Hogan Lovells US LLP Columbia Square 555 Thirteenth Street, NW Washington, DC 20004 T +1 202 637 5600 F +1 202 637 5910 www.hoganlovells.com

Robert E. Cohn, Senior Counsel +1.202.637.4999 Direct Line [email protected]

Patrick R. Rizzi, Counsel +1.202.637.5659 Direct Line [email protected] January 8, 2021

Ms. Lauralyn J. Remo Chief, Air Carrier Fitness Division Mr. Jerish Varghese Office of Aviation Analysis U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, DC 20590

Re: Trans of : Documentation for Effective Certificate for Foreign Charter Air Transportation (Docket DOT-OST-2015-0233)

Dear Ms. Remo and Mr. Varghese:

Pursuant to DOT Order 2017-3-22, served March 30, 2017, and DOT Order 2017-6-11, served June 15, 2017, Trans Executive Airlines of Hawaii, Inc. d/b/a Transair Express d/b/a Transair Global d/b/a Interisland Airways (“Trans Executive”) hereby requests that the Department make effective Trans Executive’s Certificate of Public Convenience and Necessity for Foreign Charter Air Transportation (“Foreign Charter Certificate”).

Trans Executive had planned to commence foreign charter air transportation services well before now. Unfortunately, as a result of various factors beyond its control, including the global COVID-19 pandemic, Trans Executive was unable to secure the necessary Operations Specifications from the FAA for foreign air transportation until recently. It has just received Operations Specifications for foreign operations (e.g., Canada, Mexico, Central and South America, the Caribbean).

Accordingly, Trans Executive is furnishing the following documents and providing updated information to the Department to bring into effect its Foreign Charter Certificate:

(a) Ops Specs. Attachment TEA-1 is a copy of Trans Executive’s FAA Air Carrier Certificate (No. TXHA688I) and excerpts of Operations Specifications amendments reflecting, among other things, authorizations for its -200 VIP passenger operations in foreign air transportation.

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(b) Certificate of Insurance. Attachment TEA-2 is a completed Certificate of Insurance on OST Form 6410 evidencing liability insurance coverage exceeding the requirements of 14 C.F.R. § 205.5(b) for Trans Executive’s current fleet.

(c) Changes. Mr. Riahi, Trans Executive’s President and CEO, confirms that Trans Executive has not undergone any changes to its ownership, operating plans, or compliance history, nor have there been any negative developments to its financial posture, since the date of the Show Cause Order in this case.

There have been two changes to Trans Executive’s key personnel since the Show Cause Order. First, Mr. Raja Segaran, formerly VP of Maintenance, is no longer with the air carrier, and his position has been eliminated. Mr. Chris Harness remains as the Director of Maintenance. We previously submitted a completed key employee compliance questionnaire and resume for Mr. Harness. Second, Mr. William Stickney has retired as Chief Pilot, and Mr. Mario Roman is now Trans Executive’s Chief Pilot. A completed key employee compliance questionnaire and resume for Mr. Roman are provided as Attachment TEA-3.

(d) Pre-Operating Expenses and Available Funds. Mr. Riahi has confirmed that all pre-operating expenses have been paid, and none remain outstanding. Attachment TEA-4 is an updated balance sheet for Trans Executive, showing positive working capital. Attachment TEA-5 is a letter from Central Pacific Bank confirming that Trans Executive has a balance for its depository accounts in “the low eight figures” (meaning at least $10 million). That is significantly more than the financial fitness threshold of $471,000 set forth in the Show Cause Order.

Trans Executive clearly meets the Department’s requirements to make its Certificate of Public Convenience and Necessity for foreign charter air transportation effective. Trans Executive is ready to put its Boeing 737-200 VIP passenger aircraft to revenue use in foreign charter service and is eager to advertise, contract for, and operate such flights with this aircraft under its fully effective Foreign Charter Certificate. Accordingly, Trans Executive respectfully urges the Department to accelerate its review of this submission and confirm that its Foreign Charter Certificate will be made immediately effective rather than requiring Trans Executive to wait six business days before its certificate will come into effect.

A Verification signed by Mr. Riahi is also attached to this Letter.

Respectfully submitted,

Robert E. Cohn Patrick R. Rizzi Counsel for Trans Executive Airlines of Hawaii, Inc. d/b/a Transair Express d/b/a Transair Global d/b/a Interisland Airways

Attachments: Verification, Attachments TEA-1 through TEA-5 cc: Teimour Riahi, President & CEO, Trans Executive Airlines of Hawaii, Inc.

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ATTACHMENT TEA-1

US. Cencement of Transpertotrcui Federal Aviation Administration

Air Carrier Certificate

This certifies that TRANS EXECUTIVE AIRLINES OF HAWAII COMMUTER TERMINAL INTERNATIONAL AIRPORT HONOLULU, HI 96819 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 riot transferable and, unless sooner surrendered. suspended, or revoked, shall continue in effect indefinitely_

By Direction of the Administrator.

