BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

Application of 

CITY WINGS, INC. 

for authority to conduct scheduled 

passenger operations as a commuter air 

carrier under 49 U.S.C. § 41738 

Docket DOT-OST-2010-0263

SUPPLEMENT NO. 5 TO APPLICATION OF CITY WINGS, INC. 

Communications with respect to this document should be sent to: 

 

Don Lewis 

President 

8248 Plantation Manor #78 

St. Thomas, V.I. 00802 

Tel: 340-714-3000 

Fax: 340-714-3008 

rivhotel@earthlink.net

Jason E. Maddux 

Garofalo Goerlich Hainbach PC 

1200 New Hampshire Ave., N.W. 

Suite 800 

Washington, D.C. 20036 

Tel: (202) 776-3970 

Fax: (202) 776-3975 

jmaddux@ggh-airlaw.com 

Counsel for City Wings, Inc.

December 21, 2011 
1

BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

Application of 

CITY WINGS, INC. 

for authority to conduct scheduled 

passenger operations as a commuter air 

carrier under 49 U.S.C. § 41738 

Docket DOT-OST-2010-0263

SUPPLEMENT NO. 5 TO APPLICATION OF CITY WINGS, INC. 

In response to the Department's Information Request dated December 12, 2011, City 

Wings, Inc. ("City Wings") hereby submits the following information and attached 

documentation in support of its application: 

1. Attached as Exhibit A are responses to the Department’s information requests. 

2. Last week, Mr. Kembert Mason, City Wings’ Chief Pilot, resigned. Fortunately, 

City Wings was able to bring onboard Mr. David Peltier, who was approved by FAA as City 

Wings’ new Chief Pilot on December 20, 2011. Attached as Exhibit B is Mr. Peltier’s resume. 

Also included in Exhibit B is a statement attesting that Mr. Peltier is a U.S. citizen. 

3. Attached as Exhibit C is the certification required by the Department’s 

regulations.


Replies to Information Requests of City Wings 

1. As an initial point and as stated in Supplement No. 3 of October 18, 2011, any 

discrepancy must be attributed to imperfect memory recall. Mr. Don Lewis has had a 

long and varied business carrier and does not have written records of some of these 

matters, which date back decades. Specifically regarding the cited NTSB case, as stated 

in Supplement No. 3 of October 18, 2011, Mr. Lewis never held an ownership interest in 

Kingfisher Air Service, was never an officer or director of Kingfisher, and was never an 

employee of Kingfisher. Mr. Lewis owned Sea Jet, which licensed the “Sea Jet” trade 

name, and leased an aircraft to, Kingfisher. Mr. Lewis now recalls that Sea Jet was not 

the corporate name but a trade name of Lewis Airlines, Inc. And as stated previously, 

Mr. Lewis was the owner, president and operating manager of this entity. While Mr. 

Lewis recalls testifying at the cited NTSB hearing, he does not recall what lead the 

Administrative Law Judge to state that Mr. Lewis owned or held an officership in 

Kingfisher. Lewis Airlines, Inc. d/b/a Sea Jet and Kingfisher Air Service d/b/a Sea Jet 

did have a close business relationship, which may have resulted in this confusion. 

2. (a) As stated in Supplement No. 3, City Wings was providing Mr. Lewis’ updated 

resume at that time. Again, due to imperfect memory, some dates and names were 

incorrectly recalled initially by Mr. Lewis. In the interim, Mr. Lewis recalled additional 

details and updated his resume accordingly, which in turn was submitted on October 

18th. One of those details was that Sea Jet was not an operating airline but instead was 

an entity that leased a trade name (Sea Jet) and a seaplane to an operating airline 

(Kingfisher). As mentioned above, Mr. Lewis now recalls Sea Jet’s corporate name to be 

Lewis Airlines, Inc.

(b) Enclosed is a table identifying the name of each air carrier in which Mr. Lewis 

has held a 10 percent or greater equity interest or served as an officer or director.

