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.