) 

for an emergency exemption pursuant to ) 

_4_9_u_.s_.c_.~§~4_0_10_9~(g~) 

________ ) 

APPLICATION OF ANTONOV AIRLINES 

FOR AN EMERGENCY EXEMPTION 

Communications with respect to this document should be sent to: 

March 16, 2015 

Sheryl R. Israel 

HOGAN LOVELLS US LLP 

Columbia Square 

555 Thirteenth Street, NW 

Washington, DC 20004 

+1 202 637 8898 

sheryl.israel@hoganlovells.com 

Counsel for 

ANTONOV COMPANY 

tla ANTONOV AIRLINES 

NOTICE: THIS APPLICATION IS BEING FILED PURSUANT TO THE EMERGENCY 

EXEMPTION PROCEDURES OF 14 C.F.R. § 302.311, WHICH AUTHORIZE 

THE DEPARTMENT TO ACT ON EMERGENCY EXEMPTION REQUESTS 

IMMEDIATELY. ANY PERSON INTERESTED IN FILING AN ANSWER IS 

REQUESTED TO DO SO IN THE ABOVE DOCKET IMMEDIATELY. 

COPIES OF THE SUBMISSION SHOULD BE SERVED ON THE PERSONS 

LISTED ABOVE AND ON THE ATTACHED SERVICE LIST. 

\\DC- 0270741000001 - 6474219 vi 
for an emergency exemption pursuant to ) 

_4_9~U~.S~.C~-~§~4_0_10_9~(9~) __________ ) 

March 16, 2015 

APPLICATION OF ANTONOV AIRLINES 

FOR AN EMERGENCY EXEMPTION 

Antonov Company Ua Antonov Airlines ("Antonov") hereby applies for an 

emergency exemption pursuant to 49 U.S.C. §§ 401 09(g) and 41703(c), to permit 

Antonov to operate a single one-way all-cargo charter flight transporting up to six (6) 

outsized aircraft engines, plus additional engines and ancillary parts and equipment, 

from Columbus (Rickenbacker Airport), Ohio to Seattle or Everett, Washington, 

March 19-23, 2015, using an AN-124-1 00 aircraft. Antonov respectfully requests 

expedited consideration and approval of this application to address a pressing 

commercial requirement of GE Aviation and Boeing Commercial Airplanes ("Boeing"). 

In support of this application, Antonov states the following: 

1. Antonov is a foreign air carrier that holds exemption authority to conduct 

charter all-cargo foreign air transportation between Ukraine and the United States, and 

between the United States and third countries pursuant to 14 C.F.R. Part 212. See 

Notice of Action Taken dated October 12, 2005 (Docket DOT-OST-1996-1454). 

2. GE Aviation has chartered Antonov to conduct a flight transporting 

outsized GEnx aircraft engines from Rickenbacker Airport to Seattle to offset a Boeing 

production line work stoppage situation. GE Aviation has asked Antonov to carry at 

\\DC- 0270741000001-6474219 vi 
192" x 135" x 147" each. Engines of these dimensions cannot be accommodated by any 

freighter aircraft operated by U.S. air carriers. Therefore, they need to be transported 

using Antonov's AN-124-1 00 aircraft. 

3. Although the primary purpose of this flight is to carry as many outsized 

GEnx engines as possible, to the extent that unused capacity is available on the aircraft 

based on the number of outsized GEnx engines that are ultimately ready for delivery, 

GE Aviation has requested that Antonov also carry other aircraft engine types and 

ancillary parts and equipment that are also required for Boeing airplane production in the 

Seattle area. 

4. GE Aviation has requested that Antonov conduct this flight carrying 

aircraft engines from Columbus to Seattle on or about March 20, 20151 to offset a 

production line work stoppage created by delayed engine deliveries from GE Aviation. 

Air transportation of GEnx engines from Rickenbacker Airport, near the GE Aviation 

facility where the engines are produced, to the Boeing production facilities in the Seattle 

area is the best solution to prevent further production line delays. Failure to deliver the 

engines by air would cause additional setbacks to the production and subsequent 

delivery of Boeing airplanes, which would cause financial harm to GE Aviation, Boeing 

Antonov requests a period of validity of March 19-23, 2015 to account for the potential for a 

slight acceleration in the schedule or for unforeseen flight or engine production delays. 

Furthermore, although the flight is currently anticipated to operate to Seattle (SEA) Antonov 

requests the flexibility to operate to Everett (PAE) to avoid the need to request a late notice 

amendment if that destination is ultimately chosen. 

