OST-98-3876 / Shuttle America / Certificate of Public Convenience / May 22, 1998

Applicant Requests Processing Under the Expedited Licensing Procedures of Subpart Q of the Department's Procedural Regulations. 14 C.F.R. 302.1701 et seq.

Notice: Any Person that wishes to support or oppose this Application must file an answer by June 19, 1998 and serve that answer on all persons served with this Application.

Application of

SHUTTLE AMERICA CORPORATION / DOCKET OST 98-3876

for a Certificate of Public Convenience and Necessity Pursuant to 49 U.S. C. §41102 to engage in interstate scheduled air transportation

Shuttle America Corporation ("Shuttle America") respectfully applies for a Certificate of Public Convenience and Necessity authorizing the carrier to engage in interstate scheduled air transportation of persons, property and mail pursuant to 49 U.S. C. §41102. Shuttle America requests expedited action under Subpart Q of the Department of Transportation's (the "Department") Procedural Regulations to allow final Department action in time for the carrier to commence scheduled service in September, 1998.

As demonstrated below, Shuttle America is a citizen of the United States within the meaning of 49 U. S.C. §40102(a)15. Shuttle America is fit, willing and able to provide the air transportation for which authority is sought and to comply with the Statute and the Department's Regulations.

Shuttle America has assembled a highly experienced and qualified management team. The carrier has obtained the financing necessary to initiate and maintain its proposed operations. Shuttle America has developed a sound operational plan; the carrier's Application demonstrates that management has developed a thoughtful, carefully designed proposal to convenience an important under served segment of the traveling public.. By all measures used by the Department, Shuttle America is qualified to commence scheduled passenger service and this Application should be expeditiously granted.

In Support of its Application Shuttle America states as follows:

1. Shuttle America is a corporation organized on January 19, 1996 under the Laws of the State of Delaware. Shuttle America originally was incorporated as "National Air Shuttle, Inc." However, on August 27, 1996, by written consent of a majority of shareholders, its name was changed to Shuttle America Corporation. A copy of a certificate of the Secretary of State of Delaware, attesting to Shuttle America's good standing is attached as Exhibit 1.

Shuttle America's address and telephone number are:

2. Shuttle America is a citizen of the United States within the meaning of 49 U.S. C. §40102(a)(I 5). With the exception of CEBC Wood Gundy Capital Ventures, which holds 14.3 % of the voting convertible preferred stock of Shuttle America and therefore 11. 1% of the outstanding voting stock, all other stockholders, officers, directors and key personnel are U.S. citizens.

3. Shuttle America plans to provide short-haul, point-to-point air transportation utilizing 50-seat turboprop aircraft, initially serving medium-sized cities and satellite airports of major cities in the Northeast and Mid-Atlantic States. Shuttle America will offer a unique service to cities whose size can not support low-fare jet service. Shuttle America will begin serving four cities in the Northeast whose identities will remain confidential for competitive reasons. Further information regarding the identity of the specific cities to be served will be provided at the Department's request.

4. Shuttle America will offer safe, affordable, reliable and convenient air transportation to cities that have experienced significant fare increases and a loss of service as a result of airline industry consolidation over the last ten years. Shuttle America's unique combination of affordable and simple fares, frequent flights, and attractive and comfortable aircraft will provide a valuable service to the traveling public.

5. Shuttle America has attracted an experienced, highly trained management team and staff comprised of maintenance, operating, financial and marketing personnel all with experience in the airline industry. (Exhibit 3). Management is focused on ensuring the highest levels of safety, reliability and compliance with all rules and regulations of the Department. Shuttle America's maintenance and operations managers have prior Part 121 new entrant experience.

6. Shuttle America plans to initiate service with 50-seat Bombardier Dash 8 Series 300 aircraft in an all-coach, two-by-two seating configuration. Initially. Shuttle America plans to lease six aircraft with an option for an additional three in the first year of operation. The Dash 8-300 aircraft will enable Shuttle America to provide safe and reliable air transportation to the public and generate a reasonable rate of return for investors.

7. Shuttle America already has obtained its initial financing through capital investments by management and outside investors. As demonstrated in the Exhibits, funds currently available are more than sufficient to institute service and maintain and develop that service according to the carrier's marketing plans. There also is ample capital for unforeseen events. As demonstrated in Exhibit 15, Shuttle America's capital structure is more than sufficient to meet the Department's financial fitness test.

8. Shuttle America has developed a reasonable growth plan based on the extensive experience of the management team and the awareness of changes that have occurred in the air transportation industry since its deregulation in 1978. After the success of its initial service, Shuttle America will expand to other similar markets in the Northeast and Mid-Atlantic States. Shuttle America has designed its planned rate of growth to ensure that it can property mange the recruitment and training of its personnel and maintain the highest standards of safety reliability and quality of service.

Information in support of Shuttle America's Application is contained in Exhibits I through 18, attached. Additional information, if any, sought by the Department's staff will be supplied expeditiously. As indicated on the attached service list and, with the consent of Department staff, Shuttle America, for commercial and competitive reasons, is not specifically naming the cities it initially plans to serve. However, all the exhibits are based on actual mileages and operational characteristics of the cities the carrier plans to serve, and the Airport Authorities of each city have been served with a copy of the Application and Exhibits.

For all these reasons, Shuttle America Corporation respectfully requests the Department grant its Application for a certificate of public convenience and necessity to engage in interstate scheduled air transportation.

Respectfully submitted,

Stephen Lachter

LAW OFFICES OF STEPHEN H. LACHTER

1150 Connecticut Avenue, N.W.

Suite 900

Washington, D.C. 20036

(202) 862-4321