BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

) 

Application of ) 

) 

VOLGA-DNEPR AIRLINES LLC ) 

) Docket OST -2012-0 156 __ _ 

for an emergency exemption from ) 

conditions established by Order 98-2-5, ) 

and for Statement of Authorization ) 

Washington, D.C.- Tunis, Tunisia - Khartoum, Sudan ) __________________________________ ) 

RESPONSE OF VOLGA-DNEPR AIRLINES 

Communication with respect to this document should be addressed to: 

Alexey I. lsaikin 

Chainnan 

Volga-Dnepr Airlines LLC 

14 Karbysheva Street 1215 

Ulyanovsk, Russia 

DATED: September 18, 2012 

Colon Miller 

Volga Dnepr-Unique Air Cargo, Inc. 

9400 Grogan's Mill Road, 

Town Center Plaza, Suite 220, 

The Woodlands, TX USA 

(832) 585-8611 

NOTICE: THIS APPLICATION IS FILED PURSUANT TO THE EMERGENCY 

EXEMPTION PROCEDURES OF 14 C.F.R. § 302.410, WHICH AUTHORIZE THE 

DEPARTMENT TO ACT ON EMERGENCY EXEMPTIONS IMMEDIATELY. ANY 

PERSON INTERESTED IN FILING AN ANSWER IS REQUESTED TO DO SO IN THE 

ABOVE DOCKET IMMEDIATELY. COPIES OF THE SUBMISSION SHOULD BE 

SERVED ON THE PERSONS LISTED ABOVE AND ON THE ATTACHED SERVICE LIST. 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

) 

Application of ) 

) 

VOLGA-DNEPR AIRLINES LLC ) 

) Docket OST-2012-0156 __ _ 

for an emergency exemption from ) 

conditions established by Order 98-2-5, ) 

and for Statement of Authorization ) 

Washington, D.C. - Tunis, Tunisia - Khartoum, Sudan ) 

----------------------------~----) 

RESPONSE OF VOLGA-DNEPR AIRLINES 

Volga-Dnepr Airlines LLC ("Volga-Dnepr Airlines" or "Volga-Dnepr"), submits in 

response to Kalitta Air's objection of Volga-Dnepr Airlines request to be granted an emergency 

exemption from the provisions of the Department's Order No. 98-2-5 ("The Sudan Order") so as 

to pennit Volga-Dnepr to operate one (1) one-way all-cargo charter flight, utilizing VolgaDnepr's AN-124-100 aircraft to transport U.S. diplomatic cargo from Washington, D.C. to 

Tunis, Tunisia and Khartoum, Sudan on or about September 19, 2012 - September 22, 2012, on 

behalfof the U.S. Department of State, the following: 

Department of State officials had solicited U.S. Flag Carriers (B-747 Operators), initially 

to support movement of the cargo in question. However after review of the replies/offers from 

U.S. Carriers, Department of State officials decided the proposed timelines, B-74 7 aircraft 

availability, and the need to use additional and external loading and unloading equipment to 

support B-747 aircraft, complicated their situation, adding to delays in support, timeline increase 

for loading and offloading, additional coordination, and exposure on the ground in Tunisia and 

Sudan. Furthennore offers from B-747 operators suggested the cargo be moved to New York 
v1a land, prepped for airlift from JFK, fly via UAE, then eventually onward to requested 

destinations. As previously stated these offers and options using B-74 7 limited State 

Department's flexibility and speed to respond to the shipment requirements, further complicating 

an already complicated and pressing situation in the developing unrest ongoing in Tunisia and 

Sudan, and would further delay delivery of critically needed cargo and equipment to provide 

security and stability to State Department personnel and U.S. Citizens in the region. A decision 

to contact Volga-Dnepr was made due to the airlines ability to provide quick on load and offload 

capability, greater payload for additional cargo that can be provided to the Embassy as the 

current security situation continues to be unstable and unsafe for U.S. citizens in the area, and the 

fact the Department of State personnel were well acquainted with Volga-Dnepr's capability to 

provide a "quick reaction" scenario, as Volga-Dnepr has performed many flights for the 

