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BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

U.S.-Mexico Procedures for U.S. Carriers

(MEXICO PROCEDURAL DOCKET)

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Docket DOT-OST-2011-0076

Application of

MESA AIRLINES, INC.

for an exemption under 49 U.S.C. § 40109

(Dallas/Ft. Worth and Leon/Guanajuato, Mexico)

(Dallas/Ft. Worth and Queretaro, Mexico)

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Docket DOT-OST-2014-0179

MOTION OF MESA AIRLINES, INC.

FOR TEMPORARY WAIVER OF DORMANCY CONDITIONS

Communications with respect to this document should be addressed to:

Brian Gillman

Executive Vice President,

General Counsel and Secretary

Mesa Air Group, Inc.

410 North 44th Street, Suite 700

Phoenix, AZ 85008

TEL: 602-685-4000

FAX: 602-685-4350

Robert E. Cohn

Patrick R. Rizzi

HOGAN LOVELLS US LLP

Columbia Square

555 Thirteenth Street, NW

Washington, DC 20004

TEL: 202-637-4999/-5659

robert.cohn@hoganlovells.com

patrick.rizzi@hoganlovells.com

Counsel for

MESA AIRLINES, INC.

January 22, 2015

NOTE: Mesa will be polling on this Motion and will provide the results of

that polling to the Department as soon as it is completed.
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BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

U.S.-Mexico Procedures for U.S. Carriers

(MEXICO PROCEDURAL DOCKET)

)

)

)

)

)

)

Docket DOT-OST-2011-0076

Application of

MESA AIRLINES, INC.

for an exemption under 49 U.S.C. § 40109

(Dallas/Ft. Worth and Leon/Guanajuato, Mexico)

(Dallas/Ft. Worth and Queretaro, Mexico)

)

)

)

)

)

)

)

)

Docket DOT-OST-2014-0179

January 22, 2015

MOTION OF MESA AIRLINES, INC.

FOR TEMPORARY WAIVER OF DORMANCY CONDITIONS

Pursuant to DOT Order 2012-1-30 in the Mexico Procedural Docket,

Mesa Airlines, Inc. (“Mesa”) hereby moves the Department for a temporary

waiver of the dormancy period attached to Mesa’s exemption authority to operate

scheduled foreign air transportation of persons, property, and mail between

Dallas/Ft. Worth (“DFW”), on the one hand, and Leon/Guanajuato (“BJX”) and

Queretaro (“QRO”), Mexico, on the other hand. Mesa will poll regarding this

Motion and report the polling results to the Department as soon as possible.

1. By Notice of Action Taken, dated October 24, 2014, in Docket

DOT-OST-2014-0179, the Department granted exemption authority to Mesa to
Motion of Mesa Airlines, Inc.

Page 2

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operate scheduled service between Dallas/Ft. Worth and Leon/Guanajuato and

between Dallas/Ft. Worth and Queretaro.

2. The current dormancy period for this authority is scheduled to

expire before Mesa will be able to commence these services. The application

and approval process with the Mexican government has taken longer than

expected. Accordingly, Mesa is requesting this temporary waiver of the

dormancy period in order to bridge the gap between the end of the current

dormancy period and the date by which Mesa estimates it will be able to begin

operating these services, i.e., until April 15, 2015.

3. The Department has granted dormancy waivers in cases involving

other transborder U.S.–Mexico routes. See, e.g., Notice of Action Taken, dated

October 17, 2000 (Docket DOT-OST-2000-6911); Approval, dated May 16, 2013

(Docket DOT-OST-2011-0076).

4. As previously recognized by the Department, Mesa is fully qualified

to provide air transportation between DFW and BJX/QRO, and its scheduled

DFW-BJX and DFW-QRO services are fully consistent with the Air Transport

Agreement between the United States and Mexico. See Notice of Action Taken,

dated October 24, 2014 (Docket DOT-OST-2014-0179). Moreover, this

scheduled service will benefit consumers by enabling Mesa, operating as

“American Eagle”, to enhance competitive transborder service offerings to

Leon/Guanajuato and Queretaro.
Motion of Mesa Airlines, Inc.

Page 3

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WHEREFORE, Mesa respectfully requests that the Department promptly

grant Mesa’s motion for a temporary dormancy waiver until April 15, 2015, with

respect to its exemption authority to engage in scheduled foreign air

transportation of persons, property, and mail between Dallas/Ft. Worth, on the

one hand, and Leon/Guanajuato and Queretaro, Mexico, on the other hand.

Respectfully submitted,

______________________________________

Robert E. Cohn

Patrick R. Rizzi

HOGAN LOVELLS US LLP

555 Thirteenth Street, NW

Washington, DC 20004

202-637-4999/-5659

Counsel for

MESA AIRLINES, INC.
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CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Motion of Mesa Airlines, Inc. for

Temporary Waiver of Dormancy Conditions has been served this 22nd day of

January 2015, upon each of the following addresses:

dheffernan@cozen.com; howard.kass@aa.com; robert.wirick@aa.com;

sascha.vanderbellen@delta.com; chris.walker@delta.com; matwood@cozen.com;

stephen.lachter@lachterlaw.com; jhill@cooley.com; perkmann@cooley.com;

bob.kneisley@wnco.com; leslie.abbott@wnco.com;

dkirstein@yklaw.com; jyoung@yklaw.com; thomas.ting@suncountry.com;

dan.weiss@united.com; steve.morrissey@united.com;

barbara.russell@virginamerica.com; brian.hedberg@dot.gov;

brett.kruger@dot.gov; englets@state.gov; info@airlineinfo.com

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