BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

UNITED PARCEL SERVICE CO. 

for Renewal of Exemption 

from 49 U.S.C. § 41101 

(Los Angeles - Guadalajara) 

Docket OST -2000-7282 

APPLICATION OF UNITED PARCEL SERVICE CO. 

FOR RENEWAL OF EXEMPTION FROM 49 U.S.C. § 41101 

Communications with respect to this document should be sent to: 

Dontai L. Smalls 

United Parcel Service Co. 

Public Affairs 

316 Pennsylvania Avenue, S.E. 

Washington, DC 20003 

dsmalls@ups.com 

Scott C. Casey 

United Parcel Service Co. 

1400 N. Hurstboume Parkway 

Louisville, KY 40223 

scasey@ups.com 

Dated: December 19, 2014 

Anita M. Mesner 

Jennifer M. Nowak 

HOLLAND & KNIGHT LLP 

800 171

h Street, N.W., Suite 1100 

Washington, D.C. 20006 

Phone: (202) 419-2604 

Fax: (202) 955-5564 

anita. mosner@hklaw. com 

Attorneys for UNITED PARCEL SERVICE 

co. 

NOTICE: ANY PERSON MAY FILE AN ANSWER TO THIS APPLICATION. 

ANSWERS MUST BE FILED IN THIS DOCKET AND SERVED UPON THE 

PERSONS LISTED ABOVE, ON OR BEFORE JANUARY 5, 2014. 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

UNITED PARCEL SERVICE CO. 

for Renewal of Exemption 

from 49 U.S. C. § 41101 

(Los Angeles - Guadalajara) 

Docket OST-2000-7282 

APPLICATION OF UNITED PARCEL SERVICE CO. 

FOR RENEWAL OF EXEMPTION FROM 49 U.S.C. § 41101 

United Parcel Service Co. ("UPS") hereby applies pursuant to 49 U.S.C. § 40109 

for renewal of an exemption from 49 U.S.C. § 41101, authorizing UPS to provide certain 

scheduled non-stop all-cargo service between Los Angeles, California and Guadalajara, 

Mexico. 

In accordance with Subpart C of the Department's rules, UPS submits the 

following information in support of this Application: 

1. By Notice of Action Taken dated May 1, 2013, the Department renewed 

an exemption from 49 U.S.C. § 41101 which permits UPS to serve the Los Angeles, 

California- Guadalajara, Mexico route through May 1, 2015. 

2. UPS currently provides the service and has been providing the service 

since the original grant of the exemption.1 In lieu of other information required by the 

Department's regulations, UPS relies on the history of its service in the market. Service 

has been, and remains, consistent with the U.S.-Mexico bilateral air services 

1 See Notice of Action Taken, May 11, 2000. 
UNITED PARCEL SERVICE CO. 

APPLICATION FOR RENEWAL OF EXEMPTION 

agreement. 2 The same factors that warranted the grant of the original exemption remain 

applicable and warrant the grant of this renewal. All of the facts set forth in UPS's 

original Application in Docket OST-2000-7282 regarding UPS's citizenship, corporate 

identity, DOT authority, management and fitness remain accurate today. UPS requests 

that the authority continue for two years from the Department's final grant of authority 

requested herein, or as the Department determines to be appropriate. 

3. In accordance with Section 377.1 O(c) of the Department's rules, this 

renewal application is timely filed prior to the expiration date of the authority at issue. 

UPS intends to rely upon the Administrative Procedure Act, specifically, 5 U.S.C. 558(c), 

which provides that UPS's existing exemption shall not expire until the instant 

Application has been finally determined by the Department because the existing 

exemption authorizes "an activity of a continuing nature" within the meaning of that 

provision. 

WHEREFORE, for the foregoing reasons, UPS respectfully requests that the 

Department grant the requested exemption renewal and any different or additional relief 

that the Department may deem necessary. 

2 U.S.-Mexico Air Transport Services Agreement of August 15, 1960, as amended and expanded. 

2 
UNITED PARCEL SERVICE CO. 

APPLICATION FOR RENEWAL OF EXEMPTION 

Respectfully submitted, 

Jennifer M. Nowak 

HOLLAND & KNIGHT LLP 

Attorneys for UNITED PARCEL SERVICE CO. 

3 
CERTIFICATE OF SERVICE 

hereby certify that I have this date served the foregoing document on the persons 

identified below by causing a copy to be sent by electronic mail. 

howard.kass@aa.com 

robert. wirick@aa.com 

dan.weiss@united.com 

steve.morrissey@united.com 

nssparks@fedex. com 

gbleopard@fedex.com 

jrichardson@johnlrichardson.com (Counsel for Amerijet) 

jcanny@amerijet.com 

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

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

thomas.ting@suncountry.com 

robert.kneisley@wnco.com (Counsel for Southwest and AirTran) 

leslie.abbott@wnco.com (Counsel for Southwest and AirTran) 

matwood@cozen.com (Counsel for Frontier) 

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

jyoung@yklaw.com (Counsel for Spirit) 

dkirstein@yklaw.com (Counsel for Spirit) 

msinick@ssd.com (Counsel for Alaska) 

john.s.duncan@faa.gov 

cristinasa@state.gov 

/Jennifer M. Nowak 

December 19, 2014