BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_____________________________________

Application of )

)

 AMERICAN AIRLINES, INC. )

) 

for an exemption ) Docket DOT-OST-2015____

pursuant to 49 U.S.C. § 40109 )

(Dallas/Ft. Worth, Texas )

– San Luis Potosi, Mexico) )

)

_____________________________________ )

APPLICATION OF AMERICAN AIRLINES, INC.

FOR AN EXEMPTION

(Dallas/Ft. Worth, Texas – San Luis Potosi, Mexico)

Communications with respect to this document should be addressed to:

Howard Kass

Vice President – Regulatory Affairs

Robert A. Wirick,

Managing Director, Regulatory and International Affairs

Abigail Donovan

Director, Congressional and Federal Affairs

American Airlines, Inc.

1101 17

th Street, N.W.

Washington, DC 20036

(202) 326-5153

howard.kass@aa.com

robert.wirick@aa.com

abigail.donovan@aa.com

February 25, 2015

NOTICE: American Airlines plans to poll on this application and therefore requests

that any parties wishing to support or oppose this application notify 

American Airlines immediately.
2

BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_____________________________________

Application of )

)

 AMERICAN AIRLINES, INC. )

) 

for an exemption ) Docket DOT-OST-2015-____

pursuant to 49 U.S.C. § 40109 )

(Dallas/Ft. Worth, Texas ) February 25, 2015

– San Luis Potosi, Mexico) )

_____________________________________ )

APPLICATION OF AMERICAN AIRLINES, INC.

FOR AN EXEMPTION 

(Dallas/Ft. Worth, Texas – San Luis Potosi, Mexico)

Pursuant to 49 U.S.C. § 40109 and Subpart C of the Department of 

Transportation’s (“Department”) Rules of Practice (14 C.F.R. Part 302), American 

Airlines, Inc. (“American Airlines”) applies for exemption authority to engage in 

scheduled foreign air transportation of persons, property, and mail between Dallas, Ft. 

Worth/Texas (“DFW”) and San Luis Potosi, Mexico (“SLP”) pursuant to a codesharing 

arrangement with Mesa Airlines, Inc. (“Mesa”). 

American Airlines requests expedited processing of this application so that it can 

begin seeking necessary regulatory approvals from the Mexican authorities as soon as 

possible.

In support of this application, American Airlines respectfully states as follows:

1. American Airlines is a Delaware corporation with its principal office at 

4333 Amon Carter Boulevard, Fort Worth, Texas 76155.

2. The services proposed in this application will serve the public interest by 

enabling American Airlines to offer consumers enhanced U.S.-Mexico services while 
Application of American Airlines for an Exemption

(Dallas/Ft. Worth, Texas – San Luis Potosi, Mexico)

3

supporting commerce and providing substantial competition to other carriers serving 

Mexico from the United States.

3. In order to initiate this scheduled air service, American Airlines requests 

an exemption from 49 U.S.C. § 41101 permitting it to engage in scheduled foreign air 

transportation of persons, property, and mail between Dallas/Ft. Worth, Texas, and San 

Luis Potosi, Mexico pursuant to a codeshare arrangement with Mesa. 

4. American Airlines is a citizen of the United States within the meaning of 49 

U.S.C. § 40102(a)(15)(C) and is fit, willing, and able to provide the services 

contemplated by this application. American Airlines holds various certificates of public 

convenience and exemption authorities. (See, e.g., DOT Order 2007-4-2, April 3, 2007, 

Dockets OST-2000-8516 and OST-2005-22228 (Blanket Open-Skies Route Authority);

Notice of Action Taken, October 7, 2014, Docket DOT-OST-2014-0169 (Dallas/Ft. 

Worth, Texas-Beijing, People’s Republic of China).) Pursuant to Rule 24 of the 

Department’s Rules of Practice, American Airlines requests that the Department take 

official notice of all information previously filed to establish its fitness. 

5. American Airlines will provide service pursuant to a codeshare 

arrangement whereby American Airlines will place its code on flights operated by Mesa

in the DFW to SLP market.

