Before the United States Department of Transportation

Washington, DC

October 15, 2014

Essential Air Service at:

PIERRE, SOUTH DAKOTA Docket OST-2011-0138

under 49 U.S.C. 41731 et.seq.

This document contains Great Lakes Aviation, Ltd.'s response to Order Requesting 

Proposals 2014-9-10.

Great Lakes has been continuously providing Pierre scheduled air service since October of 1991. 

Today the company provides three round trips of non-stop service to Denver daily. The service

is provided utilizing Embraer 30 passenger EMB-120's twice daily and a Beech 1900-D, with

nine passenger seats installed, scheduled once daily non-stop to Denver for a total of 69 seats 

daily. Our proposal contained herein, provides the requested increase in available seats by

replacing the non-stop nine seat Beech 1900-D with 30 passenger EMB-120.

Great Lakes is also providing Pierre with twice daily one-stop service to Minneapolis/St. Paul 

utilizing nine seat configured Beech 1900-D. The removal of 10 seats from the Beech 1900-D's 

was a direct result of relatively new Congressionaly mandated changes to pilot hiring requirements

for FAR part 121 scheduled operations. Despite frequent efforts by the airline industry to inform

Congress of the small community air service crisis that is now becoming a reality, versus 

speculation, therehas been no industry relief granted to date.

As an alternative to the subsidization of the 30 Seat aircraft, the company would be prepared to 

eliminate the subsidy requirement when the 10 seats can be reinstalled in our Beech 1900-D fleet. 

The reinstallation of the seats would provide an additional 30 seats available per day to the current 

schedule at no cost to the Taxpayer.

New FAA pilot qualification rules have created an industry-wide pilot shortage which has had an 

acute impact on Great Lakes. These new rules mandated that first officers obtain an Airline 

Transport Pilot certification (“ATP”) prior to being qualified to perform crewmember duties in 

scheduled airline passenger service under FAR Part 121 regulatory requirements. A key factor to 

enable a pilot to receive an ATP certificate is the accumulation of 1,500 flight hours. 

On March 18th of this year, Great Lakes received from the FAA new operations specifications 

allowing us to hire pilots under it's FAR Part 121 Certificate utilizing FAR Part 135 regulatory hiring 

requirements. This allows our new hire pilots to operate the Beech 1900-D aircraft in a nine seat 

configuration and will enable Great Lakes to restore pilot staffing levels while maintaining FAR Part 

121 hiring, training and maintenance standards. 
Questions and comments may be referred to:

Michael O. Matthews

Chief Financial Officer

Great Lakes Aviation, Ltd.

1022 Airport Parkway

Cheyenne, WY 82001

(307) 432-7000

Our proposal contemplates conveniently timed connecting services to our Denver hub, whereby 

passengers may utilize our code-share agreement with United Airlines. Local service will be 

marketed and priced utilizing the Great Lakes (ZK) brand and reservations system. Additionally, 

Great Lakes maintains interline ticketing and baggage agreements with the majority of the other 

carriers serving Denver, including interline e-ticketing agreements with American Airlines, Delta 

Airlines (with the ability to earn Delta Skymiles) and United Airlines. All of which will offer 

passengers traveling to and from these communities supplemental access to the domestic and 

international air transportation system.

It is Great Lakes' belief that regulatory relief for small community air service must be granted in the 

near future. Excessive subsidy requirements will force communities to loose EAS service eligibility 

as available seats are being dramatically reduced due to arbitrary limitations on aircraft seating 

configurations. Great Lakes’ stands ready to participate in creative solutions to assist small 

communities in their efforts to remain in the National Air Transportation System.
Great Lakes Aviation, Ltd.

Annual Compensation Requirements for Essential Air Service at

Pierre, South Dakota to Denver (DEN)

One Round Trips - EMB-120 

(at 98 percent completion)

Departures: 512

Block Hours: 759

Revenue Passenger Miles: 3,850,000

Available Seat Miles: 5,913,600

Operating Revenues:

Passenger: PIR-DEN 10,000 psgrs at $122.74 $1,227,400

Other: (at 0.62% of passenger revenue) $7,610

Total Operating Revenues: $1,235,010

Operating Expenses:

Direct: Aircraft and Hull Insurance $112,653

Fuel and Oil $549,420

Flying Operations $180,088

Maintenance $269,870

Total Direct Expenses: $1,112,031

Total Indirect Expenses: $795,165

Total Operating Expenses: $1,907,196

Operating Loss ($672,186)

Profit Element (5.0% of Total Operating Expenses) $95,360

Annual Compensation Requirement: $767,546

 All Pierre - Denver - Pierre Service is Non-Stop

 This Proposal is submitted with no upline scheduling restrctions.