Certificate number: TXHA6881 f7441ILLIAR H,_ LLIAMS, JR, (Srgnature) June 5, 1991 Effective date: Manager, Flight Standards Division (Title)

Issued at: Honolulu, Hawaii kPqtorn-PA,-4fir Region (RegiOniaffiCei

FAA Form 8430-18 (8-071

ATTACHMENT TEA-2

AGENCY DISPLAY OF ESTIMATED BURDEN The public reporting burden for this collection of information is estimated to average 30 minutes per response. If you wish to comment on the accuracy of the estimate or make suggestions for reducing this burden, please direct your comments to: U.S. Department of Transportation, Office of Aviation Analysis, X-56, 400 7th St., SW., Washington, D.C. 20590. According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless it displays a valid OMB control number. Office of the Secretary of Transportation NOTE: For information on where to file completed copies of this form, see FILING INSTRUCTIONS below.

OMB No. 2106-0030 Expires 9-30-2007 U.S. AIR CARRIERS - CERTIFICATE OF INSURANCE POLICIES OF INSURANCE FOR AIRCRAFT ACCIDENT BODILY INJURY AND PROPERTY DAMAGE LIABILITY

FILING INSTRUCTIONS: File a signed original of this form with the Federal Aviation Administration, AFS-260, 800 Independence Ave., S.W., Washington, D.C. 20591. (See EXCEPTIONS 1 and 2 below.) EXCEPTION 1: If Block 2B on the reverse is filled in because the insured is a commuter air carrier, file a signed original of this form with the Department of Transportation, Air Carrier Fitness Division, X-56, 400 7th St., SW, Washington, DC 20590. EXCEPTION 2: For any insured that is located in the State of Alaska (regardless as to whether Block 2A, 2B, or 2C is filled in), file a signed original of this form with the Federal Aviation Administration, Alaskan Region Hq., AAL-230, 222 W. 7th Ave., #14, Anchorage, Alaska 99513.

(Please type information, except signatures.) National Union Fire Insurance Company of Pittsburgh, PA through AIG Aerospace Insurance THIS CERTIFIES THAT: ______Services, Inc. and various other insurers (Name of Insurer)

has issued a policy or policies of Aircraft Liability Insurance to ______Trans Air Holdings, Inc.; Trans Executive Airlines of Hawaii, Inc. dba Trans______Air

______FAAPO Box 29239 Honolulu, HI 96820 Certificate Number______TXHA688I (Name, address and FAA Certificate number of Insured U.S. Air Carrier)

effective from ______July 31, 2020 until ten (10) days after written notice from the insurer or carrier of the intent to terminate coverage is received by the Department of Transportation. NOTE: Part 205 of the Department’s Regulations does not allow for a predetermined termination date, and a certificate showing such a date is unacceptable. ______1. The Insurer (Check One): is licensed to issue aircraft insurance policies in the United States; is licensed or approved by the government of ______to issue aircraft insurance policies; or is an approved surplus line insurer in the State(s) of ______2. The insurer assumes, under the policy or policies listed below, aircraft accident liability insured to minimums at least equal to the following during operation, maintenance, or use of aircraft in “air transportation” as that term is defined in 49 U.S.C. 40102. (Complete applicable section(s) A, B, or C below): A. U.S. AIR TAXI OPERATORS (EXCLUDING U.S. COMMUTER AIR CARRIERS) WITH PART 298 AUTHORITY ONLY: The aircraft covered by this policy are SMALL AIRCRAFT (i.e., with 60 or fewer passenger seats or with a maximum payload capacity of 18,000 pounds or less). (Complete separate or combined coverage as appropriate):

Separate Coverages: Minimum Limit Policy No. Type of Liability Each person Each Occurrence ______Bodily Injury Liability (Excluding Passengers) $ 75,000 $300,000 ______Passenger Bodily Injury $ 75,000 $75,000 x 75% of total number of passengerseats installed in aircraft ______Property Damage $100,000

Combined Coverage: The amount of coverage set forth below is a single limit of liability for each occurrence at least equal to the required minimums stated above for bodily injury (excluding passengers), property damage, and passenger bodily injury.

Policy No.______Amount of Coverage______

This policy covers CARGO operations only and excludes passenger liability insurance.

