) 

for an emergency exemption pursuant to ) 

________ ) 

APPLICATION OF ANTONOV AIRLINES 

FOR AN EMERGENCY EXEMPTION 

Communications with respect to this document should be sent to: 

February 4, 2015 

Sheryl R. Israel 

HOGAN LOVELLS US LLP 

Columbia Square 

555 Thirteenth Street, NW 

Washington, DC 20004 

+1 202 637 8898 

sheryl.israel@hoganlovells.com 

Counsel for 

ANTONOV COMPANY 

tfa ANTONOV AIRLINES 

NOTICE: THIS APPLICATION IS BEING FILED PURSUANT TO THE EMERGENCY 

EXEMPTION PROCEDURES OF 14 C.F.R. § 302.311, WHICH AUTHORIZE 

THE DEPARTMENT TO ACT ON EMERGENCY EXEMPTION REQUESTS 

IMMEDIATELY. ANY PERSON INTERESTED IN FILING AN ANSWER IS 

REQUESTED TO DO SO IN THE ABOVE DOCKET IMMEDIATELY. 

COPIES OF THE SUBMISSION SHOULD BE SERVED ON THE PERSONS 

LISTED ABOVE AND ON THE ATTACHED SERVICE LIST. 

',\DC. 6-101519 vi 
for an emergency exemption pursuant to ) 

_4~9~u~s~c~·~§~4~01~0~9<~g~>---------> 

February 4, 2015 

APPLICATION OF ANTONOV AIRLINES 

FOR AN EMERGENCY EXEMPTION 

Antonov Company Ua Antonov Airlines ("Antonov") hereby applies for an 

emergency exemption pursuant to 49 U.S.C. §§ 40109(g) and 41703(c), to permit 

Antonov to operate a single one-way all-cargo charter flight transporting one outsized 

aircraft engine, plus ancillary equipment, from Columbus (Rickenbacker Airport), Ohio to 

Seattle or Everett, Washington, February 11-13, 2015, using an AN-124-100 aircraft. 

Antonov respectfully requests expedited consideration and approval of this application to 

address a pressing commercial requirement of GE Aviation and Boeing Commercial 

Airplanes ("Boeing"). 

In support of this application, Antonov states the following: 

1. Antonov is a foreign air carrier that holds exemption authority to conduct 

charter all-cargo foreign air transportation between Ukraine and the United States, and 

between the United States and third countries pursuant to 14 C.F.R. Part 212. See 

Notice of Action Taken dated October 12, 2005 (Docket DOT-OST-1996-1454). 

2. GE Aviation has chartered Antonov to conduct a flight transporting one 

outsized GEnx aircraft engine, plus ancillary equipment, from Rickenbacker Airport to 

Seattle to offset a Boeing production line work stoppage situation. The GEnx engine on 

its shipping stand measures approximately 210" x 142" x 149". Cargo of this size cannot 

'\DC · 027074/000001 • C>IOBS 19 vl 
about February 11, 20151 to offset a production line work stoppage created by delayed 

engine deliveries from GE Aviation. Air transportation of this engine from Rickenbacker 

Airport, near the GE Aviation facility where the engine is produced, to the Boeing 

production facilities in the Seattle area is the best solution to prevent further production 

line delays. Failure to deliver the engine by air would cause additional delays to the 

production and subsequent delivery of Boeing airplanes. which would cause financial 

harm to GE Aviation, Boeing and their customers. Accordingly, transportation of the 

engines by AN-124-100 is warranted. 

4. This application meets all of the relevant criteria for the grant of an 

exemption under 49 U.S.C. § 40109(g): 

a. Grant of this application is in the public interest. Transportation of 

the engine by air will allow major American jet aircraft engine and airplane 

manufacturers to address a production line disruption as efficiently as possible and will 

help meet airplane delivery commitments to customers. Surface transportation of the 

engine is not an economical or desirable option in this case given the distance between 

Ohio and Washington, coupled with the complications and permitting requirements 

associated with the truck movement of such a large item. GE Aviation and Boeing must 

The flight is currently scheduled to depart Columbus late in the night on February 11, 2015, 

and to arrive in Seattle early the following morning. Antonov requests a period of validity of 

February 11-13, 2015 to account for unforeseen flight or engine production delays. 

Furthermore, although the flight is currently anticipated to operate to Seattle (SEA) Antonov 

requests the flexibility to operate to Everett (PAE) instead to avoid the need to request a late 

notice amendment if that destination (which was initially requested by the charterer) is 

ultimately chosen instead. 

\\DC . Ol70WOOOOOI • 6408519 vi 
b. Approval of the requested exemption authority is necessary to 

enable Antonov to respond to an emergency created by unusual circumstances. 

