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BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________

)

Application of )

)

SKYGREECE AIRLINES S.A. )

) Docket No. OST-2014-_____

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

a foreign air carrier permit pursuant to )

49 U.S.C. § 41301 )

)

(EU-U.S. Open Skies) )

_________________________________________ )

APPLICATION OF SKYGREECE AIRLINES S.A.

FOR AN EXEMPTION AND FOREIGN AIR CARRIER PERMIT

Communications with respect to this document should be addressed to:

Josh Romanow

Peter Nelson

PILLSBURY WINTHROP SHAW PITTMAN LLP

2300 N Street, N.W.

Washington, D.C. 20037

Tel: (202) 663-8000

Fax: (202) 663-8007

E-mail: romanow@pillsburylaw.com

E-mail: peter.nelson@pillsburylaw.com

March 18, 2014 Counsel for SkyGreece Airlines S.A.

NOTE: Any person may support or oppose this application by filing an answer and 

serving a copy of the answer on counsel for SkyGreece Airlines. Answers to the foreign 

air carrier permit application are due on or before April 8, 2014; Answers to the 

exemption application are due on or before April 2, 2014.
501305610v2

BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________

)

Application of )

)

SKYGREECE AIRLINES S.A. )

) Docket No. OST-2014-_____

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

a foreign air carrier permit pursuant to )

49 U.S.C. § 41301 )

)

(EU-U.S. Open Skies) )

_________________________________________ )

APPLICATION OF SKYGREECE AIRLINES S.A.

FOR AN EXEMPTION AND FOREIGN AIR CARRIER PERMIT

Pursuant to 49 U.S.C. §§ 40109 and 41301, Part 211 of the U.S. Department of 

Transportation’s economic regulations, and the Department’s rules of practice,

SkyGreece Airlines S.A. (“SkyGreece”), a foreign air carrier of Greece, hereby applies 

for exemption authority and a foreign air carrier permit to conduct foreign scheduled and 

charter air transportation of persons, property, and mail, between a point or points in 

Member States of the European Union, and a point or points in the United States, to the 

full extent allowed under the Air Transport Agreement between the United States and the 

European Community and the Member States of the European Union,1

as more fully 

described herein.

This application is filed pursuant to the Department’s Notice of February 19, 2009 

relating to Application Procedures for Foreign Air Carriers of the European Union.

 1

 Air Transport Agreement between the U.S. and the European Community and its Member States, signed 

Apr. 25 and 30, 2007, applied provisionally from Mar. 30, 2008, as amended.
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Consistent with the Department’s notices of May 3, 2007 and August 23, 2005 (Docket

No. OST-2005-22228), SkyGreece requests expedited processing of this application to 

allow it to begin the proposed services as soon as possible. The authority sought herein 

will result in increased travel choices, greater service options, and enhanced competition,

thereby benefiting consumers in both the United States and the Member States of the 

European Union. The following is provided in support of this application:

1. The applicant’s full name is SkyGreece Airlines S.A. Its principal place of

business is located at 33 K. Papadimitriou Street, 190 03 Markopoulo Mesogaias, 

Attiki, Greece. 211.20(a).

2. Consistent with rights available to carriers of both parties to the U.S.-EU Air

Transport Agreement, SkyGreece requests authority to engage in:

a. Foreign scheduled and charter air transportation of persons, property, and 

mail from any point or points behind any Member State of the European 

Union via any point or points in any Member State and via intermediate 

points to any point or points in the United States and beyond;

b. Foreign scheduled and charter air transportation of persons, property, and 

mail between any point or points in the United States and any point or 

points in any Member of the European Common Aviation Area;

c. Foreign scheduled and charter cargo air transportation between any point 

or points in the United States and any other point or points;

d. Other charters pursuant to the prior approval requirements set forth in part 

212 of the Department’s economic regulations; and

e. Scheduled and charter transportation consistent with any future, additional 

rights that may be granted to foreign air carriers of the Member States of 

the European Union. 211.20(c).

3. SkyGreece’s Air Operator Certificate (AOC) from the Hellenic Civil Aviation 

Authority is attached hereto as Exhibit A. 211.20(b) and (i).
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4. SkyGreece’s insurance meets the minimum requirements specified in 14 C.F.R. 

205. A copy of OST Form 6411, Foreign Air Carriers—Certificate of Insurance 

is attached hereto as Exhibit B. 211.20(h).

5. A copy of OST Form 4523, Waiver of Warsaw Convention Liability Limits is

attached hereto as Exhibit C. 211.20(t).