OST Form 6410 B. U.S. COMMUTER AIR CARRIERS OR CERTIFICATED AIR CARRIERS OPERATING SMALL AIRCRAFT The aircraft covered by this policy are SMALL AIRCRAFT (i.e., with 60 or fewer passenger seats or with a maximum payload capacity of 18,000 pounds or less). (Complete separate or combined coverage as appropriate): Separate Coverages: Minimum Limit Policy No. Type of Liability Each person Each Occurrence ______Combined Bodily Injury (Excluding Passengers other than cargo attendants) and Property Damage Liability $300,000 $2,000,000 ______Passenger Bodily Injury $300,000 $300,000 x 75% of total number of passenger seats installed in aircraft Combined Coverage: The amount of coverage set forth below is a single limit of liability for each occurrence at least equal to the required minimums stated above for bodily injury (excluding passengers), property damage, and passenger bodily injury. Policy No.______FV 001855368-16/FG 001855369-16 Amount of Coverage______See Attached Schedule

This policy covers CARGO operations only and excludes passenger liability insurance. ______C. U.S. CERTIFICATED AIR CARRIERS OPERATING LARGE AIRCRAFT The aircraft covered by this policy are LARGE AIRCRAFT (i.e., with more than 60 passenger seats or with a maximum payload capacity of more than 18,000 pounds). (Complete separate or combined coverage as appropriate): Separate Coverages: Minimum Limit Policy No. Type of Liability Each person Each Occurrence ______Combined Bodily Injury (Excluding Passengers other than cargo attendants) and Property Damage Liability $300,000 $20,000,000 ______Passenger Bodily Injury $300,000 $300,000 x 75% of total number of passenger seats installed in aircraft Combined Coverage: The amount of coverage set forth below is a single limit of liability for each occurrence at least equal to the required minimums stated above for bodily injury (excluding passengers), property damage, and passenger bodily injury. Policy No.FV______001855368-16/FG 001855369-16 Amount of Coverage______See Attached Schedule

This policy covers CARGO operations only and excludes passenger liability insurance. ______3. The policy or policies listed in this certificate insure(s) (Check One): Make and Model FAA or Foreign Flag Registration No. Operations conducted with all aircraft operated by the insured See Attached Schedule Operations conducted with the following types of aircraft: Operations with the following aircraft: (Use additional page if necessary) ______4. Each policy listed in this certificate meets or exceeds the requirements in 14 CFR Part 205.

National______Union Fire Insurance Company of Pittsburgh, PA ______McGriff, Seibels,& Williams (Name of Insurer) (Name of Broker, if applicable)

100______Colony Square, 1175 Peachtree Street NE ______7525 SE 24th St., Suite 520 (Address) (Address)

Atlanta,______GA 30361 ______Mercer Island, WA 98040 (City, State, Zip Code) (City, State, Zip Code)

Clay______Garner, Underwriter, AIG Aerospace ______Jenney Lindblom, Account Coordinator Contact (person who can verify the effectiveness of the coverage) (Officer or authorized representative)

______/______404-853-3123 404-249-1917 ______/______206-232-9870 206-232-9515 (Area Code, Phone Number) (Area Code, Fax Number) (Area Code, Phonehonone Number)Number) (Area(Are Code, Fax Number)

______(Signature, if applicable) (Signature)(S(Sigi nature)

______7/30/20 (Date) (Date) 7.50% B0507AV2000878 5.00% QSE453985‐01 20.00% FV001855368‐16 17.50%15.00% SASICOM60020720‐11 15.00%10.00% 100008584 10.00% UA00003930AV20A 016130‐011 NQC6034195 Participation Policy No. each each each FFR FFR FFR $1M each FFR iates AIG Aerospace nce Companies

uly 31, 2020‐2021 Trans Air Holdings, Inc. Aircraft Hull & Liability J Insurer Aircraft Description Reg. No. Liability Limit Status Underwriters at Lloyd's of London and/or Various Foreign Insura through Price Forbes & Partners Ltd. Starr Indemnity & Liability Company through Starr Aviation QBE Insurance Corporation through QBE Americas Great American Insurance Company XL Specialty Insurance Company through AXA XL Houston Casualty Company Endurance American Insurance Company through W. Brown and Assoc 1988 Shorts SD3‐601987 Shorts SD3‐601987 Shorts SD3‐60 N808KR $5,000,000 CSL excluding Pax1984 Boeing 737‐2Q8 N221LM $10,000,000 CSL with Pax limited to $1M N4476F N413JG $10,000,000 CSL with Pax limited to $1M $100,000,000 CSL, with Pax limited to GRO National Union Fire Insurance Company of Pittsburgh, PA through 1989 Shorts SD3‐601987 Shorts SD3‐601988 Shorts SD3‐60 N351TA $20,000,000 CSL including Pax N808TR $5,000,000 CSL excluding Pax N827BE $10,000,000 CSL with Pax limited to $1M FFR GRO Total Participation 100.00%

ATTACHMENT TEA-3

ATTACHMENT TEA-4

ATTACHMENT TEA-5