BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_____________________________________

Application of )

)

 AMERICAN AIRLINES, INC. ) Docket DOT-OST-1996-1353

) 

for renewal of an exemption )

pursuant to 49 U.S.C. § 40109 )

(Points in the United States – )

Points in Brazil) )

_____________________________________ )

APPLICATION OF AMERICAN AIRLINES, INC. 

FOR RENEWAL OF AN EXEMPTION

(Points in the United States – Points in Brazil)

Communications with respect to this document should be addressed to:

Howard Kass

Vice President – Regulatory Affairs

Robert A. Wirick

Managing Director, Regulatory and International Affairs

Abigail Donovan

Director, Congressional and Federal Affairs

American Airlines, Inc.

1101 17th Street, N.W.

Washington, D.C. 20036

(202) 326-5153

howard.kass@aa.com

robert.wirick@aa.com

abigail.donovan@aa.com

December 2, 2014
1

BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_____________________________________

Application of )

)

 AMERICAN AIRLINES, INC. )

) Docket DOT-OST-1996-1353

for renewal of an exemption )

pursuant to 49 U.S.C. § 40109 ) December 2, 2014

(Points in the United States – )

Points in Brazil) )

_____________________________________ )

APPLICATION OF AMERICAN AIRLINES, INC. 

FOR RENEWAL OF AN EXEMPTION

(Points in the United States – Points in Brazil)

Pursuant to 49 U.S.C. § 40109 and Subpart C of the Department’s Rules of 

Practice (14 C.F.R. Part 302), American Airlines, Inc. (“American Airlines”) applies for 

renewal of its exemption authority to engage in scheduled foreign air transportation of 

persons, property, and mail between a point or points in the United States, via 

intermediate points, and Belem, Belo Horizonte, Brasilia, Manaus, Porto Alegre, Recife, 

Rio de Janeiro, Salvador, and Sao Paulo, and beyond Brazil to Argentina, Chile, 

Paraguay, and Uruguay.

In support of this renewal application, American Airlines respectfully states as 

follows:

1. American Airlines is a Delaware corporation with its principal office at 

4333 Amon Carter Boulevard, Fort Worth, Texas 76155.

2. American Airlines is a citizen of the United States within the meaning of 49 

U.S.C. § 40102(a)(15)(C) and is fit, willing, and able to provide the services 

contemplated by this application. American Airlines holds various certificates of public 
Application of American Airlines for Renewal of an Exemption

(Points in the United States – Points in Brazil) 

2

convenience and exemption authorities. (See, e.g., DOT Order 2007-4-2, April 3, 2007, 

Dockets OST-2000-8516 and OST-2005-22228 (Blanket Open-Skies Route Authority);

Notice of Action Taken, October 7, 2014, Docket DOT-OST-2014-0169 (Dallas/Ft. 

Worth, Texas – Beijing, People’s Republic of China).) Pursuant to Rule 24 of the 

Department’s Rules of Practice, American Airlines requests that the Department take 

official notice of all information previously filed to establish its fitness. 

3. By Notice of Action Taken (February 4, 2013), the Department granted 

American Airlines a two-year exemption from 49 U.S.C. § 41101 to engage in 

scheduled foreign air transportation of persons, property, and mail “between a point or 

points in the United States, via intermediate points, and Belem, Belo Horizonte, Brasilia, 

Manuas, Porto Alegre, Recife, Rio de Janeiro, Salvador, and Sao Paulo, and beyond 

Brazil to Argentina, Chile, Paraguay, and Uruguay.” (Docket DOT-OST-1996-1353.). 

4. American Airlines currently provides scheduled air service between points 

in the United States and points in Brazil. Renewal of American Airlines’ exemption will 

greatly serve the public interest by providing substantial competition to other carriers 

serving Brazil from the United States, while supporting commerce and enhancing the 

options available to the traveling public. 

5. The Department has previously determined that the exemption authority 

sought in this renewal application is consistent with the aviation agreement “between

the United States and Brazil, as amended, and the Memorandum of Consultations 

signed March 19, 2011.” (See Notice of Action Taken, February 4, 2013, Docket DOTOST-1996-1353.)
Application of American Airlines for Renewal of an Exemption

(Points in the United States – Points in Brazil) 

3

6. Pursuant to 14 C.F.R. § 377.10, American Airlines intends to rely on the 

Administrative Procedures Act, 5 U.S.C. § 558(c) implemented by Part 377, to continue 

in effect its current exemption pending a final determination on this renewal application. 

American Airlines’ current exemption, as described herein, is effective through February 

4, 2015. Accordingly, this renewal application is timely filed under the provisions of Part 

377.
Application of American Airlines for Renewal of an Exemption

(Points in the United States – Points in Brazil) 

4

WHEREFORE, American Airlines respectfully requests that the Department 

renew its exemption authority to engage in scheduled foreign air transportation of 

persons, property, and mail between a point or points in the United States, via 

intermediate points, and Belem, Belo Horizonte, Brasilia, Manaus, Porto Alegre, Recife, 

Rio de Janeiro, Salvador, and Sao Paulo, and beyond Brazil to Argentina, Chile, 

Paraguay, and Uruguay, as discussed herein.

Respectfully submitted,

_______________________

Howard Kass

Vice President – Regulatory Affairs

Robert A. Wirick

Managing Director, Regulatory and 

International Affairs

Abigail Donovan

Director, Congressional and Federal Affairs

American Airlines, Inc.

1101 17th Street, N.W.

Washington, D.C. 20036

(202) 326-5153 

howard.kass@aa.com

robert.wirick@aa.com

abigail.donovan@aa.com

December 2, 2014
CERTIFICATE OF SERVICE

I certify that, on December 2, 2014, I caused to be served a copy of the foregoing 

Application of American Airlines, Inc. for Renewal of Exemption Authority, by email upon 

those addressees listed below:

englets@state.gov (Department of State)

cristinasa@state.gov (Department of State)

brian.hedberg@dot.gov (Department of Transportation)

todd.homan@dot.gov (Department of Transportation)

peter.irvine@dot.gov (Department of Transportation)

laura.remo@dot.gov (Department of Transportation)

brett.kruger@dot.gov (Department of Transportation)

john.allen@faa.gov (Federal Aviation Administration)

dan.weiss@united.com (United)

steve.morrissey@united.com (United)

gmurphy@crowell.com (Counsel for United)

sascha.vanderbellen@delta.com (Delta)

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

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

robert.land@jetblue.com (JetBlue)

msinick@ssd.com (Counsel for Alaska)

jyoung@yklaw.com (Counsel for Spirit)

dkirstein@yklaw.com (Counsel for Spirit)

bob.kneisley@wnco.com (Southwest)

leslie.abbott@wnco.com (Southwest)

ethan.blank@rjet.com (Republic)

robert.cohn@hoganlovells.com (Counsel for Republic)

patrick.rizzi@hoganlovells.com (Counsel for Republic)

john.fredericksen@suncountry.com (Sun Country)

thomas.ting@suncountry.com (Sun Country)

matwood@cozen.com (Counsel for Frontier)

stephen.lachter@lachterlaw.com (Counsel for Frontier)

rpommer@atlasair.com (Atlas)

anita.mosner@hklaw.com (Counsel for UPS)

jennifer.nowak@hklaw.com (Counsel for UPS)

cefelts@fedex.com (FedEx)

nssparks@fedex.com (FedEx)

kevin.montgomery@polaraircargo.com (Polar)

_________________________

Abigail Donovan