BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_________________________________________ )

Application of )

)

EASTERN AIR LINES GROUP, INC. ) DOCKET OST

- 201 4

- 0012/13

)

for Certificate s of Public Convenience )

and Nec essity ( Interstate and Foreign )

Passenger Charter Service) )

_______________________________________ __ _)

MOTION OF EASTERN AIR LINES GROUP, INC.

TO SHORTEN ANSWER PERIOD

Communications with respect to this document should be sent to:

Edward J. Wegel

President and CEO

EASTERN AIR LINES GROUP, INC.

Building 5A, Miami Int’l Airport

Miami, FL 33142

(305) 869

- 4249

ed.wegel@easternairlines.aero Jo hn R. Mietus, Jr.

Law Office of John Mietus, LLC

6701 Democracy Blvd., Suite 300

Bethesda, MD 20817

- 750 0

(202) 747

- 5212

john@mietuslaw.com

Counsel for EASTERN AIR LINES

GROUP, INC.

NOTICE: Eastern requests than answers to this motion be filed no later

than March 5, 2015. Eastern is polling U.S. carriers served with this

application.

February 2 6 , 2015BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_________________________________________ )

Application of )

)

EASTERN AIR LINES GROUP, INC. ) DOCKET OST

- 201 4

- 0012/13

) February 2 6 , 2015

for Certificate s of Public Co nvenience )

and Necessity ( Interstate and Foreign )

Passenger Charter Service) )

_______________________________________ __ _)

MOTION OF EASTERN AIR LINES GROUP, INC.

TO SHORTEN ANSWER PERIOD

Pursuant to Rule 11 of the Department's Rules of Practice , 14 C.F.R.

§ 302.1 1

, Eastern Air Lines Group, Inc. respectfully moves the Department to

shorten the answer period associated with any show cause order it may issue

with respect to Eastern’s requests for interstate and foreign passenger

charter authority.

On January 28 , 2014 Eastern applied for Certificates of Public

Convenience and Necessity pursuant to 49 U.S.C. § 41102 authorizing

Eastern to engage in interstate and foreign charter air transportation of

person s , property, and mail. Since that initial fi ling, Eastern has provided

updates on its financing, management, and other issues relating to its

fitness, and Eastern’s applications are ripe for action by the Department.Eastern

Motion

Page 2

Eastern also anticipates that its FAA certification will be complete as early

as A pril 15, 2015.

Eastern wishes to commence revenue operations immediately once

FAA certification is complete , and in reviewing the market, Eastern

anticipates that a substantial portion of customer requests will involve

foreign air transportation. Eastern therefore requests that the Department,

in any show cause order it issues tentatively granting E astern 's request for

interstate and/or foreign charter authority, reduce its standard fourteen

- day

objection and seven

- day answer period for such order s to five days ( for

objection s ) and three days ( for answer s thereto). This will decrease the

objection/answer period by sixteen days, which is of primary importance to

Eastern’s foreign air transportation plans, since any tentative grant of

foreign authority will be subject to Presidential review under 49 U.S.C. §

41307 for up to 60 additional days. While th e primary ration a le for the

requested relief relates to foreign authority , for administrative convenience

Eastern proposes identical objection/answer periods f or action on both its

interstate and foreign certificate applications. As in the two cases cited

below, Eastern will poll U.S. carriers served with this Motion regarding their

position on it and will report the results to the Department.

Last year t he Dep artment granted similar relief to two carriers. By

Order 2014

- 12

- 8 (at 10), the Department shortened the answer period to its

tentative finding that Sky King was fit to resume interstate and foreign