BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, DC 

Application of 

VIRGIN AMERICA INC. 

) 

) 

) Docket No. ______ _ 

) 

for waiver pursuant to Section 1-2 of Part 241 ) 

""-of,,,-,th=e-,,=,D=eJ;:::pa=I=tI=ne=n=t'-,=,-s-=.R=ecc.gu=l=at=io=n=s ______ ) 

PETITION OF VIRGIN AMERICA INC. FOR REVIEW OF STAFF 

ACTION UNDER 14 C.F.R. § 385.30 AND CONTINGENT 

MOTION TO STAY EFFECTIVENESS OF STAFF ACTION 

Communications with respect to this document should be sent to: 

John Varley 

Senior Vice President & 

General Counsel 

Virgin America Inc. 

555 Airport Boulevard, Suite 500 

Burlingame, CA 94010 

(650) 762-7108 

(650) 762-7001 (fax) 

john.varley@virginamerica.com 

January 31,2011 

John E. Gillick 

Jonathon H. Foglia 

Zuckert, Scoutt & Rasenberger L.L.P. 

888 Seventeenth Street, N.W., Suite 700 

Washington, DC 20006 

Tel: (202) 973-7939 

Fax: (202) 342-0683 

j egillick@zsrlaw.com 

jhfoglia@Zsrlaw.com 

Counsel for 

Virgin America Inc. 
~ ,

Application of 

VIRGIN AMERICA INC. 

BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, DC 

) 

) 

) Docket No. _______ _ 

) 

for waiver pursuant to Section 1-2 of Part 241 ) 

~o"'-f_""th_':!:e'_'D::o..e"".lp"""artm=""'e""'n~t:....::'s'-'R"-!:e"""gu=l~at"'"io""'n"""sc_ ______ .) 

PETITION OF VIRGIN AMERICA INC. FOR REVIEW OF STAFF 

ACTION UNDER 14 C.F.R. § 385.30 AND CONTINGENT 

MOTION TO STAY EFFECTIVENESS OF STAFF ACTION 

Pursuant to Subpart C of Part 385 of the Department's regulations, Virgin America Inc. 

("Virgin America") hereby respectfully petitions for review of the staff action taken by the 

Director, Office of Airline Information ("OAr'), Bureau of Transportation Statistics, Research 

and Innovative Technology Administration ("Decision"), denying Virgin America's request for a 

waiver from Latin American entity reporting. 1 As demonstrated herein, the Decision is contrary 

to the Department's rules and directly applicable precedent, is substantially deficient, and 

involves a substantial and important question of policy. The Decision should, therefore, be set 

aside, and Virgin America's request for a waiver should be granted forthwith. 

Furthermore, to the extent the staff action is not automatically stayed under the provisions 

of 14 C.F.R. § 385.32, Virgin America moves to stay such action pending disposition of this 

petition by the Department, given that the Decision: (i) establishes an immediate deadline of 

February 15, 2011, for Virgin America to submit Form 41 data under the Latin American 

1 Although the Decision is dated January 21,2011, it was not served on Virgin America until January 24,2011, by 

electronic transmission. 

1 
operating entity; and, more importantly, (ii) is silent as to the effect a petition for review shall 

have on the effectiveness of the action, notwithstanding the requirements of 14 C.F.R. § 385.4 

that staff actions "state whether the filing of a petition shall preclude the action from becoming 

effective." As a consequence, Virgin America is compelled to include this contingent motion 

with its petition for review. 

Background 

Virgin America began service in August 2007, and has, until recently, only provided 

domestic air transportation. Virgin America launched international service from San Francisco 

and Los Angeles to Toronto in June 2010, but, under Part 241 of the Department's regulations, 

Canadian transborder operations are to be reported with "the domestic entity," so this limited 

international service did not impose any additional, burdensome and costly reporting 

requirements on Virgin America. See Subsection 21(g). 

On December 16, 2010, Virgin America began very limited service to Mexico, with five 

weekly roundtrips in the San Francisco (SFO}-San Jose del Cabo (SJD) city pair market (or a 

total of 12 roundtrip flights in December and, indeed, the entire Fourth Quarter of 2010), 

accounting for only 0.7% of Virgin America's total capacity for the month of December. 

