ALASKA AIRLINES, INC. 

for an exemption 

pursuant to 49 U.S.C. § 40109 

) Docket DOT-OST-2015-

) 

) 

) _________________________________) 

APPLICATION OF ALASKA AIRLINES, INC. 

FOR EXEMPTION AUTHORITY AND REQUEST FOR DESIGNATION 

Communications with respect to this document should be addressed to: 

Jeremy Ross 

Senior Attorney, Litigation and Regulatory 

and Director, Legal 

ALASKA AIRLINES, INC. 

19300 International Boulevard 

Seattle, Washington 98188 

jeremy.ross!'malaskaair.com 

March 10,2015 

David Heffernan 

COZEN O'CONNOR 

The Army & Navy Club Building 

1627 I Street, NW 

Suite 1100 

Washington, DC 20006 

(202) 463-2537 

dheffeman!'mcozen.com 

Counsel for 

ALASKA AIRLINES, INC. 

NOTE: The applicant requests expedited approval of this application and will poll 

the carrier representatives on the attached service list and report the polling results 

to the Department. 
Application of 

) 

) 

) 

ALASKA AIRLINES, INC. ) Docket DOT-OST-2015-

) 

for an exemption ) 

pursuant to 49 U.S.C. § 40109 ) 

_________________________________) 

DATED: March 10,2015 

APPLICATION OF ALASKA AIRLINES, INC. 

FOR EXEMPTION AUTHORITY AND REQUEST FOR DESIGNATION 

Pursuant to 49 U.S.C. § 40109 and Subpart C of the Department's Procedural 

Rules (14 CFR §§ 302.301 et seq.), Alaska Airlines, Inc. ("Alaska") hereby applies for an 

exemption from the provisions of 49 U.S.C. § 41101 authorizing it to engage in 

scheduled foreign air transportation of persons, property and mail between Santa 

Ana/Orange County (SNA), California, on the one hand, and Puerto Vallarta (PVR) and 

San Jose del Cabo (SJD), Mexico, on the other hand. Alaska also requests a designation 

to operate in the Santa Ana/Orange County-Puerto Vallarta and Santa Ana/Orange 

County-San Jose del Cabo city pairs. Alaska requests that the exemption be granted for a 

two-year period consistent with DOT precedent. 

Expedited treatment of this application is requested in order to permit Alaska to 

begin advertising and selling seats as soon as possible. Alaska plans to begin service 

between Santa Ana/Orange County and San Jose del Cabo on October 8, 2015 and 

between Santa Ana/Orange County and Puerto Vallarta on October 9, 2015. Counsel for 
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Boulevard, Seattle, Washington. Alaska is incorporated under the laws of the State of 

Alaska and is a wholly owned subsidiary of Alaska Air Group, Inc. ("AAG"). AAG is 

incorporated under the laws of the State of Delaware. 

2. Alaska is a citizen of the United States within the meaning of 49 U.S.C. § 

401 02(a)(15). Alaska has been found fit, willing and able to provide interstate and 

foreign air transportation. Alaska holds certificates of public convenience and necessity 

authorizing it to engage in scheduled foreign air transportation of persons, property, and 

mail on certain routes between the United States and points in Mexico, as well as 

between the United States and points in countries with which the United States has 

entered into open skies agreements.' Alaska also holds exemption authority for 

additional U.S.-Mexico service.2 

3. Alaska requests exemption authority to allow it to operate scheduled 

foreign air transportation of persons, property and mail between Santa Ana/Orange 

County, California, on the one hand, and Puerto Vallarta and San Jose del Cabo, Mexico, 

1 See Application of Alaska Airlines, Inc. for Amendment to Certificate of Public Convenience and 

Necessity (U .S.-Mexico), Order 2000-5-31, dated March 29, 2000 (Docket DOT-OST-1999-6276); In the 

Matter of Blanket Open-Skies Route Authority, Order 2007-7-3, dated May 7, 2007 (Docket DOT-OST2007-27790). 