6. Foreign Air Carrier Family Support Act Plan: A copy of SkyGreece’s Family 

Assistance Plan is attached as Exhibit D.

7. Summary of Passenger Manifest Information Collection Procedures: SkyGreece

will collect the passenger manifest information required by 14 C.F.R. § 243 and 

will transmit that information to the U.S. Department of State in the event of an 

aviation disaster. A summary of SkyGreece’s procedures is attached as Exhibit E. 

8. Grant of the authority sought herein will not result in a near term increase in fuel 

consumption of ten million gallons or more, and therefore will not comprise a 

“major regulatory action” under the Energy Policy and Conservation Act of 1975, 

as defined at 14 C.F.R. § 313(a)(1).

9. The verification required by 14 C.F.R. 302.4(b) is attached hereto as Exhibit F.

10. As demonstrated by the information provided herein, SkyGreece is fully qualified 

to operate the services for which authority is requested; grant of the requested

authority is consistent with the U.S.-EU Air Transport Agreement and will 

therefore serve the public interest.2

 2 See S. REP. NO. 96-329, at 4 (1979), reprinted in 1980 U.S.C.C.A.N. 54, 57 (“[T]he negotiation of a 

bilateral agreement itself represents a determination by the Government of the United States that the grant 

of route authority provided for under the bilateral is in the ‘public interest.’”). 
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WHEREFORE, for the foregoing reasons, SkyGreece respectfully requests that 

the Department issue an exemption and foreign air carrier permit authorizing SkyGreece

to engage in foreign scheduled and charter air transportation of persons, property, and 

mail to the full extent allowed under the U.S.-EU Air Transport Agreement.

Respectfully submitted,

Josh Romanow

Peter Nelson

PILLSBURY WINTHROP SHAW PITTMAN LLP

2300 N Street, N.W.

Washington, D.C. 20037

Tel: (202) 663-8000

Fax: (202) 663-8007

E-mail: romanow@pillsburylaw.com

March 18, 2014 Counsel for SkyGreece Airlines S.A.
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CERTIFICATE OF SERVICE

The undersigned certifies that on March 18, 2014, the Application of SkyGreece 

Airlines S.A. for an Exemption and Foreign Air Carrier Permit, was served by electronic 

mail on the individuals identified below:

John Allen

Federal Aviation Administration

john.allen@faa.gov

Steve Morrissey

United Airlines

steve.morrissey@united.com

Robert Wirick

American Airlines

robert.wirick@aa.com

Sascha Vanderbellen

Delta Airlines

sascha.vanderbellen@delta.com

Dan Weiss

Continental Airlines

dan.weiss@coair.com

Howard Kass

US Airways

howard.kass@usairways.com

Malcolm L. Benge

North American, World Airways

mlbenge@zsrlaw.com

Russell E. Pommer

Atlas Air Inc.

rpommer@atlasair.com

Nancy Sparks

Bailey Leopard

FedEx

nsparks@fedex.com

gbleopard@fedex.com

Anita Mosner

Jennifer Nowak

UPS

anita.mosner@hklaw.com

jennifer.nowak@hklaw.com

/s/Melinda A. Hernandez__

Melinda A. Hernandez
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TABLE OF EXHIBITS

Exhibit A Air Operator Certificate (AOC)

Exhibit B OST Form 6411, Foreign Air Carriers—Certificate of Insurance

Exhibit C OST Form 4523, Waiver of Warsaw Convention Liability Limits

Exhibit D Family Assistance Plan

Exhibit E Summary of Passenger Manifest Information Collection Procedures

Exhibit F Verification
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EXHIBIT A

AIR OPERATOR CERTIFICATE
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EXHIBIT B

OST FORM 6411 FOREIGN AIR CARRIERS—CERTIFICATE OF INSURANCE
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EXHIBIT C

OST FORM 4523 

WAIVER OF WARSAW CONVENTION LIABILITY LIMITS
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EXHIBIT D

SKYGREECE AIRLINES S.A.

FAMILY ASSISTANCE PLAN

1. Overview

1.1. The purpose of the SkyGreece Airlines S.A. Family Assistance Plan is to provide 

company personnel with the guidelines, procedures and training that will enable 

them to act in the best interests of the families of passengers involved in any 

aircraft accident involving SkyGreece aircraft and resulting in a major loss of 

life, to treat survivors and families with dignity, and to respect the cultural and 

religious backgrounds of survivors and families.