Beginning on January 19-20, 2011, Virgin America began five weekly roundtrip flights in the 

Los Angeles (LAX)-Cancun (CUN) city pair market and three weekly roundtrip flights in the 

SFO-CUN city pair market. With the addition of this Cancun service, all of Virgin America's 

Mexico flights account for only two percent of its total scheduled capacity for the reportable 

January 2011 period. On a quarterly basis, these Virgin America flights account for only 2.7 

2 
percent of the carrier's total scheduled capacity for the three month period ending on March 31, 

2011. 

Given the very limited scope of its service to Mexico, Virgin America requested a waiver 

(copy enclosed as Exhibit A) from the otherwise applicable requirement that the traffic, financial 

and other data associated with these very limited Mexican operations be compiled and reported 

separately from the rest of Virgin America's operations under the Latin American operating 

entity. In that waiver request, Virgin America set forth the extremely limited nature of its 

Mexican operations, demonstrated the burden and costs associated with setting up a Latin 

American operating entity, explained that its Mexico service would be only extremely 

remarkably small part of the overall Latin American system of records compiled by the 

Department (estimated at only 0.3 percent of the ASMs reported by all other u.s. carriers in the 

First Quarter of 2010 for their Latin American operating entities), articulated the manner in 

which users would be able to retrieve Latin America traffic data from Virgin America's traffic 

reports and pointed out the Department had previously granted similar waivers to other carriers 

until their Latin American operations had grown to a point that it was in the public interest to 

report that information as a separate operating entity. 

In this latter regard, and as Virgin America noted in its waiver request, the Department 

granted a nearly identical waiver to JetBlue on July 29, 2004, permitting JetBlue to report traffic 

and financial data for its three daily round-trip flights to the Dominican Republic within the 

"Domestic" operating entity. A copy of the application of and waiver granted to JetBlue are 

attached as Exhibit B. In granting the waiver, the Department stated that the "reason for the 

grant of the waiver is the very limited scope of JetBlue's Latin American operations," and 

3 
indicated that the ''waiver will remain in effect until JetBlue increases service to the Latin 

American entity." Id.2 

However, in a January 21, 2011, letter that failed to provide any meaningful 

consideration or examination of the matters raised in Virgin America's request, much less any 

mention of the clearly applicable JetBlue precedent, the Director of the Office of Airline 

Information denied the waiver request stating that, acting under authority delegated by Sections 

385.19(d) and (f),3 the office "believes it is [imperative] to keep our data complete for analytical 

purposes." The Decision merely asserted, without any analysis whatsoever, that the 13 weekly 

roundtrip flights operated by Virgin America is a "significant" service and the limited grant of 

the requested waiver would create a "significant" data gap making market analysis a problem for 

data users. A copy of the Decision is enclosed as Exhibit C. 

The Decision Must Immediately Be Reviewed 

And Reversed For Several Important Reasons 

Section 385.4 of the Department's regulations requires that staff action taken pursuant to 

assignment under Part 385 must, among other things, contain (i) a brief reference to the right of 

the aggrieved parties to petition the Reviewing Official for review under applicable procedural 

rules, including a statement of time within which such petitions for review must be filed and (ii) 

all findings, determinations and conclusions which would be required or appropriate if they were 

issued by the Secretary of Transportation. Not only does the Decision fail to provide either the 

required notice or the findings, determinations and conclusions required by Section 385.4 for all 

staff actions made using authority delegated by the Secretary of Transportation, but, more 

2 The Department reconsidered the wai~er on March 22, 2005, or about nine months after JetBlue had begun its 

Dominican Republic service. 

3 The waiver sought by Virgin America should have been acted upon under the authority delegated to the Director 

by Section 385. 19(c), rather than (d) or (t), as had been correctly cited in the JetBlue decision. See Exhibit B. 

4 
importantly, it conflicts with directly applicable Department precedent, is substantially deficient 

in several respects and involves a substantial and important policy question concerning requests 

for waivers from the otherwise applicable requirements of Part 241 of the Department's 

regulations. The Decision should, therefore, be reversed and the waiver requested by Virgin 

America granted until Virgin America "increases service to the Latin American entity" as the 

Department did in the JetBlue case. 