\\DC- 027074/000001 -6474219 vi 
a. Grant of this application is in the public interest. Transportation of 

the engines by air will allow major American jet aircraft engine and airplane 

manufacturers to address production line disruptions as efficiently as possible and will 

help them meet airplane delivery commitments to customers. Surface transportation of 

the engines is not an economical or desirable option in this case given the distance 

between Ohio and Washington, coupled with the complications and permitting 

requirements associated with the truck movement of such large items. GE Aviation and 

Boeing must take every possible step to avoid additional production line delays and 

meet aircraft delivery commitments. Accordingly, it is critical that Antonov be authorized 

to use an AN-124-1 00 aircraft to address GE Aviation's and Boeing's requirements for 

the delivery of these engines to Seattle as soon as possible. 

b. Approval of the requested exemption authority is necessary to 

enable Antonov to respond to an emergency created by unusual circumstances. 

GE Aviation needs to transport outsized GEnx commercial aircraft engines from 

Columbus to Seattle to address a Boeing production line stoppage created by engine 

delivery delays. The sheer size of the engines, coupled with the distance between Ohio 

and Washington, forecloses the possibility of transporting these units on an expedited 

basis using surface transportation. In order to avoid unnecessary and costly additional 

delays, the engines need to be shipped by air, and because no civil aircraft operated by 

IIDC-027074100000!-64742!9v! 
granted, the transportation of GE aircraft engines from Columbus to Seattle will be 

unnecessarily delayed, adversely impacting GE Aviation, Boeing and their customers. 

6. Antonov's fitness and ability to carry out the proposed transportation has 

been amply demonstrated through its conduct of numerous outsized cargo charter 

operations over the past several years. By DOT Order 91-10-11, Antonov was first 

issued exemption authority jointly with Air Foyle Ltd., and has operated numerous 

outsized cargo charters to and from the United States since 1991. As noted above, 

Antonov holds independent exemption authority last renewed by Notice of Action Taken 

dated October 12, 2005. 

7. Grant of this application is consistent with Department precedent. The 

Department has previously granted emergency exemption authority to permit Antonov to 

conduct commercial flights between U.S. points on numerous occasions where 

AN-124-1 00 aircraft were similarly needed to deliver outsized cargo, including Boeing 

airplane and GE Aviation engine products, on an emergency basis. The Department 

has consistently found that approval of such requests is in the public interest. See. e.g., 

Notice of Action Taken dated October 11, 2002 (Docket DOT-OST-2002-13572); Notice 

of Action Taken dated August 28, 2002 (Docket DOT-OST-2002-13252); DOT Order 

2 Counsel for Antonov will contact the U.S. operators of large all-cargo aircraft set forth in the 

service list attached to this application to verify that each carrier cannot accommodate the 

cargo and does not oppose the grant of this application, and will promptly notify the 

Department of the polling results. 

\\DC - 027074/00000 I - 6474219 vI 
DOT-OST-2006-26749), January 23 and 26, 2007 (Docket DOT-OST-2007-27029), 

June 18, 2014 (Docket DOT-OST-2014-0106), February 10, 2015 (Docket 

DOT-OST-2015-0020), and February 27, 2015 (Docket DOT-OST-2015-0039 (granting 

Antonov exemptions for the transportation of GE90 and GEnx aircraft engines under 

similar circumstances). 

8. Section 302.311 of the Department's Procedural Regulations provides 

that the Department can act on an emergency exemption application immediately. In 

light of the exigent circumstances, Antonov respectfully requests expeditious processing 

and the immediate grant of this emergency exemption application in order to provide 

assurances to GE Aviation and Boeing that Antonov will be permitted to transport the 

GEnx aircraft engines on the required date. 

\\DC. 0270741000001 -6474219 vi 
Airport), Ohio to Seattle or Everett, Washington, March 19-23, 2015, using an 

AN-124-1 00 aircraft, as described herein, and grant such other and further relief as the 

Department deems to be consistent with the public interest. 

1\DC. 027074/000001-6474219 vi 

Sheryl R. Israel 

HOGAN LOVELLS US LLP 

Columbia Square 

555 Thirteenth Street, NW 

Washington, DC 20004 

+1 202 637 8898 

sheryl.israel@hoganlovells.com 

Counsel for 

ANTONOV COMPANY 

tla ANTONOV AIRLINES 
rpommer@atlasair.com; john@mietuslaw.com; sascha.vanderbellen@delta.com; 

sametta. c. barnett@delta. com; sllunsford@fedex. com; sharon. pasley@fedex. com; 

charles.donley@squirepb.com; magitlitz@fwia.com; jmaloney@fwia.com; 

matwood@cozen. com; lstauffer@wallaceair. com; nwallace@wallaceair. com; 

rzerkel@lac.lynden. com; jdavis@lac.lynden. com; mwiegele@nac. aero; 

kevin.montgomery@polaraircargo.com; agoerlich@ggh-airlaw.com; 

dan.weiss@united.com; steve.morrissey@united.com; pdoell@naca.cc; 

herb. herzog @faa. g ov; patrick. crowley@faa. g ov 

Jonathan Echmalian 

1\DC • 027074 '000001 • 6474219 vi