BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

) Application of ) ) CENTURION AIR CARGO, INC. ) Docket OST-2008-0228 ) for an Exemption from 49 U.S.C. ) § 41101 and Allocation of Frequencies ) (U.S.-Brazil All-Cargo Service) ) )

APPLICATION OF CENTURION AIR CARGO, INC. FOR ADDITIONAL EXTENSION OF START-UP DATE

EXPEDITED ACTION REQUESTED COUNSEL WILL POLL U.S. CARRIERS SERVED

Communications with respect to this document may be served upon:
William C. Evans John R. Mietus, Jr. LAW OFFICE OF JOHN MIETUS, LLC 6701 Democracy Boulevard, Suite 300 Bethesda, MD 20817 (410) 827-5074 (202) 747-5212 john@mietuslaw.com bill@mietuslaw.com Counsel for Centurion Air Cargo, Inc.

DATED: October 20, 2010BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

Application of ) ) CENTURION AIR CARGO, INC ) Docket OST-2008-0228 ) October 20, 2010 for an Exemption from 49 U.S.C. ) § 41101 and Allocation of Frequencies ) (U.S.-Brazil All-Cargo Service) ) )

APPLICATION OF CENTURION AIR CARGO, INC. FOR AN ADDITIONAL EXTENSION OF START-UP DATE

By Notice of Action Taken dated August 5, 2008, the Department granted Centurion Air Cargo, Inc. (“Centurion”) an exemption to engage in scheduled air transportation of property and mail between points in the United States, via intermediate points, and certain named Brazilian co-terminal points and beyond Brazil to Argentina, Uruguay, Paraguay and Chile. The Notice also allocated Centurion seven (7) weekly U.S.- Brazil all-cargo frequencies and provided that any unused frequencies would revert to the Department if service was not begun within 90 days of a proposed September 1, 2008 start-up date (the “Start-Up Condition”). The Department has extended the start-up date several times at Centurion's request, and the current start-up date is October 27, 2010. In support of this request for an additional 90-day extension of the start-up date, Centurion states as follows:Centurion Air Cargo Application for Extension Page 2 1. In prior requests for extension of the start-up date, Centurion detailed the very significant administrative requirements that Brazil has imposed on Centurion and the carrier's efforts to satisfy those requirements. This process suffered yet a further delay when ANAC, the Brazilian aviation authority, questioned whether past Brazil activities of Challenge Air Cargo, Inc. ("Challenge") should affect the manner in which ANAC processes Centurion's authority. (This latest issue was described in greater detail in the July 22, 2010 extension request.) 2. Centurion has spent the last several months working with ANAC to resolve this apparently unprecedented legal issue. Centurion has had to research missing ANAC records and develop a response to the agency's questions, which Centurion submitted in September. To date, ANAC has not responded. As a result, Centurion's application before ANAC for scheduled authority remains suspended, and it is not yet clear what additional, administrative requirements may flow from ANAC's resolution of the Challenge issue. Thus, it is clear that Centurion will not be able to initiate service before the October 27, 2010 start-up date, and Centurion respectfully requests a further, 90-day
extension. 3. The relief Centurion requests is consistent with the public interest and should not prejudice any party. The demand forCenturion Air Cargo Application for Extension Page 3 Centurion’s service is evidenced by the fact that during the first six months of 2010, it operated nearly 200 charters between the U.S. and Brazil. Centurion remains eager to transition its Brazil charter operations to scheduled service, and it will continue to diligently pursue its efforts to obtain the requisite authority. Centurion will poll the U.S. airlines on the service list as to their position on this request and will report the results to the Department. For all the foregoing reasons, Centurion respectfully requests that the Department modify the Start-Up Condition as suggested herein and grant such other relief as may be necessary or proper. Respectfully submitted,

John R. Mietus, Jr. William C. Evans LAW OFFICE OF JOHN MIETUS, LLC 6701 Democracy Boulevard, Suite 300 Bethesda, MD 20817 (410) 827-5074 (202) 747-5212 bill@mietuslaw.com Counsel for Centurion Air Cargo, Inc. DATED: October 20, 2010CERTIFICATE OF SERVICE I certify that I have this 20th day of October, 2010, served the foregoing document on the following persons by electronic mail:

nssparks@fedex.com dvaughan@kelleydrye.com, dfisher@kelleydrye.com for UPS hershel.kamen@coair.com, dan.weiss@coair.com rpommer@atlasair.com pmurphy@ggh-airlaw.com for Arrow Air kevin.montgomery@polaraircargo.com, peter.beckett@polaraircargo.com

John R. Mietus, Jr.

4837-7979-5463, v. 1