BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.
Application of EXPRESSJET AIRLINES, INC. Docket DOT-OST-2013
-0115 for renewal of an exemption under 49 U.S.C . § 40109 (Atlanta
-Leon/Guanajuato, Mexico)

APPLICATION OF EXPRESSJET AIRLINES, INC. FOR RENEWAL Communications with respect to this document should be sent to: Jon Lindlief Director
- Planning and Development EXPRESSJET AIRLINES , INC. 990 Toffie Terrace Atlanta, GA 30354

April20, 2015 Gerald F. Murphy Steven J. Seiden CROWELL & MORING LLP 1001 Pennsylvania Avenue, NW Washington, DC 20004
-2595 (202) 624-2500 

### gm u mbv@crQ_yyeli, Q.Q_l]1 Bseiden(a)croy,rell ,com Counsel for ExpressJet Airlines, Inc.BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C . Application of EXPRESSJET AIRLINES, INC. for renewal of an exemption under 49 U.S.C . § 40109 (Atlanta-Leon/Guanajuato, Mexico) Docket DOT-OST-2013-0115

APPLICATION OF EXPRESSJET AIRLINES, INC. FOR RENEWAL ExpressJet 1 applies, pursuant to 49 U.S.C. § 40109 and Subpart C of the Department's Rules ofPractice, for renewal of its exemption from 49 U.S.C. § 41101 authorizing ExpressJet to provide scheduled foreign air transportation of persons , property and mail between Atlanta, Georgia and Leon/Guanajuato, Mexico. ExpressJet requests that its exemption be renewed for a period of at least two years. ExpressJet states as follows in support ofits application: 1. ExpressJet's Atlanta-Leon/Guanajuato exemption authority was granted by Notice of Action Taken dated June 19, 2013 in this docket. Absent renewal, ExpressJet's authority will expire on June 19 , 2015. Express]et requests that its exemption authority be renewed for a period of at least two years.

Common names are used for airlines.

### Renewal Application ofExpressJet Page 2 2. Renewal of this exemption authority is clearly in the public interest as it will permit ExpressJet to continue operating year-round Atlanta-Leon/Guanajuato scheduled service
as a Delta Connection carrier with CRJ-900 or CRJ-700 aircraft. Granting this renewal application will also enable ExpressJet to continue providing substantial consumer benefits by maintaining existing service options for the U.S. traveling public, including the online connections offered between points on Delta's network via Atlanta. Renewal of ExpressJet's exemption authority is fully consistent with the terms of the U.S.-Mexico bilateral aviation agreement, as amended. 3. Expn!ssJet remains fit, willing and able to perform the Atlanta-Leon/Guanajuato services applied for herein. ExpressJet is a well-established regional carrier and holds various certificate and exemption authorities permitting it to engage in scheduled interstate and foreign air transportation of persons, property and mail? ExpressJet requests that the Department, pursuant to Rule 24 of its Rules of Practice, take official notice of all information and data that have been filed to establish its fitness. 4. ExpressJet invokes the automatic extension provisions of 5 U.S .C . § 

### 558(c), as implemented by Pati 377 of the Department's Special Regulations, to continue this authority in effect pending action on this application. WHEREFORE, ExpressJet asks the Department to renew its exemption from 49 U.S .C . § 411 01 authorizing Express]

### et to provide scheduled foreign air transportation of persons , property and mail between Atlanta, Georgia and Leon/Guanajuato, Mexico.

2 See, e.g., 

### Order 2012-1-3 at 1-2 (listing ExpressJet's certificate, exemption, and other operating authorities) and Notices of Action Taken dated Mar. 17, 2015 in Docket DOT
-OST2006-24591 (U .S.-Dominican Republic), Feb. 17, 2015 in Docket DOT
-OST-2011-0889 (Atlanta-Monterrey) and Jan. 20,2015 in Docket DOT-OST-2006-25018 (U.S.-Belize).Renewal Application ofExpressJet Page 3

April20, 2015 Respectfully submitted, CROWELL & MORING LLP
Gerald F. Murphy Steven J . Seiden gmUJ}1hy@crowel l.com sseiden@crowcll.com Counsel for ExpressJet Airlines, Inc.CERTIFICATE OF SERVICE
I certify that I have this date served the foregoing document on the following persons in accordance with the Department's Rules ofPractice : bob.kneislev({V,wnco.com leslie.abbott(d;,wnco.com clheffernan(a),cozen.com jeremy.rossl@alaskaair.com robert.wirick@aa.com howard.kass(a{aa.com pmurphy@lopmurphy.com jhill@cooley.com pcrkmann(a{coo 

### Iey.com sascha.vanderbellenr7vdelta.com

**sametta.c.b(l~~delta.com**

**jyoung(il{vkla_~.com** dkirstein@vklaw.com

April20, 2015 robert.cohn({V,hoganlovells.com patrick.rizzi(ii!,hoganlovells.com dan.weiss @ united.com steve.monissey(c_/)united.com j ohn.fredericksen@suncountrv.com thomas.

**ting(a~sw1country** .com matwoocl(c!)cozen.com

**anita.mosncr(a),hklaw.~om** jennitcr.nowak(cV,hklaw.com barbara.russell(l1!,virginamerica.com john.varley(i!>virginamerica.com john.s.duncan@faa.gov englets({i)state. gov

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