350630/1/WASHINGTON

BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

)

Application of )

)

ALASKA AIRLINES, INC. ) Docket DOT-OST-2004-19419

)

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 Ouellette Counsel to Alaska Airlines, Inc.

Managing Director, Government &

Community Relations

Alaska Airlines, Inc.

19300 International Boulevard

Seattle, Washington 98188

DATED: February 4, 2014
350630/1/WASHINGTON

BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

)

Application of )

)

ALASKA AIRLINES, INC. ) Docket DOT-OST-2004-19419

)

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

perform scheduled foreign air transportation of persons, property and mail between Los Angeles,

California, and Loreto, Mexico. This exemption authority expires on May 2, 2014. Alaska requests

renewal of this authority for a two-year period and 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-2004-19419

February 4, 2014

2

350630/1/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 2000-5-31.

4. Alaska holds out scheduled service between Los Angeles and Loreto under a

codeshare arrangement with Horizon Air Industries, Inc. (“Horizon). Under the two carriers’

agreement, Alaska displays its two-letter designator code on flights operated by Horizon between

Los Angeles and Loreto.1The Department has found previously that Alaska’s service in the Los

Angeles-Loreto market is consistent with the terms of the U.S.-Mexico bilateral agreement.2

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.

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, as more fully

described herein.

1 Horizon holds an exemption permitting it to operate between Los Angeles and Loreto. Notice of Action Taken,

Docket DOT-OST-2009-0180, April 9, 2013

2

See, Notice of Action Taken, Docket DOT-OST-2004-19419, August 28, 2008; Notice of Action Taken, Docket

DOT-OST-2004-19419, June 14, 2010; Docket DOT-OST-2004-19419, Notice of Action Taken, May 2, 2012
Application for Renewal of Exemption

Docket DOT-OST-2004-19419

February 4, 2014

3

350630/1/WASHINGTON

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: February 4, 2014
350630/1/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: February 4, 2014

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

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

patrick.rizzi@hoganlovells.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