BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON , D . C. Application of UNITED PARCEL SERVICE CO . for an amended Certificate of Public Convenience and Necessity, an Exemption, and a designation under the U.S. - Mexico Air Serv i ce Agreem e nt Dockets OST-2011 - 0076 OST-1999 -6663

APPLICATION OF UNITED PARCEL SERVICE CO. Communicati ons with resp ect to this document should be sent to : D ontai 

### L. Smalls United Parc el Servic e Co. Public Affa i rs 316 Pennsylvan ia Ave n ue, S . E. W as hi ngton , D C 20 0 03 dsmalls@ups.com Emily Johnson United Parcel Service Co. 1 40 0 N . H urstb o u me Parkway Lo u isville, KY 4 0223 emilyjohnson@ups . com

D ated : Ma rch 24 , 2015 A n ita M . M esner Jennifer M . Nowak HOLLAND & KNIGHT LLP 800 17 1 h Street , N .W., Suite 1100 Was h i n gton , D .C . 20006 P hone: (202) 419-2604 Fax : (202) 955-5564 anita .mosner@hklaw.com Atto rn eys for UNITED PARCEL SERVICE 

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NOTICE: United Parc el Servi ce Co . will poll carri er representative s served with th i s application .BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C. Application of UNITED PARCEL SERVICE CO . for an amended Certificate of Public Convenience and Necess i ty, an Exemption, and a designation under the U . S.-Mexico Air Service Agreement Dockets OST-2011-0076 OST-1999-6663

APPLICATION OF UNITED PARCEL SERVICE CO. Pursuant to 49 U.S .C. 

### §§ 40109 and 41101, and Part 302 of the Rules of Practice of the Department , United Parcel Service Co . ("UPS") hereby applies for an amendment of its U.S .- Mexi co Certificate of Public Convenience and Necessity and a related Exemption , as well as a designation under the U . S . -Mexico Air Transport Agreement ("U . S.-Mexico Agreement") , 1 authorizing it to provide scheduled foreign air transportation of property and mail between Dallas , Texas (DFW) and Mexico City, Mexico (MEX). UPS wishes to launch this service in the near future , and is accordingly seeking exped ited rel ief from the Department. UPS w i ll poll all interested carriers served with this App li cat i on . In support of this Application , UPS submits the following : 1 . UPS is a citize n of the United States as that term is defined in the Federal Aviation Act. UPS is a Delaware corporation whose mailing address is 1400 North

1 U. S. -Mexico Ai r Transport Services Agreement of August 15, 1960 , as amended and expanded .

### Application of United Parcel Service, Co . U . S . -Mexico Authority (DFW-MEX) Hurstborne Parkway , Louisville , Kentucky 40223 . All officers , directors , shareholders of UPS , persons who have the power to influence the management of the applicant , or persons holding any voting interest in the applicant are U . S. citizens . 2 . UPS holds various Certificates of Public Convenience and Neces si ty issued by the Department authorizing UPS to engage in all-cargo air transportation . See Order No . 2002 - 7-31 (July 25 , 2002), Order No . 2001-1-6 (January 10, 200 1); Order No . 98-6-22 (June 25, 1998) . As such, DOT has determined on numerous occasions that UPS is fit , willing and able to provide the proposed service and to conform to the provisions of the Federal Aviation Act and the rules , regulations and requirements of the Department thereunder. UPS requests that the Department take official notice, pursuant to 14 C . F. R. 

### § 302.24 of the econom i c authorities and data on file that support UPS' fitness . 3 . UPS currently holds authority to operate scheduled all-cargo service between the U .S. and Mexico pursuant to its Certificate of Public Convenience and Necessity for Route 569 , which was first issued in 1989 , and was most recently renewed in 2013. 2 

### UPS requests that the Department amend th i s Certificate to include authority to operate scheduled fore ig n air transportation of property and mail between DFW and MEX . 3 

### As UPS i ntends to commence service on this routing in the very near future , UPS also requests exemption authority pursuant to the Department's streamlined lice ns ing procedures, in order to commence this service while the Department considers its Certificate amendment request. 4

2 See Order 89-9-36 (Sep . 15 , 1989) , most recent ly renewed by DOT Order 2013-7-7 (May 8 , 2013) . UPS also holds exempt ion authority to operate between Los Angeles (LAX) and Guadalajara (GDL) . See Notice of Action Taken, Docket No . OST-2000-7282 (May 1, 2013) (a timely application for renewal was filed on December 19, 2014). 3 UPS asks that the Department align the exp i ration date of the added route with the balance of the Cert ificate , which is set to expire on Ju ly 8 , 2018 . 4 See In the Matter of Streamlining Regu l atory Procedures for Licensing U . S . and Foreign Carri ers , Docket No . OST-2005 -22 228 (Aug . 26 , 2005) .

