BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________ ) Application of ) ) CENTURION AIR CARGO, INC. ) ) DOCKET OST-2013- for scheduled, all-cargo exemption authority ) (Los Angeles/Miami- ) Mexico City/Guadalajara) ) __________________________________________)

EXPEDITED ACTION REQUESTED APPLICATION OF CENTURION AIR CARGO, INC.

FOR AN EXEMPTION

Communications with respect to this document should be sent to: John R. Mietus, Jr. Law Office of John Mietus, LLC 6701 Democracy Blvd., Suite 300 Bethesda, MD 20817- 7500 (202) 747-5212 (240) 396-5362 fax john@mietuslaw.com Counsel for CENTURION AIR CARGO, INC.

NOTICE: Any person may support or oppose this application by filing an

answer and serving a copy of the answer on counsel for Centurion and upon persons served with this application no later than May 29, 2013. However, Centurion requests expedited treatment and Department action as soon as possible; it will poll the U.S. carriers shown on the attached service list and inform the Department of the polling results.

May 14, 2013BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________ ) Application of ) ) CENTURION AIR CARGO, INC. ) ) DOCKET OST-2013- for scheduled, all-cargo exemption authority ) May 14, 2013 (Los Angeles/Miami- ) Mexico City/Guadalajara) ) __________________________________________)

EXPEDITED ACTION REQUESTED APPLICATION OF CENTURION AIR CARGO, INC.

FOR AN EXEMPTION

Pursuant to 49 U.S.C. § 40109 and Subpart C of the Department’s

Rules of Practice , Centurion Air Cargo, Inc. (“Centurion”) respectfully requests an exemption from the provisions of 49 U.S.C. § 41101 and the Department’s rules to the extent necessary to permit Centurion to provide scheduled foreign air transportation of property and mail between Los Angeles, California and Miami, Florida, on the one hand, and Mexico City (Benito Juarez International Airport) and Guadalajara, Mexico, on the other, for an initial period of two years. Centurion also requests authority to integrate this authority with its existing exemption and certificate authority. Centurion further requests that the U.S. government designate Centurion under the U.S.-Mexico Air Transport Agreement, as amended, to provide the scheduled, all-cargo service described above. Centurion requests that the- 2 - Centurion Application Department act on an expedited basis, and it will poll U.S. carriers served with this application and report the results as soon as possible. In support of this application , Centurion states as follows: 1. Centurion is an air carrier of property and mail headquartered at Miami International Airport in Miami, Florida. It is a U.S. citizen within the meaning of 49 U.S.C. § 40102(a)(5) and holds two certificates of public

co nvenience and necessity: one authorizing domestic all-cargo transportation (and worldwide charter service) and a second with blanket, all-cargo, open skies authority; Centurion also holds scheduled exemption authority to serve China and several Latin American countries. Centurion provides extensive

scheduled and charter service in a number of international markets with MD11 freighter aircraft. Information officially noticeable under Rule 24(g) of the Department’s Procedural Regulations supports Centurion’s continued fitness.

2. Centurion has operated freighter services, both scheduled and charter, between the United States and Mexico during several periods in its history. Centurion understands that only three U.S. all-cargo carriers

– Amerijet, ABX, and UPS

– currently operate scheduled, all-cargo service between the U.S. and Mexico City (Benito Juarez), while five U.S. carriers may do so under the Agreement. It also understands that at least one designation is available to U.S. all-cargo carriers in each of the four city-pair

markets at issue.- 3 - Centurion Application

3

. Centurion wishes to commence U.S.-Mexico City scheduled service , operating MD-11 freighter aircraft already in its fleet, initially operating on Thursdays and Sundays between Miami and Mexico City, then expanding within a few months to the following, twice-weekly operation:

arrive depart

Miami 0500 Mexico City 0830 1030 Los Angeles 1400 2200 Guadalajara 0100+1 0300+1 Mexico City 0400+1 0700+1 Miami 1030+1 As appropriate to meet demand, Centurion may alter this linear operation, for example by operating directly between Guadalajara and Miami. Centurion intends to commence the service described above upon receipt of authority from the Department and the Mexican government; while it intends to operate the service on a year-round basis, it may reduce its operations during periods of low demand. As the proposed operations will not result in a net annual increase in fuel consumption of 10 million gallons or

more , g rant of the application will not constitute a major regulatory action under Part 313 of the Department’s regulations and the Energy Policy and

Conservation Act of 1975. 4. Grant of the requested authority is in the public interest. U.S. carrier designations are available under the Agreement for the four city-pair markets at issue. Expanding the number of U.S. all-cargo carriers serving