As Virgin America pointed out in its waiver request and also discussed supra, the waiver 

requested by Virgin America is virtually identical to the waiver the Department considered and 

granted to JetBlue in 2004. Indeed, JetBlue requested and was granted a waiver covering 21 

weekly flights compared to the only 13 weekly flights that Virgin America operates to and from 

Mexico (or only 63 percent of the flights operated by JetBlue). It defies credulity for the 

Department to, on the one hand, grant JetBlue a waiver for 21 weekly flights on the basis of the 

"very limited scope of JetBlue's Latin America operations" and, on the other hand, deny such a 

request to a carrier operating far fewer Latin America flights than the carrier the Department 

previously determined had a "very limited" operation in Latin America. 

Although Virgin America specifically raised this precedent in its waIver request, 

including acknowledging that the waiver would be withdrawn at some point in the future once 

Virgin America's operations had grown to a point that it was in the public interest to report that 

information as a separate operating entity, the Decision neither mentions nor discusses the 

JetBlue precedent that should, without question, be dispositive of the Virgin America waiver 

request. On this basis alone, the Decision must be reviewed and Virgin America's waiver 

request granted forthwith. 

5 
Similarly, the Decision fails to provide any, much less the required, reasoned, analysis of 

the particular and "unusual" (in the words of Section 1-2) facts and circumstances concerning a 

request for a waiver from the unnecessarily burdensome imposition of Form 41 Latin American 

operating entity reporting requirements where the operation constitutes only a very small fraction 

of Virgin America's total scheduled flying - 0.7 percent in December 2010,2 percent in January 

2011 and 2.7 percent for the First Quarter of 2011. Moreover, as the Department well knows 

(and contrary to the erroneous suggestions contained in the Decision), data users of the 

Department's Form 41 data will be able to easily retrieve Virgin America's Mexico traffic 

statistics by segment-specific airports, thus permitting these data users to continue to obtain this 

data without any "gaps." 

Balanced against this very limited amount of data to be categorized under the Latin 

American operating entity for all carriers (estimated at only 0.3 percent of the ASMs reported by 

all other U.S. carriers in the First Quarter of 2010) is the significant burden that will be placed 

upon Virgin America to develop an entirely new and separate set of accounting systems for a 

Latin American operating entity. Search as one may in the Decision, however, and there is 

absolutely no mention, much less discussion and analysis, of what should have been a critically 

important consideration in the Decision - precisely the type of findings, determinations and 

conclusions that Section 385.4 requires be included in any decision by a staff member involving 

an authority that has been delegated by the Secretary of Transportation. And, the failure to 

address these considerations is all the more important when these very same matters were raised 

by JetBlue in its waiver request and formed the basis of the Department's decision to grant 

JetBlue the waiver now sought by Virgin America in this petition. These decisions involving 

authority granted to the Secretary of Transportation by the Congress and delegated by the 

6 
Secretary to a particular Departmental Office demand the very same thoughtfulness and 

thoroughness as go into Secretarial decisions, a thoughtfulness and thoroughness that is clearly 

missing from the Decision and for which Departmental precedent already existed. This is the 

reason for the requirements contained in Section 385.4, and the Decision should be reversed on 

this basis as welL 

Finally the Decision raises a substantial and important question of Departmental policy. 

Section 1-2 of the General Accounting Provisions, contained in Part 241 of the Department's 

regulations, 14 C.F.R. Part 241, upon which JetBlue and Virgin America based their requests, 

creates a mechanism by which an air carrier or a group of air carriers may request a waiver "from 

any provision of this system of accounts or reports" upon a showing that the waiver is in the 

public interest and meets three specified criteria. This waiver provision has been in Part 241 for 

at least four decades and has been used by the Civil Aeronautics Board and the Department on 

numerous occasions to respond to "existing peculiarities or unusual circumstances" that "warrant 

a departure from a prescribed procedure." 

The responsibility for making such waiver decisions has been delegated by the Secretary 

of Transportation to the Director of OAI, allowing the Director to: 

(c) Waive any of the accounting, reporting, and record retention requirements 

upon a showing of the existence of such facts, circumstances or other 

grounds, and subject to such limitations or conditions as may be prescribed 

for waivers in the applicable regulations, unless such authority is otherwise 

specifically assigned. 