### Applicat i on of United Parcel Service , Co . U . S .- Mexi co Authority ( DFW-MEX) 4. UPS proposes to operate seasonal service with 2 weekly flights between DFW and MEX , us i ng a 8767 aircraft with a payload capacity of 132 ,000 pounds that is currently i n UPS ' fleet. UPS wish es to commence the services descri bed herein on or before November 1 , 2015 , and therefore requests exped ited approval of this Applicat i on . 5 . T he requested authority i s fu lly consistent with the terms ofthe U .S . -Mexico Agreement. While the U.S.-Mexico Agreement current ly limits the number of available scheduled all-cargo des ignations , UPS understands that no U . S . all -cargo carri er is current ly designated to operate between Dallas-Forth Worth and Mexico , and that this designation is availab le . UPS requests that the Department promptly designate UPS to provide servi ce on th is route . 6 . Granting UPS amended certificate and exemption authority and a des i gnation to operate between Dallas-Fort Worth and Mexi co C ity is clea rl y in the pub lic interest. Approval will maximize the ri ghts granted under the U .S.-Mexico Agreement and provide additional compet itive options for shipping services between the U . S . and Mex ico , wh i ch will benefit U . S . shippe rs . 7. The grant of th is Application will not constitute a "major" regulatory action under the Energy , Policy and Conservation Act of 1975 , as defined by Secti on 313 .4(a )( 1 ) of the Department's regu l ati ons . The grant of this Applicat ion wi ll resu lt in an increase in fuel consumption of less than 10 million gallons . UPS has adequate fuel ava i lab le for the services proposed . 8. UPS agrees to accept and comply with all terms and conditions the Department rout i ne ly attaches to exempti on and certificate authority for sched uled fore i gn air transportation.Application of United Parcel Service , Co . U . S . -Mexico Authority (DFW-MEX) 9. UPS asks that the exemption authority requested be made effective immediately and remain in effect for two years, or until the Department grants the requested amended ce rtificate authority. WHEREFORE , UPS respectfully requests that the Department grant UPS the amended certificate authority, exemption authority, and des ignation requested herein , and grant such other further relief as the Department may deem necessary.

Anita M . Mesner Jennifer M. Nowak Holland & Kn ight LLP Attorneys for United Parcel Service Co .CERTIFICATE OF SERVICE I hereby certify that I have this date served the forego ing document on the persons ide ntifi ed below by causing a copy to be sent by electronic mail. howard .kass@aa .com robert .wi r ick@a a . com dan.we i ss@un ited . com steve .morrissey@united .com nsspa r ks@fedex. com gbleopard@fedex . com jrichardson@j o hn lrichardson .com (Counsel for Amerijet) jcanny@am eri jet.com jhill@cooley.com (Counsel for Hawaiian and JetBiue) perkmann@coo ley.com (Co unsel for Hawaiian and JetBiue) john.fredericksen@suncountry. com thomas . ting@suncountry .com bob .k ne i sley@wnco .com leslie.abbott@wnco .com matwood@cozen . com (Counsel for Frontier) slachter@cozen .com (Counsel for Frontier) jyoung@yklaw.com (Counsel for Spirit) dkirstein@yklaw .com (Co unse l for Spirit) dheffernan@cozen .com (Counsel for Alaska) Jeremy . ross@alaskaair . com rsi lverberg@sgbdc . com (Couns el for ABX) Barbara .russell@v i rg in ameri ca .com John . varl ey@vi rginameri ca .com rpommer@atlasair .com brett. kruger@dot. com john.s.duncan@faa .gov cristinasa@state .gov

Peter Ormerod March 24 , 2015