317237/1/WASHINGTON

BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

)

Application of )

)

ALASKA AIRLINES, INC. ) Docket DOT-OST-2010-0103

)

for an exemption pursuant to 49 U.S.C. 40109 )

)

APPLICATION FOR RENEWAL OF EXEMPTION

Communications with respect to this document should be addressed to:

Kyle B. Levine Charles F. Donley II

Deputy General Counsel and Marshall S. Sinick

Managing Director, Legal Squire Sanders (US) LLP

Alaska Airlines, Inc. 1200 19th Street, N.W., Suite 300

19300 International Boulevard Washington, D.C. 20036

Seattle, Washington 98188 (202) 626-6840

charles.donley@squiresanders.com

marshall.sinick@squiresanders.com

Megan Lawrence Counsel to Alaska Airlines, Inc.

Managing Director, Government &

Community Relations

Alaska Airlines, Inc.

19300 International Boulevard

Seattle, Washington 98188

DATED: January 21, 2014
317237/1/WASHINGTON

BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

)

Application of )

)

ALASKA AIRLINES, INC. ) Docket DOT-OST-2010-0103

)

for an exemption pursuant to 49 U.S.C. 40109 )

)

APPLICATION FOR RENEWAL OF EXEMPTION

Alaska Airlines, Inc. (“Alaska”) hereby requests renewal of the exemption authority granted

to it by the Department of Transportation (the “Department”) in the above-captioned docket to

engage in the seasonal scheduled foreign air transportation of persons, property and mail between

San Diego, California, and Puerto Vallarta, Mexico. This exemption authority expires on April 5,

2014. Alaska requests renewal of this authority for a two-year period. Alaska relies on the

provisions of the Administrative Procedure Act and Part 377 of the Department’s procedural

regulations to continue its existing authorization in force pending a final decision on this renewal

request.

In further support of its request for renewal, Alaska states as follows:

1. Alaska’s principal headquarters are located at 19300 International Boulevard,

Seattle, Washington. Alaska is incorporated under the laws of the State of Alaska and is a

wholly-owned subsidiary of Alaska Air Group, Inc. (“AAG”). AAG is incorporated under the

laws of the State of Delaware.
Application for Renewal of Exemption

Docket DOT-OST-2010-0103

January 21, 2014

2

317237/1/WASHINGTON

2. Alaska is a citizen of the United States within the meaning of 49 U.S.C.

40102(a)(15). The president and at least two-thirds of Alaska’s directors and other managing

officers are U.S. citizens. Additionally, to Alaska’s knowledge, U.S. citizens hold at least

seventy-five percent of Alaska’s voting stock.

3. Alaska has repeatedly been found fit, willing and able to provide interstate and

foreign air transportation. The Department is requested to take official notice of Alaska’s

continuing fitness. See, e.g., Order 00-5-31.

4. Alaska currently operates seasonal roundtrip scheduled flights on the San DiegoPuerto Vallarta route. The Department has found previously that Alaska’s service in the San

Diego-Puerto Vallarta market is consistent with the terms of the U.S.-Mexico bilateral

agreement.1

5. This renewal application does not raise any environmental or energy concerns.

All flights will continue to be performed with aircraft that meet all applicable noise requirements.

Similarly, approval of this application will not result in a near-term increase in fuel consumption of

ten million gallons or more.

1

See, Notices of Action Taken, Docket DOT-OST-2010-0103, May 20, 2010 and April 5, 2012
Application for Renewal of Exemption

Docket DOT-OST-2010-0103

January 21, 2014

3

317237/1/WASHINGTON

WHEREFORE, Alaska Airlines, Inc. respectfully requests that the exemption granted to

it in the above-captioned docket be renewed for an additional two-year period on its existing

terms and conditions, as more fully described herein.

Respectfully submitted,

/s/ Charles F. Donley II

_________________________________

Charles F. Donley II

Marshall S. Sinick

Squire Sanders (US) LLP

1200 19th Street, N.W., Suite 300

Washington, D.C. 20036

(202) 626-6840

charles.donley@squiresanders.com

marshall.sinick@squiresanders.com

Counsel to Alaska Airlines, Inc.

DATED: January 21, 2014
317237/1/WASHINGTON

CERTIFICATE OF SERVICE

I hereby certify that one copy of the foregoing Application for Renewal of Exemption has

this day been served on each of the following individuals via email.

/s/ Charles F. Donley II

___________________________

Charles F. Donley II

DATED: January 21, 2014

sascha.vanderbellen@delta.com; sametta.c.barnett@delta.com

steve.morrissey@united.com; dan.weiss@united.com

patrick.rizzi@hoganlovells.com

msinick@ssd.com

bob.kneisley@wnco.com

howard.kass@usairways.com; benjamin.slocum@usairways.com

jhill@dowlohnes.com

mlbenge@zsrlaw.com

dkirstein@yklaw.com

robert.wirick@aa.com; francis.heil@aa.com

pmurphy@lopmurphy.com; pmurphy@ggh-airlaw.com

barbara.russell@virginamerica.com

AGoerlich@ggh-airlaw.com

Esta.Rosenberg@dot.gov