BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

)

Motion of )

)

SPIRIT AIRLINES, INC. ) Docket DOT-OST-2011-0175

)

U.S.-Colombia Combination Frequency )

Allocation Proceeding )

 )

MOTION OF SPIRIT AIRLINES, INC.

FOR EXTENSION OF STARTUP DATE 

Communications with respect to this document should be sent to:

Joanne W. Young

David M. Kirstein

Kirstein & Young, PLLC

1750 K Street, N.W. 

Suite 200

Washington, D.C. 20006

(202) 331-3348 (telephone)

(202) 331-3933 (facsimile)

Attorneys for

SPIRIT AIRLINES, INC.

April 27, 2012
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

)

Motion of )

)

SPIRIT AIRLINES, INC. ) DOT-OST-2011-0175

)

U.S.-Colombia Combination Frequency )

Allocation Proceeding )

 )

MOTION OF SPIRIT AIRLINES, INC.

FOR EXTENSION OF STARTUP DATE 

On September 15, 2011, Spirit Airlines, Inc. (“Spirit”) filed an application for

fourteen (14) U.S.-Colombia frequencies and exemption authority to provide service 

between Fort Lauderdale, Florida and Bogotá, Colombia and beyond to points in Ecuador 

and Lima, Peru. By Notice of Action Taken, in this docket, dated October 4, 2011, the 

Department granted Spirit this authority. The NOAT specified that Spirit would be 

required to inaugurate service between Fort Lauderdale and Bogotá within ten (10) days 

of April 1, 2012. On January 30, 2012, Spirit filed a motion to extend the start-up date on 

seven (7) of the awarded frequencies until May 24, 2012 and released the remaining 

seven (7) frequencies. This motion was granted by the Department on February 10, 2012.

Spirit respectfully requests an additional extension of the start-up date until 

September 1, 2012. Spirit has obtained all necessary route authority from Peru and 

Columbia, but has not been able to obtain the necessary slot allocations at Bogotá to 

operate the flights. The extension is necessary to allow additional time to obtain these
Motion of Spirit Airlines, Inc.

U.S.-Colombia Frequency Allocation Proceeding

Page 2 of 2

slots.

Grant of this motion will not adversely affect service in the FLL-BOG market and 

will not result in injury to any competitor or potential competitor. Twenty-eight (28)

frequencies remain open to potential competitors in this market. 

WHEREFORE, for the reasons described above, Spirit respectfully requests that 

the Department grant its Motion to extend the startup date on seven (7) combination 

frequencies to be used by Spirit for scheduled foreign air transportation between Fort

Lauderdale, Florida and Bogotá, Colombia until September 1, 2012. Spirit further 

requests any other relief the Department may deem necessary.

Respectfully Submitted, 

 

Joanne W. Young

David M. Kirstein

Kirstein & Young PLLC

1750 K Street N.W.

Suite 200

Washington, D.C. 20006

(202) 331-3348 (telephone)

(202) 331-3933 (facsimile)

Attorneys for

SPIRIT AIRLINES, INC.
CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing “Motion of Spirit 

Airlines, Inc.” by email on the following persons:

__________________________

 Lyndsey Grunewald

April 27, 2012

dan.weiss@united.com

jonathan.linde@united.com

jeff.morgan@delta.com

sascha.vanderbellen@delta.com

steve.morrissey@united.com

robert.land@jetblue.com

jhill@dlalaw.com

carl.nelson@aa.com

urskr@state.gov

esta.rosenberg@dot.gov

brett.kruger@dot.gov

brian.hedberg@dot.gov