BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

Application of 

 FEDERAL EXPRESS CORPORATION 

for one Hong Kong-Dubai fifth-freedom 

all-cargo frequency 

Docket OST-2010-__________ 

APPLICATION OF FEDERAL EXPRESS CORPORATION 

FOR IMMEDIATE ALLOCATION 

Communications with respect to this document should be sent to: 

G. Bailey Leopard, Jr. 

Senior Counsel 

FEDERAL EXPRESS CORPORATION 

Regulatory Affairs 

3620 Hacks Cross Road 

Building B, 3rd Floor 

Memphis, Tennessee 38125 

(901) 434-6664 (phone) 

(901) 434-8283 (fax) 

Email: gbleopard@fedex.com 

Attorney for 

FEDERAL EXPRESS CORPORATION 

NOTICE: Answers to this application are due on June 16, 2010, but FedEx Express 

respectfully requests expedited treatment of this application. FedEx Express will 

poll interested parties and advise the Department of the results.

June 1, 2010
BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

Application of 

 FEDERAL EXPRESS CORPORATION 

for one Hong Kong-Dubai fifth-freedom 

all-cargo frequency 

Docket OST-2010-___________ 

APPLICATION OF FEDERAL EXPRESS CORPORATION 

FOR IMMEDIATE ALLOCATION 

 Federal Express Corporation (“FedEx Express”) submits this application under 14 

C.F.R. Part 302, subpart C and the October 19, 2002 Memorandum of Understanding 

between the United States and Hong Kong (“the 2002 MOU”). FedEx Express hereby 

applies for one weekly Hong Kong-Dubai frequency, with full traffic rights, to use on the 

following service, which will connect FedEx Express’s Dubai hub in the Middle East to 

its SuperHub in Memphis, its European hub in Paris and Hong Kong with full traffic 

rights: 

Equipment Day (Local) Origin Destination 

MD-111 Friday MEM CDG 

CDG DXB+ 

Saturday DXB HKG 

The requested frequency is available under the Hong Kong-Dubai point-cap since 

Kalitta Air, L.L.C. recently exchanged two Hong Kong-Dubai frequencies for two Hong 

 

1 FedEx Express will use MD-11 aircraft from its existing fleet on this year-round service. The 

MD-11 has a gross payload of 196,000 pounds. 

June 1, 2010 
Application of 

Federal Express Corporation 

Page 2 

Kong-Manama, Bahrain frequencies, and FedEx Express has long sought Hong KongDubai fifth-freedom authority since it became available under the 2002 MOU. The 

Department’s grant of FedEx Express’s request will be in the public interest, allowing it 

to provide competition on this important lane segment one time per week against UPS, 

who holds five Hong Kong-Dubai fifth-freedom frequencies, and foreign carriers in the 

market. 

FedEx Express seeks an allocation for an indefinite period, consistent with 

Department practice, and will accept the Department’s standard dormancy requirement. 

The authority requested in this application is consistent with bilateral air services 

agreements between the United States, on the one hand, and Hong Kong, the United Arab 

Emirates, and all other relevant countries, on the other hand. 

FedEx Express currently operates the above-described service on a “blind sector” 

basis between Hong Kong and Dubai, so it could start using the relevant frequency as 

soon as the Department grants this application and the Hong Kong Civil Aviation 

Department approves the service for the exercise of full traffic rights between Dubai and 

Hong Kong. Therefore, FedEx Express is respectfully requesting expedited treatment of 

this application, and FedEx Express will poll interested parties and advise the Department 

of the results. 

 FedEx Express is a Delaware corporation with its principal office at 3610 Hacks 

Cross Road, Memphis, Tennessee 38125. FedEx Express holds certificates of public 

convenience and necessity authorizing it to engage in domestic and foreign all-cargo air 
Application of 

Federal Express Corporation 

Page 3 

transportation.2 The proposed services are well within the scope of the operations that 

FedEx Express is authorized to provide. 

 FedEx Express is a citizen of the United States and is fit, willing, and able to 

provide the requested service. All of FedEx Express’s officers, directors, shareholders, 

and influential management are citizens of the United States, and well over 75% of its 

voting rights are in the hands of U.S. citizens. The proposed services would not 

constitute a major regulatory action under the Energy Policy and Conservation Act and 

Part 313 of the Department’s regulation. 

Conclusion

FedEx Express respectfully requests that the Department grant FedEx Express 

authority for one U.S.-Hong Kong-Dubai fifth-freedom frequency. FedEx Express also 

respectfully requests the Department to consider this application on an expedited basis. 

 Respectfully submitted, 

 FEDERAL EXPRESS CORPORATION 

 _______/s/____________________ 

 G. Bailey Leopard, Jr. 

 Sr. Counsel 

 Regulatory Affairs

 

2 See Order 98-7-6 (US domestic), Orders 89-5-10, 90-7-50, 90-10-11, 94-6-5, and 98-6-22 

(transpacific), and broad route integration authority granted on September 25, 2003, in Docket OST-95-

838. 
Certificate of Service 

 I hereby certify that I have this 1st day of June, 2010, caused the Application of 

Federal Express Corporation for Immediate Allocation to be served upon each party 

listed below in the manner indicated. 

_________/s/_____________________ 

 G. Bailey Leopard, Jr. 

Edward W. Sauer 

Counsel for 

Evergreen International Airlines, Inc. 

esauer@ssd.com 

(via e-mail) 

C. Blair Berselli 

Evergreen International Airlines, Inc. 

blair.berselli@evergreenairlines.com 

(via e-mail) 

Mark W. Atwood 

Counsel for Kalitta Air, LLC 

matwood@sherblackwell.com 

(via e-mail) 

Alexander Van der Bellen 

Counsel for 

Delta Air Lines, Inc. 

sascha.vanderbellen@delta.com 

(via e-mail) 

Pierre Murphy 

Counsel for Arrow Air, Inc. 

pmurphy@lopmurphy.com 

(via e-mail) 

Kevin P. Montgomery 

Polar Air Cargo, Inc. 

kevin.montgomery@polaraircargo.com 

(via e-mail) 

Dontai Smalls 

United Parcel Service Co. 

dsmalls@ups.com 

(via e-mail) 

Danielle Fisher 

Counsel for United Parcel Service Co. 

dfisher@kelleydrye.com 

(via e-mail) 

Aaron A. Goerlich 

Counsel for Southern Air Inc. 

agoerlich@ggh-airlaw.com 

(via e-mail) 

Tim Brown, President 

Gemini Worldwide Airways LLC 

tbrown@geminiairways.com 

(via e-mail) 

Malcolm L. Benge 

Counsel for World Airways, Inc. 

mlbenge@zsrlaw.com 

(via e-mail) 

Russell E. Pommer 

Atlas Air, Inc. 

rpommer@atlasair.com 

(via e-mail) 

Bill Evans 

Counsel for TradeWinds Airlines 

bill@mietuslaw.com 

(via e-mail)