BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C. 

 

 ) 

Application of ) 

 ) 

ALASKA AIRLINES, INC. ) Docket DOT-OST-2004-19419 

 ) 

for an exemption pursuant to 49 U.S.C. 40109 ) 

 ) 

APPLICATION FOR RENEWAL OF EXEMPTION

Communications with respect to this document should be addressed to: 

Kyle Levine, Esq. Marshall S. Sinick, Esq. 

Associate General Counsel Charles F. Donley II, Esq. 

Commercial Law and Litigation Squire, Sanders & Dempsey L.L.P. 

Alaska Airlines, Inc. 1201 Pennsylvania Avenue, N.W. 

19300 International Boulevard Washington, D.C. 20004 

Seattle, Washington 98188 (202) 626-6651 

 msinick@ssd.com

cdonley@ssd.com

Megan Lawrence, Esq. Counsel to Alaska Airlines, Inc. 

Managing Director, Government Affairs 

 & Community Relations 

Alaska Airlines, Inc. 

19300 International Boulevard 

Seattle, Washington 98188 

DATED: May 25, 2010 
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C. 

 

 ) 

Application of ) 

 ) 

ALASKA AIRLINES, INC. ) Docket DOT-OST-2004-19419 

 ) 

for an exemption pursuant to 49 U.S.C. 40109 ) 

 ) 

APPLICATION FOR RENEWAL OF EXEMPTION

 Alaska Airlines, Inc. (“Alaska”) hereby requests renewal of the exemption authority granted 

to it by the Department of Transportation (the “Department”) in the above-captioned docket to 

perform scheduled foreign air transportation of persons, property and mail between Los Angeles, 

California, and Loreto, Mexico. This exemption authority expires on August 28, 2010. Alaska 

requests renewal of this authority for a two-year period and relies on the provisions of the 

Administrative Procedure Act and Part 377 of the Department’s procedural regulations to continue 

its existing authorization in force pending a final decision on this renewal request. 

 In further support of its request for renewal, Alaska states as follows: 

 1. Alaska’s principal headquarters are located at 19300 International Boulevard, 

Seattle, Washington. Alaska is incorporated under the laws of the State of Alaska and is a 

wholly-owned subsidiary of Alaska Air Group, Inc. (“AAG”). AAG is incorporated under the 

laws of the State of Delaware. 
Application for Renewal of Exemption 

Docket DOT-OST-2004-19419 

May 25, 2010 

2

 2. Alaska is a citizen of the United States within the meaning of 49 U.S.C. 

40102(a)(15). The president and at least two-thirds of Alaska’s directors and other managing 

officers are U.S. citizens. Additionally, to Alaska’s knowledge, U.S. citizens hold at least 

seventy-five percent of Alaska’s voting stock. 

 3. Alaska has repeatedly been found fit, willing and able to provide interstate and 

foreign air transportation. The Department is requested to take official notice of Alaska’s 

continuing fitness. See, e.g., Order 2000-5-31. 

 4. Alaska holds out scheduled service between Los Angeles and Loreto under a 

codeshare arrangement with Horizon Air Industries, Inc. (“Horizon). Under the two carriers’ 

agreement, Alaska displays its two-letter designator code on flights operated by Horizon between 

Los Angeles and Loreto.1

 Alaska does not serve Los Angeles-Loreto with its own aircraft and 

does not plan to resume service in this market with its own aircraft. Alaska would therefore have 

no objection to withdrawal of its Los Angeles-Loreto designation provided it receives a 

codeshare authorization that will permit it to continue to hold out such service without 

interruption. The Department has found previously that Alaska’s service in the Los AngelesLoreto market is consistent with the terms of the U.S.-Mexico bilateral agreement.2

 5. This renewal application does not raise any environmental or energy concerns. 

All flights will continue to be performed with aircraft that meet all applicable noise requirements. 

Similarly, approval of this application will not result in a near-term increase in fuel consumption of 

ten million gallons or more. 

 

1

 Horizon holds an exemption permitting it to operate between Los Angeles and Loreto. Notice of Action Taken, 

Docket DOT-OST-2009-0180, August 18, 2009 

2 See, Notice of Action Taken, Docket DOT-OST-2004-19419, August 28, 2008 
Application for Renewal of Exemption 

Docket DOT-OST-2004-19419 

May 25, 2010 

3

WHEREFORE, Alaska Airlines, Inc. respectfully requests that the exemption granted to 

it in the above-captioned docket be renewed for an additional two-year period, as more fully 

described herein. 

 Respectfully submitted, 

 ________________________________ 

 Marshall S. Sinick, Esq. 

 Squire, Sanders & Dempsey L.L.P. 

 1201 Pennsylvania Avenue, N.W. 

 Washington, D.C. 20004 

 (202) 626-6651 

 msinick@ssd.com 

 Counsel to Alaska Airlines, Inc. 

DATED: May 25, 2010 
CERTIFICATE OF SERVICE

I hereby certify that one copy of the foregoing Application for Renewal of Exemption has 

this day been served on each of the following individuals via telecopier or email.

 ___________________________ 

 Marshall S. Sinick 

DATED: May 25, 2010 

hkamen@coair.com

sascha.vanderbellen@delta.com

sametta.c.barnett@delta.com

jeffrey.manley@united.com

anbird@fedex.com

dvaughan@kelleydrye.com

efaberman@wrf.com

howard_kass@usairways.com

dkirstein@yklaw.com

jhill@dowlohnes.com

mcmillin@woa.com

pmurphy@lopmurphy.com

jyoung@yklaw.com

carl.nelson@aa.com