U.S. Department of Transportation Office ofthe Secretary ofTransportation January 14, 2015 Ms. Rebecca B. MacPherson Jones Day 51 LouisianaAve., N.W. Washington, DC 20001

DearMs. MacPherson: ;., 1200 New Jersey Avenue SE Washington DC 20590

Thank you for the supplemental information dated Deceml;ler 23, 2014, provided in support of the application filed by Menagerie Enterprises, Inc. d/b/a Monarch Air ("Monarch") for the determination ofits fitness to conduct scheduled passengertransportationas a U.S. commuter air carrier. We have completed ourreview ofthe information submitted, and this review has revealed theneed for additional and/or clarifying information before we can complete processing ofMonarch's application. The attached Information Request lists the areas where further information and/or clarification is necessary. I ask that you respond fully to this request within 30 days ofthe date ofthis letter. You may uploadyourresponse viathe web at www.regulations.gov, or youmay mail yourresponse to U.S. Department ofTransportation Dockets, West Building, Ground Floor, (M-30, Room Wl2-140), 1200 New Jersey Avenue SE, Washington, D.C. 20590. In either case, your response should be filed in DocketDOT-OST-2014-0192. As is the Department's practice, further processing ofMonarch's application will be deferred pending receipt of this material. In addition, please remember that Monarch should promptly provide the Department with any information regarding changes it may undergo in areas affecting its fitness (i.e., management, operating plans or financial condition, compliance disposition, or ownership) while its application is underreviewbythe Department. Thank you for your cooperation in this matter. Ifyou have any questions regarding this letter or the requested information, please feel free to contact Shabu Thomas of my staff at (202) 366-9721 or shabu.thomas@dot.gov. Sincerely,

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. .---- "-··----· ,7-' ...- \.;::'.\ Shabu Thomas Analyst, Air CarrierFitness Division Office ofAviationAnalysis

cc: DocketDOT-OST-2014-0192 Mr. Cameron Baker POIfor Menagerie Enterprises, Inc. d/b/aMonarchAir FAAInformation Request

GENERAL INFORMATION 

### 1. The supplemental information dated December 23, 2014, filed by Monarch did not contain the requisite certification statement affirming that the information submitted wastrue and correct. Therefore, please providethe certification. MANAGEMENTAND KEY TECHNICAL PERSONNEL 

### 1. Please provide a resume for Mr. Raymond Sawtelle, detailing his experience, expertise and responsibilities. Also provide the compliance history information as requiredby sections 204.3 (1), (m), ( o ), and (p) 

### ofourrules. FINANCIAL POSITION AND OPERATING PLANS An 

### applicant for commuter authority is expected to be prepared to fully prosecute its application at the time it is filed. With respect to fmancial fitness, the applicant is required to provide current fmancial data, 1 

### and three years of historic financial data, together with a detailed forecast ofits pre-operating costs and a pro-forma forecast profit and loss statementreflecting all revenues and expenses the applicant expects to earn/incur during its first year of actual commuter operations. In 

### addition, the company must demonstrate that it has obtained all ofthe funding needed to meet our financial fitness tesr or, at a minimum, that it has a reasonable plan for doing so. Please provide the following: 1. In

### the December 23, 2014, submission, you indicate that Monarchwill need $422,349 to commence the proposed commuter operations. Does Monarch consider this as its pre-operating cost forecast? If so, please explain how these costs were derived. If not, pleaseprovide apre-operating cost forecast that identifies all costs expected to be incurred by Monarchpriorto the actual start ofits proposed operations. 2. In 

### your application, you indicated that Monarch intends to add three aircraft to its fleet and provided information related to the fmancing ofeach ofthe aircraft. The forecasted profit and loss statement specifically states the interest payments for each ofthe aircraft. However, we are unable to determine how Monarch calculated the aircraft interest payments since detailed information regarding the aircraft fmancing from Legacy Texas Bank was not provided. Thus we askthat you please provide the following: a. The line ofcredit from Legacy Texas Bankthat will be used to fmance the three aircraft. This should include the total available line of credit, the

The balance sheet and income statement supplied must be for a period ending no more than three months priorto the date offiling. 2 The applicant shouldprovide the Department with funding plans that can coverthe pre-operating expenses and 25 percentofthe first year operating expenses.2

amount drawn down to date, the terms ofrepayment, any conditions that mustbe metbefore funds will be advanced, andthe expiration date. b. An updated first-year profit and loss forecast that reflects the interest payments associated with the terms ofthe aircraft financing from Legacy Texas Bank. 3. Inyour application·and supplemental information submitted, you stated that Monarch intends to supportthe Rise operations by drawing on a line ofcreditprovidedby Rise. However, we are unable to ascertain the veracity ofthis statement without additional information onRise. Therefore we askthatyoupleaseprovidethe following:

a. The line ofcredit agreement between Rise and Monarchthat includes the total available line ofcredit, amount drawn down, terms ofrepayment, any conditions that must be met before funds will be advanced and the expirationdate. b. Third party verification of Rise's ability to extend the line of credit to Monarch, including Rise's current (within 3 months) fmancial statements, together with their accompanying explanatory footnotes. Since Monarch is relying on Rise, we need to determine that Rise has the necessary fmancial wherewithal to fulfill any financial commitment made to or on behalfofMonarch. 4. Please provide the explanatory footnotes associated with the projected balance sheet and profit and loss statement submitted onDecember 23, 2014. Certification The information provided pursuant to this Information Request should be accompanied bythe following certification: The contents ofthis application and the attached exhibit (s) are true andcorrectto the best ofmy knowledge and belief. Pursuant to Title 18 United States Code Section 1001, I 

### [the individual signing the application, who shall be aprincipal owner, senior officer, or internal counsel ofthe applicant], in my individual capacity and as the authorized representative of the applicant, have not in any manner knowingly and willfully falsified, concealed or failed to disclose any material fact or made any false, fictitious, or fraudulent statement or knowingly used any documents which contain such statements in connection with the preparation, filing or prosecution ofthe application. I understand that an individual who is found to have violated the provisions of 18 U.S.C section 1 001 shall be fined or imprisoned notmore than five years, orboth.