April 2, 2024

Scott Faulk
Office of Aviation Analysis
US Department of Transportation 1200
New Jersey Avenue SE
Washington, DC 20590

RE: Docket No. DOT-OST-2023-0186

Proposal to Provide EAS at Lanai, Hawaii

Dear Mr. Faulk:

Pacific Air Charters Incorporated (PACI) is pleased to present our response to the Request for
Proposals for Essential Air Service to/from Lanai City, Hawaii (LNY). In addition to responding
to the specifics of the RFP, we will demonstrate that PACI is the safest and best possible
service provider for the island of Lanai.

A. Proposal Summary
PACI proposes to provide safe, reliable, and cost-efficient Essential Air Service between Lanai
City (LNY) and Honolulu (HNL) and Kahului (OGG). PACI intends to operate the Essential Air
Service flights with our new, state-of-the-art, twin-engine, 9- passenger seat Tecnam P2012
Traveller airplanes with a schedule consistent with Lanai’s EAS determination.
Two alternative proposals are presented:
OPTION A - 81 inbound and outbound seats per day, with six roundtrips to Honolulu
and three roundtrips to Maui; and
OPTION B - 81 inbound and outbound seats per day, with seven roundtrips to Honolulu
and two roundtrips to Maui.

B. PACI Background

Pacific Air Charters, Inc. is a Hawaii corporation based in Honolulu and authorized to operate
as a Part 135 – FAA Certificated U.S. air carrier (QFAO929K). Since 2004 we have been
operating on-demand charter flights throughout the Hawaiian Islands. Our DUNS Number is
188101666; our Cage Number is 4FV22.

1|Page PACI EAS Proposal - Lanai

Concurrent with this proposal, PACI is applying to the FAA for intrastate commuter
authority. We believe our current insurance policy meets the requirements for such authority.

PACI is committed to developing and maintaining its own reservations system, capable of
handling the demands of the Lanai traveler. Passengers will book PACI flights through an
online reservations system or its telephone reservations center. PACI commits to maintain
consumer-friendly relationships with the major U.S. and international air carriers.

As a Part 135 certificated air carrier, PACI adheres to the airline industry's rigorous standard
safety practices. In addition to oversight from the Federal Aviation Administration, PACI
maintains an Air Research Group - ARGUS Gold Rating.

Patrick McNamee (Director of Operations) is a 50-year veteran in the airline industry, has 35
years of experience as a commercial pilot with a major worldwide airline and 45 years of
experience as Director of Operations with Part 135 carriers. He has been with PACI from its
inception and is the President of the General Aviation Council of Hawaii (GACH). Patrick’s
passion is to keep our skies safe by training professional, safety-minded pilots.

James Vanderkamp (PACI Chief Pilot and Safety Officer) is a retired Navy Fighter Pilot and

2|Page PACI EAS Proposal - Lanai

was formerly employed by the NTSB. Mr. Vanderkamp was also employed by several
international carriers and piloted the Boeing 747 for Japan Airlines and the Boeing 757
freighters here in Hawaii. He volunteers for the Civil Air Patrol flying missions and provides
orientation flights for the cadets.

Abigail Dang (PACI Assistant Chief Pilot) was trained in our Pilot Development Program and
received all her ratings at minimum age. She is employed as a Pilot in Command (PIC) and
as a Flight Instructor. Abigail is the Vice President of Women in Aviation, and Vice President
of the Aloha Chapter 99's, an organization committed to mentoring and training up
professionals interested in different aspects of the aviation industry.

Timothy Austen (Director of Maintenance) is a retired Southwest Airlines (SWA) pilot, and a
long time Aviation Mechanic. Tim has managed maintenance facilities for several airlines and
corporate flight departs. Tim holds a current Airline Transport Pilot (ATP) license and Airframe
and Powerplant Mechanic (A&P) license, along with an Inspection Authorization Certificate
(IA).

