BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_____________________________________

Application of )

)

 AMERICAN AIRLINES, INC. ) Docket DOT-OST-2012-0209

) 

for renewal of an exemption )

pursuant to 49 U.S.C. § 40109 )

(United States – Brazil) )

_____________________________________ )

APPLICATION OF AMERICAN AIRLINES, INC. 

FOR RENEWAL OF AN EXEMPTION

(United States – Brazil)

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

January 22, 2015
2

BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_____________________________________

Application of )

)

 AMERICAN AIRLINES, INC. )

) Docket DOT-OST-2012-0209

for renewal of an exemption )

pursuant to 49 U.S.C. § 40109 ) January 22, 2015

(United States – Brazil) )

_____________________________________ )

APPLICATION OF AMERICAN AIRLINES, INC. 

FOR RENEWAL OF AN EXEMPTION

(United States – Brazil)

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 on flights operated by “American Airlines or American 

Eagle1between (1) points in the United States; (2) points in the United States and 

points in Brazil (either nonstop or via intermediate points in third countries); (3) points in 

the United States and points in third countries; and (4) points in Brazil and points in third 

countries” pursuant to a codeshare agreement with TAM-Linhas Aereas, S.A. (“TAM”).

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.

 

1 American Eagle, Inc. is now certificated and registered as Envoy Air Inc., but still uses the trade name 

“American Eagle.” (See Order 2014-4-13, April 15, 2014.)
Application of American Airlines for Renewal of an Exemption

(United States – Brazil)

 

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, October 7, 2014, Docket DOT-OST-2014-0169 (Dallas/Ft. 

Worth, Texas – Beijing, People’s Republic of China).) Pursuant to 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 (January 25, 2013), the Department granted 

American Airlines a two-year exemption from 49 U.S.C. § 41101 to engage in 

scheduled foreign air transportation of persons, property, and mail on flights operated 

by American Airlines or American Eagle between (1) points in the United States; (2) 

points in the United States and points in Brazil (either nonstop or via intermediate points 

in third countries); (3) points in the United States and points in third countries; and (4) 

points in Brazil and points in third countries.” (Docket DOT-OST-2012-0209.)

2

4. American Airlines currently provides scheduled air service between the 

United States and Brazil pursuant to a codeshare with TAM. Renewal of American 

Airlines’ exemption will greatly serve the public interest by providing substantial 

 

2 American respectfully requests a waiver of the 60-day advance filing requirement of the automatic 

continuance provisions of Part 377 of the Department’s rules so that its authority may remain in effect pending 

Department action, as provided in 5 U.S.C. Section 558(c).
Application of American Airlines for Renewal of an Exemption

(United States – Brazil)

 

competition to other carriers serving Brazil 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 aviation agreement between the 

United States and Brazil (See Notice of Action Taken, January 25, 2013, Docket DOTOST-2012-0209.) 

6. Carriers have already been polled and raised no objections. As such, we 

request that the Department consider American Airlines’ application expeditiously. 
Application of American Airlines for Renewal of an Exemption

(United States – Brazil)

 

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 Brazil, 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

January 22, 2015
CERTIFICATE OF SERVICE

I certify that, on January 22, 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:

englets@state.gov (Department of State)

cristinasa@state.gov (Department of State)

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.allen@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)

chris.walker@delta.com (Delta)

_________________________

Abigail Donovan