BEFORE THE 

UNITED STATES DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

) 

Application of ) 

) 

UNITED PARCEL SERVICE CO. ) 

) 

For an Allocation of One ) 

Frequency (U.S.-China) ) 

) 

Docket OST-2010-

APPLICATION OF UNITED PARCEL SERVICE CO. 

FOR AN ALLOCATION OF ONE FREQUENCY 

Communications with respect to this document should be served upon: 

Dontai L. Smalls 

United Parcel Service 

Public Affairs 

316 Pennsylvania Avenue, S.E. 

Washington, D.C. 20003 

E-mail: dsmalls@ups.com 

Scott C. Casey 

Michael J. Francesconi 

United Parcel Service Co. 

1400 N. Hurstbourne Parkway 

Louisville, KY 40223 

E-mail: scasey@ups.com 

mfrancesconi@ups.com 

Date: July 2,2010 

David L. Vaughan 

Danielle K. Fisher 

Kelley Drye & Warren LLP 

3050 K Street, N.W., Suite 400 

Washington, D.C. 20007 

(202) 342-8462 

Fax: (202) 342-8451 

E-mail: dvaughan@kelleydrye.com 

dfisher@kelleydrye.com 

Attorneys for 

United Parcel Service Co. 

NOTE: Any person wishing to support or oppose this Application must file an answer 

with the DOT's Documentary Services Division by July 19,2010. A copy of 

such Answer must be served upon United Parcel Service Co. and its counsel and 

all persons named on the attached Service List. Nevertheless, UPS will poll all 

persons on the service list for an immediate response. 
BEFORE THE 

UNITED STATES DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

) 

Application of ) 

) 

UNITED PARCEL SERVICE CO. ) 

) 

For an Allocation of One ) 

Frequency (US.-China) ) 

) 

Docket OST-2010-

APPLICATION OF UNITED PARCEL SERVICE CO. 

FOR AN ALLOCATION OF ONE FREQUENCY 

In accordance with Subpart C ofthe Rules of Practice (14 C.F.R 302.301 et seq.) 

ofthe Department of Transportation (the "Department" or "DOT"), United Parcel Service 

Co. ("UPS") hereby applies for an allocation of one (1) round-trip weekly US.-China allcargo frequency, enabling UPS to provide additional scheduled all-cargo (property and 

mail) air transportation services between the US. and China, and China and the world. 

Assuming that the DOT grants the Application of Federal Express for twenty (20) 

all-cargo frequencies, there are nine (9) Zone 1 or Zone 2 frequencies available to allcargo carriers. I UPS will utilize the frequency requested herein to serve the Shanghai 

market. UPS will serve the US. and Shanghai via Dubai and Cologne one (1) time per 

week using MD-l1 aircraft with a payload capacity of 202,000 pounds that are currently 

in UPS's fleet. UPS plans to commence service on September 20,2010. 

See Application of Federal Express Corporation, OST-2010-0149 (June 9, 2010). 
Application of UPS 

OST-2010-----

Page 2 of 4 

UPS holds certificate and exemption authority to serve China. 2 UPS currently 

operates forty-two (42) weekly U.S.-China all-cargo frequencies. 3 The frequency 

requested in this Application will complement those services and enable UPS to provide 

a service pattern required to meet the demands of this market. 

In support ofthis Application, UPS states as follows: 

1. UPS is a Delaware corporation whose current mailing address is 

1400 Hurstbourne Parkway, Louisville, Kentucky 40223. UPS holds certificates of 

public convenience and necessity authorizing it to engage in domestic and foreign all-

. . 4 

cargo air transportatIOn. 

2. 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's fitness. 

2 See Order 2001-1-6, Order 2004-10-8, Notice of Action Taken, OST-2009-0006 (Jan. 

16,2009), Notice of Action Taken, OST-2009-0177 (Aug. 20, 2009), Notice of 

Action Taken, OST-2010-0136 (May 25,2010). 

3 See Orders 2001-1-6, 2004-10-8 and 2005-3-40. 

4 See e.g., Order 2001-1-6, Order 2006-1-1 and Notice of Action Taken, OST-2009-

0006 (Jan. 16,2009). 
Application of UPS 

OST-2010-----

Page 3 of 4 

3. UPS is a citizen of the United States as that term is defined in the Federal 

Aviation Act. All officers, directors, shareholders of UPS, or persons who have the 

power to influence the management of UPS or persons holding any voting interest in UPS 

are U.S. citizens. 

4. The authority requested herein is consistent with the consolidated bilateral 

air services agreement between the United States and China and it is comparable to that 

which UPS currently operates and, thus, would not constitute a substantial change in 

operations requiring review under Part 204 of the Department's regulations. The 

proposed service would cause a near term net annual increase in aircraft fuel 

consumption of less than 10 million gallons and the annual fuel consumption is under the 

threshold set forth in Part 313 of the Department's Regulations which effectuate the 

Energy Policy and Conservation Act. 
Application of UPS 

OST-2010-___ _ 

Page 4 of4 

WHEREFORE, UPS respectfully requests that the Department allocate UPS one 

(1) round-trip weekly cargo frequency to enable UPS to provide additional scheduled allcargo air transportation services between the United States and China and beyond China 

to the world. UPS also requests that the Department grant such other and further relief as 

may be deemed just and necessary. 

Date: July 2,2010 

Respectfully submitted, 

tL .. :' ~\ L \:. x ~()t . .o 

David L. Vaughan 

Danielle K. Fisher 

Kelley Drye & Warren LLP 

3050 K Street, N.W., Suite 400 

Washington, D.C. 20007 

(202) 342-8462 

Fax: (202) 342-8451 

E-mail: dvaughan@kelleydrye.com 

dfisher@kelleydrye.com 

Attorneys for 

United Parcel Service Co. 
CERTIFICATE OF SERVICE 

I hereby certify that I have this day served the foregoing document by electronic 

mail on all persons named below: 

Name Representing E-mail 

Carl B. Nelson, Jr. American Carl.nelson@aa.com 

Hershel Kamen Continental Hershel.Kamen@coair.com 

Dan Weiss Dan.Weiss@coair.com 

Sametta Barnett Delta Sametta.C.Barnett@delta.com 

Alexander Van der sascha. vanderbellen@delta.com 

Bellen 

G. Bailey Leopard Jr. Federal Express gbleopard@fedex.com 

Edward W. Sauer Evergreen esauer@ssd.com 

C. Blair Berselli blair.berselli@evergreenairlines.com 

Mark W. Atwood Kalitta matwood@sherblackwell.com 

Kevin Montgomery Polar kevin.montgomery@polaraircargo.com 

Aaron Goerlich Southern Air agoerlich@ggh-airlaw.com 

Jason Maddux jmaddu~@ggh-airlaw.com 

Julie Oettinger United julie.oettinger@united.com 

Jeffrey Manley j effrey.manley@united.com 

Howard Kass US Airways howard kass@usairways.com 

Esta Rosenberg DOT Esta.Rosenberg@dot.gov