C. Proposal Details

Option A (Based on 9 Passenger Seats)

HNL OGG
Route Inbound Outbound Inbound Outbound Block Hrs

HNL-LNY-OGG-LNY-HNL 9 9 9 9 2:45
HNL-LNY-HNL 9 9 0 0 1:25
HNL-LNY-OGG-LNY-HNL 9 9 9 9 2:45
HNL-LNY-HNL 9 9 0 0 1:25
HNL-LNY-OGG-LNY-HNL 9 9 9 9 2:45
HNL-LNY-HNL 9 9 0 0 1:25

54 54 27 27 12:30

3|Page PACI EAS Proposal - Lanai

 Option B (Based on 9 Passenger Seats)

HNL OGG
Route Inbound Outbound Inbound Outbound Block Hrs

HNL-LNY-OGG-LNY-HNL 9 9 9 9 2:45
HNL-LNY-HNL 9 9 0 0 1:25
HNL-LNY-HNL 9 9 0 0 1:25
HNL-LNY-HNL 9 9 0 0 1:25
HNL-LNY-OGG-LNY-HNL 9 9 9 9 2:45
HNL-LNY-HNL 9 9 0 0 1:25
HNL-LNY-HNL 9 9 0 0 1:25

63 63 18 18 12:45

The schedules indicated are subject to change as we receive further community input and
market data. All flights would be serviced using our Tecnam P2012 Travellers. PACI proposes
to operate the services described for at least a two-year term, beginning 60 to 90 days after
award of the EAS contract.

PACI schedules are designed around the published schedules and minimum connection times
of major carriers. This will give Lanai passengers access to more than 120 destinations via
Honolulu and Maui.

All PACI aircraft are based at HNL. PACI schedules will allow for morning and evening arrivals
from and to Lanai, allowing travelers to create "daytrips" and maximize their time at their desired
destinations.

C. Reliability

Reliable air transportation begins with aircraft selection. PACI has chosen the twin-engine
Tecnam P2012 Traveller aircraft to provide service, with aircraft dedicated to Lanai routes.
PACI currently has four of these Travellers under lease, with more on order. Twin-engine
aircraft provide a significant safety advantage over single-engine aircraft. This is
especially important for over-water operations. There has been a significant number of
engine failures with the single-engine Cessna Caravans and Pilatus PC-12’s which are currently
used in Hawaii.

4|Page PACI EAS Proposal - Lanai

 TECNAM P2012 TRAVELLER

The Tecnam P2012 Traveller features a modern design and state-of-the-art equipment.
The Traveller seats up to 9 passengers in a configuration similar to other commuter
aircraft. Entry is through a large door with two easy steps from the ground to the plane.
The loading of carry-on bags is easer with the design of the Traveller
The interior features single seats with generous pitch, dedicated large viewing windows,
in-seat amenities (USB port, cup holder, seat pocket, armrest), and air conditioning
(which can also be operated via a DC power connection to “pre- cool” the aircraft prior to
boarding) offering limousine level comfort.
The Traveller is powered by two 375 HP Lycoming engines, with an Electronic Engine
Control System. Powered by low-lead avgas, green-house gas emissions are 15% of the
Pratt & Whitney engines of the Caravan, PC-12, and the Cessna 408. These same
5|Page PACI EAS Proposal - Lanai
Lycoming engines will be powered by no-lead avgas when it becomes available, cutting
emissions even further.

The simple and easily accessed airframe and systems, fixed landing gear, robust
interiors, and easy-to-replace parts result in high efficiency and low maintenance costs.
These attributes, and many more, make this the ideal aircraft for small market/short haul
routes such as those found in Hawaii.

Another key to reliable airline operations is a consistent supply of pilots. PACI currently
has a steady stream of prospective pilots and no reliability concerns related to lack of
crew. We are continuously improving our pilot hiring program to attract talented people
who wish to be a part of the communities we serve. PACI has instituted a Professional
Development Program (PDP) to help aspiring airline pilots acquire flight time and
experience as Second in Command Pilots. As they gain experience these Second- in-
Command Pilots go through the same training as a Pilot- in-Command and easily
advance to that position.

