404979112v4 BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D. C.

--------------------------------------------- ------------------- Application of )

) DOT

- OST

- 201 3

- 0035

INSELAIR ARUBA N.V. )

)

F or a S tatement of )

A uthorization under Part 212 )

( Aruba

– Miami codesharing) )

----------------------------------------------- -----------------

APPLICATION OF INSELAIR ARUBA N.V.

Communications with respect to this document should be addressed to:

Josh Romanow

Peter Nelson

PILLSBURY WINTHROP

SHAW PITTMAN LLP

1200 Seventeenth Street, NW

Washington, DC 20036

Phone: +1

- 202

- 663

- 8000

Fax: +1

- 202

- 663

- 8007

Email: r omanow@pillsburylaw.com

peter.nelson@pillsburylaw.co m

Counsel for InselAir Aruba N.V.

April 2, 2015

NOTE: Any person may support or oppose this Application by filing an answer and serving a

copy of the answer on counsel for InselAir Aruba N.V. and upon each person served with this

application. Answers are due by April 1 7 , 2015

. The applicant intend s to poll parties on the

service list and will advise the Department of the results.1

404979112v4 BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D. C.

--------------------------------------------- ------------------- Application of )

) DOT

- OST

- 2015

-

INSELAIR ARUBA N.V. )

)

F or a S tatement of )

A uthorization under Part 212 )

( Aruba

– Miami codesharing) )

----------------------------------------------- -----------------

APPLICATION OF INSELAIR ARUBA N.V.

InselAir Aruba N.V

. ( “ Insel Aruba ” ) hereby appl ies, pursuant to 14 C.F.R. Part 212

, for a

Statem e nt of Authorization to enable InselAir Aruba to p lace the Insel Air International B.V.

(“Insel Air”) code “7I” on scheduled flights operated by Insel Aruba between Aruba and Miami.

Insel Aruba respectfully seeks expedited treatment of this application and a waiver of the

advance filing requirement in 14 C.F.R. § 212. 10(d)(2) , and request s that the Statement of

Authorization be effective for an indefinite period, consistent with Department precedent.

Insel Aruba is a foreign carrier of Aruba that holds an open skies foreign air carrier

permit to conduct scheduled and charter foreign air tra nsportation between Aruba and the United

States, via behind, intermediate, and beyond points ( See Order 2013

- 8

- 10). Insel Aruba began

scheduled operations from Aruba to Miami in 2014.

Insel Air is a foreign air carrier of Curacao that holds a foreign air carrier permit and

exemption authority to conduct scheduled and charter foreign air transportation between the U.S.

and the (former) Netherlands Antilles , via intermediate points, as provided by the Air Transport

Agreement between the U nited States and the Kingdom of the Netherlands in Respect of the404979112v4 Netherlands Antilles ( See Order 2007

- 12

- 1 and Notice of Action Taken dated December 2, 2009,

for which renewal is pending under the Administrative Procedures Act ). Insel Air has been

operating s cheduled service to the United Sta tes from Curacao for several years.

For operations where the “7I” code will be placed on Insel Aruba flights in this market,

the 7I flight will either begin in or end in Curacao

.

Article 8, Section 7(b) of the Air Transport Agreement between the United States and the

Kingdom of the Netherlands in Respect of Aruba provides:

a. “ I n operating the authorized services on the agreed routes, a ny designated airline

of one Party may enter into cooperative marketing arrange ments such as blocked

space, code

- sharing or leasing arrangements, with:

b. an airline or airlines of a third country, provided that such third country authorizes

or allows comparable arrangements between the airlines of the other Party and

other airlines on services to, from and via such third country; ”

Similarly, for Curacao, Article 8, Section 7(b) of the (former) Netherlands Antilles Air

Transport Agreement also authorizes third country code

- sharing:

a. “ In operating or holding out the authorized services on the agreed routes, any

designated airline of one Party may enter into cooperative marketing

arrangements such as blocked

- space, code

- sharing or leasing arrangements, with :

b. an airline or airlines of a third country, provided that such third country authori zes

or allows comparable arrangements between the airlines of the other Party and

other airlines on services to, from and via such third country; ”

Both carriers are fully qualified to operate the services for which authority is here in

requested . Grant of this authority will provide additional air service opportunities to travelers in

Curacao, Aruba and the United States and is consistent with the rights granted in the relevant a ir

t ransport a g reements, and will, therefore, serve the public interest

. Inse l Air will comply with

the requirements of Part 257 of the Department’s regulations with respect to the disclosure of

code share relationships.404979112v4 WHEREFORE, based upon the foregoing information, Insel Aruba respectfully request

that the Department grant its request for a Statement of Authorization as more fully described

above

.

Respectfully submitted,

Josh Romanow

Peter Nelson

PILLSBURY WINTHROP

SHAW PITTMAN LLP

1200 Seventeenth Street, NW

Washington, DC 2036

Phone: (202) 663

- 8000

Fax: (202) 663

- 8007

Email: romanow@pillsburylaw.com

peter.nelson@pillsburylaw.com

Counsel for InselAir Aruba N.V.

April 2 , 2015404979112v4 CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing joint application has been served this the 2 nd

d ay of April , 2015 , upon each of the parties below by electronic mail.

Sascha Vanderbellen

Chris Walker

Delta Airlines

sascha.vanderbellen@delta.com

chris.walker@delta.com

Robert Wirick

Howard Kass

American Air lines

robert.wirick@aa.com

howard.kass@aa.com

Steve Morrissey

Dan Weiss

United Air lines

steve.morrissey@united.com

dan.weiss@united.com

Anita Mosner

Jennifer Nowak

Counsel for United Parcel Service Co

Holland & Knight

anita.mosner@hklaw.com

jennifer.nowak@hklaw.com

Russell Pommer

Atlas Air

rpommer@atlasair.com

James R. Jelenski

Federal Aviation Administration

jamesr.jelenski@faa.com

Jonathan Hill

J. Parker Erkmann

Cooley LLP

JetBlue Airways

jhill@cooley.com

perkmann@cooley.com Bailey Leopard

Nancy Sparks

Federal Express Corporation

gbleopard@fedex.com

nssparks@fedex.com

David Kirstein

Counsel for

Spirit Airlines

dkirstein@yklaw.com

Robert Kneisley

Leslie Abbott

Southwest Airlines

bob.kneisley@wnco.com

leslie.abbott@wnco.com

Paul Gre tch

Brian Hedberg

Department of Transportation

paul.gretch@dot.gov

brian.hedberg@dot.gov

/s/ Melinda A. Hernandez

Melinda A. Hernandez