BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_________________________________________

)

)

Application of )

)

TRANS STATES AIRLINES, LLC ) Docket DOT-OST-2014-

)

for an exemption pursuant to )

49 U.S.C. 40109 (US – Canada) )

)

_________________________________________ )

APPLICATION OF 

TRANS STATES AIRLINES, LLC FOR AN EXEMPTION

Communications with respect to this document should be sent to:

Lisa A. Harig

McBreen & Kopko

1501 Lee Highway, Suite 180

Arlington, VA 22209

Phone (703) 247 5487

Fax (703) 852 3490

LHarig@mklawdc.com

Counsel for Trans States Airlines, LLC

Dated: December 5, 2014

Notice: Any person may respond to this application by filing an answer in the above referenced 

docket and serving a copy thereof on each person named on the attached service list. Answers 

are due not later than December 22, 2014. Counsel for Trans States Airlines, LLC will poll the 

carriers on the attached service list and will notify the Department of any objections.
_________________________________________

)

)

Application of )

)

TRANS STATES AIRLINES, LLC ) Docket DOT-OST-2014-

)

for an exemption pursuant to )

49 U.S.C. 40109 (US – Canada) )

)

_________________________________________ )

Dated: December 5, 2014

APPLICATION OF 

TRANS STATES AIRLINES, LLC FOR AN EXEMPTION

Trans States Airlines, LLC (“Trans States”) hereby requests an exemption from 49 

U.S.C. Section 41101, and such other relief as the Department may deem necessary, in order to 

engage in the scheduled foreign air transportation of person, property, and mail between and 

point or points in the United States and a point or points in Canada. Trans States proposes to 

engage in such services utilizing 50-seat Embraer ERJ145 regional jet aircraft. Trans States

plans to initiate service to Canada on January 6, 2015, and therefore requests that this exemption 

authority be granted as expeditiously as possible.

In support of this application, Trans States respectfully submits as follows:

1. Trans States is a limited liability company organized under the laws of the State 

of Delaware. Its principal place of business is located at 11494 Navaid Road, St. Louis, Missouri 

63044, with its principal operations and maintenance base at Lambert St. Louis International 

Airport, St. Louis, Missouri 63145. Trans States holds a domestic air service certificate 

authorizing it to engage in interstate air transportation of persons, property, and mail. See Order 

2009-5-8.
2. Trans States is a citizen of the United States as defined in 49 U.S.C. Section 

40102(a)(15), and is owned and controlled by U.S. citizens. All senior officers and the 

managing director of Trans States are citizens of the United States. Trans States is a wholly 

owned subsidiary of Trans States Holdings, Inc., which in turn is 100% owned by citizens of the 

United States.

3. Trans States is fit, willing, and able to perform the foreign air transportation 

requested herein. Trans States is presently engaged in scheduled air transportation of persons, 

property, and mail pursuant to a certificate of public convenience and necessity issued by the 

Department. Further, Trans States has previously operated between the U.S. and Canada 

pursuant to an exemption. See Notice of Action Taken dated August 26, 2002 in Docket OST2002-13176.

4. Issuance of the requested exemption to Trans States is fully consistent with the 

public interest. The Air Transport Agreement between the United States and Canada signed on 

March 12, 2007 provides for unlimited entry for air carriers of either nation. 

5. A grant of Trans States’ application would not constitute a “major regulatory 

action” under 14 C.F.R. Part 313. Specifically, grant of Trans States’ application will not result 

in a near-term increase in fuel consumption of ten million gallons or more. Thus, a grant of 

Trans States’ application will not constitute a “major regulatory action” within the meaning of 

Section 102(2)(c) of the National Environmental Policy Act as implemented by 14 C.F.R. 

Section 313.4. As a result, Trans States is not required to submit additional information about 

the energy consumption and energy efficiency consequences of this application.
WHEREFORE, Trans States Airlines, LLC respectfully requests that the Department 

grant it the requested exemption, or such other and further relief as the Department determines to 

be appropriate and consistent with the public interest.

Respectfully submitted,

____________________________

Lisa A. Harig

Counsel for Trans States Airlines, LLC
Certificate of Service

I hereby certify that on this 5th day of December 2014, a copy of the attached Application of 

Trans States Airlines, LLC for An Exemption was served on the following persons:

American francis.heil@aa.com; robert.wirick@aa.com 

World Airways BGillman@glah.com; mbenge@zsrlaw.com

NACA rpriddy@naca.cc; pdoell@naca.cc

Alaska, Horizon msinick@ssd.com

Evergreen esauer@ssd.com

Delta sascha.vanderbellen@delta.com; chris.walker@delta.com

UPS anita.mosner@hklaw.com

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

USAirways howard_kass@usairways.com; benjamin.slocum@usairways.com

Skywest gmurphy@crowell.com

Southern Air, Allegiant agoerlich@ggh-airlaw.com

Federal Express anbird@fedex.com; nssparks@fedex.com

Atlas Air rpommer@atlasair.com

Polar kevin.montgomery@polaraircargo.com

Spirit jyoung@yklaw.com

GoJet, Compass lharig@mklawdc.com

Air Wisconsin, Hawaiian, JetBlue jhill@dowlohnes.com

Amerijet jrichardson@johnlrichardson.com; jcanny@amerijet.com

Frontier matwood@cozen.com

DOT brett.kruger@dot.gov; esta.rosenberg@dot.gov

Dated: December 5, 2014

_________________________________

Lisa A. Harig