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BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Application of

REPUBLIC AIRLINE INC.

for an exemption pursuant to 49 U.S.C. § 40109

(United States-Belize)

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Docket DOT-OST-2014-______

APPLICATION OF REPUBLIC AIRLINE INC.

FOR EXEMPTION AUTHORITY

Communications with respect to this document should be addressed to:

Ethan J. Blank

Vice President and General Counsel

Scott L. Durgin

Vice President, Administration

REPUBLIC AIRWAYS HOLDINGS INC.

8909 Purdue Road

Indianapolis, Indiana 46268

Robert E. Cohn

Patrick R. Rizzi

HOGAN LOVELLS US LLP

Columbia Square

555 Thirteenth Street, NW

Washington, DC 20004

+1 202 637 4999/5659

robert.cohn@hoganlovells.com

patrick.rizzi@hoganlovells.com

Counsel for

REPUBLIC AIRLINE INC.

November 19, 2014
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BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Application of

REPUBLIC AIRLINE INC.

for an exemption pursuant to 49 U.S.C. § 40109

(United States-Belize)

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)

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)

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Docket DOT-OST-2014-_____

November 19, 2014

APPLICATION OF REPUBLIC AIRLINE INC.

FOR EXEMPTION AUTHORITY

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

of Practice, Republic Airline Inc. (“Republic”) hereby applies for a designation

and an exemption authorizing it to provide scheduled foreign air transportation of

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

point or points in Belize. Republic requests that its exemption authority be

granted as soon as possible and remain in effect for a period of at least two

years, or until 90 days after the Department’s final determination on a Republic

application for U.S.–Belize certificate authority,1 whichever occurs earlier.

In support of its Application, Republic states as follows:

1

See Application dated December 12, 2007, in Docket DOT-OST-2007-0084. In DOT

Order 2008-4-26 granting certain carriers, including Republic, broad U.S.–Open Skies authority,

the Department deferred its consideration of the request for U.S.–Belize certificate authority,

among others, because that proceeding only dealt with authority to serve Open Skies partners.

Id. at n.3.
Application of Republic Airline Inc.

Page 2

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1. Republic is a U.S. airline providing scheduled interstate air

transportation pursuant to a Certificate of Public Convenience and Necessity

issued by DOT Order 2009-9-13. Republic also has Open Skies certificate

authority and various exemption authorities for scheduled foreign air

transportation. See DOT Order 2008-4-26 (Route 882); Notice of Action Taken,

dated December 27, 2013 (Docket DOT-OST-2012-0026) (U.S.–Turks and

Caicos Islands); Notice of Action Taken, dated December 10, 2012 (Docket

DOT-OST-2011-0018) (U.S.–Bahamas).

2. Republic plans to begin nonstop “American Eagle” service under

the AA* designator code of American Airlines, Inc. (“American”) between Miami,

Florida (MIA), and Philip S.W. Goldson International Airport, Belize City, Belize

(BZE), with 76-seat EMB 175 aircraft in June 2015.2

3. Approval of this Application is in the public interest. Republic’s

proposed service will provide U.S. communities and travelers with enhanced

options for service to Belize, as well as competition to other air carriers offering

U.S.–Belize service. The Miami–Belize City flights in particular will benefit

travelers not only in the Miami metropolitan area, but also throughout the United

States given the extensive connecting opportunities at American’s major Miami

hub.

2

American is already authorized to provide U.S.-Belize service. See Certificate of Public

Convenience and Necessity for Route 137, as issued by DOT Order 1996-5-9.
Application of Republic Airline Inc.

Page 3

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4. Although its initial service is planned for Miami–Belize City,

Republic seeks a broader exemption for U.S.–Belize authority so that it has the

flexibility to introduce additional U.S.-Belize services in the future as market

conditions and passenger demand warrant.

5. Republic is fit, willing, and able to perform the proposed U.S.-Belize

services. As noted above, Republic has authority to operate scheduled

interstate and foreign air service, including overwater routes between the United

States and points in the Caribbean. Its proposed services to Belize are not

materially different in terms of aircraft size or stage length from its previously

authorized interstate and foreign air services.

6. Republic requests that the Department take official notice, pursuant

to Rule 24 of the Department’s Rules of Practice, of all other data on file with the

Department necessary to establish its fitness.

7. Approval of the requested exemption is consistent with the U.S.-

U.K. Air Services Agreement of 1977, to which Belize acceded upon its

independence, the overall state of aviation relations between the two countries,

and the broad U.S.-Belize exemption authority previously granted to other U.S.

carriers. See, e.g., ExpressJet Airlines, Inc., Notice of Action Taken, dated

March 1, 2013 (Docket DOT-OST-2006-25018); US Airways, Inc., Notice of

Action Taken, dated July 29, 2013 (Docket DOT-OST-2002-12259).
Application of Republic Airline Inc.

Page 4

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8. The Belize services proposed in this Application are not projected

to utilize more than 10 million gallons of fuel annually, and, in any event,

Republic does not envision having any difficulties in acquiring fuel for this

service.

WHEREFORE, for the foregoing reasons, Republic respectfully requests

that the Department promptly grant a designation and the requested exemption

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

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

points in Belize, as described herein.

Respectfully submitted,

__________________________________

Robert E. Cohn

Patrick R. Rizzi

HOGAN LOVELLS US LLP

Columbia Square

555 Thirteenth Street, NW

Washington, DC 20004

Counsel for

REPUBLIC AIRLINE INC.
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CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Application of Republic Airline Inc.

for an Exemption has been served this 19th day of November, 2014, upon each of

the following addressees:

robert.wirick@aa.com; howard.kass@aa.com; sascha.vanderbellen@delta.com;

chris.walker@delta.com; dan.weiss@united.com;

steve.morrissey@united.com;JCanny@amerijet.com;

jrichardson@johnlrichardson.com; brett.kruger@dot.gov; englets@state.gov;

info@airlineinfo.com

Jonathan Echmalian