WCKERT SCOUTT & RASENBERGER, L.L.P. 

ATTORNEYS AT LAW 

888 Seventeenth Street, NW, Washington, DC 20006-3309 

Telephone [202] 298-8660 Fax [202] 342-0683 

www.zsrlaw.com 

August 15, 2013 

Submitted via www.regulations.gov 

Robert Finamore 

Chief, Foreign Air Carrier Licensing Division 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.W. 

Washington, D.C. 20590 

Re: Avianca and the TACA Group; Docket OST-2012-0136 

Dear Mr. Finamore: 

Avianca and the TACA Group1 (collectively, the "Joint Applicants") hold: (1) an 

exemption under 49 U.S.C. § 40109 permitting them to register under 14 C.F.R. Part 215 for 

their collective use of the trade name "Avianca" and use of the designator code "AV" for their 

services in foreign air transportation to and from the United States; and (2) (for the TACA 

Group) blanket statements of authorization pursuant to 14 C.F .R. Part 212 in order to display the 

"AV*" designator code. Notice of Action Taken, Docket OST-2012-0136 (December 13, 2012). 

On March 27, 2013 the Department approved through August 31, 2013, the Joint Applicants' 

request to extend the use of the TACA trade name and "TA" code for the TACA Group carriers 

pending resolution of certain technological issues in connection with the Joint Applicant's 

transition to a single Avianca brand and their shared usage ofthe "AV" code. 

The Joint Applicants respectfully request a further extension of time to use the TACA 

trade name and "TA" code through March 31, 2014, as they continue their migration toward the 

shared usage of a common brand and designator code. Although A vianca and the T ACA Group 

had fully anticipated that all outstanding issues would be resolved prior to August 31, 2013, this 

extension of time is necessary to address several significant remaining challenges, including, but 

not limited to, an expansion of their information technology infrastructure and data processing 

capabilities, communication automation between their respective databases to facilitate seamless 

passenger check-in, testing of shared computer reservation systems, platforms and connectivity, 

quality assurance audits, and, ultimately, itinerary validation andre-issuance, all of which must 

be accomplished prior to full "cutover." 

These challenges remain particularly acute with respect to the finalization of the Joint 

Applicants' combined Web presence, which they must ensure remains functional and stable 

Aerovias Del Continente Americana S.A. Avianca and TACA International Airlines, S.A., 

Trans American Airlines, S.A. d/b/a TACA, Lineas Aereas Costarricenses S.A., and Aviateca 

S.A., respectively. 
ZUCKERT SCOUIT & RASENBERGER, L.LP. 

Robert Finamore 

August 15,2013 

Page2 

during and after migration. In this regard, significant hardware and software upgrades are 

necessary to fully support the Joint Applicants' Web site changes. Thereafter, new content and 

web-based functionality will need to be tested and validated, with itineraries re-issued to reflect 

travel under the common code-a process that, independent of the other challenges described 

herein, is expected to take as long as eight weeks. Ensuring these steps are completed smoothly 

is of critical importance to the customers of not only A vianca and the T A CA Group, but those of 

their numerous codeshare and interline partners, both in the U.S. and around the world. 

Additionally, given the large percentage of the Joint Applicants' ticket sales conducted via their 

Web sites, as well as the number of passengers who utilize Web check-in for flights, the Joint 

Applicants must be able to ensure that Web-based transactions and requests function efficiently 

throughout the transitional period without disruption. 

The Joint Applicants continue to devote significant resources to the successful 

completion of a common brand and code, including a dedicated team of 100 full-time employees 

specifically tasked with overseeing common brand and code implementation. The Joint 

Applicants estimate that, thus far, approximately 420,000 employee hours have been expended 

on the project, with commercial core processes in functional areas such as inventory 

management, reservations and passenger airport services now largely aligned. Indeed, nearly 

4,000 employees have received training in connection with unified carrier policies and 

technology platforms. Notwithstanding these significant achievements, the Joint Applicants 

require additional time to address the remaining challenges. While the Joint Applicants are 

optimistic that they will have addressed most of the remaining issues by the end ofthis year, the 

additional time requested will permit the Joint Applicants to ensure that full migration can be 

accomplished in a manner that will minimize potential disruption to customers, particularly 

during the busy upcoming peak travel season. It should be noted that the Joint Applicants, using 

existing IT infrastructure, have already begun displaying Avianca's code on a limited number of 

former "TA" flights to and from the U.S., and anticipate a steady but measured expansion in the 

number of such flights in the coming months, culminating in full migration by the first quarter of 

2014. 

Like the initial extension granted to the Joint Applicants, grant of this request will serve 

the public interest. In its December 13, 2012 approval of the common branding arrangement, the 

Department cited the "aviation agreements between the U.S. and the homelands of each of the 

joint applicants" as the basis for the approval. Notice of Action Taken at 2. Collectively, these 

agreements represent the view of the U.S. and the homeland of each carrier here that liberalized 

air services and cooperative marketing agreements best serve the public interest, and provide for 

greater access to a variety of air service offerings. The additional time requested will permit 

A vianca and the TACA Group to smoothly transition to a common trade name and designator 

code, will not prejudice any party, and will permit Avianca, the TACA Group, and travelers to 

fully realize the efficiencies and benefits of common branding in a wide variety of geographic 

markets. 
ZUCKERI' SCOUIT & RASENBERGER, L.LP. 

