324113/1/WASHINGTON

BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

)

Application of )

)

ALASKA AIRLINES, INC. ) Docket DOT-OST-2010-0234

)

for an exemption pursuant to 49 U.S.C. 40109 )

)

APPLICATION FOR RENEWAL OF EXEMPTION

Communications with respect to this document should be addressed to:

Kyle B. Levine Charles F. Donley II

Deputy General Counsel Marshall S. Sinick

and Managing Director, Legal Squire Sanders (US) LLP

Alaska Airlines, Inc. 1200 19th Street, N.W., Suite 300

19300 International Boulevard Washington, D.C. 20036

Seattle, Washington 98188 (202) 626-6840

charles.donley@squiresanders.com

Counsel to Alaska Airlines, Inc.

DATED: April 18, 2014
324113/1/WASHINGTON

BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

)

Application of )

)

ALASKA AIRLINES, INC. ) Docket DOT-OST-2010-0234

)

for an exemption pursuant to 49 U.S.C. 40109 )

)

APPLICATION FOR RENEWAL OF EXEMPTION

Alaska Airlines, Inc. (“Alaska”) hereby requests renewal of the exemption authority granted

to it by the Department of Transportation (“Department”) in the above-captioned docket to perform

scheduled foreign air transportation of persons, property and mail between San Jose, California, and

Guadalajara, Mexico.1This exemption authority expires on July 31, 2014. Alaska requests renewal

of this authority for a two-year period and relies on the provisions of the Administrative Procedure

Act and Part 377 of the Department’s procedural regulations to continue its existing authorization in

force pending a final decision on this renewal request.

In further support of its request for renewal, Alaska states as follows:

1. Alaska’s principal headquarters are located at 19300 International Boulevard,

Seattle, Washington. Alaska is incorporated under the laws of the State of Alaska and is a

wholly-owned subsidiary of Alaska Air Group, Inc. (“AAG”). AAG is incorporated under the

laws of the State of Delaware.

1 Alaska does not request renewal of its exemption to serve Sacramento-Guadalajara.
Application for Renewal of Exemption

Docket DOT-OST-2010-0234

April 18, 2014

2

324113/1/WASHINGTON

2. Alaska is a citizen of the United States within the meaning of 49 U.S.C.

40102(a)(15). The president and at least two-thirds of Alaska’s directors and other managing

officers are U.S. citizens. Additionally, to Alaska’s knowledge, U.S. citizens hold at least

seventy-five percent of Alaska’s voting stock.

3. Alaska has repeatedly been found fit, willing and able to provide interstate and

foreign air transportation. The Department is requested to take official notice of Alaska’s

continuing fitness. See, e.g., Order 2000-5-31.

4. Alaska operates five-times weekly service in the San Jose-Guadalajara market

using B737 aircraft. The Department has found previously that Alaska’s service is consistent

with the terms of the U.S.-Mexico bilateral agreement.2

5. This renewal application does not raise any environmental or energy concerns.

All flights will continue to be performed with aircraft that meet all applicable noise requirements.

Similarly, approval of this application will not result in a near-term increase in fuel consumption of

ten million gallons or more.

2

See, Notice of Action Taken, Docket DOT-OST-2010-0234, July 31, 2012
Application for Renewal of Exemption

Docket DOT-OST-2010-0234

April 18, 2014

3

324113/1/WASHINGTON

WHEREFORE, Alaska Airlines, Inc. respectfully requests that the exemption granted to

it in the above-captioned docket be renewed for an additional two-year period, as more fully

described herein.

Respectfully submitted,

/s/ Charles F. Donley II

_________________________________

Charles F. Donley II

Marshall S. Sinick

Squire Sanders (US) LLP

1200 19th Street, N.W., Suite 300

Washington, D.C. 20036

(202) 626-6840

charles.donley@squiresanders.com

Counsel to Alaska Airlines, Inc.

DATED: April 18, 2014
324113/1/WASHINGTON

CERTIFICATE OF SERVICE

I hereby certify that one copy of the foregoing Application for Renewal of Exemption has

this day been served on each of the following individuals via telecopier or email.

/s/ Charles F. Donley II

___________________________

Charles F. Donley II

DATED: April 18, 2014

sascha.vanderbellen@delta.com; sametta.c.barnett@delta.com

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

patrick.rizzi@hoganlovells.com

bob.kneisley@wnco.com

jhill@cooley.com

mlbenge@zsrlaw.com

dkirstein@yklaw.com

howard.kass@aa.com; robert.wirick@aa.com

pmurphy@lopmurphy.com; pmurphy@ggh-airlaw.com

barbara.russell@virginamerica.com

AGoerlich@ggh-airlaw.com

Brett.kruger@dot.gov