Department of State and the U.S. Military supporting similar critical sensitive moves in such 

times of crisis. Volga-Dnepr's ability to move quickly, provide instant support for both flight 

operations and ground support for loading/unloading, expertise in HAZMA T and ammunition 

transport, also contributed to the Department of State's decision to request AN-124 airlift 

support. Taking into consideration the due diligence the State Department planners put forth in 

seeking U.S. airlift, the weighing of their options and choosing what best fit the mission scenario 

for directed results responding rapidly to needed security equipment, personnel, and critical 

cargo; Volga-Dnepr's application should be granted. Failure to uphold Volga-Dnepr's 

application this close/short to required mission execution and delivery, would impact the State 

Department's mission of providing a rapid response and maximizing their delivery capability by 

utilizing the AN-124 aircraft, and could jeopardize safety of U.S. Citizens on the ground in 

Tunisia and Sudan. Furthermore the AN-124 aircraft will provide much needed support to allow 

for transportation of key State Department couriers (15), direct into Tunisia avoiding issues and 

safety concerns surrounding traveling via commercial means to areas currently restricted for 

public travel. Not only will the choice of aircraft provide much needed delivery of critical cargo, 
armored vehicles, ammunition, etc. etc., rapidly in support of the ongoing threats to U.S. interest 

in Tunisia and Sudan; but also provide safe travel for the required personnel from the State 

Department who are needed to accompany the cargo and be on location in Tunisia and Sudan 

ASAP. In addition the Director, Regional Logistics Division, U.S. Department of State provided 

a letter of support/urgency, as previously filed. For these reasons, Yolga-Dnepr pleads their 

application stand as requested, and be granted authority to operate the flight as scheduled; 

approximately 12 hours from now (0 I :30 Local D.C. Time/19 Sep ). 
WHEREFORE, Volga-Dnepr Airlines respectfully requests that the Department issue an 

emergency exemption from the provisions of Order DOT 98-2-5 and grant Statement of 

Authorization under 14 C.F.R. Part 212 so as to permit Volga-Dnepr to operate one one-way all 

cargo charter flight utilizing Volga-Dnepr' s AN 124-1 00 aircraft to transport the above described 

cargo on behalf of U.S. Department of State from Washington, D.C. to Tunis, Tunisia and 

Khartoum, Sudan on September 19, 2012 - September 22, 2012. 

Dated: September 18, 2012 

Respectfully submitted, 

Colon Miller 

Designated agent for Volga-Dnepr Airlines 

(832) 585-8611 
CERTIFICATE OF SERVICE 

I hereby certify that I have on this day served a copy of the foregoing document upon all 

persons named on the attached service list via electronic mail. 

Colon Miller 

Dated: September 18, 2012 
Volga-Dnepr Unique Air Cargo 

Town Center Plaza 

ATTN: Colon Miller 

9400 Grogans Mill Rd, Suite 220 

The Woodlands, TX 77380 

United States Department of State 

Washingtmr, D.C. 20520 

September 17, 2012 

As discussed over the last 24 hours, the U.S. Department of State has an urgent airlift 

requirement to move I 05,000 lbs of Diplomatic Cargo destined for our U.S. Embassies 

Tunis, Tunisia and Khartoum, Sudan. The cargo consists of seven (7) fully armored 

vehicles and physical security materials required to secure and protect these embassies 

and staff. It is critical that we use aircraft with a roll-on/roll-off capability such as the 

AN-124 to minimize reliance on aircraft ground handling equipment and cargo facilities 

at the destination airfields. Using this type of aircraft will minimize the risk caused by 

disruptions to nonnal airport operations due to the current conditions in the region. The 

swift unimpeded offload of this equipment is critical to the lives and safety of our 

personnel. 

The Department of State appreciates your company's prompt support on this very 

important mission. 

Respectively, 

k~~ Robert S. Browning 

Director, Regional Logistics 

U.S. Department of State 

' 
Service List 

Marshall S. Sinick 202/626-6600

Squire, Sanders & Dempsey

1201 Pennsylvania Avenue, N.W.

Suite 400

Washington, DC 20004

For: ALASKA AIRLINES, INC. 

 FLORIDA WEST

(FAX: 202/626-6780)

Angelia Bird 901/434-8589

FEDERAL EXPRESS CORPORATION 

3620 Hacks Cross Rd.

Memphis, TN 38125

 (FAX: 901/434-9289)

Carl B. Nelson, Jr. 202/496-5647

Associate General Counsel

AMERICAN AIRLINES 

1101 17th Street, N.W.

Suite 600

Washington, DC 20036

(FAX: 202/496-5660)

Margot Wiegele 907/249-5142

NORTHERN AIR CARGO, Inc.

