BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

AMERICAN AIRLINES, INC. 

for an exemption 

pursuant to 49 U.S.C. § 40109 

(Los Angeles, California 

-Guadalajara, Mexico) 

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Docket DOT -OST -2015 

APPLICATION OF AMERICAN AIRLINES, INC. 

FOR AN EXEMPTION 

(Los Angeles, California- Guadalajara, Mexico) 

Communications with respect to this document should be addressed to: 

Howard Kass 

Vice President- Regulatory Affairs 

Robert A. Wirick, 

Managing Director, Regulatory and International Affairs 

Abigail Donovan 

Director, Congressional and Federal Affairs 

American Airlines, Inc. 

1101 1 ih Street, N.W. 

Washington, DC 20036 

(202) 326-5153 

howard. kass@ a a. com 

robert. wirick@ a a. com 

abigail. donovan@ a a. com 

January 23, 2015 

NOTICE: American Airlines plans to poll on this application and therefore requests 

that any parties wishing to support or oppose this application notify 

American Airlines immediately. 
BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

AMERICAN AIRLINES, INC. 

for an exemption 

pursuant to 49 U.S.C. § 40109 

(Los Angeles, California 

-Guadalajara, Mexico) 

) 

) 

) 

) 

) 

) 

) 

) __________________________ } 

Docket DOT-OST-2015 

January 23, 2015 

APPLICATION OF AMERICAN AIRLINES, INC. 

FOR AN EXEMPTION 

(Los Angeles, California- Guadalajara, Mexico) 

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

Transportation's ("Department") Rules of Practice ( 14 C. F. R. Part 302}, American 

Airlines, Inc. ("American Airlines") applies for exemption authority, and a designation, to 

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

Los Angeles, California ("LAX") and Guadalajara, Mexico ("GDL"). 

American Airlines requests expedited processing of this application so that it can 

begin seeking necessary regulatory approvals from the Mexican authorities as soon as 

possible. 

In support of this application, American Airlines respectfully states as follows: 

1. American Airlines is a Delaware corporation with its principal office at 

4333 Amon Carter Boulevard, Fort Worth, Texas 76155. 

2. The services proposed in this application will serve the public interest by 

enabling American Airlines to offer consumers enhanced U.S.-Mexico services while 

1 
Application of American Airlines for an Exemption 

(los Angeles, California- Guadalajara, Mexico) 

supporting commerce and providing substantial competition to other carriers serving 

Mexico from the United States. 

3. In order to initiate this scheduled air service, American Airlines requests 

an exemption from 49 U.S.C. § 41101 and a designation permitting it to engage in 

scheduled foreign air transportation of persons, property, and mail between Los 

Angeles, California, and Guadalajara, Mexico. 

4. American Airlines is a citizen of the United States within the meaning of 49 

U.S.C. § 401 02(a)(15)(C) and is fit, willing, and able to provide the services 

contemplated by this application. American Airlines holds various certificates of public 

convenience and exemption authorities. (See, e.g., DOT Order 2007-4-2, April 3, 2007, 

Dockets OST-2000-8516 and OST-2005-22228 (Blanket Open-Skies Route Authority); 

Notice of Action Taken, October 7, 2014, Docket DOT-OST-2014-0169 (Dallas/Ft. 

Worth, Texas- Beijing, People's Republic of China).) Pursuant to Rule 24 of the 

Department's Rules of Practice, American Airlines requests that the Department take 

official notice of all information previously filed to establish its fitness. 

5. American Airlines plans to commence LAX-GDL service on June 4, 2015. 

Service between LAX and GDL will be operated year-round using Airbus 319 aircraft 

(8J/120Y). American Airlines' service proposal is attached hereto as Exhibit AA-1. 

6. American Airlines' Application is consistent with the 1960 Air Transport 

Agreement between the Government of the United States of America and the 

Government of the United Mexican States, as amended by the Memorandum of 

Consultations signed on September 21, 2005 ("Air Service Agreement"). The Air 

Service Agreement allows the United States Government to designate up to three (3) 

2 
Application of American Airlines for an Exemption 

(Los Angeles, California- Guadalajara, Mexico) 

airlines to provide air service between points in the United States and Guadalajara. 

(See Annex I, Paragraph B, Sub-paragraph 5.) 

7. Sufficient designations are available to accommodate American Airlines' 

proposed service. As of September 24, 2014, one designation is available for a U.S. 

carrier to provide scheduled air service from the United States to GDL. 1 Accordingly, 

American Airlines' proposed service is consistent with the aviation agreement between 

the United States and Mexico. 

8. In November 2014, the U.S. and Mexican governments successfully 

negotiated and initialed an amended Air Transport Agreement that will include, among 

other provisions, open third and fourth freedom rights for passenger airlines. American 

applauds the efforts on the part of both governments and recognizes that the agreement 

is scheduled to enter into force on January 1, 2016, after both Parties have completed 

the necessary internal processes. The new agreement, once entered into force, will 

expand opportunities for each Party. Nevertheless, American's request for authority for 

this route is consistent with the existing U.S.-Mexico aviation agreement currently in 

place. 

