U.S. Department of 

Transportation 

Office of the Secretary 

of Transportation 

January 14, 2015 

Ms. Rebecca B. MacPherson 

Jones Day 

51 Louisiana Ave., N.W. 

Washington, DC 20001 

Dear Ms. 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 

of its fitness to conduct scheduled passenger transportation as a U.S. commuter air carrier. 

We have completed our review of the information submitted, and this review has revealed the need for 

additional and/or clarifying information before we can complete processing of Monarch'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 of the date of this letter. You 

may upload your response via the web at www.regulations.gov, or you may mail your response to U.S. 

Department of Transportation 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 

Docket DOT-OST-2014-0192. 

As is the Department's practice, further processing of Monarch'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 under review by the Department. 

Thank you for your cooperation in this matter. If you have any questions regarding this letter or the 

requested information, please feel free to contact Shabu Thomas of my staff at (202) 3 66-9721 or 

shabu.thomas@dot.gov. 

Sincerely, 

~~J' (':;_) . .----

"-··----· ,7-' ...- \.;::'.\ 

Shabu Thomas 

Analyst, Air Carrier Fitness Division 

Office of Aviation Analysis 

cc: Docket DOT-OST-2014-0192 

Mr. Cameron Baker 

POI for Menagerie Enterprises, Inc. d/b/a Monarch Air 

FAA 
Information 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 

was true and correct. Therefore, please provide the certification. 

MANAGEMENT AND 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 

required by sections 204.3 (1), (m), ( o ), and (p) of our rules. 

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 of its pre-operating costs and a pro-forma forecast profit 

and loss statement reflecting 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 of the 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 Monarch will 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, please provide a pre-operating cost forecast that identifies all costs expected to be 

incurred by Monarch prior to the actual start of its 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 of each of the aircraft. The 

forecasted profit and loss statement specifically states the interest payments for each 

of the 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 ask that you please provide the 

following: 

a. The line of credit from Legacy Texas Bank that 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 prior to the date of filing. 2 The applicant should provide the Department with funding plans that can cover the pre-operating 

expenses and 25 percent of the first year operating expenses. 
2 

amount drawn down to date, the terms of repayment, any conditions that 

must be met before funds will be advanced, and the expiration date. 

b. An updated first-year profit and loss forecast that reflects the interest 

payments associated with the terms of the aircraft financing from Legacy 

Texas Bank. 

3. In your application· and supplemental information submitted, you stated that Monarch 

intends to support the Rise operations by drawing on a line of credit provided by Rise. 

However, we are unable to ascertain the veracity of this statement without additional 

information on Rise. Therefore we ask that you please provide the following: 

a. The line of credit agreement between Rise and Monarch that includes the 

total available line of credit, amount drawn down, terms of repayment, any 

conditions that must be met before funds will be advanced and the 

expiration date. 

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 

behalf of Monarch. 

4. Please provide the explanatory footnotes associated with the projected balance sheet 

and profit and loss statement submitted on December 23, 2014. 

Certification 

The information provided pursuant to this Information Request should be accompanied 

by the following certification: 

The contents of this application and the attached exhibit (s) are true and correct to 

the best of my knowledge and belief. Pursuant to Title 18 United States Code Section 

1001, I [the individual signing the application, who shall be a principal owner, senior 

officer, or internal counsel of the 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 of the 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 not more than five years, or both.