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 inthe EAS docket ofKake, Alaska (DOT-OST-2008-0217) inresponse to afiling 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 ofAlaska, and Alaska Seaplanes.
On May 29, 2014, Alaska Seaplanes filed a response to the proposals ofHarris 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 inDocket .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.comBEFORE 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 byApril 24, 2014. Three carriers submitted timely proposals: Harris Aireraft Services, Inc. (Harris Air), SeaPort Airlines, Inc. dba Wings ofAlaska (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 aresponse 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 oftheir original proposal. It is apparent that this negative campaign and excess narrative is meant to influence the decision making process ofthe community ofKake more than it is intended to add substance totheir Proposal.
In defense ofHarris 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 iscompletely without merit. Alaska Seaplanes isNOT the sole provider of IFR services in Southeast Alaska. Harris Air has been operating with this authority since 2000. Furthermore, ithas been operating as acommuter since 2012. This information has been brought up inevery public

. meeting at Kake, the questions asked by Kake officials and answered bythe operators.A chart showing Harris Air as lacking "Known Ice Capability" is also afalsehood. 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 ofthe Cessna Caravan. The Cessna Caravan has amuch published.history ofproblems flying in icing conditions. Thinly veiled within the response by Seaplanes istheir ongoing issue with the scheduled service Harris Air provides. Harris Air is authorized by the FAA to conduct Commuter Operations which does allow for 

### 14round 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 requiredfor commercial operations conducting intrastate transportation underpart 121 or 135 " These sections of fAA Order 8900.1 are the basis ofHarris' operating authority and the reason we have Commuter Operations Specifications. Furthermore, Harris Air was found fit by the Department ofTransportation in its original economic authority Certificate bid. Due to the loss of akey 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 arecent entrant into the world of known ice, IFR flying. In fact, Harris Air has a 

### 14year history oftraining and flying in these conditions. Our maintenance staff has an intimate knowledge ofthe 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 ofwhat the Department considers relevant in its selection process. 

### Itwould 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 clearthatthe response ofAlaska Seaplanesisonlymeantto shednegative lightoneach

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 communityofKake andfollowthecriteriaoutlinedinthe selectionprocess. In closing, Harris Air has been slowly and deliberately expanding its service inthe region. We arc a Medallion participant with 4 of 5 of its "stars". We are a single s~ away from becominga Shieldcarrier. Wehave established anon-linebooking andpaymentsystemand have spentthe lastyearworking outthebugs. Wewill soonbesubmittingourapplicationfor A US DOT Certificate ofPublic Convenience andNecessity and will obtainthat by fall of 2014. With that Certification we will upgrade our website and enable thc on-line system we've spent somuch time working with. Withthatbeing said, ifthe Departmentdetermines that Harris Air is not eligible for EAS at Kake, Alaska and the community prefers Alaska Seaplanes over SeaPortlWings werequestthe DepartmentnotauthorizeanEAS contractfor more than 2 years. Within this period Alaska Seaplanes will finally have a "track record" proving ordisproving allthey claimwithintheirresponseandHarrisAirwillhavetheability toagainbidcompetitively.

Respectfully submitted, Robert S. Harris,President HarrisAircraft Services,Inc.



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