49 C.F.R. § 385.19(c) 

Acting under such delegated authority, the Assistant Director of OAI granted JetBlue 

precisely the same waiver requested by Virgin America. Moreover, the explanation contained in 

7 
the Virgin America Decision failed to address, in any manner whatsoever, either the clearly 

applicable letBlue precedent or the unique facts and circumstances relating to Virgin America's 

request. Instead, the Decision merely asserted that the missing data would create a significant 

data gap making market analysis a problem for data users - a "gap" that was, by definition, less 

than the data "gap" created when the Department granted a waiver to letBlue with its greater 

number of weekly operations. 

Where, as here, Virgin America has been denied a requested waiver based on facts even 

more compelling than when the Department's delegated official made each of the findings 

required by Section 1-2 and then granted a waiver to letBlue "until letBlue increases service to 

the Latin American entity," a substantial and important question has been raised as to whether 

any meaning and integrity remains in the Form 41 waiver process. Indeed, if this Virgin 

America decision is not reviewed and the Department's clearly applicable letBlue precedent 

followed, there is a serious question as to whether the carriers that are required to follow the Part 

241 requirements should have any confidence in the waiver process provided in Section 1-2 

going forward. Once again, this Decision must be reviewed and reversed by the Reviewing 

Official in the manner specified in Part 385. 

8 
WHEREFORE. for the foregoing reasons, Virgin America Inc. urges the Department to 

review the Decision, grant Virgin America's request for a waiver as more fully described in its 

January 7, 2011, letter and, to the extent necessary, stay the effectiveness of the staff action 

pending disposition by the Department. 

January 31,2011 

Respectfully submitted, 

John E. Gillick 

Jonathon H. Foglia 

Zuckert, Scoutt & Rasenberger L.L.P. 

888 Seventeenth Street, N.W., Suite 700 

Washington, DC 20006 

Tel: (202) 973-7939 

Fax: (202) 342-0683 

jegillick@zsrlaw.com 

jhfoglia@zsrlaw.com 

Counsel for 

Virgin America Inc. 

9 
VERIFICATION 

Pursuant to Section 1001 of Title 18 of the U.S. Code, I, John E. Gillick, in my individual 

capacity and as the authorized representative of the petitioner, have not in any manner knowingly 

and willfully falsified, counseled or failed to disclose any material fact or made any false, 

fictitious or fraudulent statement or knowingly used any documents which contain such 

statements in connection with the preparation, filing or prosecution of this petition. I understand 

that an individual who is found to have violated the provisions of 18 U.S.C. § 1000 shall be fined 

or imprisoned not more than five years, or both. 

ohn E. GIllIck 

January 31,2011 
Certificate of Service 

I hereby certify that a copy of the foregoing Petition and Contingent Motion of Virgin 

America Inc. was served this 31 st day of January, 2011, by electronic transmission, on: 

Ms. Anne Suissa 

Director, Office of Airline Information 

Bureau of Transportation Statistics 

Research and Innovative Technology Administration 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

anne. suissa@dot.gov 

Dr. Steven K. Smith 

Associate Administrator and Director (Acting) 

Bureau of Transportation Statistics 

Research and Innovative Technology Administration 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

steven.k.smith@dot.gov 

~~Foglia 

Washington, DC 
EXHIBIT A 
america 

BY ELECTRONIC MAIL 

Anne Suissa 

Director 

Office of Airline Information 

Bureau of Transportation Statistics 

January 7,2011 

Research and Innovative Technology Administration 

U.S. Department of Transportation 

1200 New Jersey Ave., S.E. 

Washington, D.C. 20590 

Dear Ms. Suissa: 

As discussed with you earlier today, Virgin America Inc. ("Virgin America") is 

requesting a waiver from the otherwise applicable System of Accounts and Reports for 

large certificated air carriers, 14 C.F.R.Part 241, as more fully described herein. Virgin 

America respectfully submits that a grant of this waiver would be in the public interest. 

