 5200 5200 5200 5200 5200 5200 5200 62400 Flight plans and runway report 940 940 940 940 940 940 940 940 940 940 940 940 11280 Aircraft parking fees 2700 2700 2700 2700 2700 2700 2700 2700 2700 2700 2700 2700 32400 

### Subtotal: A/C and traffic services 10,375 10,375 10,375 10,375 10,375 10,375 10,375 10,375 10,375 10,375 10,375 10,375 124,500

Bank charges-Wire transfers 2000 2000 2000 2000 2000 2000 2000 2000 2000 2000 2000 2000 24000 Drug & Alcohol Testing 400 400 400 400 400 400 400 400 400 400 400 400 4800 Travel expenses 600 600 600 600 600 600 600 600 600 600 600 600 7200 Telephone/ Fax expenses 600 600 600 600 600 600 600 600 600 600 600 600 7200 Cellular phones 1000 1000 1000 1000 1000 1000 1000 1000 1000 1000 1000 1000 12000 Data communication 100 100 100 100 100 100 100 100 100 100 100 100 1200 Security 80 80 80 80 80 80 80 80 80 80 80 80 960 Payroll processing fees 330 330 330 330 330 330 330 330 330 330 330 330 3960 Others services purchased 1360 1360 1360 1360 1360 1360 1360 1360 1360 1360 1360 1360 16320 Office supplies 700 700 700 700 700 700 700 700 700 700 700 700 8400 Other supplies 80 80 80 80 80 80 80 80 80 80 80 80 960 Health insurance 3800 3800 3800 3800 3800 3800 3800 3800 3800 3800 3800 3800 45600 Workmen compensation 2000 2000 2000 2000 2000 2000 2000 2000 2000 2000 2000 2000 24000 Payroll taxes for additional personnel 4955 4955 4955 4955 4955 4955 4955 4955 4955 4955 4955 4955 59460 Pre-operating 50000 0 0 0 0 0 0 0 0 0 0 0 50000 

### Subtotal: General and admin 68,005 18,005 18,005 18,005 18,005 18,005 18,005 18,005 18,005 18,005 18,005 18,005 266,060


### TOTAL: MONTHLY EXPENSES 534,666 336,466 336,466 336,466 336,466 336,466 336,466 336,466 336,466 336,466 336,466 336,466 4,235,792