## Before the United States Department of Transportation 

# Washington, DC May 23, 2014

Essential Air Service at WORLAND, WYOMING Docket OST-1997-2981
under 49 U.S.C. 41731 et.seq.
This document contains Great Lakes Aviation, Ltd.'s. response to Order Requesting Proposals 2014-4-5. Our proposal contemplates conveniently timed connecting services to our Denver hub, whereby passengers may utilize our code-share agreements with United Airlines and Frontier 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, Frontier Airlines 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. The proposed service is being offered utilizing pressurized, multi-engine Beech 1900D aircraft flown by two pilots. Service will be one-stop over either Riverton or Cheyenne; or at Great Lakes discretion, we would provide non-stop service to Denver provided we have no upline restrictions. New FAA pilot qualification rules has created an industry-wide pilot shortage which has had an acute impact on Great Lakes. Theses 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. Great Lakes received from the FAA new operations specifications on March 18th of this year allowing us to hire pilots under it's FAR Part 121 Certificate utilizing FAR Part 135 regulatory hiring requirements. This will allow our pilots to operate the Beech 1900D aircraft in a nine seat configuration and enable Great Lakes to restore pilot staffing levels while maintaining FAR Part 121 hiring, training and maintenance standards. The company intends on returning the aircraft to a 19 seat configuration once pilot staffing has achieved adequate levels of qualified personnel. The recently implemented regulatory requirements have dramatically accelerated a long anticipated pilot shortage, causing nationwide damage to small community air service. The unintended consequences of the Congressionally mandated regulatory changes will require commitments to be made to address the long-term impact on the airline industry as a whole. Great Lakes’ stands ready to participate in creative solutions to assist small communities in their efforts to remain in the National Air Transportation System.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

# Great Lakes Aviation, Ltd. Annual Compensation Requirements for Essential Air Service at 

# Worland, Wyoming to Denver (DEN) Two Round Trips - B1900 (at 98 percent completion)
Departures: 1,227 Revenue Passenger Miles: 2,062,500

Operating Revenues: Passenger: WRL-DEN 6,250 psgrs at $134.72 $842,000

Other: (at 0.62% of passenger revenue) $5,220 Total Operating Revenues: $847,220
Operating Expenses: Direct: Aircraft and Hull Insurance $365,710 Fuel and Oil $1,049,550 Flying Operations $242,014 Maintenance $430,051 Total Direct Expenses: $2,087,325 Total Indirect Expenses: $936,682 Total Operating Expenses: $3,024,007 Operating Loss ($2,176,787) Profit Element (5.0% of Total Operating Expenses) $151,200 Annual Compensation Requirement: $2,327,987 Current published schedules should be used as sample service levels Worland Service will be One-Stop to Denver over either Cheyenne or Riverton. At Great Lakes discretion, Non-Stop to Denver would provided so long as there are no upline restrictions.