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BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Application of

FRONTIER AIRLINES, INC.

for an exemption under 49 U.S.C. § 40109

(Lansing, Michigan – Puerto Vallarta/Cancun, Mexico)

(St. Louis, Missouri – San Jose del Cabo, Mexico)

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Docket DOT-OST-2013-_______

APPLICATION OF FRONTIER AIRLINES, INC. FOR EXEMPTION

Communications with respect to this document should be addressed to:

Daniel Shurz

Vice President, Planning and Strategy

FRONTIER AIRLINES, INC.

Frontier Center One

7001 Tower Road

Denver, CO 80249

Robert E. Cohn

Patrick R. Rizzi

HOGAN LOVELLS US LLP

Columbia Square

555 Thirteenth Street, NW

Washington, DC 20004

+1 202 637 4999/5659

robert.cohn@hoganlovells.com

patrick.rizzi@hoganlovells.com

Counsel for

FRONTIER AIRLINES, INC.

July 22, 2013

NOTE: Frontier will be polling on this Application and will provide the results of

that polling to the Department as soon as it is completed.
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BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Application of

FRONTIER AIRLINES, INC.

for an exemption under 49 U.S.C. § 40109

(Lansing, Michigan – Puerto Vallarta/Cancun, Mexico)

(St. Louis, Missouri – San Jose del Cabo, Mexico)

)

)

)

)

)

)

)

)

)

Docket DOT-OST-2013-_______

July 22, 2013

APPLICATION OF FRONTIER AIRLINES, INC. FOR EXEMPTION

Pursuant to Subpart C of the Department’s Rules of Practice,

Frontier Airlines, Inc. (“Frontier”) hereby applies under 49 U.S.C. § 40109 for an

exemption and related designation authorizing it to engage in scheduled foreign air

transportation of persons, property, and mail between (i) Lansing (LAN), Michigan and

Puerto Vallarta (PVR), Mexico, (ii) Lansing (LAN), Michigan, and Cancun (CUN),

Mexico, and (iii) St. Louis (STL), Missouri, and San Jose del Cabo (SJD), Mexico.

Frontier will poll on this Application and report the polling results to the Department as

soon as possible.

In support of this Application, Frontier states as follows:

1. Frontier holds a certificate of public convenience and necessity

authorizing it to engage in scheduled foreign air transportation of persons, property, and

mail on certain U.S.–Mexico routes. See DOT Order 2011-6-12 (Route 904).1Frontier

also holds exemption authority for various additional U.S.-Mexico routes.2Frontier’s

1

The routes are: Denver-Cancun, Denver-Cozumel, Denver-Ixtapa/Zihuatanejo, DenverMazatlan, Denver-Puerto Vallarta, Denver-San Jose del Cabo, Indianapolis-Cancun, Kansas CityCancun, Kansas City-Puerto Vallarta, Kansas City-San Jose del Cabo, Milwaukee-Cancun,

St. Louis-Cancun, St. Louis-Puerto Vallarta, and Salt Lake City-Cancun.

2

See Notices of Action Taken, dated November 28, 2011 (Docket DOT-OST-2011-0209);

December 9, 2011 (Docket DOT-OST-2011-0214); February 28, 2012 (Docket DOT-OST-2012-

0027); June 13, 2013 (Docket DOT-OST-2013-0116).
Application of Frontier Airlines, Inc.

Page 2

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scheduled services are provided using a fleet of Airbus A-318, A-319, and A-320

aircraft.

2. On or about January 24, 2014, Frontier plans to introduce weekly

scheduled service between Lansing, Michigan, and Puerto Vallarta, Mexico, using

138-seat Airbus A-319 aircraft. On or about January 25, 2014, Frontier plans to

introduce twice weekly scheduled service between Lansing, Michigan, and Cancun,

Mexico, using 138-seat Airbus A-319 aircraft. On or about February 15, 2014, Frontier

plans to introduce weekly scheduled service between St. Louis, Missouri, and San

Jose del Cabo, Mexico, using 168-seat Airbus A-320 aircraft. Each of these three

services (LAN-PVR, LAN-CUN, STL-SJD) will be operated on a seasonal basis.

3. Frontier is fully qualified to perform the proposed services, which are

similar in length and type to Frontier’s other U.S.-Mexico services. Frontier requests

that the Department take official notice, pursuant to Rule 24 of the Department’s Rules

of Practice, of all other data on file with the Department necessary to establish its

fitness.

4. Frontier’s proposed services are fully consistent with the Air Transport

Agreement between the United States and Mexico. Three carriers of each country may

be designated to provide scheduled nonstop combination service between any given

U.S. gateway and each of Puerto Vallarta, Cancun, and San Jose del Cabo. See United

States–Mexico Air Transport Agreement, Annex I(B)(5), as amended. Based on

information and belief, unused U.S. airline designations are available for Frontier’s

proposed services between Lansing and Puerto Vallarta, Lansing and Cancun, and

St. Louis and San Jose del Cabo.

5. Grant of this Application is in the public interest. The proposed LAN-PVR

and LAN-CUN services will benefit consumers by enabling Frontier to enhance
Application of Frontier Airlines, Inc.

Page 3

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competitive service offerings to Mexico, by expanding Mexico service for Lansing and its

surrounding regions, and by bringing scheduled nonstop Puerto Vallarta and Cancun

service to Lansing. Similarly, the proposed STL-SJD services will benefit consumers by

enabling Frontier to enhance competitive service offerings to Mexico, by expanding

Mexico service for St. Louis and its surrounding regions, and by bringing scheduled

nonstop San Jose del Cabo service to St. Louis.

6. The environmental impacts of Frontier’s proposed aircraft operations on

this route are de minimis, and Frontier does not anticipate that the roundtrip LAN-PVR,

LAN-CUN, and STL-SJD flights contemplated herein will cause a near-term net annual

change in aircraft fuel consumption of 10 million gallons or more. Frontier anticipates

that it will have no difficulty obtaining adequate supplies of fuel for these services.

WHEREFORE, Frontier respectfully requests that the Department promptly grant

Frontier an exemption and designation authorizing it to engage in scheduled foreign air

transportation of persons, property, and mail between (i) Lansing, Michigan, and Puerto

Vallarta, Mexico, (ii) Lansing, Michigan, and Cancun, Mexico, and (iii) St. Louis,

Missouri, and San Jose del Cabo, Mexico.

Respectfully submitted,

______________________________________

Robert E. Cohn

Patrick R. Rizzi

HOGAN LOVELLS US LLP

555 Thirteenth Street, NW

Washington, DC 20004

+1 202 637 4999/5659

Counsel for

FRONTIER AIRLINES, INC.
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CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Application of Frontier Airlines, Inc. for an

Exemption has been served this 22nd day of July 2013, upon each of the following

addressees:

bob.kneisley@wnco.com; marshall.sinick@squiresanders.com; robert.wirick@aa.com;

francis.heil@aa.com; sascha.vanderbellen@delta.com; chris.walker@delta.com;

jhill@dowlohnes.com; perkmann@dowlohnes.com; jyoung@yklaw.com;

dkirstein@yklaw.com; Thomas.Ting@suncountry.com; dan.weiss@united.com;

steve.morrissey@united.com; howard_kass@usairways.com;

benjamin.slocum@usairways.com; barbara.russell@virginamerica.com;

brian.hedberg@dot.gov; esta.rosenberg@dot.gov; brett.kruger@dot.gov; urskr@state.gov;

info@airlineinfo.com

Jonathan Echmalian