BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

FRONTIER AIRLINES, INC. 

for an exemption under 49 U.S.C. § 40109 

) 

) 

) 

) Docket DOT-OST-2012-__ _ 

) 

) 

) 

(Pittsburgh, PA/Cincinnati, OH- Cancun, Mexico; ) 

~C~h~ic~a~g~o~·~IL~/S~t~·~Lo~u~is~·~M~O~-~H~u~a~t~ul~c~o,~M~ex~ic~o~) ______ ) 

APPLICATION OF FRONTIER AIRLINES, INC. FOR EXEMPTION 

Communications with respect to this document should be addressed to: 

Daniel Shurz 

Vice President, Planning and Strategy 

FRONTIER AIRLINES, INC. 

Frontier Center One 

7001 Tower Road 

Denver, CO 80249 

February 21, 2012 

Robert E. Cohn 

Patrick R. Rizzi 

HOGAN LOVELLS US LLP 

Columbia Square 

555 Thirteenth Street, NW 

Washington, DC 20004 

+1 202 637 4999/5659 

robert.cohn@hoganlovells.com 

patrick. rizzi@hoganlovells. com 

Counsel for 

FRONTIER AIRLINES, INC. 

NOTE: Frontier will be polling on this Application and will provide the results of 

that polling to the Department as soon as it is completed. 

\\DC- 036787/000001-3351566 vl 
Application of 

BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

) 

) 

) 

FRONTIER AIRLINES, INC. ) Docket DOT-OST-2012-__ _ 

for an exemption under 49 U.S.C. § 40109 

) 

) February 21, 2012 

) 

(Pittsburgh, PA I Cincinnati, OH- Cancun, Mexico; ) 

_C_h_ic_a_..g_o,_, I_L_/_S_t._L_o_u_is-'-, _M_O_-_H_u_at_u_lc_o,_, M_e_x_ic_o_.L.) __ ) 

APPLICATION OF FRONTIER AIRLINES, INC. FOR EXEMPTION 

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

Frontier Airlines, Inc. ("Frontier") hereby applies under 49 U.S.C. § 40109 for an 

exemption and related designations authorizing it to engage in scheduled foreign 

air transportation of persons, property, and mail, on the following U.S.-Mexico 

routes: 

(i) Cincinnati, Ohio- Cancun, Mexico; 

(ii) Pittsburgh, Pennsylvania- Cancun, Mexico; 

(iii) Chicago (O'Hare), Illinois- Huatulco, Mexico; and 

(iv) St. Louis, Missouri - Huatulco, Mexico. 

Frontier requests expedited approval of this Application for an initial term of two 

years. Frontier will poll on this Application and report the polling results to the 

Department as soon as possible. 

In support of this Application, Frontier states as follows: 

1. Frontier holds a certificate of public convenience and necessity 

authorizing it to engage in scheduled foreign air transportation of persons, 

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Application of Frontier Airlines, Inc. 

Page 2 

property, and mail on certain U.S.-Mexico routes. See DOT Order 2011-6-12 

(Route 904); 1 see also, SUL_, Notice of Action Taken, dated December 9, 2011 

(Docket DOT-OST-2011-0214) (Chicago - Puerto Vallarta and Chicago - San 

Jose del Cabo exemption authority). Frontier's scheduled services are provided 

using a fleet of Airbus A-318, A-319, and A-320 aircraft. 

2. Cincinnati-Cancun. Frontier plans to operate Saturday service 

between Cincinnati and Cancun on a year-round basis2 using 138-seat A-319 

aircraft and 162-seat A-320 aircraft. Frontier intends to operate this as a singleplane CLE-CVG-CUN service between mid-August and early December, and 

thus the benefits of this service will extend not only to the Cincinnati catchment 

area, but also to the Cleveland metropolitan region. Frontier plans to commence 

this service on or about April 7, 2012, or earlier if it receives the requisite DOT 

and Mexico government approvals sooner. 

3. Pittsburgh-Cancun. Frontier plans to operate twice weekly 

service between Pittsburgh and Cancun on a seasonal basis using 162-seat 

A-320 aircraft. Frontier intends to operate this as a single-plane CLE-PIT-CUN 

service, and thus the benefits of this service will extend not only to the Pittsburgh 

catchment area, but also to the Cleveland metropolitan region. Frontier plans to 

The routes are: Denver-Cancun, Denver-Cozumel, Denver-lxtapa/Zihuatanejo, Denver-Mazatlan, 

Denver-Puerto Vallarta, Denver-San Jose del Cabo, lndianapolis-Cancun, Kansas City-Cancun, Kansas 

City-Puerto Vallarta, Kansas City-San Jose del Cabo, Milwaukee-Cancun, St. Louis-Cancun, St. LouisPuerto Vallarta, and Salt Lake City-Cancun. 

