BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

MN Airlines, LLC d/b/a 

SUN COUNTRY AIRLINES 

Docket OST-2015-

For an exemption pursuant to 

49 U.S.C. §40109 (scheduled service 

between Fmi Myers, Florida 

and Cancun, Mexico) 

APPLICATION OF MN AIRLINES, LLC 

D/B/A SUN COUNTRY AIRLINES 

FOR AN EXEMPTION 

Communications with respect to this document should be addressed to: 

NOTICE: 

Thomas W. Ting 

General Counsel 

MN Airlines, LLC 

1300 Mendota Heights Road 

Mendota Heights, MN 55120 

Telephone: (651) 905-2729 

Fax: (651) 681-3911 

April15, 2015 

MN Airlines, LLC d/b/a Sun Country Airlines will conduct a poll of all 

carrier representatives listed on the service list attached to this application to 

determine if there are any objections to this application. 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

MN Airlines, LLC d/b/a 

SUN COUNTRY AIRLINES 

For an exemption pursuant to 

49 U.S.C. §40109 (scheduled service 

between Fort Myers, Florida 

and Cancun, Mexico) 

April15, 2015 

Docket OST-2015-

APPLICATION OF MN AIRLINES LLC, D/B/A 

SUN COUNTRY AIRLINES FOR AN EXEMPTION 

MN Airlines, LLC d/b/a Sun Country Airlines (Sun Country), pursuant to 49 U.S.C. 

§ 40109 and Subpart C of the Department's Rules of Practice, hereby applies for a two-year 

exemption order to provide scheduled foreign air transportation of persons, property and mail 

between Fort Myers, Florida (RSW) and Cancun (CUN) Mexico. 

Sun Country plans to commence twice-a-week seasonal service in the RSW market on 

Thursday, October 1, 2015, according to the attached schedule and to continue the same schedule 

the following year. Sun Country will provide this new service utilizing Boeing 737-800 aircraft 

with 162 seats each with 12 first class seats included. Sun Country believes no other U.S. catTier 

is cunently designated to provide non-stop, scheduled service between Fort Myers and Cancun. 

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In support of this application, Sun Country submits the following: 

Required Showings 

1. Applicant. Sun Count1y is a Minnesota Limited Liability Company with its 

principal place of business at 1300 Mendota Heights Road, Mendota Heights, Minnesota 55120. 

2. Citizenship. Sun Country is a citizen of the United States within the meaning of 

49 U.S.C. § 40102 (15)(C). The president and more than two-thirds ofthe officers and directors 

of Sun Country are citizens of the United States. At least 75 percent of Sun Country's voting 

stock is owned by citizens of the United States. 

3. Fitness. Sun Country is presently engaged in scheduled air transportation of 

persons, property, and mail pursuant to certificates of public convenience and necessity issued 

under Section 401 of the Federal Aviation Act. Sun Country is fit, willing and able to perform 

the foreign air transportation applied for herein. Sun Country currently provides seasonal service 

between Minneapolis (MSP), Minnesota, and/or Dallas-Ft. Worth (DFW), Texas, and seven 

cities in Mexico pursuant to exemptions granted by the Depmiment in Dockets OST-2014-0086, 

OST-2012-0175, OST-2012-0065 and OST-2002-12211. 

4. Aircraft. All Sun Country service to Mexico is provided using Boeing 737-800 

aircraft. Sun Country's Boeing 737-800 aircraft have a total of 162 seats each with 12 first class 

seats included. 

5. Fuel Consumption. Sun Country's fuel consumption for this service would not 

exceed the ten million gallon threshold specified in Section 313.4 of the Department's 

regulations. 

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6. Nonhearing Procedures. Sun Country requests that this Application be subject to 

the simplified, nonhearing procedures contemplated by Section 302.309 of the Departments 

Rules ofProceeding. 

Grant of this application is in the public interest because it will allow Sun Country 

Airlines to provide quality low fare airline service and competition on the route between Fort 

Myers in the United States and Cancun, Mexico. 

WHEREFORE, Sun Country respectfully requests that the Department grant the 

exemption as sought above and grant such other relief as the Department deems necessary and 

appropriate. 

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Respectfully submitted, 

Thomas W. mg 

General Cou 1 --~-----~ 

MN Airlines, LLC 

13 00 Mendota Heights Road 

Mendota Heights, MN 55120 

Telephone: (651) 905-2729 

Fax: (651) 681-3911 

Thomas.ting@suncountry.com 
sun 0 r.!.· . " •.. t Y ~ ~ 

FT. MYERS/CANCUN 

Start Dept Dept Arvl Arrv 

Date Freq Arp Time Arp Time Aircraft 

Tuesdays, 

1-0CT-15 Fridays RSW 11:55 CUN 13:25 B737-800 

Tuesdays, 

1-0CT-15 Fridays CUN 14:15 RSW 15:45 B737-800 

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CERTIFICATE OF SERVICE 

I hereby certify that I served a copy of the foregoing Application ofMN Airlines, LLC d/b/a Sun 

Country Airlines for an exemption on April 15, 2015 by e-mail or mail upon each of the 

following addresses: 

Hailey cGarvey 
SERVICE LIST 

Robert. Wirick 

American Airlines, Inc./TWA LLC 

1101 1 i 11 Street, N.W., Suite 600 

Washington, D.C. 20036 

robert. wirick@aa. com 

Daniel A. Weiss 

Managing Director-International & 

Regulatory Affairs 

UNITED AIR LINES, INC. 

77 West Wacker Drive- HDQIZ 

Chicago, IL 60601 

dan. weiss@united.com 

Jonathan Hill 

JetBlue 

1200 New Hampshire A venue, NW 

Washington, DC 20036 

jhill@cooley.com 

John Varley 

Virgin America 

555 Airport Blvd., Suite 200 

Burlingame, CA 94010 

John. varley@virginamerica. com 

Alexander Van der Bellen 

Managing Director, Gov't Affairs & 

Associate General Counsel Delta Air Lines 

sascha. vanderbellen@delta. com 

Southwest Florida International Airport 

1100 Terminal Access Rd. 

Fmi Myers, FL 33913 

RobetiLand 

Jet Blue 

27-01 Queens Plaza N 

Long Island City, NY 111 01 

Ro beti.land@j etblue. com 

Bob Kneisley 

Southwest Airlines 

33647-1CR 

Dallas, TX 75235 

bob.kneisley@wnco.com 

MarshallS. Sinick 

Squire, Sanders & Dempsey, LLP 

1201 Pennsylvania Ave., NW 

Washington, D.C. 20044 

(Counsel for Alaska) 

msinick@ssd.com 

HowardKass 

American Airlines, Inc./TWA LLC 

1101 17th Street, N.W., Suite 600 

Washington, D.C. 20036 

Howard.kass@aa.com 

Joanne Young 

SPIRIT 

1001 Pennsylvania Ave, NW Ste 600S 

Washington, DC 20004 

jyoung@yklaw.com 

Robert Turner (Mail) 

FAA FSDO Manager 

6020 28th Avenue South 

Minneapolis, MN 55450 

Stephen Lachter 

Frontier Airlines 

P.O. Box 492085 

Denver, CO 80249 

Stephen.Lachter@lachterlaw. com