BEFORE THE 

UNITED STATES DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

UNITED PARCEL SERVICE CO. 

For an Allocation of One 

Frequency (U.S.-China) 

Docket OST-2010- oi3(o 

CD 

APPLICATION OF UNITED PARCEL SERVICE CO. 

FOR AN ALLOCATION OF ONE FREQUENCY 

Communications with respect to this document should be served upon: 

Dontai L. Smalls 

United Parcel Service 

Public Affairs 

316 Permsylvania Avenue, S.E. 

Washington, D.C. 20003 

E-mail: dsmalls@ups.com 

Scott C. Casey 

Michael J. Francesconi 

United Parcel Service Co. 

1400 N. Hurstboume Parkway 

Louisville, KY 40223 

E-mail: scasey@ups.com 

mfrancesconi@ups.com 

Date: May 19,2010 

David L. Vaughan 

Danielle K. Fisher 

Kelley Drye & Warren LLP 

3050 K Street, N.W., Suite 400 

Washington, D.C. 20007 

(202) 342-8462 

Fax: (202)342-8451 

E-mail: dvaughan@kelleydrye.com 

dfisher@kelleydrye.com 

Attorneys for 

United Parcel Service Co. 

NOTE: Any person wishing to support or oppose this Application must file an answer 

with the DOT'S Documentary Services Division by June 3, 2010. A copy of such 

Answer must be served upon United Parcel Service Co. and its counsel and all 

persons named on the attached Service List. Nevertheless, UPS will poll all 

persons on the service list for an immediate response. 
BEFORE THE 

UNITED STATES DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

UNITED PARCEL SERVICE CO. 

For an Allocation of One 

Frequency (U.S.-China) 

Docket OST-2010-

APPLICATION OF UNITED PARCEL SERVICE CO. 

FOR AN ALLOCATION OF ONE FREQUENCY 

In accordance with Subpart C of the Rules of Practice (14 C.F.R 302.301 et seq.) 

of the Department of Transportation (the "Department" or "DOT"), United Parcel Service 

Co. ("UPS") hereby applies for an allocation of one (1) round-trip weekly U.S.-China allcargo frequency, enabling UPS to provide additional scheduled all-cargo (property and 

mail) air transportation services between the U.S. and China, and China and the world. 

Assuming that the DOT finalizes its tentative award of six (6) all-cargo 

frequencies to Kalitta, there are ten (10) Zone 1 or Zone 2 frequencies available to allcargo carriers.' UPS will utilize the frequency requested herein to serve the Shenzhen 

market. UPS will serve the U.S. and Shenzhen via Dubai and Cologne one (1) time per 

week using B-747 aircraft with a payload capacity of 256,500 pounds that are currently in 

UPS's fleet. UPS plans to commence service on July 24, 2010. 

See Order to Show Cause, OST-2010-0017 (May 7, 2010). 
Application of UPS 

OST-2010-

Page 2 of4 

UPS holds certificate and exemption authority to serve China.^ UPS currently 

operates forty-one (41) weekly U.S.-China all-cargo frequencies.'^ The frequency 

requested in this Application will compliment those services and enable UPS to provide a 

service pattern required to meet the demands of this market. 

In support of this Application, UPS states as follows: 

1. UPS is a Delaware corporation whose current mailing address is 

1400 Hurstboume Parkway, Louisville, Kentucky 40223. UPS holds certificates of 

public convenience and necessity authorizing it to engage in domestic and foreign allcargo air transportation.'' 

2. UPS is fit, willing and able to provide the proposed service and to conform 

to the provisions of the Federal Aviation Act and the rules, regulations and requirements 

of the Department thereunder. UPS requests that the Department take official notice, 

pursuant to 14 C.F.R. 302.24 of the economic authorities and data on file that support 

UPS's fitness. 

3. UPS is a citizen of the United States as that term is defined in the Federal 

Aviation Act. All officers, directors, shareholders of UPS, or persons who have the 

^ See Order 2001-1-6, Order 2004-10-8, Notice of Action Taken, OST-2009-0006 (Jan. 16, 2009), Notice 

of Action Taken, OST-2009-0177 (Aug. 20, 2009). 

' See Orders 2001-1-6, 2004-10-8 and 2005-3-40. 

" See e.g., Order 2001-1-6, Order 2006-1-1 and Notice of Action Taken, OST-2009-0006 (Jan. 16, 2009). 
Application of UPS 

OST-2010-

Page 3 of4 

power to influence the management of UPS or persons holding any voting interest in UPS 

are U.S. citizens. 

4. The authority requested herein is consistent with the consolidated bilateral 

air services agreement between the United States and China and it is comparable to that 

which UPS currently operates and, thus, would not constitute a substantial change in 

operations requiring review under Part 204 of the Department's regulations. The 

proposed service would cause a near term net annual increase in aircraft fiael 

consimiption of less than 10 million gallons and the annual fuel consumption is under the 

threshold set forth in Part 313 of the Department's Regulations which effectuate the 

Energy Policy and Conservation Act. 
Application of UPS 

OST-2010-

Page 4 of4 

WHEREFORE, UPS respectfully requests that the Department allocate UPS one 

(1) round-trip weekly cargo frequency to enable UPS to provide additional scheduled allcargo air transportation services between the United States and China and beyond China 

to the world. UPS also requests that the Department grant such other and further relief as 

may be deemed just and necessary. 

Respectfully submitted. 

Vaughan 

Danielle K. Fisher 

Kelley Drye & Warren LLP 

3050 K Street, N.W., Suite 400 

Washington, D.C. 20007 

(202) 342-8462 

Fax: (202)342-8451 

E-mail: dvaughan@kelleydrye.com 

dfisher@kelleydrye.com 

Attorneys for 

United Parcel Service Co. 

Date: May 19,2010 
CERTIFICATE OF SERVICE 

I hereby certify that I have this day served the foregoing document by electronic 

mail on all persons named below: 

Name 

Carl B. Nelson, Jr. 

Hershel Kamen 

Dan Weiss 

Sametta Bamett 

Alexander Van der 

Bellen 

G. Bailey Leopard Jr. 

Edward W. Sauer 

C. Blair Berselli 

Mark W. Atwood 

Kevin Montgomery 

Aaron Goerlich 

Jason Maddux 

Julie Oettinger 

Jeffrey Manley 

Howard Kass 

Esta Rosenberg 

Representing 

American 

Continental 

Delta 

Northwest 

Federal Express 

Evergreen 

Kalitta 

Polar 

Southern Air 

United 

US Airways 

DOT 

E-mail 

Carl .nelson@aa. com 

Hershel. Kamen@coair.com 

Dan.Weiss@coair.com 

Sametta.C.Bamett@delta.com 

sascha.vanderbellen@delta.com 

gbleopard@fedex. com 

esauer@ssd.com 

blair.berselli@evergreenairlines.com 

matwood@sherblackwelI.com 

kevin. montgomery @polaraircargo .com 

agoerlich@ggh-airlaw.com 

j maddux @ggh-airl aw. com 

j ulie. oettinger @united. com 

jeffrey.manley@united.com 

howard kass@usairways.com 

Esta.Rosenberg@dot.gov