3900 West International Airport Road

Anchorage, AK 99502

(FAX: 907/249-5190)

Scott Yohe 202/216-0700

Vice-President, Government Affairs

1629 K Street, N.W.

Suite 501

Washington, DC 20006

For: DELTA AIRLINES, INC.

(FAX: 202/216-0824)

Tom Gillies 203/847-6000

President

117 Glover Avenue

Norwalk, CT 06850

For: SOUTHERN AIR 

(FAX: 203/847-6000)

Department of State - EUR/RUS 

Room 4223

2201 C Street, N.W.

Washington, DC 20250

(FAX: 202/736-4710)

Russell E. Pommer 202/822-9121

Associate General Counsel and Director of 

Regulatory Affairs

ATLAS AIR, INC. 

1747 Pennsylvania Ave., N.W., Suite 875

Washington, DC 20006

 (FAX: 202/822-9152)

Deputy Assistant Secretary for

Transportation Affairs

Department of State 

Bureau of Economics and Business

Affairs, EB/TRA, Room 5830

2201 C Street, N.W.

Washington, DC 20250

(FAX: 202/647-4324)

Jeffrey Manley 202/663-6655

1455 Pennsylvania Ave, N.W.

Washington, DC 20004

For: UNITED AIRLINES 

 (FAX: 202/772-6670)

Roger Rapier 202/267-9555

(ATO-R) Office of International Aviation

Federal Aviation Administration 

800 Independence Avenue, S.W.

Washington, DC 20591

(FAX: 202/267-9208)

Pierre Murphy, Esq. 202/776-3980

1200 New Hampshire Avenue, N.W.

Suite 800

Washington, D.C. 20036

For: ARROW AIR, INC. 

 (FAX: 202/776-3975)
David Vaughan 202/955-9864

Kelley Drye & Warren

1200 19th Street, N.W.

Suite 500

Washington, D.C. 20036

For: U.P.S. 

(FAX: 202/955-9792)

John L. Richardson 202/828-0158

 202/371-2258

Crispin & Brenner|

1156 15th Street, NW, Suite 1105

Washington, DC 20005

For: AMERIJET INTERNATIONAL, 

 INC. 

(FAX: 202/828-0152)

Robert Silverberg 202-944-3300

Silverberg, Goldman & Bikoff

1101 30th St., N.W., Suite 120

Washington, D.C. 20007

 For: ABX Air, Inc 

 (FAX: 202/944-3304)

Mark Atwood 202/463-2513

Sher & Blackwell

1850 M Street, N.W., Suite 900

Washington, D.C. 20036

 For: KALITTA AIR, L.L.C. 

 (FAX: 202/463-4950)

Hershel Kamen 713/324-6697

Senior Managing Director of International 

Regulatory Affairs

CONTINENTAL AIRLINES

2929 Allen Parkway

Suite 1925

Houston, TX 77019

(FAX: 713/324-2749)

Stephen H. Lachter 202/962-4321

1150 Connecticut Ave, N.W.

Suite 900

Washington, D.C. 20036

For: ASTAR AIR CARGO 

(FAX: 202/835-3219)

Ronald Priddy 703/358-8060

National Air Carriers’ Association

1000 Wilson Bvd., Suite 1700

Arlington, VA 22209

 (FAX: 703/358-8070)

Judy McKenzie 907/249-4100

6441 South Air Park Place

Anchorage, AK 99502

 LYNDEN AIR CARGO 

 (FAX: 907/245-0642)

Ben Graves 503/472-9361

EVERGREEN INTERNATIONAL, INC.

1401 New York Ave., N.W., Suite 530

Washington, D.C. 20005-2147

(FAX: 202/638-4593)

Mark McMillin 770/632-8215

Assistant General Counsel

HLH Bldg, 101 World Drive

Peachtree City, GA 30269

For: WORLD AIRLINES 

(FAX: 770/632-8048)

David Vaughan 202/955-9864

Kelley Drye & Warren

1200 19th Street, N.W.

Suite 500

Washington, D.C. 20036

For: U.P.S. 

(FAX: 202/955-9792)

Kevin P. Montgomery 202/828-1002

POLAR AIR CARGO 

1747 Pennsylvania Ave., N.W., Suite 875

Washington, DC 20006

 (FAX: 202/828-1003)