1

 

6. American Airlines’ Application is consistent with the 1960 Air Transport 

Agreement between the Government of the United States of America and the 

Government of the United Mexican States, as amended by the Memorandum of 

 

1 Mesa intends to operate scheduled air service in the DFW-SLP market using regional jet aircraft operating under 

the “American Eagle” brand.
Application of American Airlines for an Exemption

(Dallas/Ft. Worth, Texas – San Luis Potosi, Mexico)

4

Consultations signed on September 21, 2005 (“Air Service Agreement”). Under the 

terms of the Air Service Arrangement, “any designated airline of one Party may enter 

into cooperative marketing arrangements with an airline or airlines of either Party”, 

provided that either the United States or Mexico may “grant such authorization to no 

more than ten of its airlines for each non-stop gateway city pair segment” (Air Service 

Agreement, Annex III, Paragraphs 1 and 3). In November 2014, the U.S. and Mexican 

governments successfully negotiated and initialed an amended Air Transport 

Agreement that will include, among other provisions, open third and fourth freedom 

rights for passenger airlines. American applauds the efforts on the part of both 

governments and recognizes that the agreement is scheduled to enter into force on 

January 1, 2016, after both Parties have completed the necessary internal processes. 

The new agreement, once entered into force, will expand opportunities for each Party.

Nevertheless, American’s request for authority for this route is consistent with the 

existing U.S.-Mexico aviation agreement currently in place. To the best of American 

Airlines’ knowledge, the DFW-SLP route is not fully subscribed with ten codeshare 

authorizations granted by the Department.

7. American Airlines states that approval of this application will have no 

effect on its CRAF commitments. Furthermore, American Airlines submits that its 

application raises no environmental or energy issues, and anticipates no difficulty in 

obtaining fuel for this service. 

8. American Airlines will accept and abide by all terms, limitations, and 

conditions that the Department normally attaches to exemption authority for scheduled 
Application of American Airlines for an Exemption

(Dallas/Ft. Worth, Texas – San Luis Potosi, Mexico)

5

foreign air transportation. American Airlines asks that this requested authority be 

granted for an unlimited term rather than the standard two (2) years.

9. American Airlines requests the Department to use expedited procedures 

to approve the authority sought in this application. 

10. The requisite filing fee is enclosed.

WHEREFORE, American Airlines respectfully requests that its application for an 

exemption, as discussed herein, be granted, as well as such further relief as the 

Department deems warranted for such services. American Airlines further requests that 

the Department notify the Government of Mexico in writing of the designation of 

American Airlines for scheduled air services at issue in this application.

Respectfully submitted,

Howard Kass

Vice President – Regulatory Affairs

Robert A. Wirick

Managing Director, Regulatory and 

International Affairs

Abigail Donovan

Director, Congressional and Federal Affairs

American Airlines, Inc.

1101 17th Street, N.W.

Washington, DC 20036

(202) 326-5153

howard.kass@aa.com

robert.wirick@aa.com

abigail.donovan@aa.com

February 25, 2015
CERTIFICATE OF SERVICE

I certify that, on February 25, 2015, a copy of the foregoing Application of 

American Airlines, Inc. for an Exemption, was sent by email upon those addressees 

listed below:

englets@state.gov (Department of State)

cristinasa@state.gov (Department of State)

paul.gretch@dot.gov (Department of Transportation)

brian.hedberg@dot.gov (Department of Transportation)

todd.homan@dot.gov (Department of Transportation)

peter.irvine@dot.gov (Department of Transportation)

laura.remo@dot.gov (Department of Transportation)

brett.kruger@dot.gov (Department of Transportation)

john.s.duncan@faa.gov (Federal Aviation Administration)

dan.weiss@united.com (United)

steve.morrissey@united.com (United)

gmurphy@crowell.com (Counsel for United)

sascha.vanderbellen@delta.com (Delta)

chris.walker@delta.com (Delta)

jhill@cooley.com (Counsel for JetBlue and Hawaiian)

perkmann@cooley.com (Counsel for JetBlue and Hawaiian)

robert.land@jetblue.com (JetBlue)

jeremy.ross@alaskaair.com (Alaska)

dheffernan@cozen.com (Counsel for Alaska)

jyoung@yklaw.com (Counsel for Spirit)

dkirstein@yklaw.com (Counsel for Spirit)

bob.kneisley@wnco.com (Southwest)

leslie.abbott@wnco.com (Southwest)

matwood@cozen.com (Counsel for Frontier)

stephen.lachter@lachterlaw.com (Counsel for Frontier)

ethan.blank@rjet.com (Republic)

robert.cohn@hoganlovells.com (Counsel for Republic)

patrick.rizzi@hoganlovells.com (Counsel for Republic)

thomas.ting@suncountry.com (Sun Country)

rpommer@atlasair.com (Atlas)

anita.mosner@hklaw.com (Counsel for UPS)

nssparks@fedex.com (FedEx)

kevin.montgomery@polaraircargo.com (Polar)

barbara.russell@virginamerica.com (Virgin America)

_______________________

Howard Kass