3. While Mr. Lewis now recalls owning an entity named Lewis Airlines, Inc., he does not 

recall this entity ever holding a Part 298 registration with the Department. It is possible 

Lewis Airlines, Inc. obtained its own air carrier authority (i.e. a Part 298 registration and 

Part 135 operations specifications), but Mr. Lewis does not recall any situation in which 

such authority would have been used. However, this is only conjecture as Mr. Lewis has 

no specific recollection of Lewis Airlines, Inc. obtaining any air carrier authority.

Indeed, an inquiry to City Wing’s FAA Flight Standards District Office (FSDO), which 

would have been the same FSDO for Lewis Airlines, Inc., revealed no records for a 

Lewis Airlines, Inc., though the FSDO confirmed it does not generally keep records back 

that far.

4. Cosmopolitan Broadcasting Corporation currently is a holding company that owns 

Riverside Tower Hotel. It conducts no other business activities. Mr. Lewis is the sole 

owner of Cosmopolitan Broadcasting Corporation and in turn the hotel. Mr. Lewis’ 

duties and responsibilities in relation to Cosmopolitan Broadcasting Corporation are to 

oversee that entity’s business, which consists of only owning the Riverside Tower Hotel.

Accordingly, Mr. Lewis’ duties and responsibilities are negligible.

Exhibit A
5. As stated in the original application of October 12, 2010, Mr. Lewis devotes 90% of his 

time to overseeing City Wings. Mr. Lewis devotes the remaining 10% of his time to 

overseeing the Riverside Tower Hotel. As noted in number 4 above, what little time Mr. 

Lewis devotes to Cosmopolitan Broadcasting Corporation is included in the 10% devoted 

to the Riverside Tower Hotel since that hotel is Cosmopolitan Broadcasting 

Corporation’s only asset. Aguadilla Airline Service is not actively engaged in any 

business at this time. Therefore, Mr. Lewis does not devote any of his time to this 

company. 

As Director of Operations, Mr. William Weist oversees and is responsible for all City 

Wings flight activities. Mr. David Peltier, Chief Pilot, is in charge of day-to-day flights.

Mr. Edward Lucia, Director of Maintenance, is responsible for maintaining the 

airworthiness of City Wings’ two aircraft. As manager of non-flight personnel, Ms. 

Yilong Xiang is responsible for sales, marketing and other administrative aspects of the 

business. Given that Mr. Lewis devotes 90% of his time to City Wings, his residence is 

in the same location (St. Thomas) as City Wings’ base of operations, and his years of 

experience with owning and operating small air carriers, there is no question that Mr. 

Lewis will maintain adequate supervision at City Wings. 
Air carriers in which Don Lewis Holds or Has Held a 10 Percent or Greater Equity 

Interest or Serves or Has Served as an Officer or Director 

Carrier % Equity Held Positions Held DOT/FAA Authority 

City Wings 100 President Part 298 registration/Part 

135 on demand operations 

specifications 

Aguadilla Air 

Services 

511 President Part 298 registration/Part 

135 on demand operations 

specifications 

V.I. Seaplane Shuttle 50 Chairman Commuter Air Carrier 

Authorization/Part 135 

commuter operations 

specifications 

Shuttle Transport2 100 President Part 298 registration/Part 

135 on demand operations 

specifications 

Seaplane Shuttle 

Transport2

100 President Part 298 registration/Part 

135 on demand operations 

specifications

 1

 Supplement No. 3 inadvertently implied that Mr. Lewis owned 100% of Aguadilla Air Services 

when he actually owns only 51%, as stated in City Wing’s original application. 

2

 The names of Seaplane Shuttle Transport and Shuttle Transport were misspelled in Mr. Lewis’s 

resumes previously submitted. Instead of Seaplane Shuttle Transit and Shuttle Transit, these 

carriers were named Seaplane Shuttle Transport and Shuttle Transport, respectively. 
Exhibit B


Exhibit C