BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

United Parcel Service Co. 

For the Allocation of Two Hong Kong-Dubai 

Fifth-Freedom Frequencies 

Docket OST-2010 . <9/^3 

APPLICATION OF UNITED PARCEL SERVICE CO. 

Communications with respect to this document should be served upon: 

Dontai L. Smalls 

United Parcel Service 

Public Affairs 

316 Pennsylvania Avenue, S.E. 

Washington, D.C. 20003 

E-mail: dsmalls@ups.com 

Scott C. Casey 

Michael J. Francesconi 

United Parcel Service Co. 

1400 N. Hurstboume Parkway 

Louisville, KY 40223 

E-mail: scasey@ups.com 

mfrancesconi@ups. com 

Date: June 1,2010 

David L. Vaughan 

Danielle K. Fisher 

Kelley Drye & Warren LLP 

3050 K Street, N.W., Suite 400 

Washington, D.C. 20007 

(202) 342-8462 

Fax: (202)342-8451 

E-mail: dvaughan@kelleydrye.com 

dfisher@kelleydrye.com 

Attorneys for 

United Parcel Service Co. 

NOTE: Any person wishing to support or oppose this Application must file an answer 

with the DOT'S Documentary Services Division by June 16, 2010. A copy of 

such Answer must be served upon United Parcel Service Co. and its counsel and 

all persons named on the attached Service List. Nevertheless, UPS will poll all 

persons on the service list for an immediate response. 
BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

United Parcel Service Co. 

For the Allocation of Two Hong Kong-Dubai 

Fifth-Freedom Frequencies 

Docket OST-2010-

APPLICATION OF UNITED PARCEL SERVICE CO. 

Pursuant to Part 302, Subpart C of the Department's Rules of Practice and 

the October 19, 2002 Memorandum of Understanding between the United States and 

Hong Kong (the "MOU"), United Parcel Service Co. ("UPS") hereby applies for two (2) 

weekly Hong Kong-Dubai fifth-freedom all-cargo frequencies. 

In support of this Application UPS respectfiilly states as follows: 

1. The proposed service is authorized by the bilateral agreement 

between Hong Kong and the United States. Frequencies are available from the pool of 64 

fifth-freedom all-cargo frequencies. The requested Hong Kong-Dubai frequencies are 

available after Kalitta Air, L.L.C. exchanged two Hong Kong-Dubai fifth-freedom 

frequencies for two Hong Kong-Bahrain fifth-freedom frequencies. 

2. UPS proposes to operate the frequencies with a 747-400 freighter 

aircraft that is currently in UPS's fleet. In fact, UPS already operates the flights between 

Hong Kong and Dubai on a blind sector basis. The grant of this Application will enable 

See Notice of Action Taken, OST-2002-14049 (May 28, 2010). 
Application of UPS 

OST-2010-

Page 2 of4 

UPS to "open the door" of this aircraft at Dubai. UPS could initiate service immediately, 

without any costs or network disruption, and provide more shippers and businesses in the 

Dubai-Hong Kong market with the benefits of UPS's wide spectrum of cargo products. 

The public interest supports the award of the additional requested frequency to UPS. 

With the requested authority, UPS will further enhance its worldwide express and general 

air freight network services, benefiting global shippers, businesses and the U.S. economy. 

3. UPS is prepared to begin the proposed fifth-freedom services as 

requested and will operate the services year-round once the award is received. UPS 

requests that the authority granted pursuant to this Application be unlimited in its 

duration. 

4. UPS is a citizen of the United States as that term is defined in the 

Federal Aviation Act. UPS is a Delaware corporation whose mailing address is 1400 

North Hurstbome Parkway, Louisville, Kentucky 40223. All officers, directors, 

shareholders of UPS, persons who have the power to influence the management of the 

applicant, or persons holding any voting interest in the applicant are U.S. citizens. 

5. UPS holds various certificates of public convenience and necessity 

issued by the Department authorizing UPS to engage in all-cargo air transportation. UPS 

possesses the underlying route authority, including route integration authority, to serve 

the route proposed in this Application.^ UPS does not propose to operate the requested 

frequency under a code share or other cooperative service arrangement. 

See Order 2002-7-31, Order 2006-1-1 and Order 2007-7-4. 
Application of UPS 

OST-2010-

Page 3 of4 

6. UPS is fit, willing and able to provide the proposed service and to 

conform to the provisions of the Federal Aviation Act and the rules, regulations and 

requirements of the Department thereunder. UPS requests that the Department take 

official notice, pursuant to 14 C.F.R. 302.24 of the economic authorities and data on file 

that support UPS's fitness. 

7. The grant of this Application will not constitute a "major" 

regulatory action under the Energy, Policy and Conservation Act of 1975, as defined by 

Section 313.4(a)(1) of the Department's regulations. The grant of this Application will 

result in an increase in fuel consumption of less than 10 million gallons. UPS has 

adequate fuel available for the services proposed. 
Application of UPS 

OST-2010-

Page 4 of4 

WHEREFORE, United Parcel Service Co. respectfully requests the Department of 

Transportation to grant it the additional Hong Kong fifth-freedom frequencies requested 

herein and to grant such additional or other relief as the Department may deem necessary 

or appropriate. 

Respectftilly submitted, 

David L. Vaughan 

Danielle K. Fisher 

Kelley Drye & Warren LLP 

3050 K Street, N.W., Suite 400 

Washington, D.C. 20007 

(202) 342-8462 

Fax: (202)342-8451 

Date: June 1,2010 
CERTIFICATE OF SERVICE 

I hereby certify that I have this day served the foregoing document by electronic 

mail to all persons in this proceeding. 

Name 

John L. Richardson 

Russell E. Pommer 

Sametta Bamett 

Sascha Van der Bellen 

Jeff Morgan 

Edward W. Sauer 

C. Blair Berselli 

G. Bailey Leopard 

Tim Brown 

Moffett Roller 

Mark W. Atwood 

Kevin Montgomery 

Pierre Murphy 

Malcolm L. Benge 

Representing 

Amerijet 

Atlas 

Delta 

Evergreen 

FedEx 

Gemini Air Cargo 

Kalitta Air 

Polar 

Trade Winds 

Airlines, Inc. and 

Arrow Air, Inc. 

World Airways 

^//yuU^ P^— 

E-mail 

jrichardson@johnlrichardson.com 

rpommer@atlasair.com 

Sametta.C.Bamett@delta.com 

sascha.vanderbellen@delta.com 

jeff.morgan@delta.com 

esauer@ssd.com 

blair.berselli@evergreenairlines.com 

gbleopard@fedex. com 

tbro wn@geminiairway s .com 

mroller@rollerbauer.com 

matwood@sherblackwell.com 

kevin.montgomery@polaraircargo.com 

pmurphy@lopmurphy.com 

mlbenge@zsrlaw.com