U.S. Department of 

Transportation 

Office of the Secretary 

Of Transportation 

November 9, 2012 

Mr. John Swasey 

President 

Exec Air, Inc. ofNaples 

160 13th Street NW 

Naples, FL 34120 

Dear Mr. Swasey: 

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Washington, DC 20590 

This letter is in reference to the amended application of Exec Air, Inc. of Naples 

(''Exec Air") filed in Docket DOT-OST-2007-27815 on July 6, 2011, for commuter air 

carrier authority. We have completed our review of the information Exec Air has filed in 

support of its request for commuter authority. This review has revealed the need for 

additional and/or clarifying information before we can complete processing Exec Air's 

application. We note that some of this information was previously requested, and has not 

been satisfactorily answered. . While the Department does closely work with applicants 

through the application process, it is not our policy to keep incomplete applications open 

indefinitely. 

The attached Information Request lists the areas where further and/or clarification 

information is necessary. I ask that you respond fully to this request within 30 days of the 

date of this letter, that is, December 10, 2012. 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-2007-27815. 

As is the Depatiment's practice, further processing of Exec Air's application will be 

deferred pending receipt of this material. In addition, please remember that Exec Air 

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. 

If you have any questions regarding this letter, please feel free to contact Katy O'Toole of 

my staff at (202 )-366-9721 or Catherine.O'Toole@dot.gov. 
Chief: Air Carrier Fitness Division 

Office of Aviation Analysis 

cc: Docket DOT-OST-2007-27815 

Mr. Sergio Lopez, FAA 

Mr. Felix Molina, FAA 

POI for Exec Air, Inc. 

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Please provide the following: 

Information Request 

Exec Air, Inc. ofNaples 

1. The balance sheet Exec Air last provided was dated December 2007. A copy of Exec 

Air's balance sheet, current' to within 3 months of the date of this letter is required. 

2. Income Statements for Exec Air for the past three calendar or fiscal years. Please do not 

provide U.S. Income Tax statements. 

3. Pursuant to 204.3(t)(l) : a forecast balance sheet for the first normal year ending after 

the initially proposed operations have been incorporated. 

4. A statement identifying the person who has prepared the financial statements and a 

summary of the individual's qualifications for preparing such statements. 

5. A statement as to whether the balance sheet and income statements were prepared in 

accordance with Generally Accepted Accounting Principles. 

6. A list of pre-operating costs, such as legal fees, deposits, and Federal Aviation 

Administration (FAA) certification fees. 

7. Third-party verification, such as a letter from a bank, of the cash that Exec Air has on 

deposit with its financial institution(s). 

8. A detailed description of the plans Exec Air has, if any, to acquire additional capital to 

meet the Department's financial fitness requirements. 

9. Exhibit 9, which is a letter to the FAA regarding Exec Air's intent to operate, is 

unclear. Please provide a copy of the Pre-Application Statement oflntent that Exec Air 

has filed with the FAA for commuter air carrier operations that clearly outlines Exec 

Air's planned commuter operation including day of week and time of day information. 

Please address the following questions: 

10. With respect to its forecast expenses, Exec Air prepared a summary of its projected 

"Corporate Headquarters" expenses. These projections show Exec Air's Chief Pilot 

and its Director of Maintenance earning a wage of $1.44 per hour. Also, the projection 

shows the Director of Operations earning a wage of $5.77 per hour. These wages are 

significantly below the Florida minimum wage rate of $7.31 per hour. In its December 

2011 response to this question, Exec Air noted that these employees also draw 
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additional pay when flying or maintaining aircraft. Please account for this additional 

pay and provide revised projections if necessary. 1 

11. The expenses for employee taxes and benefits appear to apply only to the three 

individuals that Exec Air intends to hire and not to the Chief Pilot, Director of 

Maintenance, and Director of Operations. Please explain how Exec Air accounts for 

employee taxes and benefits for these above-mentioned employees. 

12. According to Exec Air's Monthly Cost Analysis, the company expects to incur variable 

aircraft costs of$400 per month. In Exec Air's December 2011 response, this question 

does not appear to have been answered. Please state what is included in these variable 

costs and describe the underlying assumptions used as a basis for determining this 

amount. 

13. Some of the mathematical calculations for Exhibit 6 are not readily understandable. 

Please provide this data in spreadsheet format in order for the Department to fully 

analyze it. 

14. In our request for information to Exec Air in September 2011, we noted that in the 

Monthly Cash Analysis, the air carrier's list of projected airport fees indicated that it 

does not expect to incur any "GPU/station rental" expenses and asked for an 

explanation. In Exec Air's response, it appears that that information is now deleted. 

Please explain how Exec Air intends to provide ground power for its aircraft. 

15. Exec Air's financial projections to do not vary, that is, increase or decrease, from 

month to month. Generally, air carriers experience f1uctuating monthly expenses 

depending on when the company expects to incur various expenses such as aircraft 

maintenance, employee training, or insurance payments. Likewise, air carrier revenues 

generally fluctuate with changes in demand periods. Please explain why Exec Air does 

not expect its monthly revenues and expenses to fluctuate. 

16. In evaluating a new entrant applicants' financial fitness, the Department generally asks 

that those applicants have resources sufficient to cover all pre-operating costs and any 

negative working capital balance, plus a working capital reserve equal to the operating 

costs that would be incurred in three months of nonnal commuter operations. Exec 

Air's total first year projected expenses as stated in Exhibit 6, page 6 of 7, indicates 

total operating expenses of $154,284. To meet the Department's financial fitness 

requirement, Exec Air would have to show that it has access to capital equal to 

3 months of normalized operations which would be $ 38,571. Please discuss Exec 

Air's plans for satisfying the Department's capital requirements. 

If Exec Air is exempt fi·om the Florida minimum wage rate, please provided a detailed explanation ofthe basis 

of the exemption.