GE Aviation needs to transport a large commercial aircraft engine from Columbus to 

Seattle to address a Boeing production line stoppage created by an engine delivery 

delay. The sheer size of the engine, coupled with the distance between Ohio and 

Washington, forecloses the possibility of transporting this unit on an expedited basis 

using surface transportation. In order to avoid unnecessary and costly additional delays, 

the engine needs to be shipped by air, and because no civil aircraft operated by U.S. 

carriers are capable of carrying such outsized cargo,2 the only way to resolve this 

emergency is for the engine to be transported using an AN-124-100 aircraft. 

c. Thus, grant of this exemption application is necessary to avoid 

unreasonable hardship for the traffic at issue. Simply put, unless the application is 

granted, the transportation of a GE aircraft engine from Columbus to Seattle will be 

unnecessarily delayed, adversely impacting GE Aviation, Boeing and their customers. 

5. Antonov's fitness and ability to carry out the proposed transportation has 

been amply demonstrated through its conduct of numerous outsized cargo charter 

operations over the past several years. By DOT Order 91-10-11, Antonov was first 

issued exemption authority jointly with Air Foyle Ltd., and has operated numerous 

2 Counsel for Antonov will contact the U.S. operators of large all-cargo aircraft set forth in the 

service list attached to this application to verify that each carrier cannot accommodate the 

cargo and does not oppose the grant of this application, and will promptly notify the 

Department of the polling results. 

\OC-0270741000001· 640S519 vl 
Department has previously granted emergency exemption authority to permit Antonov to 

conduct commercial flights between U.S. points on numerous occasions where 

AN-124-100 aircraft were similarly needed to deliver outsized cargo, including Boeing 

airplane and GE Aviation engine products, on an emergency basis. The Department 

has consistently found that approval of such requests is in the public interest. See. e.g., 

Notice of Action Taken dated October 11, 2002 (Docket DOT-OST -2002-13572); Notice 

of Action Taken dated August 28, 2002 (Docket DOT-OST-2002-13252); DOT Order 98-

3-9; Notice of Action Taken dated December 24, 1997 (Docket DOT-OST-1997-3284). 

See also Notices of Action Taken dated November 14, 2006 (Docket 

DOT -OST -2006-26361 ), November 30, 2006 (Docket DOT-OST-2006-26474), 

December 8, 2006 (Docket DOT-OST-2006-26568), January 3, 2007 (Docket 

DOT-OST-2006-26749), January 23 and 26, 2007 (Docket DOT-OST-2007-27029), and 

June 18, 2014 (Docket DOT-OST-2014-0106) (granting Antonov exemptions for the 

transportation of GE90 and GEnx aircraft engines under similar circumstances). 

7. Section 302.311 of the Department's Procedural Regulations provides 

that the Department can act on an emergency exemption application immediately. In 

light of the exigent circumstances, Antonov respectfully requests expeditious processing 

and the immediate grant of this emergency exemption application in order to provide 

assurances to GE Aviation and Boeing that Antonov will be permitted to transport the 

GEnx aircraft engine on the required dates. 

\J>C • 0270741000001. 6408S 19 vl 
Washington, February 11-13, 2015, using an AN-124-1 00 aircraft, as described herein, 

and grant such other and further relief as the Department deems to be consistent with 

the public interest. 

1\DC • OZ707410000DI·6408SI9vl 

Sheryl R. Israel 

HOGAN LOVELLS US LLP 

Columbia Square 

555 Thirteenth Street, NW 

Washington, DC 20004 

+1 202 637 8898 

sheryl.israel@hoganlovells.com 

Counsel for 

ANTONOV COMPANY 

Ua ANTONOV AIRLINES 
rpommer@atlasair.com; john@mietuslaw.com; sascha.vanderbellen@delta.com; 

sametta.c.barnett@delta.com; sllunsford@fedex.com; sharon.pasley@fedex.com; 

charles.donley@squirepb.com; matwood@cozen.com; lstauffer@wallaceair.com; 

nwallace@wallaceair.com; rzerkel@lac.lynden.com; jdavis@lac.lynden.com; 

mwiegele@nac.aero; kevin.montgomery@polaraircargo.com; agoerlich@gghairlaw.com; dan.weiss@united.com; steve.morrissey@united.com; pdoell@naca.cc; herb. herzog@faa. gov; patrick. crowley@faa .gov 

Jonathan Echmalian 

\DC- vl 
DATE: February 3, 2015 

SUBJECT: Request for approval urgent ad hoc charter 

Dear Sir or Mod om 

T 15131 552·2541 

c 1513)549·3175 

dove douenhouer!lge.com 

We (GE Aviation) kindly ask you to grant the traffic rights for on urgent od hoc flight to operate on February 11. 2015 from Rieken backer, OH ILCK) to Seattle-Tacoma International Airport (SEAl, details 

os per below: 

Our customer Boeing, has production line work stoppage due to delayed engines from GE. 

They are in need of engines as soon as possible in order to continue their operations. 

Our carrier, Antonov Design Bureau {AOB), is set for departure February 11, 2015, Flight AOB 

2870, toil- UR 82007 MAWB 000-00067686 

Sean Ostenberg, The Boeing Company is our contact and con be reached at 1425) 965-7375. 

Please do not hesitate to contact us for more information if needed. Vou con reach me at the above 

phone numbers or via email. 

u for you assistance in this urgent matter 

Dove Dauenhauer 

~----

GEnx Manufacturing Programs