2 See Notices of Action Taken, dated August 25,2014 (Docket DOT-OST-2005-20406); May 29,2014 

(Docket DOT-OST-2014-0078); April23, 2014 (Dockets DOT-OST-2003-14542, DOT-OST-2004-19419, 

DOT-OST-2010-0103, and DOT-OST-2010-0193); April14, 2014 (Docket DOT-OST-2014-0049); and 

July 31, 2012 (Docket DOT-OST-20 I 0-0234). 
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Puerto Vallarta, both with 8737-800 aircraft. Alaska requests that the Department grant 

the requested exemption as soon as possible to enable Alaska to begin marketing the new 

services. 

4. Alaska's proposed Santa Ana/Orange County-Puerto Vallarta and Santa 

Ana/Orange County-San Jose del Cabo service is fully consistent with the U.S.-Mexico Air Transport Agreement, as amended. 3 That agreement permits U.S. air carriers to 

operate scheduled passenger service from a point or points in the United States to a point 

or points in Mexico. Annex 1.8.5 of the agreement allows each country to designate up 

to three airlines to provide scheduled combination services between each point in the 

United States and each of Puerto Vallarta and San Jose del Cabo, Mexico. Alaska 

understands that there is at least one unused U.S. airline designation available for each of 

the Santa Ana/Orange County-Puerto Vallarta and Santa Ana/Orange County-San Jose 

del Cabo city pairs. Alaska requests that a designation be provided for each of its 

proposed services. 

5. Grant of Alaska's application is in the public interest, as it will benefit 

consumers by allowing the carrier to increase competition in the U.S.-Mexico market. In 

addition, Alaska's Santa Ana/Orange County-Puerto Vallarta and Santa Ana/Orange 

3 See Air Transport Agreement Between the Government of the United States of America and the 

Government of the United Mexican States, August 15, 1960, as amended and extended most recently on 

December 12, 2005. 
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the Department's regulations. All flights will be operated with 8737-800 aircraft that 

meet all applicable noise and environmental requirements. Similarly, approval of this 

application will not result in a near-term increase in fuel consumption of ten million 

gallons or more. Alaska anticipates no problem in obtaining fuel for these flights from its 

normal sources of supply. 

WHEREFORE, Alaska respectfully requests that the Department promptly grant 

it an exemption and designation for its proposed Santa Ana/Orange County-Puerto 

Vallarta and Santa Ana/Orange County-San Jose del Cabo service. 

Dated: March 10, 201 5 

Respectfully submitted, 

~~L{~ 

David Heffernan 

COZEN O'CONNOR 

The Army & Navy Club Building 

1627 I Street, NW 

Suite 1100 

Washington, DC 20006 

Telephone (202) 463-2537 

E-mai I: dheffernan@cozen. com 

Counsel for 

ALASKA AIRLINES, INC. 
Florida West Airlines: 

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JetBlue: 

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Southern Air: Southwest Airlines: Spirit Airlines: 

Sun Country Airlines: 

United Airlines: United Parcel Service: 

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Dated: March 10, 2015 

robert. wirick@aa. com 

abigail.donovan@aa.com 

sandysinick@gmail.com 

howard.diamond@flyfrontier.com 

jcanny@amerijet.com 

rpommer@atlasair. com 

john@mietuslaw.com 

sascha.vanderbellen@delta.com 

christopher. walker@delta.com gmurphy@crowell.com 

john.s.duncan@faa.gov 

nssparks@fedex.com 

cefelts@fedex.com 

j hill@cooley .com 

perkmann@cooley .com 

psanderlin@kalittaair.com 

kevin.montgomery@po laraircargo. com 

agoerlich@ggh-airlaw.com 

bob.kneisley@wnco.com 

leslie.abbott@wnco.com 

jyoung@yklaw.com 

dkirstein@yklaw .com 

thomas. ting@suncountry .com 

dan. weiss@united.com 

steve.morrissey@united.com 

gmurphy@crowell.com 

anita.mosner@hklaw.com 

Jennifer.nowak@hklaw.com 

mlbenge@zsrlaw.com 

Kenneth C. Hines