404979112v4

BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D. C.

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

Application of )

) DOT-OST-2013-0035

INSELAIR ARUBA N.V. )

)

For a Statement of )

Authorization under Part 212 )

(Aruba – Miami codesharing) )

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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: romanow@pillsburylaw.com

peter.nelson@pillsburylaw.com

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 17, 2015. The applicant intends 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. )

)

For a Statement of )

Authorization under Part 212 )

(Aruba – Miami codesharing) )

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

APPLICATION OF INSELAIR ARUBA N.V.

InselAir Aruba N.V. (“Insel Aruba”) hereby applies, pursuant to 14 C.F.R. Part 212, for a 

Statement of Authorization to enable InselAir Aruba to place 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 requests 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 transportation 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 United States and the Kingdom of the Netherlands in Respect of the 
404979112v4

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 scheduled service to the United States 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. “In operating the authorized services on the agreed routes, any designated airline 

of one Party may enter into cooperative marketing arrangements such as blockedspace, 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 authorizes 

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 herein

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 air 

transport agreements, and will, therefore, serve the public interest. Insel 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, 2015
404979112v4

CERTIFICATE OF SERVICE

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

day 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 Airlines

robert.wirick@aa.com

howard.kass@aa.com

Steve Morrissey

Dan Weiss

United Airlines

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 Gretch

Brian Hedberg

Department of Transportation

paul.gretch@dot.gov

brian.hedberg@dot.gov

/s/ Melinda A. Hernandez

Melinda A. Hernandez