Finally, reliable airline service depends on aircraft maintenance. PACI maintenance

personnel have been factory-trained by the Tecnam manufacturer. PACI operates its
primary maintenance facility at the Daniel K. Inouye Honolulu International Airport (HNL).
We recently secured the only available covered hangar-maintenance facility available at
HNL to maintain our Traveller fleet. Having the aircraft covered is essential to maintaining
safety and reducing costs. If left in the open, the salt air from the Pacific Ocean quickly
causes corrosion and additional maintenance. If left unchecked, this poses a safety issue
as well as additional expense.

E. Marketing

The PACI schedule will be designed to allow maximum connectivity to major carriers
operating from HNL and OGG. PACI will incorporate Lanai City into its own marketing
efforts, including adding the ability for sales though PACI’s website, call centers, and
travel agents . PACI will commit to a minimum annual marketing budget of $25,000.
These funds will be expended on behalf of the proposed service to Lanai City, and in
coordination with community leaders and commercial organizations.

PACI will seek to foster and leverage community relationships and cooperative marketing
programs to extend the reach of marketing for each community. This can include use
of pre-existing airport sponsored sales teams, and the use of promotions and trade with
local organizations to extend the reach and frequency of PACI marketing efforts. PACI
will also work to become a greater part of the Lanai City community through community
outreach, sponsorships, promotions, and volunteer programs.

6|Page PACI EAS Proposal - Lanai

F. Financial Proposal

PACI requires a total annual subsidy package of $8,115,418 to initiate 42 weekly

roundtrips between Lanai City and Honolulu, and 21 weekly roundtrips between
Lanai City and Maui.

Information Option A Option B

Completed Departures per year 6,570 6,570

Completed Block Hours 4566 4,599

Passengers 44,106 44,106

Load Factor 75% 75%

Revenue per Passenger $101 $101

Passenger Revenue $4,468,500 $4,468,500

Variable Costs $10,159.684 $10,232,775

Station operations $1,800,000 $1,800,000

Marketing Expense $25,000 $25,000

Total Expenses $11,984,684 $12,057,775

Profit (Loss) Excluding Subsidy ($7,516,184) ($7,589,275)

Subsidy Revenue (5% margin) $8,115,418 $8,192,164

Subsidy per Departure $1,235 $1,247

Subsidy per Block Hour $1,777 $1,781

Subsidy per Passenger $184 $186

PACI requires a minimum service period of 24 months, with an inflation adjustment of

3% for the second 12 months

7|Page PACI EAS Proposal - Lanai

G. Conclusion

We believe PACI has presented a compelling case to become the Essential Air Service
provider at Lanai City. PACI is uniquely positioned to meet all the Department's selection
criteria while offering the community the maximum consumer benefits. Our proposal
can fundamentally improve air service to Lanai City given the key attributes to the product
offering, including:

• An uncompromising commitment to safety, with an unblemished safety record

• Twin-engine aircraft for safe over-water flights
• Two highly trained and experienced pilots operating each flight
• Factory-trained maintenance personnel and covered maintenance facilities
• Pilot Development Program to prepare the next generation of airline pilots
• Experienced airline executives who live and work in Hawaii
• A local airline that understands the culture and needs of the community

We are enclosing letters of support from our community leaders.

We look forward to working with the Department of Transportation and the Lanai
community to implement this award. The PACI team and I are available to answer any
questions as we eagerly await the prospect of serving the Lanai market.