Under the Department's reporting requirements (Sections 21-25 of the System of 

Accounts and Reports), large certificated air carriers must regularly submit detailed onflight market and nonstop segment data as well as financial results to the Department, with 

separate data reported for each applicable operating entity (Domestic, Latin America, 

Atlantic and Pacific). Until last month, all of the markets served by Virgin America fell 

within the "Domestic" operating entity and, therefore, Virgin America's traffic and financial 

data have not been reported under separate operating entities) 

On December 16, 2010, Virgin America launched limited service to Mexico, with 5 

weekly roundtrips in the San Francisco (,'SFO")-San Jose del Cabo ("SJD") city pair. Virgin 

America plans to introduce 5 weekly roundtrip flights in the Los Angeles ("LAX")-Cancun 

("CUN") city pair and 3 weekly roundtrip flights in the SFO-CUN city pair beginning on 

January 19-20,2011. 

These additional flights will, however, constitute only a very small fractiOi1 of Virgin 

America's total scheduled flying. For example, Virgin America projects that it will operate 

Although Virgin America serves Toronto, Canada, under the Department's regulations "the domestic 

entity ... shall also include Canadian transborder operations." See Subsection 21(g). 

5:,)5 Airport Boukward T 650.762.7000 www.virginamerica.Gom 

Burlingame, CA 940'j 0 F 650,7(32.7001 
Anne Suissa 

January 7, 2011 

Page 2 

no more than 12 roundtrip flights in the SFO-SJD market for the reportable December 

2010 period, accounting for about 0.7% of its total capacity. Virgin America further 

anticipates that, with the addition of CUN service, all of its Mexico flights will account for no 

more than 2% of its total scheduled capacity for the reportable January 2011 period. 

Furthermore, when measured on a quarterly basis, Virgin America projects that these 

flights will account for only 2.7% of the carrier's total scheduled capacity for the three 

month period ending on March 31, 2011. 

Virgin America would ordinarily be required to separately report data for these 

flights under the "Latin America" operating entity. However, and as set forth above, these 

flights will be the only Virgin America operations that do not fall within the Domestic 

operating entity. As a consequence, the added cost to Virgin America of setting up an entire 

set of separate accounting records for a Latin American entity that is only a very small part 

of Virgin America's scheduled system clearly outweighs any benefits that will be provided 

to the overall Latin American system of records compiled by the Department. Indeed, the 

ASMs that will be flown by Virgin America in the first quarter of 2011 in Mexico constitutes 

only 0.3 percent of the ASMs reported by all other U.S. carriers in the first quarter of 2010 

for their Latin American entities. 

Turning to the criteria that must guide the Department in its review of this waiver 

request under Section 1-2 of Part 241, Virgin America submits that these particular 

circumstances warrant a departure from the otherwise applicable reporting procedures. 

Operating and financial results for Mexico will constitute but a small portion of Virgin 

America's total reportable data and, in any event, users of the Department's Form 41 data 

will be able to easily retrieve Virgin America's Mexico traffic statistics by segment specific 

airports. As a consequence, the alternative method proposed by Virgin America (i.e., 

inclusion of the operating and financial results in the Domestic operating entity) will result 

"in a substantially equivalent portrayal of operating results or financial condition, 

consistent with the principles embodied in the provisions of this system of accounts and 

reports." Id. Moreover, the alternative procedure which Virgin America proposes will 

effectively maintain the "uniformity in substantive results as between air carriers." Id. 

Furthermore, it is not in the public interest for Virgin America to expend significant 

resources to set up an entirely separate set of accounting systems for such a limited 

amount of information. Finally, it is Virgin America's understanding that similar waivers 

have been granted to carriers in the past until their Latin American operations had grown 

to the point that it was in the public interest to report that information as a separate Latin 

American entity. 

For the foregoing reasons, Virgin America respectfully urges the Department to 

grant its waiver to the extent necessary to allow the carrier to include operating and 

T 

F 
AnneSuissa 

January 7, 2011 

Page 3 

financial results for these very limited Mexican operations within the Domestic operating 

entity. 

Please contact me at 650-762-7108 if you have any questions related to this request. 

Very truly yours, 

555 Airport Boulev8fej T 650,762,7000 www.vlrqjnarnE":r!ca.com 

Burlingarne, Gf\ 940'10 F 650,762.700'1 
EXHIBIT B 
jet BlueMay2S,2004 

Department of TranspolUtlOn 

Office of Airline Information 

K-2S 

Room 412S 

Bureau ofTransponation Statistics 

400 7Ci Street S. W. 

