1 BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Application of

SEAPORT AIRLINES, INC.

for a certificate of public convenience and necessity

pursuant to 49 U.S.C. § 41102 to engage in foreign

scheduled air transportation of persons, property and

mail between the United States and Mexico. Docket No. OST

- 2014

-

_______

APPLICATION OF SEAPORT AIRLINES, INC.

FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY

FOR FOREIGN SCHEDULED AIR TRANSPORTATION AUTHORITY

Communications with respect to this document should be sent to:

Timothy Sieber

Executive Vice President

SeaPort Airlines, Inc.

7505 N E Airport Way

Portland International Airport

Portland, OR 97218

Telephone: (971) 340

- 1716

tsieber@seaportair.com

June 23 , 2014

Notice : Any person who wishes to support or oppose this Application may do so by: (1) filing an

answer by July 23 , 2014 ; and (2) serving that answer on the person(s) listed above and all

persons served with a copy of this Application

.1 BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Application of

SEAPORT AIRLINES, INC.

for a certificate of public convenience and necessity

pursuant to 49 U.S.C. § 41102 to engage in foreign

scheduled air transportation of persons, property and

mail between the United States and Mexico. Docket No. OST

- 2014

-

_______

APPLICATION OF SEAPORT AIRLINES, INC.

FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY

FOR FOREIGN SCHEDULED AIR TRANSPORTATION AUTHORITY

SeaPort Airlines, Inc. (“SeaPort”), pursuant to 49 U.S.C. § 41102, Subpart C of the

Department’s Rules of Practice (14 C.F.R. Part 302), and the Department’s streamlining

regulatory procedures for licensing U.S. air carriers, 1 hereby applies for a certificate of public

convenience and necessity to engage in foreign scheduled air transport ation of persons, property

and mail between the United States and Mexico.

SeaPort plans to initiate service in late 2014 with four (4) roundtrip flights per week

between San Diego and San Felipe, Mexico.

In support of this Application, SeaPort states as follows:

1. SeaPort is a n Alaska corporation in good standing with its principal place of

business at 7505 NE Airport Way, Portland International Airport, Portland, Oregon, 97218.

2. SeaPort is a citizen of the United States as defi ned in 49 U.S.C. § 40102(a)(1 5).

SeaPort 's President and more than two

- thirds of its directors and managing officers are

1 See Notice in Docket OST

- 2005

- 22228 directing carriers to submit applications for U.S.

- Mexico certificates of public convenien ce and

necessity to Docket OST

- 2011

- 0076.1

citizens of the United States, and at least seventy

- five percent (75%) of its voting interest is

owned and controlled by persons who are citizens of the United States.

3. SeaPort holds Commuter Air Carrier authority as defined in 49 U.S.C. § 41 738

and has been found fit to provide scheduled interstate air transportation of persons, property and

mail.

4. SeaPort is fit, willing and able to provide the air transportati on for which authority

is sought. The grant of the authority sought herein is fully consistent with the public convenience

and necessity, as required under 49 U.S.C. § 41102.

5. SeaPort currently provides daily scheduled interstate air transportation to 21 ci ties

in nine states: Gustavus, Haines, Hoonah, Juneau, and Skagway, Alaska; El Dorado, Harrison,

and Hot Springs, Arkansas; Burbank, Imperial/El Centro, and San Diego, California; Athens,

Georgia; Salina, Great Bend, and Wichita, Kansas; Kansas City, Missouri; North Bend/Coos Bay,

Pendleton, and Portland, Oregon: Jackson, Memphis, and Nashville, Tennessee; and Dallas,

Texas.

6. As stated above, SeaPort will initially provide service between San Diego and San

Felipe (four roundtrip flights per week). SeaPort also plans to additional s ervice to Mexico in 2015

from San Diego, Phoenix, and Tucson

.

7. The traffic rights sought herein are provided for under the U.S.

– Mexico Transport

Agreement. 2

8. SeaPort is seeking, pursuant to a separate petition field concurrent with this

request, an exemptions under 49 U.S.C. § 40109 to initiate service between San Diego,

California and San Felipe, Mexico and asks that the Department take official notice of all

information contained therein.

9. SeaPort 's proposed U.S.

- Mexico services are not materially different in terms

2 Air Transport Services Agreement, with schedule, between the United States and Mexico (Aug. 15, 1960), as amended and

extended.1

of aircraft size or stage length from its current scheduled interstate operations.

