BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_________________________________________ )

Application of )

)

EASTERN AIR LINES GROUP, INC. ) DOCKET OST

- 201 4

- )

for a Certificate of Public Convenience )

and Necessity ( Interstate Passenger )

Charter Service) )

_________________________________________ )

MOTION OF EASTERN AIR LINES GROUP, INC.

FOR CONFIDENTIAL TREATMENT

Communications with respect to this document should be sent to:

Edward J. Wegel

President and CEO

EASTERN AIR LINES GROUP, INC.

Building 5A, Miami Int’l Airport

Miami, FL 33142

(305) 869

- 4249

ed.wegel@easternairlines.aero Edward P. Faberman

Wiley Rein LLP

1776 K Street, NW

Washington, DC 20006

(202) 719

- 7402

efaberman@wileyrein.com

John R. Mietus, Jr.

Law Office of John Mietus, LLC

6701 Democracy Blvd., Suite 300

Bethesda, MD 20817

- 7500

(202) 747

- 5212

j ohn@mietuslaw.com

Counsel for EASTERN AIR LINES

GROUP, INC.

January 2 8 , 2014BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_________________________________________ )

Application of )

)

EASTERN AIR LINES GROUP, INC. ) DOCKET OST

- 201 4

- ) January 2 8 , 2014

for a Certificate of Public Convenience )

and Necessity ( Interstate Passenger )

Charter Service) )

_________________________________________ )

MOTION OF EASTERN AIR LINES GROUP, INC.

FOR CONFIDENTIAL TREATMENT

Pursuant to Rule 12 of the Department's Rules of Practice, 14 C.F.R.

§ 302.12, Eastern Air Lines Group, Inc. respectfully moves to withhold from

public disclosure the contents of Confidential Exhibits A

- C filed

simultaneously with the above

- capt ioned application. In accordance with

Rule 12, the exhibits have been marked “Confidential” and are being filed

under seal.

Confidential Exhibit A contains the FAA certificate numbers of the

applicant's key personnel who hold such cert ificates. The Department

previously has found that confidential treatment of such numbers is

appropriate, among other reasons, because they may be keyed to social

security numbers. See, e.g., Dynamic Airways, LLC , letter ruling of July 29,

2010 , Docket OST

- 2010

- 0058 ; Atlas Air, Inc. , letter ruling of December 3,

2009, Docket OST

- 2009

- 0267

- 11.Eastern

Motion

Page 2

Confidential Exhibit B is a copy of Eastern’s Private Placement

Memorandum. It includes financial and business information and forecasts

at a level of detail, and for a forecast horizon, well beyond that which is

required by the Department’s Rules, and such information would not

normally be released to the public. The Department has granted confidential

treatment to similar, private securities offering documents. See, e.g.,

SkyLink Airways, Inc. d/b/a Maxjet, Order 2005

- 1

- 1 at 10.

Confidential Exhibit C contains unredacted pages from public Exhibit

6 that show Eastern’s revenue forecast for its first full year of operations and

its forecast operating results, alo ng with certain, sensitive salary and

revenue assumptions; these were redacted in the public version. The

Department routinely grants confidential treatment to information, such as

applicants’ revenue forecasts and details of expense calculations, where

pu blic disclosure would give competitors the ability to readily calculate

sensitive commercial terms. See, e.g., Dynamic Airways; Atlas Air ;

Independence Air, Inc. and Compass Airlines, Inc. , letter ruling of August 23,

2006, Docket OST

- 2006

- 24295

- 4 (“the D epartment has generally granted

confidential treatment to contractual agreements and financial projections

when the nature of the information reflected in the financial statements

could well provide commercially sensitive information to competitors”)

(emph asis added)

.