Dash Air has suspended scheduled flights and will refund all ticket sales following a 96-page complaint filed by Kenmore Air with the U.S. Department of Transportation that specifies unfair and deceptive business practices and a lack of certifications.

Kenmore Air, which operated passenger service for more than 10 years at Fairchild International Airport in Port Angeles until November 2014, said Dash Air lacks proper licensing to advertise connections to airlines outside the state.

“Air Shuttle is engaging in unfair and deceptive business practices by openly proposing to operate interstate scheduled air service without having been found fit by the Department of Transportation, in violation of 49 USC 41102 and 14 CFR 201,” the complaint states.

“Fitness and certification are primary consumer protection functions of the Department, as well as being specifically required by law. By asserting that it has all necessary government authority, Air Shuttle is misleading the traveling public.”

Clint Ostler, the president of Dash Air, said inaugural flights scheduled to begin Aug. 11 have been canceled out of an abundance of caution as the airline responds to the complaint.

“We believe these claims are unfounded, and we remain committed to our guests and Port Angeles,” Ostler said. “Based on early sales, we know the service will be a success. Following a ruling from the DOT, Dash will announce a new start date and resume ticket sales.”

“We are humbled by the overwhelming enthusiasm for our service from the Port Angeles community.”

The estimated DOT review period of the complaint could be anywhere from 30-120 days, Ostler said.

The Kenmore Air complaint claims Dash Air advertises its services on its website, which is considered an interstate and international platform. It also advertises its connections to Seattle-Tacoma International Airport, seemingly without limitations or restrictions on passenger routing or contract of carriage.

Its scheduling and operations service will be operated by a company, Backcountry Aviation, with its only FAA base of operations in Albany, Ore., the complaint says.

And online sales and reservations are handled via a cloud-based system operated by a company based in Orlando, Fla., where there appear to be no geographic limitations on where a reservation and purchase of a ticket may be made.

The complaint also says Dash Air has not applied for or doesn’t have a Certification of Public Convenience and Necessity or Commuter Air Carrier, which are required for multiple flights per day.

“All these actions are prima facie (accepted as correct until proved otherwise), proof of engaging in interstate commerce,” the complaint says.

Ostler said Dash Air is awaiting approval from the FAA on Intrastate Provision, which dictates that the commuter line can only operate within the state.

“Dash Air maintains that there is ample precedent for DOT to dismiss these claims,” Ostler said in a press release issued last week.

“However, ticket sales and planned operations have been temporarily suspended out of an abundance of caution until the complaint has been resolved.

“Pending DOT review, Dash has chosen to provide maximum consumer protection in advance of planned travel and will refund all tickets sold to date.”

Ostler would not provide the amount the airline plans to refund, but he said Dash Air is focusing on giving those who purchased tickets ample time to make new travel plans.

“We are working with our legal team to get an expedited hearing date so we can start providing flights as soon as possible,” Ostler said.

“Dash encourages local members of the Port Angeles community to show support of air service in Port Angeles by filing comments with the DOT, or visit Dash on Facebook to learn more about how you can show your support for air service in Port Angeles,” he said.