1.2. This document is a part of a larger effort, which includes the National 

Transportation Safety Board, other government entities and appointed 

independent non-profit organizations, to assist survivors and families in the event 

of an aviation disaster.

2. Pre-Response Planning

2.1. In accordance with the Foreign Air Carrier Family Assistance Act of 1996 (49 

U.S.C. Section 1136 & Section 41313), as amended by Vision 100 – Century of 

Aviation Reauthorization Act, SkyGreece will publish this Family Assistance 

Plan and insert this plan into all appropriate SkyGreece manuals.

2.2. The treatment of families of non-revenue passengers (and any other victim of the 

accident) will be the same as the treatment of the families of revenue passengers.

2.3. The SkyGreece Emergency Response Team will be utilized to respond to likely 

needs of survivors and families.

2.4. Training will be based upon employee’s responsibilities and SkyGreece will 

provide logistical support to the Response Team.

2.5. Training of Family Assistance Personnel will be conducted in conjunction with 

SkyGreece’s training recognizing that:

2.5.1. A list of trained Family Assistance Personnel will be maintained in the 

SkyGreece Emergency Response Plan.

2.5.2. Personnel who are in public contact positions need to know how to 

respond to inquiries and facilitate responses to them.

2.5.3. Families may seek assistance from SkyGreece at airports that are neither 

the origin nor the destination of the flight.

2.5.4. Simulations of the Plan will be held annually in addition to participation 

in local disaster drills.
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2.5.5. After an aviation disaster involving a SkyGreece aircraft, a toll-free 

“800” number will be published for the use of families to inquire about 

passengers.

2.5.6. It is SkyGreece’s policy that manifest information will only be released 

by the designated SkyGreece Coordinator to the proper NTSB 

authorities, the director of family support services designated for the 

accident under section 1136(a)(1), the organization designated for the 

accident under section 1136(a)(2); the SkyGreece NTSB Family 

Assistance Coordinator, SkyGreece’s Chief Executive Officer, Chief 

General Affairs, Chief Operations Officer or their authorized 

representatives. Any other release of manifest information is considered 

unauthorized and prohibited.

2.5.7. SkyGreece will inform family members (or family friends or clergy who 

are with the family) at an appropriate time, but as early as possible after 

being notified, that it is critical that they contact their family dentist to 

obtain the dental records and dental x-rays of their loved one. 

SkyGreece will ask the family to have the records and x-rays sent by 

special courier to the address of the hotel where the joint family support 

operations center will be located. Packages should be addressed to the 

Director, Family Support Services, and NTSB. If the family is coming to 

the site the next day, the family may arrange to hand-carry these 

documents. If the family is already at the accident site or arrives without 

making these arrangements, the Disaster Mortuary Team personnel will 

coordinate with the family’s dentist to obtain dental records and dental xrays.

2.5.8. SkyGreece will ensure that its employees and agents receive adequate 

training to meet the needs of survivors and family members following an 

accident.

3. Passenger Manifest, Ticket Reconciliation and Notification

3.1. In order to determine which passengers actually boarded the flight, SkyGreece

personnel immediately after the accident will begin a review of the following:

3.1.1. On board Passenger Manifest.

3.1.2. Standby passengers.

3.1.3. Non-revenue passengers.

3.1.4. Re-routed passengers.

3.1.5. Passengers who cancelled their reservation.

3.1.6. Jump seat riders.

This process could be delayed by persons traveling under different names.
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3.2. SkyGreece will release, upon request, to the NTSB Family Services Director a 

passenger list. This would be upon the firm understanding that the list reflects 

the best available information at the time of the request, that it may have 

inaccuracies and it may not be complete.

3.2.1. All personnel involved with handling the manifest will be briefed as to 

the confidential/sensitive nature of this information.

3.2.2. All appropriate manifest lists will be stamped “PRELIMINARY AND 

UNCONFIRMED” with date, time and list number.

3.2.3. SkyGreece will update the list periodically.

3.2.4. Upon request, SkyGreece will provide to the Department of State 

information in its possession about foreign passengers.

3.2.5. SkyGreece will coordinate as necessary with the Department of Justice 

for family meetings to explain Department of Justice services.

3.3. Notification Procedures

3.3.1. As soon as information becomes available on each passenger, that 

passenger’s family will be notified.

3.3.1.1. Notification to family members will be made prior to release of

the passenger’s name to the public and, to the extent practical, in

person.

3.3.2. SkyGreece personnel making the notification will be suitably trained as 

noted in Paragraphs 2.4, 2.5 and 2.5.8 of this document.

