BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

MiMCM OF 

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Motion of 

ALASKA AIRLINES, INC. 

For confidential treatment of Part 241 

Submissions under 14 C.F.R. § 302.12 

Docket OST-96-1637 

MOTION OF ALASKA AIRLINES, INC. 

FOR CONFIDENTIAL TREATMENT OF 

PART 241 SUBMISSIONS UNDER RULE 12 

Please forward all communications concerning this motion to: 

Brandon Pedersen 

VP/Finance, CFO and Treasurer 

ALASKA AIRLINES, INC. 

19300 International Boulevard 

Seattle, Washington 98188 

(206) 392-5763 

Kyle B. Levine 

Deputy General Counsel 

ALASKA AIRLINES, INC. 

19300 International Boulevard 

Seattle, Washington 98188 

(206) 392-5292 

March JL » 2012 

Counsel for 

ALASKA AIRLINES, INC. 

Page 1 of 4 - MOTION OF ALASKA AIRLINES. INC. FOR CONFIDENTIAL TREATMENT OF 

PART241 SUBMISSIONS UNDER RULE 12 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

Motion of 

ALASKA AIRLINES, INC. 

For confidential treatment of Part 241 

Submissions under 14 C.F.R. § 302.12 

Docket OST-96-1637 

MOTION OF ALASKA AIRLINES, INC. 

FOR CONFIDENTIAL TREATMENT OF 

PART 241 SUBMISSIONS UNDER RULE 12 

Pursuant to section 302.12 of the Department's Rules of Practice, Alaska Airlines, Inc. 

("Alaska") hereby moves to withhold from public disclosure for a period often years certain 

commercially-sensitive information contained in Schedule B-7 ("Airfirame and Aircraft Engine 

Acquisitions and Retirements") and Schedule B-43 ("Inventory of Airframes and Aircraft 

Engines") of its Part 241 filings for the quarter ending December 31,2011. Unredacted versions 

of Schedules B-7 and B-43 are filed simultaneously with this Motion marked "Confidential 

Treatment Requested Under § 302.12." 

In support of its Motion, Alaska offers the following points and authorities: 

1. The data for which confidential treatment is sought is being disclosed to the 

Department pursuant to Part 241 of the Department's economic regulations. The majority of 

information contained in Alaska's Part 241 filings will enter the public domain, where it will be 

available for inspection and copying by members of the public, including foreign and domestic 

competitors of Alaska and competitors of Alaska's aircraft and engine suppUers, 

Page 2 of 4 - MOTION OF ALASKA AIRLINES, INC. FOR CONFIDENTIAL TREATMENT OF 

PART241 SUBMISSIONS UNDER RULE 12 
2. Certain price and cost data contained in Schedule B-7 and B-43 are highly 

sensitive and confidential. More specifically, 

(a) Schedule B-7 reflects the cost of commercial aircraft and engines Alaska 

purchased or leased firom The Boeing Company. 

(b) Schedule B-43 discloses the acquisition cost, depreciation or amortization 

values and estimated residual values of numerous commercial aircraft and engines Alaska 

has purchased fi-om The Boeing Company since the 1990s. 

3. The commercially-sensitive information found in Schedules B-7 and B-43 should 

be withheld firom pubUc disclosure pursuant to Exemptions 3 and 4 of the Freedom of 

Information Act (5 U.S.C. § 552(b)(3) and (4)) (the "FOIA") and legal authority interpreting the 

FOIA. 

4. Under Exemption 3, information in agency records should be withheld firom the 

public if it is specifically exempted fi-om disclosure by a statute, provided that the statute "(A) 

requires that the matters be withheld from the public in such a marmer as to leave no discretion 

on the issue, or (B) establishes particular criteria for withholding, or refers to particular types of 

matters to be withheld." Section 1104 of the Federal Aviation Act (49 U.S.C. § 1504) 

specifically requires the Department to withhold information firom production under the FOIA if 

its release would "adversely effect the competitive position of any carrier in foreign air 

transportation." Public release of the aircraft and engine cost data to Alaska's competitors would 

have exactly this adverse effect. 

5. Exemption 4 extends confidential treatment to records that are "commercial or 

financial information obtained from a person and privileged or confidential." 5 U.S.C. § 

552(b)(4); see also Gulf and Western Industries. Inc. v. United States. 615 F.2d 527, 529 (D.C. 

Cir. 1979). These price and cost data contained in Schedules B-7 and B-43 are of this nature 

and, additionally, "would customarily not be released to the public by [Alaska]." See National 

Parks and Conservation Association v. Morton. 498 F. 2d 765,766 (D.C. Cir. 1974) (citing S. 

Rep. No. 813, 89th Cong., 1st Sess. 9 (1965)). Finally, if released under the FOIA, price and 

Page 3 of 4 - MOTION OF ALASKA AIRLINES, INC. FOR CONFIDENTML TREATMENT OF 

PART241 SUBMISSIONS UNDER RULE 12 
cost data concerning Alaska's aircraft transactions have the potential "to cause substantial harm 

to the competitive position of the person from whom the information was obtained." Id. at 770. 

WHEREFORE, Alaska respectfiilly requests the Department of Transportation to 

withhold the redacted portions of the attached document(s) from public disclosure for a period of 

ten (10) years. 

Respectfiilly submitted. 

March 2 ^ 2012 

Kyle B. Levine 

Deputy General Counsel 

ALASKA AIRLINES, INC. 

19300 International Boulevard 

Seattle, Washington 98188 

(206) 392-5292 

Page 4 of 4 - MOTION OF ALASKA AIRLINES, INC. FOR CONFIDENTML TREATMENT OF 

PART 241 SUBMISSIONS UNDER RULE 12