BEFORE THE 

UNITED STATES DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

) 

Application of ) 

) 

AMERIJET INTERNATIONAL, INC. ) OST-2011-0083 

) 

for renewal of an exemption (U.S.-Brazil) ) 

APPLICATION OF AMERIJET INTERNATIONAL, INC. 

FOR RENEWAL OF AN EXEMPTION 

Communications with respect to this document should be served upon: 

Ms. Joan M. Canny 

Senior Vice President and 

General Counsel 

Amerijet International, Inc. 

2800 S. Andrews Avenue 

Ft. Lauderdale, Florida 33316 

PH: (954) 320 5300 

E-Mail: jcannygamerijet.com 

John L. Richardson 

John L. Richardson, P.L.L.C. 

2700 Calvert Street, N.W. 

Washington, D.C. 20008 

PH: (202) 371-2258 

E-Mail: irichardson(a~jolu-Arichardson.com 

Counsel for Amerijet International, Inc. 

March 16, 2015 

Notice: Any person who wishes to support or oppose this application must file an answer 

by March 31, 2015 and serve a copy of that answer upon counsel for Amerijet and all 

persons served with this application. Note, however, that Amerijet is asking the 

Department for expedited consideration of this application. 
BEFORE THE 

UNITED STATES DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

) 

Application of ) 

) 

AMERIJET INTERNATIONAL, INC. ) 

) 

for renewal of an exemption (U.S.-Brazil) ) 

OST-2011-0083 

APPLICATION OF AMERIJET INTERNATIONAL, INC. 

FOR RENEWAL OF AN EXEMPTION 

By Notice of Action Taken, dated Apri15, 2013, the Department renewed for an 

additional period of two years the exemption previously awarded to Amerijet 

International, Inc. ("Amerijet") authorizing Amerijet to provide scheduled all-cargo 

service in the United States- Brazil market for a period of two years. The renewed 

exemption will expire by the terms of the Notice on Apri15, 2015. 

Amerijet hereby respectfully submits this application for renewal of its exemption 

for an additional two-year period or for such longer period of time as may be deemed 

appropriate by the Department. 

For the following reasons, Amerijet also requests that the Department approve 

this application before April 5, 2015, or waive the 60-day requirement in Part 377 of the 

Department's Special Regulations so that Amerijet's exemption authority will continue in 

effect beyond April 5 until the Department acts on this application for renewal. 
-2- 

5 U.S.C. 558(c) and Part 377 provide that expiring exemption authority will 

remain in effect pending final Department action on a renewal application if that 

application is filed at least 60 days prior to the expiration date of the subject exemption. 

This application is not being filed in accordance with that 60-day requirement due to 

administrative oversight and a failure of appropriate coordination on a timely basis. 

Accordingly, Amerijet respectfully requests approval of this application or a waiver of 

the 60-day requirement prior to April 25, 2015 to preclude termination of the 

effectiveness of the exemption authority the Department has previously awarded to it. 

Approval of this request is clearly in the public interest. There can be no reason 

why Amerijet should lose the operating authority the Department has determined it 

should have just because this application in being filed late, and Amerijet believes that no 

interested party will be injured by Department approval of this request. To assure 

certainty in this regard, Amerijet will poll parties served with its application and will 

report the results of that polling to the Department. 

In support of its application for renewal of its exemption, Amerijet offers the 

following evidence and argument: 

1. Amerijet is a corporation in good standing incorporated under the laws of' 

the State of Florida, with its principal place of business located at 2800 S. Andrews 

Avenue, Fort Lauderdale, Florida 33316. 

2. Amerijet is a United States citizen as defined by 49 U.S.C. § 

40102(a)(15)(c). 

3. Amerijet is an established domestic and international all-cargo carrier 

authorized by the Department to provide scheduled and charter all-cargo air 
-3- 

transportation within the United States and between points in the United States and other 

points around the world. 

4. Amerijet is fit, willing and able to provide scheduled all-cargo service in 

international markets. Each of the Department's decisions granting new or amended 

operating authority to Amerijet has included a finding that Amerijet is qualified to 

provide the category of air transportation services authorized. Nothing has occurred 

subsequent to the issuance of those decisions which should cause the Department to 

question the validity of those fitness findings. In this connection, Amerijet requests the 

Department to take official notice of its financial statements filed with the Department on 

Form 41 for information regarding its present financial condition. 

5. Amerijet conducts its business and operations in a manner it believes to be 

consistent with conditions attached to certificates and exemptions issued to it, the 

Department's regulations, and regulations issued by other government agencies having 

jurisdiction over Amerijet. 

6. The services authorized by the Department's exemption under 

consideration here are governed by the U.S.-Brazil Air Transport Agreement, as amended 

and as supplemented by Memoranda of Consultations entered into by the two 

governments. 

7. Amerijet has access to the facilities, personnel and equipment needed to 

support scheduled all-cargo service in international markets. 

8. Although Amerij et is not currently serving the United States-Brazil ' 

market, it seeks to retain the exemption authority at issue here so that it will be able to 

mount an effective service when circumstances permit it to do so in the future. 
~ 

9. Approval of this application is in the public interest. Amerijet has 

established itself as an efficient and effective scheduled a1l-cargo carrier providing a high 

level of reliable service in its existing operating area, and it will replicate that service in 

the United States-Brazil market when circumstances make expansion economically 

feasible. 

Therefore, for all these reasons, Amerijet respectfully requests that the exemption 

awarded to it in this docket be renewed for a period of at least two years. 

Respectfully submitted, 

~ John L. ' Y, d o-c 

John L. Richardson, P.L.L.C. 

2700 Calvert Street, N.W. 

Washington, D.C. 20008 

PH: (202) 371-2258 

E-Mail: jrichardsongjohnlrichardson.com 

Counsel for Amerijet International, Inc. 

March 16, 2015 
CERTIFICATE OF SERVICE 

I hereby certify that I have, this 16th day of March, 2015, served a copy of the 

foregoing application by e-mail upon the following: 

Robert Silverberg ABX Air rsilverberggsgbdc.com 

Air Transport Int'1 

Howard Kass American Airlines howard.kasskaa.com 

Robert Wirick robert.wirickkaa.com 

Abigail Donovan abigail.donovan(a,aa.com ~

Russell Pommer Atlas Air rpommernatlasair.com 

John Mietus Centurion Air Cargo john a,mietuslaw.com 

Sascha Vanderbellen Delta Air Lines sascha.vanderbellengdelta.com 

Christopher Walker christopher.walkergdelta.com 

Nancy S. Sparks FedEx nss arksgfedex.com 

Courtney E. Felts cefelts a,fedex.com 

Mart Atwood Kalitta Air matwoodgcozen.com 

Kevin Montgomery Polar Air Cargo kevin.mont og mery@polaraircar o.com 

Aaron Goerlich Southern Air a>oerlich(cr,ggth-airlaw.com 

Dan Weiss United Air Lines dan.weiss(2cunited.com 

Steve Morrissey steve.morrisseya,united.com 

Gerald Murphy gmurphygcrowell.com 

Anita Moser UPS anita.mosner a,hklaw.com 

Jennifer Nowak jennifer.nowak(khklaw.com 

John S. Duncan FAA john.s.duncan~c~faa.gov 

Paul Gretch DOT paul. re g tch(a~dot. ov 

Robert Finamore robert.finamorekdot.gov 

John L. Richardson