3.3.3. SkyGreece will secure a facility for family members that will insure 

privacy from solicitors and the media.

3.3.4. After coordination with NTSB, SkyGreece will provide a joint support 

operations center to provide logistical support to the federal staff.

3.3.5. As appropriate, SkyGreece will continually update the public on the 

progress of family notification.

3.4. Confidential/Sensitive Information

3.4.1. As stated in paragraph 2.5.7 of this document, any unauthorized release 

of manifest information is prohibited.

4. Passenger Identification

4.1. Medical Examiner/Coroner

4.1.1. The medical examiner or coroner is responsible for the positive 

identification of fatalities.
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4.1.1.1. If the victim has died, the medical examiner will coordinate 

with the Disaster Mortuary Team Commander to provide 

official notification of death to family.

4.1.1.2. For injured passengers, the hospital is responsible for status 

updates and either the hospital or SkyGreece will advise the 

families.

5. Family Access to the Accident Site.

5.1. The NTSB has accident site jurisdiction.

5.2. Within the limits established by the authorities, SkyGreece will respond to family 

requests for access to the accident scene.

5.3. SkyGreece will assist up to two members (exceptions would be made as 

individual cases and cultural differences would have to be considered) of the 

family of a passenger traveling to the location of the accident and provide for the 

physical care of the family while the family is staying at such location.

5.3.1. For purposes of this plan, “Family” shall mean legal or common law 

spouse, parents or children of the injured/deceased. If the deceased has 

no Family as defined, up to two close living relatives would be 

considered “Family.”

5.3.2. Physical care.

5.3.2.1. Transportation to and from accident city.

5.3.2.2. Transportation to and from accident site.

5.3.2.3. Hotel accommodations at accident city for a reasonable time 

period.

5.3.2.4. Meal voucher during hotel stay and day of travel to and from 

the accident city.

6. Human Remains and Personal Effects

6.1. The medical examiner is responsible for the disposition of identifiable and 

unidentifiable human remains.

6.2. SkyGreece shall work with authorities to return identifiable personal effects to 

victim’s family rather than having SkyGreece become a custodian of them; 

SkyGreece and the authorities will work together to determine disposition of 

unidentifiable personal effects.

6.3. Personal effects that come into the control of SkyGreece will be handled in the 

following manner after release from the NTSB:
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6.3.1. SkyGreece will consult with each family about the disposition of 

personal effects that are in SkyGreece’s control.

6.3.2. SkyGreece will return to the family, if requested, any passenger’s 

possession that is under the control of SkyGreece.

6.3.3. SkyGreece will retain for 18 months any unclaimed property of a 

passenger that is under SkyGreece’s control.

6.3.4. SkyGreece will consult with the families about the construction by 

SkyGreece of any planned monument, including the inscription on it.

6.3.5. SkyGreece will only be able to return personal effects that come into 

SkyGreece’s control once permission of the NTSB has been obtained as 

the items may have some bearing on the accident investigation.

7. Liability for Man-Made Structures

7.1 In accordance with the 49 U.S.C. Section 41313(c), in the event of an accident 

resulting in significant damage to man-made structures or non-governmentowned property on the ground, SkyGreece shall promptly provide written 

notification directly to the owner of liability for any property damage and the 

means for obtaining compensation. Such notice shall advise the owner: (a) to 

contact the property insurer as the authoritative source for coverage and 

compensation information; (b) to not rely on unofficial information offered by 

SkyGreece’s representatives about compensation by SkyGreece for accident-site 

property damage; and (c) to obtain detailed evidence of property damage as soon 

as possible following the accident, consistent with restrictions to the accident 

site.

8. Simultaneous Electronic Transmission of NTSB Hearings

8.1 In accordance with 49 U.S.C. Section 41313(c), in the event of an accident in 

which the NTSB conducts a public hearing or comparable proceeding at a 

location more than eighty (80) miles from the accident site, SkyGreece shall 

ensure the proceeding is made available simultaneously by electronic means at a 

location open to the public at the origin city and destination city of the 

SkyGreece flight, if that city is located in the United States.

9. Relationship with Designated Independent Organization

9.1. SkyGreece will work with the independent nonprofit organization that is 

designated under 49 U.S.C. Section 1136(a) (2) to provide mental health and 

counseling services to families.

