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SCHUM^VN AVIATIO N COMPANY , LT D ,- . ,j ^r 

130 lOLANA PLACE. HONOLULU , HI 96819 ! V-RT^'N 

808-81)4-5813 FAX 808-837-7867 EMA m Richard@makaniki^i^oWi(J;r[ if Np 

January 19,2012 

Honorable Susan L. Kurland 

Assistant Secretary of Aviation and International Affairs 

Office of the Secretary 

United States Department of Transportation 

M-30 West Building Ground Floor W12-140 

1200 New Jersey Ave, SE 20590 

RE: Docket DOT-OST-2000-6773. Pacific Wings LLC Petition of Reconsideration of Order 2011 -11 -27 

Dear Assistant Secretary Kurland: 

Schuman Aviation Company Ltd would like to address some of the area's that Pacific Wings LLC raises in their 

Petition for Reconsideration that I believe are incorrect, erroneous and blatantly misrepresented. 

1. "Makani Kai subsidy calculations contain significant errors"... 

I find it somewhat amusing how they figure a profit of over 30%. Unlike Pac Wings having the experience, 

knowledge and historical data of having operated this route, I had to make quite a few assumptions about this 

operation. The historically low ridership in the first half of 2010, it appeared that there might be less than one 

passenger per departure or 3.6 passengers per day average. Little difficult to estimate the future ridership or 

revenue based on their numbers. 

The contract called for one aircraft flying six days a week. In my proposal, I did not include any of the second 

Caravan's expenses. I believe it takes two aircraft to service this agreement if you want to have 99.9% 

dependability, reliability, and accountability which my company is committed to do. 

None of the startup costs for aircraft accusation, aircraft maintenance upgrades, employee training, facility, 

airport desk locations, phones, computers, electric, and advertising costs were included in this first proposal. 

None of my support staff or additional aircraft to support this agreement was taken into consideration. 

Another substantial cost not included is the development of a web site for passenger booking. Often time's 

passengers returning to Honolulu from Kaluapapa are taken in our company shuttle to rent-a-car facilities and 

or dropped off in down town Honolulu. These additional services were also not included in our initial proposal. 

Currently all reservations are taken by phone utilizing real reservations people, seven days a week from 

7:00am to 10:pm, As an example of our commitment to service, our reservations made a error in departure 

time for Mr. John Wakefield on 12/21/11, a Kaluapapa resident. Mr. Wakefield showed up two hours after the 

aircraft departed. I told my chief pilot to take him to Kaluapapa in our Piper Chieftain with no additional charges 

or dely. If and when we make an error, the customer will not have to suffer. Those types of cost were not 

figured into the initial agreement either. 

We started flying the scheduled service December 10, 2011 and have already flown over 300 passengers in 

and out of Kalaupapa by the end of December. Something is obviously working. 

Makani Kai Helicopters - Makani Kal Air Charters - Ko Olina Helicopters - Pacific Air Express - Hawaii Aviation Services 
The agreement called for six day a week operation but we currently run seven days in order to better sen/ice 

the community. It took a better part of two weeks working with Mark Miller, Kaluapapa Administrator, to custom 

make a flight schedule that fit the community's needs for Damien Tours, the State and Federal employees. The 

additional cost of running an additional day per week was not in my initial proposal. 

Pac Wings should know that starting up an operation from zero is substantially more costly then taking an 

already ongoing operation and redirecting the aircraft. 

2. "Pacific Wings fair excessive" 

Passenger rates for residents from Kalaupapa to the Molokai Airport are now $38.64 and from Kalaupapa to 

Honolulu, $70.89. These prices are much more realistic with the cost and flight time. Pac Wings is correct that 

Kalaupapa is a more remote airport and much more difficult to access if you have maintenance issues. I'm 

assuming you already knew that and their assertion to support their excessive rates was because of this 

potential problems are laughable. Having to send in mechanics with parts by helicopter is very expensive but 

never necessary if another airplane operator would support them or they were able to support themselves like 

my company can. 

As far as Damien Tours, there is no exclusive agreement between my company and Damien Tours. Pac 

Wings is totally incorrect with their description of facts and assessment of reality. Damien Tours refers potential 

customers to Makani Kai because we offer great service at a reasonable price. 

We have been flying passengers. Part 135 On Demand, from Honolulu to Kalaupapa for the purpose of visiting 

Father Damien's tour. The simple math is my Piper Chieftains charter rate is $950 per hour, plus the FET and 

Segment fee per passenger. It was cheaper per person for four passengers to fly from Honolulu to Kalaupapa, 

do the Damien tour, and return to Honolulu then is was for one person to fly one way from Molokai Airport to 

Kalaupapa on Pac Wings. 

Pac Wings is correct that they did not receive much of the tourist Damien Tour business but it had little to do 

with my company and more to do with their flight time schedule and pricing strategy. 

Seems comical that Pac Wings would think they can feed the DOT so much miss information believing the 

department will gobble it up like ice-cream on a hot summer day. 

This whole situation that Pac Wings now brings up is even more comical because it was they who sent a notice 

to DOT wanting to suspend schedule service to Kalaupapa which triggered this EAS proposal. It was they who 

decided not to bid on this sen/ice given two separate opportunities and now they claim foul. 

As far as them slapping themselves on the back for saving the taxpayers lots of money by suspending the EAS 

contract when in fact patients. Federal, State, & County personnel, government contracts for support and or 

any business that had to be conducted in Kalaupapa was eventually paid by the tax payers thru 

reimbursements for travel at the State and Federal level. 

It is for these reasons I believe the Department of Transportation should deny Pacific Wings petition of 

reconsideration. 

If you have any questions, you may reach me at (808) 834-5813 or via email at Richard@makanikai.com. 

Sincerely, 

Richard Schuman 

Makani Kai Helicopters - Makani Kai Air Charters - Ko Olina Helicopters - Pacific Air Express - Hawaii Aviation Services 
President 

Makani Kai Helicopters - Makani Kai Air Charters - Ko Olina Helicopters - Pacific Air Express - Hawai i Aviation Services