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

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- 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,



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- 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, 2015CERTIFICATE 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 o g mery@polaraircar o.com Aaron Goerlich Southern Air a>oerlich(cr,ggth-airlaw.com Dan Weiss United Air Lines dan.weiss(2 cunited.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