9.1.1. Mental health services can be coordinated on a local basis through the

nonprofit organization or these services can be brought in from another 

city where the airline may have a Mental Health Professional on retainer.
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9.1.2. Should long-term counseling be required, SkyGreece will coordinate 

with the nonprofit organization appointed by the NTSB, the family and 

the company providing the service.

9.2. SkyGreece will develop a procedure to pay reasonable compensation to the 

NTSB-designated independent non-profit organization as required by 49 U.S.C. 

Section 41313(C)(11) where the nature and scope of its work and the kind of 

costs to be incurred have been discussed and agreed in advance.

9.3. SkyGreece will coordinate with family members as to their need for American 

Red Cross for assistance.

9.4. SkyGreece will participate in the daily coordination meetings to review daily 

activities, resolve problem areas, and to synchronize future family support 

operations and activities.

10. Third Party Service Provider

10.1 In order to fulfill its obligations under this Plan, SkyGreece may contract with 

third party service providers who specialize in aviation disaster response 

services. SkyGreece will work with any such third party service providers to 

carry out the responsibilities undertaken in this Plan.

11. Filing of this document with NTSB and DOT

11.1 Pursuant with the Foreign Air Carrier Family Assistance Act of 1996, 49 U.S.C. 

Section 41313(b), this document will be filed with the National Transportation 

Safety Board and the Department of Transportation.

12. Revisions and Code-Share Agreements

12.1. SkyGreece reserves the right to introduce changes to this plan from time to time.

12.2. SkyGreece does not presently have an approved code-share arrangement with 

any United States carrier. If SkyGreece were to enter into such an agreement and 

it were approved, SkyGreece may revise this plan.

13. Accidents Not Covered by this Plan

13.1 SkyGreece will consult with the NTSB and the Department of State if it 

voluntarily provides assistance to U.S. citizens in the United States with respect 

to accidents outside the United States not covered by this plan involving loss of 

life.

14. Emergency Contact Information

14.1 SkyGreece’s 24-hour, 365 days a year contact is:

Tel: +302111211010

FAX: +302299041242

Email: aoc.manager@skygreece.com
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EXHIBIT E

SUMMARY OF PASSENGER MANIFEST INFORMATION COLLECTION 

PROCEDURES

SKYGREECE AIRLINES S.A.

Introduction

This summary is submitted by SkyGreece Airlines S.A. to the U.S. Department of 

Transportation in accordance with 14 C.F.R. Part 243.

Summary of Procedures

For each covered flight segment, SkyGreece Airlines S.A. shall collect, or cause 

to be collected, the full name of each passenger who is a U.S. citizen. Any U.S. citizen 

who does not provide this information will not be permitted to board.

SkyGreece Airlines S.A. will request an emergency contact telephone number 

and name from U.S. citizen passengers. As the provision of this information is voluntary, 

SkyGreece Airlines S.A. will not deny boarding to any passenger who refuses to provide 

it.

SkyGreece Airlines S.A. shall store the information collected pursuant to the 

above procedures until passengers on the covered flight segment disembark. This 

information will be kept confidential and will not be used for purposes other than those 

described herein or disclosed to any entity except as required and permitted by law.

In the event of an aviation disaster, SkyGreece Airlines S.A. shall contact the 

Managing Director of Overseas Citizen Services, Bureau of Consular Affairs, U.S. State 

Department, by telephone. Not later than three hours after confirmation of such a disaster, 

SkyGreece Airlines S.A. shall transmit to the U.S. State Department and, upon request, 

the National Transportation Safety Board, the information collected in accordance with 

these procedures.

24 Hour Contact Information

SkyGreece Airlines S.A.’s 24-hour operations center is located in Markopoulo 

Mesogaias, Attiki, Greece. Any agent of the U.S. government may contact operations 

center personnel at any time by dialing +30211211010 or via email at 

aoc.manager@skygreece.com.
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EXHIBIT F

VERIFICATION

Pursuant to Title 18 United States Code Section 1001, I, Bill Alefantis, in my 

individual capacity and as the authorized representative of the pleader, have not in any 

manner knowingly and willfully falsified, concealed or failed to disclosed any material 

fact or made any false, fictitious, or fraudulent statement or knowingly used any 

documents which contain such statements in connection with the preparation, filing or 

prosecution of the pleading. I understand that an individual who is found to have violated 

the provisions of 18 U.S.C. Section 1001 shall be fined or imprisoned not more than five 

years, or both.

Signed:

Mr. Bill Alefantis

SkyGreece Airlines S.A. 

Title: Chief Commercial Officer

Date: March 7, 2014