BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C.

____________________________________ 

In the matter of Essential Air service at ) 

 ) 

KAKE, ALASKA ) Docket DOT-OST-2008-0217

 EXCURSION INLET, ALASKA ) Docket DOT-OST-2002-12014

 ) 

Answer of Air Excursions to Petition for ) 

Reconsideration of Order 2012-9-8 ) 

____________________________________) 

ANSWER OF AIR EXCURSIONS 

TO THE PETITION FOR RECONSIDERATION 

OF ORDER 2012-9-8 BY SEAPORT AIRLINES, 

d/b/a WINGS OF ALASKA 

Communications with respect to this document should be addressed to: 

Kent Craford 

Air Excursions, LLC 

Suite 115 

1873 Shell Simmons Drive 

Juneau, AK 99801 

October 1, 2012
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C.

____________________________________ 

In the matter of Essential Air service at ) 

 ) 

KAKE, ALASKA ) Docket DOT-OST-2008-0217

 EXCURSION INLET, ALASKA ) Docket DOT-OST-2002-12014 

 ) 

Answer of Air Excursions to Petition for ) 

Reconsideration of Order 2012-9-8 ) 

____________________________________) 

ANSWER OF AIR EXCURSIONS 

TO THE PETITION FOR RECONSIDERATION 

OF ORDER 2012-9-8 BY SEAPORT AIRLINES, 

d/b/a WINGS OF ALASKA 

Seaport Airlines d/b/a Wings of Alaska (“Seaport”) has requested reconsideration of Order 

2012-9-8. While none of the arguments made by Seaport are either sufficient or appropriate to 

justify reconsideration, their arguments are either false or at the minimum incomplete. Air 

Excursions hereby responds to the petition of Seaport, as follows: 

AIR EXCURSIONS IS A LOCAL AIRLINE TO JUNEAU 

Air Excursions has operated from bases in Juneau and Gustavus for over twenty years. Its 

previous owner, Mike Loverink, is still employed by Air Excursions and is a key manager in the 

operation. Mike Stedman, the new co-owner with Kent Craford, was born and raised in Sitka 

and has made his home in Juneau for the last 24 years. He has been flying in Southeast Alaska 

for the past 31 years. Mike is the President of the Alaska Air Carriers Association and was 

appointed by Governor Parnell to serve on the Alaska Aviation Advisory board in 2010. Mike’s 

wife Lori is a native Alaskan and a shareholder in both Shee Atika and Sealaska. Mr. Stedman 

and Mr. Craford are also co-owners of Alaska Seaplane Service. 
Air Excursions’ only operation is in Southeast Alaska, and has no relation to operations outside 

of Juneau. Air Excursions’ sister company Alaska Seaplane Service is another long time Juneau 

carrier that has an impeccable record of service, including Essential Air Service. These two 

carriers together serve more points from the Juneau Hub than any other scheduled carrier, and 

all aircraft and facilities used in the operation are locally owned by Mr. Stedman and Mr. 

Craford or by Mr. Loverink. 

THERE IS NO DISQUALIFYING SAFETY ISSUE AT AIR EXCURSIONS 

While Air Excursions did experience three unfortunate incidents/accidents this summer, the 

thorough NTSB and FAA investigations of these events have not found any operational 

deficiency on the part of the company. We encourage Department officials to contact the local 

F.A.A. investigator regarding these events if additional information is required. He can be 

reached through the Juneau Flight Standards District Office. 

Air Excursions is committed to a safety culture. This is a posture it has developed over years of 

Part 135 operations in Southeast Alaska. Mike Stedman personally directed the 

implementation of the Medallion Safety Program at Wings of Alaska and Wings Airways when 

they became the first Part 135 operators in the state to obtain the Medallion Shield. Mike now 

sits on the board of the Medallion Foundation, and oversees the Medallion implementation at 

Air Excursions and Alaska Seaplanes. 

Air Excursions and Alaska Seaplanes share a dedicated Safety Officer, who manages the 

companies’ safety program and training related to the individual Medallion stars. This position, 

while not required by the F.A.A., was created by the new ownership team. 

Even after the unfortunate events of this summer, Air Excursions has never injured a passenger 

and still has the second fewest accidents/incidents of any Juneau-based commuter operator, 

second only to our sister carrier Alaska Seaplanes which has a perfect safety record and no 

accidents/incidents. 