10. The addition of SeaPort’s reliable, high quality operations to and from Mexico will

provide much needed nonstop air service between the U.S. and smaller communities in Mexico

,

market development and trade opportunities, and high quality service to the traveling public in

the U.S.

- Mexico market.

11. Based on the entire record in Docket OST

- 2005

- 23307, the current state of

bilateral relations between the United States and Mexico, and the considerable public benefits

derived from additional service in the U.S.

- Mexico market, SeaPort respectfully requests that

the Department grant the authority sought herein. Moreover, SeaPort asks th at the authority

requested herein be integrated with all other authority held by SeaPort.

12. SeaPort does not anticipate that approval of this application will result in a net

annual change in aircraft fuel consumption of 10 million gallons or more in the nea r term , does

not anticipate any difficulty obtaining adequate supplies of fuel for its proposed U.S.

- Mexico

services, and believes that the overall environmental impact resulting from its proposed U.S.

-

Mexico services will be de minim us.

WHEREFORE, f or the foregoing reasons, SeaPort Airlines, Inc. respectfully requests that

the Department grant a certificate of convenience and public necessity under 49 U.S.C. § 41102

to SeaPort, authorizing the airline to provide scheduled foreign air transportation o f persons,

property and mail between the United States and Mexico.

Respectfully submitted,

Timothy Sieber

Executive Vice President

SeaPort Airlines, Inc.

7505 N Airport Way

Portland International Airport

Portland, OR 97218

Telephone: (971) 340

- 1716

tsieber@seaportair.com8 CERTIFICATE OF SERVICE

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

an exemption was served this 2 3rd day of J une 2014

, via email transmission on the

following persons:

urkskr@state.gov (Department of State)

cristinasa@state.gov (Department of State)

esta.rosenberg@dot.gov (Department of Transportation)

brian.hedberg@dot.gov (Department of Transportation)

peter.irvine@dot.gov (Department of Transportation)

brett.kruger@dot.gov (Department of Transportation)

benjamin.tayor@dot.gov (Department of Transportation)

kylelevine@alaskaair.com (Alaska)

charles.donely@squiressanders.com (Counsel for Alaska)

robert.wirick@aa.com (American)

abigail.donovan@aa.com (American)

dan.weiss@united.com (United)

steve.morrissey@united.com (United)

karine.faden@united.com (United)

gmurphy@crowell.com (Counsel for United)

sascha.vanderbellen@delta.com (Delta)

jhill@cooley.com (Counsel for JetBlue)

perkmann@cooley.com (Counsel for JetBlue)

Robert.land@jetblue.com (JetBlue)

howard.kass@aa.com (American Airlines and U.S. Airways)

msinick@ssd.com (Counsel for A laska)

bob.kneisley@wnco.com (Southwest)

leslie.abbott@wnco.com (Southwest)

ethan.blank@rjet.com (Republic)

Robert.cohn@hoganlovells.com (Counsel for Republic)

Patrick.rizzi@hoganlovells.com (Counsel for Republic)

John.fredricksen@suncountry.com (Sun Country)

Thomas.ting@suncountry.com (Sun Country)

rpommer@atl asair.com (Atlas)

anita.mosner@hklaw.com (Counsel for UPS)9

Jennifer.nowak@hklaw.com (Counsel for UPS)

cefelts@fedex.com (Fed Ex)

nssparks@fedex.com (Fed Ex)

kevin.montgomery@polaraircargo.com (Polar)

stephen.lachter@lachterlaw.com (Frontier)

barbara.russell@virginamerica.com (Virgin America)

jhill@dowlohness.com (Counsel for Hawaiian)

dkirstein@yklaw.com (Counsel for Spirit)

jyoung@yklaw.com (Counsel for Spirit)VERIFICATION

Pursuant to Title 18 United States Code Section 1001, I, Timothy F Sieber

, in my

individual capacity and as the authorized representative of the applicant, have not in any

manner knowingly or willfully falsified, concealed or covered up any material fact or made

any false, fictitious or fraudulent statement or knowingly used any documents which contain

such statements in connection with the preparation, filing or prosecution of this exemption

application. I understand that an individual who is found to have violated the provisions of 18

U.S.C. Section 1001 shall be fined not more than $10,000 or imprisoned not more than

five years, or both.

Name: Timothy F, Sieber

Date: June 23 , 2014

Title: Executive Vice President