BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

)

Motion of )

)

SPIRIT AIRLINES, INC. ) Docket DOT-OST-2011-0175

)

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

Kirstein & 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, 2012
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

)

Motion of )

)

SPIRIT AIRLINES, INC. ) DOT-OST-2011-0175

)

U.S.-Colombia Combination Frequency )

Allocation Proceeding )

 )

MOTION OF SPIRIT AIRLINES, INC.

FOR EXTENSION OF STARTUP DATE 

AND NOTICE OF RELEASE OF FREQUENCIES

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

receive fourteen (14) U.S.-Colombia frequencies and the exemption authority necessary 

to provide service 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, due to delays in the opening 
Motion of Spirit Airlines, Inc.

U.S.-Colombia Frequency Allocation Proceeding

Page 2 of 3

of a new 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 

restricted 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 Colombian civil aviation authorities. Spirit expects 

approval from both of these entities by early April. Once approved, Spirit expects to 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 requirements 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 were awarded in this proceeding. By this Motion, seven (7) of those 

frequencies are being returned to the Department, leaving 28 frequencies open to 

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

provide service between 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, DOTOST-2011-0174 (Jan. 4, 2012).

WHEREFORE, for the reasons described above, Spirit respectfully requests that 

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

U.S.-Colombia Frequency Allocation Proceeding

Page 3 of 3

frequencies to be used by Spirit for scheduled foreign 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) 331-3348 (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 persons:

__________________________

 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.rosenberg@dot.gov

brett.kruger@dot.gov

brian.hedberg@dot.gov