2 Frontier intends to operate this service continuously year-round except during the brief off-peak 

shoulder period around the month of May. 

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Application of Frontier Airlines, Inc. 

Page 3 

commence this service on or about May 3, 2012, or earlier if it receives the 

requisite DOT and Mexico government approvals sooner. 

4. Chicago (O'Hare) - Huatulco. Frontier plans to operate a weekly 

nonstop service between Chicago (O'Hare) and Huatulco on a seasonal basis 

using 138-seat seat A-319 aircraft beginning on or about December 17,2012. 

5. St. Louis-Huatulco. Frontier plans to operate a weekly seasonal 

nonstop service between St. Louis and Huatulco using 168-seat A-320 aircraft 

beginning on or about May 25, 2012. Frontier intends to operate this as a singleplane ORD-STL-HUX service. 

6. Frontier is fully qualified to perform the proposed services, which 

are similar in length and type to Frontier's other U.S.-Mexico services. Frontier 

requests that the Department take official notice, pursuant to Rule 24 of the 

Department's Rules of Practice, of all other data on file with the Department 

necessary to establish its fitness. 

7. Frontier's proposed services are fully consistent with the Air 

Transport Agreement between the United States and Mexico. Three carriers of 

each country may be designated to provide scheduled nonstop combination 

service between any given U.S. gateway and Cancun and Huatulco. See 

United States-Mexico Air Transport Agreement, Annex 1(8)(5), as amended. 

Based on information and belief, unused U.S. airline designations are available 

for Frontier's Cincinnati-Cancun, Pittsburgh-Cancun, Chicago-Huatulco, and St. 

Louis-Huatulco services. 

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Application of Frontier Airlines, Inc. 

Page4 

8. Grant of this Application is in the public interest. The proposed 

services will benefit consumers by enabling Frontier to enhance competitive 

service offerings to Mexico and by expanding Mexico service from Cincinnati, 

Pittsburgh, Chicago, and St. Louis, their respective catchment areas, and the 

Cleveland metropolitan region. 

9. The environmental impacts of Frontier's proposed aircraft 

operations on these routes are de minimis, and Frontier does not anticipate that 

the roundtrip CVG-CUN, PIT-CUN, ORD-HUX, and STL-HUX flights 

contemplated herein will cause a near-term net annual change in aircraft fuel 

consumption of 10 million gallons or more. Frontier anticipates that it will have 

no difficulty obtaining adequate supplies of fuel for these services. 

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Application of Frontier Airlines, Inc. 

Page 5 

WHEREFORE, Frontier respectfully requests that the Department 

promptly grant Frontier exemption authority and designations authorizing it to 

engage in scheduled foreign air transportation of persons, property, and mail 

(A) between Cincinnati, Ohio, and Pittsburgh, Pennsylvania, on the one hand, 

and Cancun, Mexico, on the other hand, and (B) between Chicago (O'Hare), 

Illinois, and St. Louis, Missouri, on the one hand, and Huatulco, Mexico, on the 

other hand. 

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Respectfully submitted, 

Robert E. Cohn 

Patrick R. Rizzi 

HOGAN LOVELLS US LLP 

555 Thirteenth Street, NW 

Washington, DC 20004 

+1 202 637 4999/5659 

Counsel for 

FRONTIER AIRLINES, INC. 
CERTIFICATE OF SERVICE 

I hereby certify that a copy of the foregoing Application of Frontier Airlines, Inc. for an 

Exemption has been served this 21 51 day of February 2012, upon each of the following 

addressees: 

bob. kneisley@wnco. com; msinick@ssd. com; carl. nelson@aa .com; 

sascha.vanderbellen@delta.com; jeff.morgan@delta.com; jhill@dowlohnes.com; 

jyoung@yklaw. com; dkirstein@yklaw. com; john. fredericksen@suncountry. com; 

dan. weiss@united. com; howard_kass@usairways. com; pmurphy@lopmurphy. com; 

barbara.russell@virginamerica.com; brian.hedberg@dot.gov; esta.rosenberg@dot.gov; 

brett. kruger@dot. gov; urskr@state. gov; info@airlineinfo. com 

Patrick Rizzi 

\\DC· 036787/0DODOI · 3351566 v3