USE OF LARGE AIRCRAFT OVER THE ROUTE

In its new proposal, Air Excursions assumes that the 9-seat Piper Chieftain will be used for all 

service except in the case of maintenance events or unavoidable weather-related delays. The 

primary reason this commitment can be made is the steady increase in traffic on the Kake 

route, and a demonstrated increase in efficiency of this aircraft and Air Excursions’ operations, 

which have resulted in a reduction in unit costs. The Chieftain has a deicing system which 

Seaport’s permanent Juneau-based Caravans do not. Although slower than the Chieftain, the 

Caravan can provide excellent service, however the lower horsepower on the conventional 

Caravans operated by Seaport leaves them more susceptible to icing on this long, over-water 
route with no alternate airfields. To that end, Air Excursions will be taking delivery of a Caravan 

with 33% more power, full deicing equipment, and higher gross weights than those used by 

Seaport. This aircraft, which will be owned by Air Excursions’ ownership team and not leased 

from outside third parties as Seaport’s Caravans are, will have a lower fuel burn, longer TBOs 

and a lower cost overhaul—making it a significantly more economical aircraft versus a 

conventional, lower-powered Caravan. This aircraft will have several upgrades installed over 

the winter, and will be ready for service in Spring, 2013. It will be available for use on all Air 

Excursions schedules, including Kake, and at no additional cost to the DOT for EAS subsidy. 

AIR EXCURSIONS HAS REVERSED SEAPORT’S RECORD OF DECLINING SERVICE AND TRAFFIC

Despite Seaport’s claims of inferior service by Air Excursions, the market has responded to this 

service well. The chart below, which was originally submitted as part of the 2012 EAS bid, 

documents the drop in service and traffic when Seaport took over from the prior carrier, L.A.B., 

in 2008. Service frequency improved immediately after Air Excursions took over service in 

2010, and traffic has increased ever since then. 

This steady growth trend is made possible by Air Excursions’ re-investment in its business and 

long-term commitment to the communities it serves. Air Excursions has spent twenty years in 

growing traffic and market share in the Juneau air service market, and is not interested in shortterm air service route experiments with low-introductory fares that ultimately lead to 

unsustainable service. 

 

0

500

1000

1500

2000

2500

3000

3500

4000

4500

Flights/Passengers

KAKE PASSENGERS

& DEPARTURES

Departures

Passengers
BETTER SERVICE AT LOWER COSTS 

In meetings with Air Excursions this past spring, Kake leaders asked for more large aircraft 

service, and Air Excursions has responded. Not only has Air Excursions obtained additional 9-

seat aircraft, it has improved utilization of its Piper Chieftain and has flown the aircraft on the 

Kake route routinely since the second week of August and predominantly since the beginning of 

September. Air Excursions’ EAS payment invoices bear this out. In 2010, Air Excursions’ bid 

based on the Chieftain was well below that of Seaport’s Caravan service. Since 2010, Air 

Excursions has been able to lower its unit costs, again resulting in a bid that is hundreds of 

thousands of dollars less than Seaport’s bid. Seaport does not mention this fact, nor does it 

acknowledge its significantly higher subsidy cost per passenger. Seaport now proposes a 

restricted lower cost fare that will save passengers little, but represents a long-term threat to 

the sustainability of the service. It is a fare that it never offered when it operated the EAS 

service previously, and is substantially lower per mile than any promotional fare Seaport 

currently offers. 

SUMMARY

Over the last two years, Air Excursions has increased traffic while simultaneously reducing 

operating expenses, and therefore reduced subsidy need at Kake. Its new owners, including a 

respected local aviator, have added financial strength and innovation that have improved the 

quality of service and lowered costs. Air Excursions safety record is second only to that of its 

sister carrier, Alaska Seaplanes. With respect to Excursion Inlet, Air Excursions is supported by 

the community, has been serving the market for two weeks now, and has already received 

positive reviews. 

Seaport’s petition is dilatory, and does not raise any issues of substance, or which provide 

justification for reconsideration of the order. 

WHEREFORE: Air Excursions respectfully requests that the Department deny the Petition for 

Reconsideration filed by Seaport Airlines d/b/a Wings of Alaska. 

Respectfully submitted, 

Air Excursions, LLC 

By Kent Craford 

October 1, 2012