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 Service 

Agreement 

Dockets OST -2011 -0076 

OST -1999-6663 

APPLICATION OF UNITED PARCEL SERVICE CO. 

Communications with respect to this document should be sent to: 

Dontai L. Smalls 

United Parcel Service Co. 

Public Affairs 

316 Pennsylvania Avenue, S.E. 

Washington, DC 20003 

dsmalls@ups.com 

Emily Johnson 

United Parcel Service Co. 

1400 N. Hurstboume Parkway 

Louisville, KY 40223 

emilyjohnson@ups.com 

Dated: March 24, 2015 

Anita M. Mesner 

Jennifer M. Nowak 

HOLLAND & KNIGHT LLP 

800 171

h Street, N.W., Suite 1100 

Washington, D.C. 20006 

Phone: (202) 419-2604 

Fax: (202) 955-5564 

anita. mosner@hklaw. com 

Attorneys for UNITED PARCEL SERVICE 

co. 

NOTICE: United Parcel Service Co. will poll carrier representatives served with 

this application. 
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 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.-Mexico 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 

expedited relief from the Department. UPS will poll all interested carriers served with this 

Application. 

In support of this Application, UPS submits the following: 

1. UPS is a citizen 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 Air 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 Necessity 

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, 2001); 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 economic 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 this Certificate to include authority 

to operate scheduled foreign air transportation of property and mail between DFW and 

MEX.

3 As UPS intends to commence service on this routing in the very near future, UPS 

also requests exemption authority pursuant to the Department's streamlined licensing 

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 recently renewed by DOT Order 2013-7-7 (May 8, 

2013). UPS also holds exemption 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 expiration date of the added route with the balance of the 

Certificate, which is set to expire on July 8, 2018. 

4 See In the Matter of Streamlining Regulatory Procedures for Licensing U.S. and Foreign Carriers, 

Docket No. OST-2005-22228 (Aug. 26, 2005). 
Application of United Parcel Service, Co. 

U.S.-Mexico Authority (DFW-MEX) 

4. UPS proposes to operate seasonal service with 2 weekly flights between 

DFW and MEX, using a 8767 aircraft with a payload capacity of 132,000 pounds that is 

currently in UPS' fleet. UPS wishes to commence the services described herein on or 

before November 1, 2015, and therefore requests expedited approval of this Application. 

5. The requested authority is fully consistent with the terms of the U.S.-Mexico 

Agreement. While the U.S.-Mexico Agreement currently limits the number of available 

scheduled all-cargo designations, UPS understands that no U.S. all-cargo carrier is 

currently designated to operate between Dallas-Forth Worth and Mexico, and that this 

designation is available. UPS requests that the Department promptly designate UPS to 

provide service on this route. 

6. Granting UPS amended certificate and exemption authority and a 

designation to operate between Dallas-Fort Worth and Mexico City is clearly in the public 

interest. Approval will maximize the rights granted under the U.S.-Mexico Agreement and 

provide additional competitive options for shipping services between the U.S. and Mexico, 

which will benefit U.S. shippers. 

7. The grant of this Application will not constitute a "major" regulatory action 

under the Energy, Policy and Conservation Act of 1975, as defined by Section 313.4(a)(1) 

of the Department's regulations. The grant of this Application will result in an increase in 

fuel consumption of less than 10 million gallons. UPS has adequate fuel available for the 

services proposed. 

8. UPS agrees to accept and comply with all terms and conditions the 

Department routinely attaches to exemption and certificate authority for scheduled foreign 

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 certificate authority. 

WHEREFORE, UPS respectfully requests that the Department grant UPS the 

amended certificate authority, exemption authority, and designation requested herein, and 

grant such other further relief as the Department may deem necessary. 

Anita M. Mesner 

Jennifer M. Nowak 

Holland & Knight LLP 

Attorneys for United Parcel Service Co. 
CERTIFICATE OF SERVICE 

I hereby certify that I have this date served the foregoing document on the persons 

identified below by causing a copy to be sent by electronic mail. 

howard. kass@aa. com 

robert.wirick@aa.com 

dan. weiss@united.com 

steve. m orrissey@u nited. com 

nssparks@fedex. com 

gbleopard@fedex.com 

jrichardson@johnlrichardson.com (Counsel for Amerijet) 

jcanny@ameri jet.com 

jhill@cooley.com (Counsel for Hawaiian and JetBiue) 

perkmann@cooley.com (Counsel for Hawaiian and JetBiue) 

john. fredericksen@suncountry. com 

thomas. ting@suncountry.com 

bob.kneisley@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 (Counsel for Spirit) 

dheffernan@cozen.com (Counsel for Alaska) 

Jeremy.ross@alaskaair.com 

rsi lverberg@sgbdc.com (Counsel for ABX) 

Barbara. russell@virginamerica. com 

John. varley@virginamerica. com 

rpommer@atlasair. com 

brett. kruger@dot. com 

john.s.duncan@faa.gov 

cristinasa@state. gov 

Peter Ormerod 

March 24, 2015