Mahalo Nui loa,

Marshall Ashley
Chief Executive Officer
 HOUSE OF REPRESENTATIVES
Hale o no Luna Maka'ainana
STATE OF HAWAl'I
STATE CAPITOL
41S SOUTH BERETANII\ ST.
HONOLULU, HAWAl'I 96813

March 2 I, 2024

United States Department of Transportation

Essential Air Services Program
Docket No. DOT-OST-2023-0186

To whom it may concern:

I have the honor of serving as the Hawai' i State Representative for House District 13 ( Pa' ia, Ha· iku, Nahiku,
Hana, KTpahulu, Kaup6, Molokini, Kaho·olawe, Lana'i. and Molokai). I am submitting this letter of support for
Essential Air Service for the island of Lana' i.
Dependable, regular, and affordable air transportation service is essential for the people of our small island
communities. Air transpo1tation is the most efficient means of connecting these communities with needed
healthcare services, government services, and the national transportation system. The island of Lana'i is
dependent on the importation of both goods and services. Many interscholastic activities require that students r
travel to other islands to paiticipate. Currently, air transpo1tation to and f om Lana· i and other rural areas in our
district has reached a crisis level, especially for those traveling to access medical care. Frequent delays and
cancellations result in patients missing imp01tant appointments. including surgeries and chemotherapy, impacting
health outcomes. Essential Air Service could bring much-needed relief to these issues.

I urge you to consider Pacific Air Cha1ters lnc.'s proposal. As a locally owned and managed company, Pacific Air
Charters Inc. may be better positioned to understand the unique needs of our communities and expeditiously
transition into essential air service provision, connecting residents to reliable air transpo1tation sooner. However, I
am generally suppo1tive of any company that can reliably provide this service. If you have any questions or need
further information, please do not hesitate to contact me at (808) 586-6790.

Aloh�•r-

Representative Mahina Poepoe

Representative Mahina Poepoe

House District 13
415 S. Beretania Street, Room 331
Honolulu, HI 96813
(808) 586-6790 reppoepoe@capitol.hawaii.gov
United States Department of Transportation
Essential Air Services Program
Docket No. DOT-OST-2023-0186

To whom it may concern:

I am submitting a letter of support for Pacific Air Charters, Inc. and their proposal to provide
Essential Air Service to Lanai.

Dependable, regular and affordable air transportation service to small Island communities such
as Lanai and Molokai are essential services that both Islands deserve and are currently not
receiving. I have one employee who has been travelling to Honolulu from Molokai on a regular
basis for life saving medical treatments unavailable at our local hospital. The current air service
has been very challenging for someone with medical issues. He is forced to go the day ahead of
his scheduled medical appointments because the current service provider simply is unable to
reliably provide transportation services. He budgets a full 24 hours to take into account the
likely delays relative to his scheduled departure to ensure he does not miss his critical
appointments. This means he needs to book an additional night of accommodation on Oahu
which is expensive. I am sure his experience on Molokai parallels what the people of Lanai are
dealing with as well.

Pacific Air Charters, Inc. has been serving Hawaii for over 20 years and I have used their
services and have found them reliable and professional. I urge you to give favorable
consideration to the proposal of Pacific Air Charters Inc.

Best,

Kevin Comcowich
Kevin Comcowich

1 Kalae Highway, Box 33, Kualapu’u, HI 96757

Mailing: PO Box 272009, Houston, TX 77277-2009
US Department
of Transportation
Federal Aviation
Administration

Air Carrier Certificate

This certifies that
Pacific Air Charters, Inc.
91-1259 Midway Road
Bldg. 104, Suite 3
Kapolei, Hawaii 96707
has met the requirements of the Federal Aviation Act of 1958, as amended, and the rules,
regulations, and standards prescribed thereunder for the issuance of this certificate and is
hereby authorized to operate as an air carrier and conduct common carriage operations in
accordance with said Act and the rules, regulations, and standards prescribed thereunder
and the terms, conditions, and limitations contained in the approved operations specifications.

This certificate is not transferable and, unless sooner surrendered, suspended, or revoked,
shall continue in effect indefinitely.

By Direction of the Administrator

MICHAEL P Digitally signed by MICHAEL P

HEENAN

Certificate number: QF0A929K HEENAN Date: 2021.02.24 18:13:36 -06'00'

(Signature)

Effective Date: June 02, 2005 MANAGER

Reissued: February 19, 2021 (Title)

Issued at: WP13, HONOLULU HAWAII WESTERN PACIFIC / WP-13

(Region/Office)

FAA Form 8430-18 (6-87) Electronic Forms (PDF)