ApplicationofBEFORETHEDEPARTMENTOFTRANSPORTATIONWASHINGTON,D.C.))ANTONOVAIRLINES)DocketDOT-OST-2015-___)foranemergencyexemptionpursuantto)________)APPLICATIONOFANTONOVAIRLINESFORANEMERGENCYEXEMPTIONCommunicationswithrespecttothisdocumentshouldbesentto:February4,2015SherylR.IsraelHOGANLOVELLSUSLLPColumbiaSquare555ThirteenthStreet,NWWashington,DC20004+12026378898sheryl.israel@hoganlovells.comCounselforANTONOVCOMPANYtfaANTONOVAIRLINESNOTICE:THISAPPLICATIONISBEINGFILEDPURSUANTTOTHEEMERGENCYEXEMPTIONPROCEDURESOF14C.F.R.§302.311,WHICHAUTHORIZETHEDEPARTMENTTOACTONEMERGENCYEXEMPTIONREQUESTSIMMEDIATELY.ANYPERSONINTERESTEDINFILINGANANSWERISREQUESTEDTODOSOINTHEABOVEDOCKETIMMEDIATELY.COPIESOFTHESUBMISSIONSHOULDBESERVEDONTHEPERSONSLISTEDABOVEANDONTHEATTACHEDSERVICELIST.',\DC.6-101519vi

# Application
of BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C

. ) ) 

# ANTONOV AIRLINES

) Docket DOT-OST-2015

- __
_ ) 

# 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 appl

i es for an emergency exemption
pu r suant 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
(R

i ckenbacker Airport)

, Oh

i o to Seattle or Everett

, Washington, February 11-13, 2015

, using an AN-124-100 aircraft

. Antonov respectfully requests expedited consideration and approval of this applicat

i on 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

a
i r carrier that holds exemption authority to conduct charter all-cargo foreign air transportation between Ukra

i ne and the United States, and between the United
S t ates 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

· 0 27074

/ 000001

• C>IOBS 19 vlApplication
of Antonov Airlines Page2 be accommodated

by any freighter aircraft operated by U.S

. air carriers. As a result, the engine needs to be transported using Antonov's AN-124-100 aircraft

. 3. As explained

in the attached support letter, GE Aviation has requested that Antonov conduct

a flight carrying an aircraft engine from Columbus
to Seattle on or about February 11, 2015

1 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

l ate 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 ant

i cipated 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 viApplication
of Antonov Airlines Page 3 take every possible step to avoid additional production line delays and meet aircraft delivery commitments. Accordingly,

it is critical that Antonov be authorized

to use an AN-124-100 aircraft to address GE Aviation's and Boeing's requirements for the delivery of this engine to Seattle as soon as possible. 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

# Application
of Antonov Airlines Page4 outsized cargo charters to and from the United States since 1991. As noted above

, Antonov holds independent exemption authority last renewed by Notice of Action Taken dated October 12, 2005. 6. Grant of this application

is consistent with Department precedent. The 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
• 027074

1 000001. 6408S 19 vlApplication
of Antonov Airlines Page 5 WHEREFORE,
for the foregoing reasons, Antonov respectfully requests that the Department issue an emergency exemption permitting Antonov
to operate

a singleoneway 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-124-1 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 Wash

i ngton, DC 20004 +1 202 637 8898 sheryl.israel@hoganlovells.com Counsel for ANTONOV COMPANY Ua ANTONOV AIRLINESCERTIFICATEOFSERVICEIherebycertifythatacopyoftheforegoingApplicationofAntonovAirlinesforanEmergencyExemptionhasbeenservedthis4thdayofFebruary,2015,uponeachofthefollowingaddressees:rsilverberg@sgbdc.com;jrichardson@johnlrichardson.com;JCanny@amerijet.com;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.govJonathanEchmalian\DC-vlDATE

: February

3 , 2015 SUBJECT: Request for approval urgent ad hoc charter Dear Sir or Mod om Aviation Dave Dauenhauer **GEn~e** Man u factur

i ng Prog

r ams One Neumann Way Evendole

. O H 45215 USA T 15131 552·2541 c 15 1 3)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 the

i r operat

i ons

. 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