BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

UNITED PARCEL SERVICE CO. 

for an amended Certificate of Public 

Convenience and Necessity, an 

Exemption, and a designation under 

the U.S.-Mexico Air Service 

Agreement 

Dockets OST -2011-0076 

OST -1999-6663 

APPLICATION OF UNITED PARCEL SERVICE CO. 

Communications with respect to this document should be sent to: 

Donta; L. Smalls 

United Parcel Service Co. 

Public Affairs 

316 Pennsylvania Avenue, S.E. 

Washinglon. DC 20003 

dsmalls@ups.com 

Emily Johnson 

United Parcel Service Co. 

1400 N. Hurstboume Parkway 

Louisville, KY 40223 

emilyjohnson@uPs.com 

Dated: February 2. 2015 

Anita M. Masner 

Jennifer M. Nowak 

HOLLAND & KNIGHT LLP 

800 1ih Street, N.W., Suite 1100 

Washinglon, D.C. 20006 

Phone: (202) 419-2604 

Fax: (202) 955-5564 

anita.mosner@hklaw.com 

Atlorneys for UNITED PARCEL SERVICE 

CO. 

NOTICE: United Parcel Service Co. will poll carrier representatives served with 

this application. 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

UNITED PARCEL SERVICE CO. 

for an amended Certificate of Public 

Convenience and Necessity, an 

Exemption, and a designation under 

the U.S.-Mexico Air Service 

Agreement 

Dockets OST-2011-0076 

OST -1999-6663 

APPLICATION OF UNITED PARCEL SERVICE CO. 

Pursuanl to 49 U.S.C. §§ 40109 and 41101, and Part 302 of the Rules of 

Practice of the Department, United Parcel Service Co. ("UPS") hereby applies for an 

amendment of its U.S.-Mexico Certificate of Public Convenience and Necessity and a 

related Exemption, as well as a designation under the U.S.-Mexico Air Transport 

Agreement ("U.S.-Mexico Agreement"),1 authorizing it to provide scheduled foreign air 

transportation of property and mail between Houston, Texas (IAH) and Monterrey, 

Mexico (MTY). 

UPS wishes to launch this service in the near future, and is accordingly seeking 

expedited relief from the Department. UPS will poll all interested carriers served with 

this Application. 

In support of this Application, UPS submits the following : 

1. 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 

j U.S.-Mexico Air Transport Services Agreement of August 15, 1960, as amended and expanded. 
Application of United Parcel Service Co. 

U.S.-Mexico Authority (IAH-MTY) 

Hurstborne 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. 

2. UPS holds various Certificates of Public Convenience and Necessity 

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

Order No. 2002-7-31 (July 25, 2002), Order No. 2001-1-6 (January 10, 2001); Order No. 

98-6-22 (June 25, 1998). As such, DOT has determined on numerous occasions that 

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' 

fitness. 

3. UPS currently holds authority to operate scheduled all-cargo service 

between the U.S. and Mexico pursuant to its Certificate of Public Convenience and 

Necessity for Route 569, which was first issued in 1989, and was most recently renewed 

in 2013.

2 UPS requests that the Department amend this Certificate to include authority 

to operate scheduled foreign air transportation of property and mail between IAH and 

MTy.3 As UPS intends to commence service on this routing in the very nearfuture, UPS 

also requests exemption authority pursuant to the Department's streamlined licensing 

2 See Order 89-9-36 (Sep. 15, 1989), most recently renewed by DOT Order 201 3-7-7 (May 8, 

2013). UPS also holds exemption authority to operate between los Angeles (lAX) and 

Guadalajara (GDl). See Notice of Action Taken, Docket No. OST-2000-7282 (May 1, 2013). 

3 UPS asks that the Department align the expiration date of the added route with the balance of 

the Certificate, which is set to expire on July 8, 2018. 
Application of United Parcel Service, Co. 

U.S.-Mexico Authority (IAH-MTY) 

procedures, in order to commence this service while the Department considers its 

Certificate amendment request. 4 

4. UPS proposes to operate year round service with 4 weekly fl ights 

between IAH and MTY, using an A300 aircraft with a payload capacity of 118,000 

pounds that is currently in UPS' fleet. UPS wishes to commence the services 

described herein on or before May 26, 2015, and therefore requests expedited approval 

of this Application. 

5. The requested authority is fully consistent with the terms of the U.S.-

Mexico Agreement. While the U.S.-Mexico Agreement currently limits the number of 

available scheduled all-cargo designations, UPS understands that no U.S. all-cargo 

carrier is currently designated to operate between Houston and Monterrey, and that this 

designation is available. UPS requests that the Department promptly designate UPS to 

provide service on this route. 

6. Granting UPS amended certificate and exemption authority and a 

designation to operate between Houston and Monterrey is clearly in the public interest. 

Approval will maximize the rights granted under the U.S.-Mexico Agreement and provide 

additional competitive options for shipping services between the U.S. and Mexico, which 

will benefit U.S. shippers. 

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. 

4 See In the Matter of Streamlining Regulatory Procedures for Licensing U.S. and Foreign 

Carriers, Docket No. OST-2005-22228 (Aug. 26, 2005). 
Application of United Parcel Service, Co. 

U.S.-Mexico Authority (IAH-MTY) 

8. UPS agrees to accept and comply with all terms and conditions the 

Department routinely attaches to exemption and certificate authority for scheduled 

foreign air transportation. 

9. UPS asks that the exemption authority requested be made effective 

immediately and remain in effect for two years, or until the Department grants the 

requested amended certificate authority. 

WHEREFORE, UPS respectfully requests that the Department grant UPS the 

amended certificate authority, exemption authority, and designation requested herein, and 

grant such other further relief as the Department may deem necessary. 

Anita M. Mosner 

Jennifer M. Nowak 

Holland & Knight LLP 

Attorneys for United Parcel Service Co. 
CERTIFICATE OF SERVICE 

I hereby certify that I have this date served the foregoing application on the persons 

identified below by causing a copy to be sent by electronic mail. 

howard.kass@aa.com 

robert.wirick@aa.com 

dan.weiss@united.com 

steve.morrissey@uniled.com 

nssparks@fedex.com 

gbleopard@fedex.com 

jrichardson@johnlrichardson.com (Counsel for Amerijet) 

jcanny@amerijet.com 

jhill@cooley.com (Counsel for Hawaiian and JetBlue) 

perkmann@cooley.com (Counsel for Hawaiian and JetBlue) 

joh n. fred ericksen@suncounlry.com 

thomas.ting@suncQunlry.com 

robert.kneisley@wnco.com 

lesJie.abbott@wnco.com 

rnatwood@cQzen.com (Counsel for Frontier) 

slachter@cQzen.com (Counsel for Frontier) 

jyoung@yklaw.com (Counsel for Spirit) 

dkirslein@yklaw.com (Counsel for Spirit) 

dheffernan@cozen.com (Counsel for Alaska) 

Jeremy.ross@alaskaair.com 

rSilverberg@sgbdc.com (Counsel for ABX) 

Ba rba ra. russell@virginamerica.com 

John.varley@virginamerica.com 

rpommer@atiasair.com 

brett.kruger@dot.com 

joh n. s. duncan@faa.gov 

cristinasa@state.gov 

LC;:; , ,-----~ - ~ 

Peter Ormerod 

February 2, 2015