for renewal of an exemption pursuant to 

) Docket DOT-OST-2010-0299 

) 

49 U.S.C. § 40109 (People's Republic of ChinaCNMI/Guam scheduled service and PRC-U.S. charters) ) ) 

APPLICATION OF SICHUAN AIRLINES CO., L TO. 

FOR RENEWAL OF AN EXEMPTION 

Communications with respect to this document should be addressed to: 

April 27, 2015 

\\DC- 038020/000001 - 6535033 vi 

George U. Carneal 

HOGAN LOVELLS US LLP 

Columbia Square 

555 Thirteenth Street, NW 

Washington, DC 20004 

Telephone: +1 202 637 6546 

Facsimile: +1 202 637 5910 

E-mail: george. carneal@hoganlovells. com 

Counsel for 

SICHUAN AIRLINES CO., L TO. 
for renewal of an exemption pursuant to 

49 U.S.C. § 40109 (People's Republic of ChinaCNMI/Guam scheduled service and PRC-U.S. charters) 

April 27, 2015 

) 

) ) 

APPLICATION OF SICHUAN AIRLINES CO., LTD. 

FOR RENEWAL OF AN EXEMPTION 

Sichuan Airlines Co., Ltd. ("SCAL") hereby applies under 49 U.S. C.§ 40109 and 

Subpart C of the Department's Rules of Practice (14 C.F.R. § 302.301, et seq.) for 

renewal of an exemption authorizing SCAL to continue to engage in (1) scheduled 

foreign air transportation of persons, property, and mail between points in the People's 

Republic of China ("PRC"), on the one hand, and Guam and the Commonwealth of the 

Northern Mariana Islands ("CNMI"), on the other hand; (2) charter foreign air 

transportation of persons, property, and mail between the PRC and the United States; 

and (3) other charters pursuant to the prior approval requirements set forth in the 

Department's regulations. SCAL's exemption authority was initially approved for one 

year by Notice of Action Taken ("NOAT") dated January 26, 2011, and most recently 

renewed for an additional year by NOAT dated May 1, 2014 (Docket DOT -OST -2010-

0299). SCAL requests renewal for a period of at least one additional year. 1 

In filing this renewal application, SCAL invokes the automatic extension provisions of the 

Administrative Procedure Act, 5 U.S.C. § 558(c), as implemented by Part 377 of the 

Department's Special Regulations. This application is timely filed pursuant to§ 377.1 O(c)(3). 

\\DC. 038020/000001 • 6535033 vi 
configured with 24-36 business class and 209-265 economy seats. The traveling public 

has continued to respond well to these services. SCAL seeks to renew its exemption 

authority so that it may continue to conduct its scheduled flights between the PRC and 

Saipan. 2 

2. Under 49 U.S.C. § 40109(c), the Department may renew an exemption if 

it finds that such a grant is in the public interest. Elements of the public interest include 

whether: (a) the applicant is fit, willing, and able to perform the transportation in issue 

and to conform to U.S. aviation law and the Department's regulations; and (b) the 

application is consistent with the relevant bilateral air transport agreement, or is 

consistent with principles of comity and reciprocity. Under these standards, the renewal 

requested by SCAL is clearly in the public interest. 

3. SCAL continues to be fit, willing, and able to provide the foreign air 

transportation described in this renewal application, remains properly licensed by its 

homeland and substantially owned and effectively controlled by citizens of the PRC, 

maintains insurance coverage in accordance with 14 C.F.R. Part 205, and otherwise 

continues to meet the requirements imposed on foreign air carriers serving the 

United States. SCAL requests that the Department take official notice pursuant to 

2 SCAL reserves the right to modify the routes, frequencies, and equipment for its scheduled 

PRC-Saipan services and to provide charter services to the United States in accordance with 

its exemption authority and the opportunities available under the PRC-U.S. Civil Air Transport 

Agreement. However, SCAL will submit applications for statements of authorization to 

conduct any charter flights subject to the Department's prior approval requirements. 

1\DC- 038020/000001 . 6S3S033 vi 
Agreement Relating to Civil Air Transport, signed September 17, 1980, under which 

SCAL has been designated, constituting prima facie evidence that renewal is in the 

public interest. 

5. Furthermore, renewal is in the public interest because SCAL's scheduled 

service will continue to promote foreign travel and tourism to the CNMI. As the 

Department is well aware, air transportation plays a crucial role in the CNMI's economy. 

See Order 2007-2-23 at 7 ("[w]e recognize that air service is vitally important to the 

CNMI, and that the CNMI ... is geographically isolated and heavily dependent on air 

transportation as a vital element of its economy.") As SCAL anticipated when it filed its 

initial exemption application on December 22, 2010 (see Application, pp. 6-7), its 

scheduled flights to Saipan have helped to meet and stimulate demand for passenger 

air transportation between the PRC and the CNMI, to the benefit of the CNMI's 

economy. SCAL has maintained a schedule of six weekly PRC-CNMI flights, 

demonstrating the continued success and substantial public benefits of its scheduled 

service. The Department should promptly renew SCAL's exemption so that these 

valuable services may continue without disruption and, if warranted, expand in the 

future. 

\\DC- 0380201000001 • 6535033 vi 
\\DC- 0380201000001 • 6535033 vi 

Respectfully submitted, 

Columbia Square 

555 Thirteenth Street, NW 

Washington, DC 20004 

Telephone: +1 202 637 6546 

Facsimile: +1 202 637 5910 

E-mail: george.carneal@hoganlovells.com 

Counsel for 

SICHUAN AIRLINES CO., L TO. 
jhill@cooley. com; perkmann@cooley. com 

matwood@cozen. com 

kevin. montgomery@polaraircargo. com 

agoerlich@ggh-airlaw.com 

dan.weiss@united.com; steve.morrissey@united.com 

anita.mosner@hklaw.com; jennifer.nowak@hklaw.com eng lets@state. g ov 

Daniel. W.Abdon@faa. gov 

Jonathan Echmalian 

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