BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

____________________________________

Application of )

 )

 AMERICAN AIRLINES, INC. ) Docket DOT-OST-2011-0228

 ) 

for renewal of an exemption )

pursuant to 49 U.S.C. § 40109 )

(United States – China Points) )

____________________________________ )

APPLICATION OF AMERICAN AIRLINES, INC. 

FOR RENEWAL OF AN EXEMPTION

(United States – China Points)

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 17th Street, N.W.

Washington, D.C. 20036

(202) 326-5153

howard.kass@aa.com

robert.wirick@aa.com

abigail.donovan@aa.com

May 29, 2015
BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

____________________________________

Application of )

 )

 AMERICAN AIRLINES, INC. ) Docket DOT-OST-2011-0228

 ) 

for renewal of an exemption ) May 29, 2015

pursuant to 49 U.S.C. § 40109 )

(United States – China Points) )

____________________________________ )

APPLICATION OF AMERICAN AIRLINES, INC. 

FOR RENEWAL OF AN EXEMPTION

(United States – China Points)

Pursuant to 49 U.S.C. § 40109 and Subpart C of the Department’s Rules of Practice (14 

C.F.R. Part 302), American Airlines, Inc. (“American Airlines”) applies for renewal of its

exemption authority to engage in scheduled foreign air transportation of persons, property, and 

mail between Seattle, Washington and Beijing, People’s Republic of China, and to any point in 

China on a code-share basis with Hainan Airlines (“Hainan”).

In support of this renewal 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. American Airlines is a citizen of the United States within 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, May 18, 

2015, Docket DOT-OST-2015-0097 (Los Angeles, California – Mazatlan, Mexico).) Pursuant to 
Application of American Airlines for Renewal of an Exemption

(United States – China Points)

2

Rule 24 of the Department’s Rules of Practice, American Airlines requests that the Department 

take official notice of all information previously filed to establish its fitness. 

3. By Notice of Action Taken (August 1, 2013), the Department granted American 

Airlines a two-year exemption from 49 U.S.C. § 40109 to engage in scheduled foreign air 

transportation of persons, property, and mail between Seattle and Beijing and to any point in 

China on a code-share basis with Hainan, as authorized by the U.S.-China Air Transport 

Agreement, as amended by Article 5 of the U.S.-China Protocol signed on July 23, 2004.

(Docket DOT-OST-2011-0228.)

4. American Airlines currently provides scheduled air service between Seattle and 

Beijing pursuant to a codeshare agreement with Hainan. Renewal of American Airlines’ 

exemption will greatly serve the public interest by providing substantial competition to other 

carriers serving China from the United States, while supporting commerce and enhancing the 

options available to the traveling public. 

5. The Department has previously determined that the exemption authority sought in 

this renewal application is consistent with the Air Transport Agreement, as amended, between 

the United States and the People’s Republic of China. (See Notice of Action Taken, August 1, 

2013, Docket DOT-OST-2011-0228.) 

6. Pursuant to 14 C.F.R. § 377.10, American Airlines intends to rely on the 

Administrative Procedures Act, 5 U.S.C. § 558(c) implemented by Part 377, to continue in effect 

its current exemption authority pending a final determination on this renewal application. 

American Airlines’ current exemption is effective through August 1, 2015. Accordingly, this 

renewal application is timely filed under the provisions of Part 377.
Application of American Airlines for Renewal of an Exemption

(United States – China Points)

3

WHEREFORE, American Airlines respectfully requests that the Department renew its 

exemption authority to engage in scheduled foreign air transportation of persons, property, and 

mail between the United States and China points, as discussed herein.

Respectfully submitted,

_______________________

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 17th Street, N.W.

Washington, D.C. 20036

(202) 326-5153 

howard.kass@aa.com

robert.wirick@aa.com

abigail.donovan@aa.com

May 29, 2015
CERTIFICATE OF SERVICE

I certify that, on May 29, 2015, I caused to be served a copy of the foregoing Application 

of American Airlines, Inc. for Renewal of Exemption Authority, by email upon those addressees 

listed below:

brian.hedberg@dot.gov (Department of Transportation)

todd.homan@dot.gov (Department of Transportation)

peter.irvine@dot.gov (Department of Transportation)

laura.remo@dot.gov (Department of Transportation)

brett.kruger@dot.gov (Department of Transportation)

john.s.duncan@faa.gov (Federal Aviation Administration)

dan.weiss@united.com (United)

steve.morrissey@united.com (United)

gmurphy@crowell.com (Counsel for United)

sascha.vanderbellen@delta.com (Delta)

robert.land@jetblue.com (JetBlue)

esahr@eckertseamans.com (Counsel for JetBlue)

dderco@eckertseamans.com (Counsel for JetBlue)

jhill@cooley.com (Counsel for Hawaiian)

perkmann@cooley.com (Counsel for Hawaiian)

jeremy.ross@alaskaair.com (Alaska)

dheffernan@cozen.com (Counsel for Alaska)

jyoung@yklaw.com (Counsel for Spirit)

dkirstein@yklaw.com (Counsel for Spirit)

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 (Counsel for Frontier)

slachter@cozen.com (Counsel for Frontier)

rpommer@atlasair.com (Atlas)

anita.mosner@hklaw.com (Counsel for UPS)

jennifer.nowak@hklaw.com (Counsel for UPS)

cefelts@fedex.com (FedEx)

nssparks@fedex.com (FedEx)

kevin.montgomery@polaraircargo.com (Polar)

_________________________

Abigail Donovan