BEFORE THE U.S. DEPARTMENT OFTRANSPORTATION 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

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@aa.com robert. wirick@aa.com abigail.donovan@aa.com January 23, 2015
NOTICE: American Airlines plans to poll on this application and therefore requests that any parties wishing to supportoroppose this application notify American Airlines immediately.BEFORE THE U.S. DEPARTMENT OFTRANSPORTATION 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) Pursuantto 49 U.S.C. 

### § 40109 and Subpart C ofthe Department of Transportation's ("Department") Rules of Practice (14 C.F.R. Part 302}, American Airlines, Inc. ("American Airlines") appliesfor exemption authority, and a designation, to engage in scheduled foreign airtransportation 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 serviceswhile



### 1Application 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 orderto 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 acitizen ofthe United Stateswithin the meaning of 49 U.S.C. 

### § 40102(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).) Pursuantto Rule 24 of the Department's Rules of Practice, American Airlines requests that the Departmenttake official notice of all information previouslyfiled to establish its fitness. 5. American Airlines plans to commence LAX-GDL service on June 4, 2015. Service between LAX and GDLwill 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 1960Air Transport Agreement between the Governmentof the United States of America and the Governmentof the United Mexican States, as amended by the Memorandum of Consultations signed on September21, 2005 ("Air Service Agreement"). The Air Service Agreement allows the United States Government to designate up to three (3)



### 2Application of American Airlinesfor an Exemption (Los Angeles, California- Guadalajara, Mexico)

airlines to provide air service between points in the United States and Guadalajara. (SeeAnnex I, Paragraph B, Sub-paragraph 5.) 7. Sufficient designations are available to accommodate American Airlines' proposed service. As of September24, 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 November2014, the U.S. and Mexican governments successfully negotiated and initialed an amended AirTransportAgreementthat 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 authorityfor this route is consistentwith the existing U.S.-Mexico aviation agreement currently in place. 9. American Airlines statesthat approval of this application will have no effect on its CRAF commitments. Furthermore, American Airlines submits that its application raises no environmental orenergy issues, and anticipates no difficulty in obtaining fuel for this service.

1Alaska 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 Departmentthat 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. 

### 3Application of American Airlinesfor 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 authorityfor scheduled foreign airtransportation. American Airlines asks thatthis requested authority be granted for aterm of at least two (2) years. 11. American Airlines requests the Departmentto use expedited procedures to approve the authority sought in this application. 12. The requisite filing fee is enclosed.

4CERTIFICATE OF SERVICE I certifythat, 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: englets@state.gov (DepartmentofState) cristinasa@state.gov (DepartmentofState) brian.hedberg@dot.gov (DepartmentofTransportation) todd.homan @dot.gov (DepartmentofTransportation) peter.irvine@dot.gov (DepartmentofTransportation) laura.remo@dot.gov (DepartmentofTransportation) brett.kruger@dot.gov (DepartmentofTransportation) john.allen@faa.gov (FederalAviationAdministration) dan.weiss@united.com (United) steve.morrissey@united.com (United) gmurphy@crowell.com (Counselfor United) sascha.vanderbellen@delta.com (Delta) jhill@cooley.com (CounselforJetBiue andHawaiian) perkmann@cooley.com (CounselforJetBiue andHawaiian) msinick@ssd.com (CounselforAlaska) jyoung@yklaw.com (CounselforSpirit) dkirstein@yklaw.com (CounselforSpirit) 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 (CounselforFrontier) stephen.lachter@ lachterlaw.com (CounselforFrontier) rpommer@atlasair.com (Atlas) anita.mosner@hklaw.com (Counselfor 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 June4, 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 1of 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 twentyfive (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