BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASIDNGTON, D.C. 

) 

Application of ) 

) 

HARRIS AIRCRAFT SERVICES, INC. ) Docket DOT-OST-2014-0145 

) 

for a certificate of public convenience and ) 

necessity pursuant to 49 U.S.C. §41102 ) 

to engage in interstate scheduled air ) 

transportation of persons, property and mail ) 

MOTION FOR LEAVE TO FILE AND RESPONSE TO 

MOTION FOR LEAVE TO FILE AND RESPONSE OF AIR EXCURSIONS LLC 

Communications with respect to this document should be sent to: 

R. Scott Harris 

President 

Harris Aircraft Services, Inc. 

400 Airport Road 

Sitka, AK 99835 

October 23, 2014 

Pierre Murphy 

Law Offices of Pierre Murphy 

1200 New Hampshire Avenue, NW 

Suite 590 

Washington, DC 20036 

Telephone: (202) 776-3980 

Facsimile: (202) 776-3975 

Email: pmurphy@lopmurphy.com 

Attorney for 

Harris Aircraft Services, Inc. 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

) 

Application of ) 

) 

HARRIS AIRCRAFT SERVICES, INC. ) Docket DOT-OST-2014-0145 

) 

for a certificate of public convenience and ) 

necessity pursuant to 49 U.S.C. §41102 ) 

to engage in interstate scheduled air ) 

transportation of persons, property and mail ) 

MOTION FOR LEAVE TO FILE AND RESPONSE TO 

MOTION FOR LEAVE TO FILE AND RESPONSE OF AIR EXCURSIONS LLC 

Harris Aircraft Services, Inc. ("Harris Air" or "Applicant") respectfully submits this 

Motion for Leave to File an unauthorized document and response in opposition to the October 6, 

2014 Motion for Leave to File and Response of Air Excursions LLC ("Air Excursions" or "lone 

Objector") filed herein. The Department's procedural regulations afford no basis for the filing of 

such a Response by Air Excursions, which Response raises no new issue or facts not already 

raised by Objector in its detailed 12-page Answer dated September 15, 2014. 1 Since it is unclear 

whether the Department will grant lone Objector's motion, Harris Air is obliged to make this 

response. 

Whereas it appears almost automatic now for Alaska certificated air carrier objectors to 
MOTION AND RESPONSE OF 

HARRIS AIR 

file multiple, unauthorized sur-responses upon sur-responses in any application involving other 

Alaska carriers, at both the application and post-Show Cause phases, lone Objector's Response 

herein should be rejected as unduly burdensome and a misuse of the Department's procedural 

process. Lone Objector has already availed itself of the right to file a detailed Answer. This 

unauthorized Response raises nothing it has not already raised in its Answer or in the 2013 

Docket. 

Notwithstanding, in the event the Department does grant the lone Objector's Motion, 

Applicant requests that its Motion to file be granted as well. 

The lone Objector raises no new argument or issues of fact in its October 6 Response not 

already raised by it in its September 15 Answer and which has already been responded to by 

Applicant. This device in Alaska cases of multiple, unauthorized pleadings filed in both the predecision phase followed by more of the same in the post-Show Cause Order process is a misuse 

of the process, interposed for delay, and is intended to improperly burden and harass legitimate 

applicants for certificate authority. 

Responded to by Applicant in its September 29 Reply authorized by the Department's procedural 

regulations. 

2 
MOTION AND RESPONSE OF 

HARRIS AIR 

October 23, 2014 

3 

Resr ctfully submitted, 

rreM 

Offic s o 1erre Murphy 

1200 New Hampshire Avenue, NW 

Suite 590 

Washington, DC 20036 

Telephone: (202) 776-3980 

Facsimile: (202) 776-3975 

Email: pmurphy@lopmurphy.com 

Attorney for Harris Aircraft Services, Inc. 
Certificate of Service 

I hereby certify that on October 23, 2014, a copy of the foregoing Motion and Response of 

Harris Aircraft Services, Inc. was served via US Mail (and by electronic transmission where 

indicated) to the following persons: 

Attn: Terry L. Gordon 

Manager 

Attn: Troy McClanahan 

POI 

Juneau Flight Standards District Office (FSDO AL05) 

Federal Aviation Administration 

3032 Vintage Park Boulevard 

Suite 106 

Juneau,AK 99801 

Peter J. Lynch 

Assistant Chief Counsel for Enforcement AGC-300 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Regional Counsel, AAL-7 

Federal Aviation Administration 

Alaskan Region Headquarters 

222 West 7th A venue, Suite 14 

Anchorage,AK 99513 

Office of Airline Info 

DOTIRITAIBTS E-36-RTS-42 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Robert E. Cohn, Esq. (via email) 

Patrick R. Rizzi, Esq. 

Counsel for AIR EXURSIONS, LLC/ ALASKA SEAPLANES, LLC 

Hogan Lovells US, LLP 

Columbus Square 

555 13th Street, NW 

Washington, DC 20004 

robert.cohn@hoganlovells.com 

patrick.rizzi@hoganlovells.com