Wuhington, D. C. 20590 

IetBlue Airways Corporation was recently granted authority by the Department of 

l'Iansportation to conduct scheduled WVice to the Dominican Republic, which we plan 

to commence in June 2004. ~tly, we have scheduled two daily round trip flights 

between New York. and Santiago and ODt daily round trip flight between New York and 

Santo Domingo. Thtl total available seat miles gertetated on those routes is initially going 

to reprcllc:nt apPl'QJtimatcly 1.5% of our total system. capacity, and will decline as we 

continue to add more domestic:: service. 

We cummtly only report the do~fltic f:ntity on Form 41. As the Dominican operations 

will repreeent a su<:h a small percentage of out $ystem capacity BOd Hpar~tely reponing 

these operations would disclose the flight aegmc:;nt profitability for these two city pain, 

we IltO requesting an exemption to tl\ertqllirem~nt outlined 14 CPR Section 3241.21(g) 

for separliWly reporting I Latin America in our Fonn 41 filings. 

We appreciate YOitt' consideration of this requellt Please contact me 203.656-7604 if you 

have any questions or require any additional data. 

~ . Holly Nelson 

VP & Controller 

JetBlua ~I/WtIya corpOrlIUon 19 Old Kine- HICIlWII)' SoIIth, Sulle <!~. Oirilfl, CT ()682Q T.I 1203) 6!6-7600 ~1Ilt (20') 656-744/1 

To fly, _.jltbIUMom or 1(800) JETB\.UE 
V,$. oepanment 01 Transponotlon 

Bureau of T~n ItatllffCi 

Ms. Rolly Nelson 

VP & Controller 

letBlue Airways CotpOfation 

19 Old Kings Highway Sooth 

Suite 23 

Darien, cr 06820 

Dear Ms. Nelson! 

J.l 29 im4 

Thi. letter grant!! your request that JetBlue be allowed to report its two daily New York~ 

Santiago. DominiCM Republic flixhts and its one daily New York-Santo Domingo flight 

in the Domestic Bntity. The waiver will remain effective until JetBlue increases service 

to the Latin America entity. 

The reason focthe grant of the waiver is the very limjredscope of JctBJue's Latin 

AmMca operations. This action is taken under authority pnled by 14 CPR ,section 

385.19(e). If you have any qge.stions. please contsct Mr. :&mi~ Stankus at 

amtm1,stankus(j!btsl~V or at (202) 366-4387. 

SinCCll:ly, 

cJJDJ/7J." 

Donald W. Bright 

~ 

Assistant Director 

Airline Information 
EXHIBIT C 
U.S. Department 

of Transportation 

Research and 

Innovative Technology 

Administration 

John Varley 

Senior Vice President and General Counsel 

Virgin America 

555 Airport Boulevard 

Burlingame. CA 94010 

Dear Mr. Varley: 

1 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

January 21, 2011 

We are denying your request, dated January 7, 2011 seeking a waiver for Virgin America from 

Latin America entity reporting. 

We reviewed your reasons for the waiver request and consulted with the DOT offices that use 

entity data. The Office of Airline Information (OAl) believes it is imperitive to keep our data 

complete for analytical purposes. While Virgin America operated only 12 round trips to Mexico 

in December, it soon will be operating 13 weeldy round trip flights to Mexico with large aircraft. 

This is a significant service and the missing data would create a significant data gap making 

market analysis a problem for data users. 

Your Latin Americ entity code is 11020. The strut date for your Latin America entity reporting is 

December 16,2010. Your first report requiring a break-out of Latin Entity data is your 

December P-12(a) Fuel Consumption by Type of Service and Entity. which was due on January 

20,2011. T-100 traffic report for December are due on January 30,2011. Quarterly FOlID 41 

fmaneial reports are due on February 10,2011. 

OAl is extending the due dates for all Virgin America's December reports to February 15,2011. 

Since Virgin America did not include Latin America fuel use on its December Schedule P-12(a), 

we are expecting a revised report by February 15,2011. 
This action is taken under authority delegated by 14 CPR 385.19(d) and (f). You may file a 

petition for reconsideration within 10 days of the date of this letter in accordance to the 

provisions of 14 CPR 302.14. 

Sincerely, 

Anne Suissa 

Director 

Airline Information 

2