BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

)

Motion of )

)

SPIRIT AIRLINES, INC

. ) Docket DOT

- OST

- 20 11

- 0175

)

U.S.

- Colombia Combination Frequency )

Allocation Proceeding )

)

MOTION OF SPIRIT AIRLINES, INC.

FOR EXTENSION OF STARTUP DATE

AND NOTICE OF RELEASE OF FREQUENCIES

Communications with respect to this document should be sent to:

Joanne W. Young

David M. Kirstein

Kir stein & Young, PLLC

1750 K Street, N.W.

Suite 200

Washington, D.C. 20006

(202) 331

- 3348 (telephone)

(202) 331

- 3933 (facsimile)

Attorneys for

SPIRIT AIRLINES, INC.

January 30 , 201 2BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

)

Motion of )

)

SPIRIT AIRLINES, INC

. ) DOT

- OST

- 20 11

- 0175

)

U.S.

- Colombia Combination Frequency )

Allocation Proceeding )

)

MOTION OF SPIRIT AIRLINES, IN C.

FOR EXTENSION OF STARTUP DATE

AND NOTICE OF RELEASE OF FREQUENCIES

On September 15, 2011, Spirit Ai r lines, Inc. (“Spirit”) filed an application to

receive fourteen ( 14 ) U.S.

- Colombia frequencies and the exemption authority necessary

to provide servic e between Fort Lauderdale, Florida and Bogotá , Colombia and to beyond

points in Ecuador and to Lima, Peru. By Notice of Action Taken, in this docket, dated

October 4, 2011, the Department granted Spirit exemption authority and fourteen (14)

frequencies to provide this service

. The NOAT specified that Spirit would be required to

inaugurate service between Fort Lauderdale and Bogotá within ten ( 10 ) days of April 1,

2012.

Spirit respectfully requests an extension of this deadline for seven (7) of the

awarded frequencies until May 24, 2012 . This extension is needed to permit time for

Spirit to obtain final approval from the Colombian and Peruvian authorities for the

beyond service between Bogotá and Lima, Peru

. In addition, d ue to delays in the openingMotion of Spirit Airlines, Inc.

U.S.

- Colombia Frequency Allocation Proceeding

Page 2 of 3

of a ne w airport in Quito, Ecuador, Spirit will not be able to initiate additional service

between Fort Lauderdale and Bogotá and beyond to Ecuador until 2013. Since under the

U.S

- Colombia bilateral air transport agreement, FLL

- BOG will no longer be a frequency

r estricted route by that time , Spirit releases the remaining seven (7) frequencies allocated

to it in these proceedings back to the Department.

Spirit has submitted its application for approval to operate the FLL

- BOG

- LIM

route to both the Peruvian and Colom bian civil aviation authorities . Spirit expects

approval from both of these entities by early April. Once approved, Spirit expects t o be

able to initiate service no later than May 24, 2012. Granting this motion will provide

Spirit with the time necessary to meet the operating requir ements of both Colombia and

Peru

.

Grant of this motion will not adversely affect service in the FLL

- BOG market and

will not result in injury to any competitor or potential competitor. Only 21 of the 42

available frequencies wer e award ed in this proceeding. By this M otion

, seven ( 7 ) of those

frequencies are being returned to the D epartment, leaving 28 frequencies open to

potential competitors. Additionally, JetBlue, which was awarded seven ( 7 ) frequencies to

provide service betwe en Fort Lauderdale and Bogotá , has been granted an extension of its

startup deadline from January 25, 2012 to May 25, 2012. See Approval of Motion , DOT

OST

- 2011

- 0174 (Jan. 4, 2012).

WHEREFORE, for the reasons described above

, S pirit respectfully requests that

the Department grant its Motion to extend the startup date on seven (7) combinationMotion of Spirit Airlines, Inc.

U.S.

- Colombia Frequency Allocation Proceeding

Page 3 of 3

frequencies to be used by Spirit for scheduled foreig n air transportation between Fort

Lauderdale , Florida and Bogotá

, Colombia until May 24, 2012

.

Spirit further requests any other relief the Department may deem necessary

.

Respectfully Submitted,

Joanne W. Young

David M. Kirstein

Kirstein & Young PLLC

1750 K Street N.W.

Suite 200

Washington, D.C. 20006

(202) 331

- 334 8 (telephone)

(202) 331

- 3933 (facsimile)

Attorneys for

SPIRIT AIRLINES, INC.CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing “ Motion of Spirit

Airlines, Inc. ” by email on the following pers ons:

___ _______________________ Lyndsey Grunewald

January 30, 2012 dan.weiss@united .com

jeff.morgan@delta.com

sascha.vanderbellen@delta.com

steve.morrissey@united.com

robert.land@jetblue.com

jhill@dlalaw.com

carl.nelson@aa.com urskr @state.gov

esta.r osenberg@dot.gov

brett.kruger@dot.gov

brian.hedberg@dot.gov