BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

) Application of ) ) ALASKA AIRLINES, INC. ) Docket DOT-OST-2010- _______ ) for an exemption pursuant to 49 U.S.C. 40109 ) (San Diego-Puerto Vallarta) ) )

APPLICATION FOR EXEMPTION

Communications with respect to this document should be addressed to:

Kyle Levine, Esq. Marshall S. Sinick, Esq. Associate General Counsel, Squire, Sanders & Dempsey L.L.P. Commercial Law and Litigation 1201 Pennsylvania Avenue, N.W. Alaska Airlines, Inc. Washington, D.C. 20004 19300 International Boulevard (202) 626-6651 Seattle, Washington 98188 msinick@ssd.com
Megan Lawrence, Esq. Counsel to Alaska Airlines, Inc. Managing Director, Government Affairs and Community Relations Alaska Airlines, Inc. 19300 International Boulevard Seattle, Washington 98188

DATED: April 21, 2010BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

) Application of ) ) ALASKA AIRLINES, INC. ) Docket DOT-OST-2010- _______ ) for an exemption pursuant to 49 U.S.C. 40109 ) (San Diego-Puerto Vallarta) ) )

APPLICATION FOR EXEMPTION

Pursuant to 49 U.S.C. 4 0109, 14 C.F.R. 302 and th e Economic and Procedural
Regulations of the Department of Transportati on (the “Department”), Alaska Airlines, Inc.
(“Alaska”) hereby requests an exemption from 49 U.S.C. 41101 a nd, to the extent
necessary, from the Department’s regulations to permit Alaska to engage in the scheduled
seasonal foreign air transportation of pers ons, property and mail between San Diego,

California, and Puerto Va llarta, Mexico. Alaska requests that this ex emption be granted for
at least a two-year period. Alaska intends to begin seasonal service on this route on
November 12, 2010, and requests prompt approv al so that marketing and selling can begin
without delay.
In further support of its exemption request, Alas ka states as follows:
1. Alaska’s principal headquarter s are located at 19300 International
Boulevard, Seattle, Washington. Alaska is in corporated under the laws of the State ofApplication of Alaska Airlines, Inc. Docket DOT-OST-2010-____ April 21, 2010

2 Alaska and is a wholly-owned subsidiary of Alaska Air Group, Inc. (“AAG”). AAG is
incorporated under the laws of the State of Delaware.

2. Alaska is a citizen of the United St ates within the meaning of 49 U.S.C.
40102(a)(15). The president and at least two- thirds of Alaska’s directors and other
managing officers are U.S. citizens. Additionally, to Alaska’s knowledge, U.S. citizens
hold at least seventy-five per cent of Alaska’s voting stock.
3. Alaska has repeatedly been found fit, willing and able to provide interstate
and foreign air transportation. The Department is requested to take official notice of
Alaska’s continuing fitness. See, e.g ., Order 00-5-31.
4. Alaska will operate seasonal serv ice between San Diego and Puerto
Vallarta beginning November 12, 2010. Service is expected to continue until mid-April
2011, and will resume for each winter/spring seas on thereafter. Initial plans call for the
operation of daily roundtrip flights utilizing B737-400 airc raft. Alaska’s proposed

schedule is attached to this application as Exhibit A.
5. On December 12, 2005, the United States and Mexico signed an
amendment to the Air Transport Agreement of August 15, 1960, broadening air transport
services between the two countries and perm itting designated U.S. carriers to operate
from “a point or points in the United States to a point or points in Mexico.” 1

Additionally, the December 2005 agreement permits the United States to designate up to

three carriers to serve Puerto Vallarta from any U.S. point. The route covered by this
application is clearly within the scope of th e amendments to the Air Transport Agreement

1 Annex I(A)1(a)Application of Alaska Airlines, Inc. Docket DOT-OST-2010-____ April 21, 2010

3 and Alaska believes sufficient designations ar e available for its proposed service. All
public interest considerations are therefore satisfied.
6. Alaska submits that its applicatio n raises no environmental or energy
issues. Alaska’s flights will be operated with aircraft that meet all applicable noise
abatement requirements. Nor will approval of this application result in an increase in fuel
consumption of ten million gallons or more.

WHEREFORE , Alaska Airlines, Inc. respectfully requests that the Department
of Transportation grant Alaska exemption au thority for two years to operate seasonal
scheduled service in foreign ai r transportation as more fully described herein, or such
other relief as the Department deems necessary and appropriate.
Respectfully submitted,

____________________________ Marshall S. Sinick, Esq. Squire, Sanders & Dempsey L.L.P. 1201 Pennsylvania Avenue, NW Washington, D.C. 20004 Phone: (202) 626-6651 Msinick@ssd.com

Counsel to Alaska Airlines, Inc.
DATED: April 21, 2010Exhibit A

Alaska Airlines, Inc.
Proposed Seasonal Schedule

Dep Arr Type Seats Days of Operation Effective Fuel (gal) SAN-PVR 1015 1455 737-400 144 Daily 11/12/2010 1,800 PVR-SAN 1540 1635 737-400 144 Daily 11/12/2010 2,300CERTIFICATE OF SERVICE

I hereby certify that one copy of the fore going Application for Exemption has this day been served on each of the following individuals via e-mail.

________________________ Marshall S. Sinick, Esq.
DATED: April 21, 2010

hkamen@coair.com ; dan.weiss@coair.com sascha.vanderbellen@delta.com ; sametta.c.barnett@delta.com ; jeff.morgan@delta.com jeffrey.manley@united.com anbird@fedex.com dvaughan@kelleydrye.com ; dfisher@kelleydrye.com efaberman@wrf.com howard_kass@usairways.com dkirstein@yklaw.com jhill@dowlohnes.com mlbenge@zsrlaw.com pmurphy@lopmurphy.com carl.nelson@aa.com brian.gillman@mesa-air.com Linda.lundell@dot.gov esta.rosenberg@dot.gov brian.hedberg@dot.gov