9. American Airlines states that approval of this application will have no 

effect on its CRAF commitments. Furthermore, American Airlines submits that its 

application raises no environmental or energy issues, and anticipates no difficulty in 

obtaining fuel for this service. 

1 Alaska Air Lines, Delta Air Lines and United Air Lines, Inc. ("United") had operated from U.S. points to 

GDL. However, on September 24, 2014, United informed the Department that it was discontinuing its 

GDL service. See Notice of Dormancy (San Francisco/Los Angeles- Guadalajara, Mexico), September 

24, 2014, Docket DOT-OST-2011-0076. No other U.S. carrier has since applied for GDL service. 

3 
Application of American Airlines for an Exemption 

(Los Angeles, California- Guadalajara, Mexico) 

10. American Airlines will accept and abide by all terms, limitations, and 

conditions that the Department normally attaches to exemption authority for scheduled 

foreign air transportation. American Airlines asks that this requested authority be 

granted for a term of at least two (2) years. 

11. American Airlines requests the Department to use expedited procedures 

to approve the authority sought in this application. 

12. The requisite filing fee is enclosed. 

4 
CERTIFICATE OF SERVICE 

I certify that, on January 23, 2015, I caused to be served a copy of the foregoing 

Application of American Airlines, Inc. for an Exemption, by email upon those 

addressees listed below: 

eng lets@ state.gov (Department of State) 

cristinasa @state.gov (Department of State) 

brian.hedberg@dot.gov (Department of Transportation) 

todd.homan @dot.gov (Department of Transportation) 

peter. irvine@ dot.gov (Department of Transportation) 

laura.remo@dot.gov (Department of Transportation) 

brett. kruger@ dot.gov (Department of Transportation) 

john.allen @faa.gov (Federal Aviation Administration) 

dan.weiss@united.com (United) 

steve.morrissey@ united.com (United) 

gmurphy@crowell.com (Counsel for United) 

sascha. vanderbellen@ delta.com (Delta) 

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

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

msinick@ssd.com (Counsel for Alaska) 

jyoung@yklaw.com (Counsel for Spirit) 

dkirstein @yklaw.com (Counsel for Spirit) 

bob.kneisley@wnco.com (Southwest) 

leslie.abbott@wnco.com (Southwest) 

john.fredericksen@ suncountry.com (Sun Country) 

thomas.ting@suncountry.com (Sun Country) 

matwood@cozen.com (Counsel for Frontier) 

stephen.lachter@ lachterlaw.com (Counsel for Frontier) 

rpommer@atlasair.com (Atlas) 

anita.mosner@hklaw.com (Counsel for UPS) 

jennifer.nowak@ hklaw.com (Counsel for UPS) 

barbara. russell @virginamerica.com (Virgin America) 

john.varley@virginamerica.com (Virgin America) 

Abigail Donovan 
AA903 

Daily 

A319 

0030 

I 

I 

I 

v 

0540 

3:10 

AMERICAN AIRLINES 

Los Angeles - Guadalajara Nonstop Service 

Effective 

June 4, 2015 

Flight Number 

Frequency 

Equipment 

Los Angeles (LAX) 

Guadalajara (GDL) 

Elapsed Time 

AA985 

Daily 

A319 

2120 

1\ 

I 

I 

I 

1955 

3:25 

Exhibit AA -1 

Page 1 of 2 

Source: American Airlines Network Planning 
AMERICAN AIRLINES 

Los Angeles - Guadalajara Nonstop Service 

Annual Operating Statistics 

Effective June 4, 2015 

Aircraft 

Departures 

Segment Miles 

Plane Miles 

ASMs 

Fuel Burn (Gallons/Hour) 

Fuel Consumption (1 ,000 Gallons) 1 

Business Class 

Economy Class 

Total 

Seating Configuration 

A319 

730 

2,492 

1 ,819,160 

232,852,480 

780 

3,815 

8 

120 

128 

AIRCRAFT AVAILABILITY- American will use aircraft currently in its fleet. 

American will have twenty five (25) A319s in its fleet. 

FUEL AVAILABILITY- American anticipates no difficulty in obtaining fuel 

from its existing suppliers at Los Angeles and Guadalajara 

1/ The environmental impact of American's proposed service is de 

minimis. Although the aggregate annual fuel usage of American's 

proposed service is expected to exceed 10 million gallons, American 

would use these aircraft in other markets in the absence of an order 

granting the operating authority American seeks in this application. 

Accordingly, the proposed service will not cause a near-term net 

annual change in aircraft fuel consumption of 10 million gallons or 

more of fuel consumption if the request were not granted. 

Exhibit AA - 1 

Page 2 of 2 

Source: American Airlines Network Planning