BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

UNITED PARCEL SERVICE CO. 

for a Certificate of Public Convenience 

and Necessity and an Exemption, and 

a designation under the U.S.-Vietnam 

Air Service agreement 

Docket OST-2011-

APPLICATION OF UNITED PARCEL SERVICE CO. 

Communications with respect to this document should be sent to: 

Dontai L. Smalls 

Michael J. Francesconi 

United Parcel Service Co. 

Public Affairs 

316 Pennsylvania Avenue, S.E. 

Washington, DC 20003 

dsmalls@ups.com 

mfrancesconi@ups.com 

Scott C. Casey 

United Parcel Service Co. 

1400 N. Hurstboume Parkway 

Louisville, KY 40223 

scasev@ups.com 

Anita M. Mosner 

Jennifer M. Nowak 

HOLLAND & KNIGHT LLP 

2099 Pennsylvania Avenue, N.W., Suite 100 

Washington, D.C. 20006-6801 

Phone: (202)419-2604 

Fax: (202) 955-5564 

anita.mosner@hklaw.com 

Attorneys for UNITED PARCEL SERVICE 

CO. 

Dated: July 19, 2011 

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 a Certificate of Public Convenience 

and Necessity and an Exemption, and 

a designation under the U.S.-Vietnam 

Air Service agreement 

Docket OST-2011-

APPLICATION OF UNITED PARCEL SERVICE CO. 

United Parcel Service Co. ("UPS"), pursuant to 49 U.S.C. §§ 40109 and 41101, 

and Part 302 of the Rules of Practice of the Department of Transportation (the 

"Department" or the "DOT"), hereby applies for a Certificate of Public Convenience and 

Necessity and an Exemption, and a designation authorizing it to provide foreign air 

transportation of property and mail between the United States and Vietnam and between 

Vietnam and any point or points, and to provide charter air transportation as authorized 

under the Air Transport Agreement between the United States and the Socialist Republic 

of Vietnam ("U.S.-Vietnam Agreement") and DOT'S charter regulations. 

As explained in greater detail below, 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 

Hurstborne Parkway, Louisville, Kentucky 40223. All officers, directors, shareholders of 
Application of UPS for Certificate, Exemption and Designation 

Page 2 

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. The precise authority requested by UPS is as follows: 

(a) Scheduled international all-cargo air transportation from points behind the 

United States via the United States and intermediate points to a point or points in 

Vietnam and beyond, 

(b) between Vietnam and any point or points; and 

(c) Charter international all-cargo air transportation between any point or points in 

the United States and any point or points in Vietnam and between any point or points in 

Vietnam and any point or points in a third country or countries. 

4. Granting UPS certificate and exemption authority and a designation is 

clearly in the public interest. There are currently few options for all-cargo service 

between the U.S. and Vietnam. The new UPS service will bring needed competition to 

the market, improving the convenience of shipping to and from Vietnam. 
Application of UPS for Certificate, Exemption and Designation 

Page 3 

5. 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. 

6. UPS proposes to operate the service to Ho Chi Minh City and Hanoi, 

Vietnam with a 757-200 aircraft with a payload capacity of 86,900 pounds that is 

currently in UPS' fleet. UPS wishes to commence service to Vietnam on or before 

November 14, 2011, and therefore requests expedited approval of this Application. 

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

Vietnam Agreement.1 The grant of this authority is also consistent with DOT precedent, 

and with principles of reciprocity. The Department previously granted U.S.-Vietnam allcargo authority to Federal Express.2 

UPS asks that the exemption authority requested be made effective immediately 

and remain in effect for two years, or until the grant of the requested certificate authority. 

1

 See Annexes I and II of the Air Transport Agreement between the Government of the United 

States of America and the Government of the Socialist Republic of Vietnam (December 4, 2003), 

as amended on May 18, 2010. 

2

 See Order 89-5-10 (authority transferred to FedEx by Order 89-5-3) and Order 90-10-11. 
Application of UPS for Certificate, Exemption and Designation 

Page 4 

WHEREFORE, United Parcel Service Co. respectfully requests the Department of 

Transportation to grant UPS the certificate and exemption authority and designation set forth 

here and grant such other further relief as the Dedartment may deem necessary. 

'/IhS^y 

Anita M. Mosner 

Jennifer M. Nowak 

Holland & Knight LLP 

2099 Pennsylvania Avenue, NW, Suite 100 

Washington, DC 20006 

Phone: (202)419-2604 

Fax: (202) 955-5564 

E-mail: anita.mosner@hklaw.com 

Attorneys for United Parcel Service Co. 

Date: July 19, 2011 
CERTIFICATE OF SERVICE 

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

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

RECIPIENT 

Carl B. Nelson 

Dan Weiss 

Alexander Van der 

Bellen 

John Allen 

Angeline Bird 

Sandra Lunsford 

Howard Kass 

Kris Urs 

COMPANY 

American Airlines 

Continental Airlines/ 

United Airlines 

Delta Air Lines 

Federal Aviation 

Administration 

FedEx 

US Airways 

U.S. Department of 

State 

E-MAIL 

carl. nelson (5>.aa. com 

dan.weiss@coair.com 

sascha.vanderbellenOdelta.com 

iohn.allen(5>faa.aov 

anbirdOfedex.com 

sllunsfordO.fedex.com 

howard kass(a>usairwavs.com 

urskrO.state.qov 

JMf-%%*fife 

Jennifer M. Nowak 

July 19, 2011