BEFORE THE DEPARTMENT OF TRANSPORTA nON'

June 11,2014

Essential Air Service At

KAKE, ALASKA

Under 49 U.S.C. 41731 etseq.

)

)

)

)

)

)

)

Docket OST -2008-0217

MOTION OF HARRIS AIRCRAFT SERVICES, INC

FOR LEAVE TO FILE AN UNAUTHORZED DOCUMENT

Harris Aircraft Services, Inc. motions for leave to file an authorized document in the EAS

docket of Kake, Alaska (DOT -OST -2008-0217) in response to a filing by Kalinin Aviation,

Inc. dba Alaska Seaplanes.

By Order 2014-3-15, the Department requested proposals from carriers interested in

providing Essential Air Service at Kake, Alaska due by April 28, 2014. Three carriers

submitted timely proposals: Harris Aircraft Services, Inc., Wings of Alaska, and Alaska

Seaplanes.

On May 29, 2014, Alaska Seaplanes filed a response to the proposals of Harris Aircraft

Services, Inc and Wings of Alaska. Harris Aircraft Services, Inc.is responding herein to

Alaska Seaplanes and respectfully asks that the Department include this document in Docket

.OST-2008-0217

Communications with respect to this document should be addressed to:

Robert S. Harris

Harris Aircraft Services, Inc.

400 Airport Road

Sitka, AK 99835

Tel. 907-966-3050

Email: scott@harrisair.com
BEFORE THE DEPARTMENT OF TRANSPORT AnON

June 11,2014

Essential Air Service at

KAKE, ALASKA.

Under U.S.C 41731.et seq.

)

)

)

)

)

)

)

DOCKET: OST-2008-0217

COMMENTS OF HARRIS AIRCRAFT SERVICES, INC

IN RESPONSE TO KALININ AVIATION, INC.

By Order 2014-3-15, the Department requested proposals from carriers interested in

providing Essential Air Service at Kake, Alaska due by April 24, 2014. Three carriers

submitted timely proposals: Harris Aireraft Services, Inc. (Harris Air), SeaPort Airlines, Inc.

dba Wings of Alaska (SeaPortlWings) and Kalinin Aviation, LLC dba Alaska Seaplanes

(Alaska Seaplanes). Comments from the Community were due on May 29,2014

On May 29,2014 Alaska Seaplanes filed a response to the proposals submitted by Harris Air

and SeaPortlWings. This response is no more than continued marketing by Alaska Seaplanes

and adds nothing substantive to their proposal. While adding nothing to the docket, the

response takes aim at Harris Air by providing incorrect, misleading information and adds a

narrative that should have been part of their original proposal. It is apparent that this negative

campaign and excess narrative is meant to influence the decision making process of the

community of Kake more than it is intended to add substance to their Proposal.

In defense of Harris Air we wish to add clarification to specific, incorrect comments within

the Seaplanes response.

Alaska Seaplanes states that "Onty Seaplanes can operate full IFR scheduled service in

known icing conditions, offering greater safety and reliability." This statement is completely

without merit. Alaska Seaplanes is NOT the sole provider of IFR services in Southeast

Alaska. Harris Air has been operating with this authority since 2000. Furthermore, it has been

operating as a commuter since 2012. This information has been brought up in every public

. meeting at Kake, the questions asked by Kake officials and answered by the operators.
A chart showing Harris Air as lacking "Known Ice Capability" is also a falsehood. Harris Air

operates late model Piper PA-31-350 Aircraft that left the factory line with all known icing

equipment installed. Unlike the older Caravan or early model Navajos we had no need for

aftermarket kitS or "improvements" to make them compliant. In fact, the Chieftain has an

excellent record for operating in the icing environment, which is in marked contrast to the

record of the Cessna Caravan. The Cessna Caravan has a much published.history of problems

flying in icing conditions.

Thinly veiled within the response by Seaplanes is their ongoing issue with the scheduled

service Harris Air provides. Harris Air is authorized by the FAA to conduct Commuter

Operations which does allow for 14 round trips per week and more. Quoting directly from

FAA Order 8900.1, Volume 3, Chapter 34, Section 2 (C, 2, B, 3):

"The FAA will issue an operating certificate and OpSpecs with commuter and ondemand operating authority to the applicant. The applicant can conduct only

scheduled and on-demand intrastate operations under this authority. It does not need

DOT economic authority. "

Quoting from FAA Order 8900.1, Volume 2, Chapter 2, Section 2, and Paragraph 2-130;

"No economic authority is required for commercial operations conducting intrastate

transportation under part 121 or 135 "

These sections of fAA Order 8900.1 are the basis of Harris' operating authority and the

reason we have Commuter Operations Specifications. Furthermore, Harris Air was found fit

by the Department of Transportation in its original economic authority Certificate bid. Due to

the loss of a key medevac contract Harris Air was forced to reevaluate its application for

economic authority and ultimately withdrew the application. The original application was for

Commuter Authority although the forthcoming application will be for Public Convenience

and Necessity.

The response by Alaska Seaplanes is clearly meant to cast a positive light on the fact that

they only recently obtained the authority and equipment necessary to operate in this

environment. As Harris Air slated in its proposal, we are not a recent entrant into the world of

known ice, IFR flying. In fact, Harris Air has a 14 year history of training and flying in these

conditions. Our maintenance staff has an intimate knowledge of the navigation, autopilot and

deice systems required to operate our scheduled service. In addition, Harris Air maintains an

extensive parts inventory in support of these aircraft. All of this combined is a testament to

our reliability and shows that we can effectively operate scheduled service to any point in

Southeast Alaska.

With regard to SeaPortlWings of Alaska: The proposal submitted by Wings appears to have

much of what the Department considers relevant in its selection process. It would appear that

SeaPortlWings submitted a proposal that not only meets much of the selection criteria but is,

most likely an accurate reflection of what the subsidy need would be to support their large

operation. It is notable that Alaska Seaplanes attacks SeaPortlWings with an unnecessary,

slanderous slogan from a biker bar in Anchorage, Alaska and news reports from a market in

Athens, Georgia. All together, these comments are meant to imply that SeaPortlWings would

somehow be cheating the Federal government.
It is clear that the response of Alaska Seaplanes is only meant to shed negative light on each

of the opposing applicants in the hopes of influencing the people of Kake. Harris Air is

confident that the Department will make its decisions based on fact and input from the

community of Kake and follow the criteria outlined in the selection process.

In closing, Harris Air has been slowly and deliberately expanding its service in the region.

We arc a Medallion participant with 4 of 5 of its "stars". We are a single s~ away from

becoming a Shield carrier. We have established an on-line booking and payment system and

have spent the last year working out the bugs. We will soon be submitting our application for

A US DOT Certificate of Public Convenience and Necessity and will obtain that by fall of

2014. With that Certification we will upgrade our website and enable thc on-line system

we've spent so much time working with. With that being said, if the Department determines

that Harris Air is not eligible for EAS at Kake, Alaska and the community prefers Alaska

Seaplanes over SeaPortlWings we request the Department not authorize an EAS contract for

more than 2 years. Within this period Alaska Seaplanes will finally have a "track record"

proving or disproving all they claim within their response and Harris Air will have the ability

to again bid competitively.

Respectfully submitted,

Robert S. Harris, President

Harris Aircraft Services, Inc.

,