Robert Finamore 

August 15,2013 

Page 3 

Avianca and the TACA Group will poll all parties set forth on the attached certificate of 

service and advise the Department of the results as soon as possible. 

cc: service list 

Respectfully submitted, 

Richard D. Mathias 

David M. Enders bee 

Jonathon H. Foglia 

Counsel for Avianca and the TACA Group 
CERTIFICATE OF SERVICE 

I hereby certify that on this 15th day of August 2013, a copy of the foregoing was served 

by email on the parties named below: 

Lorraine B. Halloway 

Gerald F. Murphy 

Counsel for Continental/United Airlines 

Crowell & Moring LLP 

1001 Pennsylvania Avenue, N.W. 

Washington, D.C. 20004-2595 

lhalloway@crowell.com 

gmurphy@crowell.com 

Dan Weiss 

Managing Director - International & 

Regulatory Affairs 

United Air Lines 

77 West Wacker Drive-HDQIZ 

Chicago, IL 60601 

dan. weiss@united.com 

Stephen J. Morrissey 

Managing Director, Regulatory and 

Policy 

United Air Lines, Inc. 

1225 New York Avenue, NW - DCAIZ 

Suite 1100 

Washington, DC 20005 

steve.morrissey@united.com 

Alexander Van Der Bell en 

Sametta C. Barnett 

Delta Air Lines 

1212 New York Avenue, NW 

Suite 200 

Washington, D.C. 20005 

sascha.vanderbellen@delta.com 

sametta.c.barnett@delta.com 
Robert Wirick 

American Airlines, Inc. 

11 01 Seventeenth Street, N. W. 

Suite 600 

Washington, D.C. 20036 

robert. wirick@aa.com 

John L. Richardson 

Joan Canny 

Counsel for Amerijet International 

John L. Richardson, P.L.L.C. 

555 131

h Street, N.W. 

Suite 420 West 

Washington, D.C. 20004 

jrichardson@j ohnlrichardson.com 

jcanny@amerijet.com 

Kelli Bryan 

Ranjit Seth 

Robert Foster 

Charter Sales 

Evergreen International Airlines, Inc. 

3850 Three Mile Lane 

McMinnville, OR 97128 

charters@evergreenairlines.com 

ranjit.seth@evergreenairlines.com 

chris.schuldt@evergreenhelicopters.com 

robert.foster@evergreenairlines.com 

Sandra L. Lunsford 

Courtney Felts 

Legal and Regulatory Affairs 

Federal Express Corporation 

3620 Hacks Cross Road 

Building B, 3rd Floor 

Memphis, TN 38125 

sllunsford@fedex.com 

cefelts@fedex.com 

Timothy Erickson 

Safety and Regulatory Affairs 

Air Transport International LLC 

2800 Cantrell Road 

Little Rock, AR 72202 

timothy.erickson@airtransport.cc 
Malcolm L. Benge 

Counsel for World Airways 

Zuckert, Scoutt & Rasenberger LLP 

888 1 ih Street, N,W. 

Suite 700 

Washington, DC 20006 

mlbenge@zsrlaw.com 

HowardKass 

Managing Director & Associate General 

Counsel 

US Airways 

1401 H Street, N.W., Suite 1075 

Washington, D.C. 20006 

howard.kass@usairways.com 

John M. Allen 

Director 

Flight Standards Seryice 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Room 821 

Washington, D.C. 20591 

john.allen@faa.gov 

Aaron Goerlich 

Counsel for Allegiant Air, Ryan 

International Airlines and Southern Air 

Garofalo Goerlich Hainbach PC 

1200 New Hampshire Avenue NW 

Suite 800 

Washington, D.C. 20036-6802 

agoerlich@ggh-airlaw.com 

Robert P. Silverberg 

Jeffrey Johnson 

Counsel for ABX Air 

Silverberg, Goldman & Bikoff, L.L.P. 

1101 30th Street, N.W. 

Suite 120 

Washington, D.C. 20007 

rsilverberg@sgbdc.com 

jjohnson@sgbdc.com 
MarshallS. Sinick 

Counsel for Alaska Airlines and Florida 

West International Airways 

Squire, Sanders & Dempsey 

1201 Pennsylvania Avenue, N.W. 

Suite 500 

Washington, D.C. 20004 

msinick@ssd.com 

Russell E. Pommer 

Associate General Counsel and 

Director ofRegulatory Affairs 

Atlas Air, Inc. 

1747 Pennsylvania Avenue, N.W. 

Suite 875 

Washington, D.C 20006 

rpommer@atlasair.com 

Mark W. Atwood 

Counsel for Kalitta Air and Xtra Airways 

Cozen O'Connor 

Army Navy Building 

1627 I Street, NW 

Suite 1100 

Washington, D.C. 20006 

matwood@cozen.com 

ldunn@xtraairways.com 

Jonathan B. Hill 

Counsel for Hawaiian Airlines and JetBlue 

Dow Lohnes 

1200 New Hampshire Avenue, N.W. 

Suite 800 

Washington, DC 20036-6802 

jhill@dowlohnes.com 

Thomas Ting 

MN Airlines, LLC dba Sun Country 

Airlines 

1300 Mendota Heights Road 

Mendota Heights, MN 55120 

thomas.ting@suncountry .com 
Joanne W. Young 

Counsel for Spirit Airlines 

Kirstein & Young PLLC 

1001 Pennsylvania Ave., N.W. 

Suite 600 South 

Washington, DC 20004 

jyoung@yklaw.com 

John R. Mietus, Jr. 

Counsel for Centurion Air Cargo and Trade 

Winds Airlines 

Law Office of John Mietus, LLC 

6701 Democracy Boulevard 

Suite 300 

Bethesda, MD 20817 

john@mietuslaw.com 

Kevin Montgomery 

Peter Beckett 

Polar Air Cargo, Inc. 

1747 Pennsylvania Avenue, N.W. 

Suite 875 

Washington, D.C 20006 

kevin.montgomery@ polaraircargo.com 

peter.beckett@aawholdings.com