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, 2014350630/1/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. 1 The 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, 2012Application 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, 2014350630/1/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