BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

) 

Request ) 

) 

of Silk Way West Airlines ) Docket OST 2014-0111 

to amend issued exemption authority and ) 

pending application for a foreign air carrier permit ) 

and motion to expedite processing ) 

(Baku-Hong Kong-Chicago-New York-Luxemburg-Baku) ) 

REQUEST OF SILK WAY WEST AIRLINES 

TO AMEND ISSUED EXEMPTION AUTHORITY AND PENDING APPLICATION 

FOR A FOREIGN AIR CARRIER PERMIT 

AND MOTION TO EXPEDITE PROCESSING 

Communications with respect to this document should be sent to: 

KAMRAN GASIMOV 

Director/CEO 

SILK WAY WEST AIRLINES 

Heydar Aliyev International Airport 

Baku, AZ-1 044, Republic of Azerbaijan 

Dated: October 8, 2014 

GLENN P. WICKS 

EKATERINA A. GRIMES 

THE WICKS GROUP, PLLC 

733 1 Olh Street NW, Suite 3002 

Washington, DC 20001 

(202) 457-7790 

gpwicks@wicks-group.com 

ekagrimes@wicks-group.com 

For: SILK WAY WEST AIRLINES 

NOTICE: Pursuant to the motion for expedited processing contained herein, any person who 

wishes to support or oppose this application must file an answer within 7 calendar days thereof, 

or by October 15, 2014, and serve that answer on Silk Way West Airlines and on all persons 

served with this application. Counsel for Silk Way West will poll the US carriers on the attached 

service list and will advise the Department of the results of the poll. 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

) 

Request ) 

) 

of Silk Way West Airlines ) Docket OST 2014-0111 

to amend issued exemption authority and ) 

pending application for a foreign air carrier permit ) 

and motion to expedite processing ) 

(Baku-Hong Kong-Chicago-New York-Luxemburg-Baku) ) ____________________________________) 

REQUEST OF SILK WAY WEST AIRLINES 

TO AMEND ISSUED EXEMPTION AUTHORITY AND PENDING APPLICATION 

FOR A FOREIGN AIR CARRIER PERMIT 

AND MOTION TO EXPEDITE PROCESSING 

Pursuant to 49 U .S.C. § 41302, (representing the recodified version of Section 

4021/ of the Federal Aviation Act of 1958 ("Act"), as amended), 49 U.S.C. § 401 09(c) 

(representing the recodified version of Section 416 'J/ of the Act), Part 211 of the 

Department ofTransportation's ("Department") Economic Regulations, and Subpart B of the 

Department's Rules of Practice, Silk Way West Airlines (hereinafter "Silk Way West") on 

June 23, 2014, applied for a foreign air carrier permit and exemption authority to engage in 

(1) scheduled air transportation of cargo between any point or points in Azerbaijan, via 

intermediate points, and any point or points in the United States; and (2) charter air 

transportation of cargo between any point or points in Azerbaijan and any point or points in 

l l Public Law 103-272, enacted July 5, 1994, revised and recodified the Act within Subtitle VII ofTitle 49, 

United States Code (Transportation). The provisions of section 402 of the Act are now contained in 49 U.S. C. 

§ 41302. Under the recodification, the tenns of section 402 were not substantively changed. 

2/ Public Law 103-272, enacted July 5, 1994, revised and recodified the Act within Subtitle VII ofTitle 49, 

United States Code (Transportation). The provisions of section 416 of the Act are now contained in 49 U.S.C. 

§ 40109(c). Under the recodification, the tenns of section 416 were not substantively changed. 

- 2 -
the United States, as well as any point or points in the United States and any point or points 

in a third country or countries subject to pertinent national, bilateral and international rules 

and regulations. Silk Way West indicated that it intends to start operating the requested 

services as soon as the Department permits them, but no later than the winter season of 

2014. Silk Way West further indicated that it intends to start operations with a scheduled 

service between Baku, Azerbaijan and New York, New York, USA, operating primarily its 

Boeing 747 freighter equipment, as well as any other aircraft that are currently in its fleet or 

as it may later acquire, in conjunction with its contemplated scheduled and charter services 

to the United States. 

In its application, Silk Way West requested that its application be decided on 

the basis ofwritten submissions pursuant to 14 C.F.R. § 302.207, and that the Department 

grant this application by proceeding directly to a final order as set forth in 14 C.F.R. 

§302.21 O(a)(2). 

Silk Way West also invoked the Department's August 23, 2005 Notice in 

Docket OST-2005-22228 (the "Streamlined Licensing Procedures Notice") and requested 

that its application for a foreign carrier permit and an exemption be processed and acted on 

by the Department pursuant to the Streamlined Licensing Procedures set forth by the 

referenced Notice. 

On August 15, 2014, the Department, by Order Granting Exemption and to 

Show Cause (see Order 2014-8-125 in Docket DOT-OST-2014-0111) granted Silk Way 

West exemption authority to permit it to engage in scheduled foreign air transportation of 

property and mail between Baku, Azerbaijan and New York, New York, as well as the 

authority to engage in charter foreign air transportation of property and mail between any 

point or points in Azerbaijan and any point or points in the United States; and other charters 

in accordance with the requirements of 14 CFR Part 212. The Department also noted that it 

"will tentatively grant Silk Way west a foreign air carrier permit for these services." 

- 3-
The Department further indicated that since the aviation relations between the 

United States and Azerbaijan are governed by comity and reciprocity, consistent with its 

usual policy in those circumstances, it will grant the applicant the specific authority to 

operate the Baku-New York route specified in the application as intended initial route, rather 

than grant the broader scheduled authority requested in the application. 

Silk Way West recognizes the Department's considerations in granting it the 

narrow scheduled authority to operate air transportation of property and mail between Baku, 

Azerbaijan and New York, New York, and is working to implement such operations. 

However, in order to ensure greater economic efficiency and better benefit the 

current market of cargo air transportation, Silk Way West would like to hereby request that 

the exemption authority granted to it by Order 2014-8-125 in Docket DOT-OST-2014-

Olllbe expanded to allow it to implement scheduled air transportation of property and mail 

on the route Baku-Hong Kong-Chicago-New York-Luxemburg-Baku (with no US domestic 

cargo transportation between the points of Chicago and New York). Silk Way West further 

requests that, subject to favorable consideration by the Department of this Request, its 

foreign air carrier permit be issued accordingly ("Request to Amend"). 

Silk Way West further motions the Department for expedited consideration of 

this Request to Amend, and will poll the US carriers on the attached service list and will 

advise the Department of the results of the poll. 

In support of this Request to Amend, Silk Way West submits as follows: 

1. The full name and address of Silk Way West is: 

"Silk Way West Airlines" Limited Liability Company 

Mailing Address: Heydar Aliyev International Airport, Baku, 

AZ-1 044, Republic of Azerbaijan 

Registered Address: Heydar Aliyev International Airport, Baku, 

AZ-1 044, Republic of Azerbaijan 

- 4-
2. The air transport authority of Azerbaijan having regulatory jurisdiction over 

Azerbaijan Airlines' air transport operations is: 

The State Civil Aviation Administration of the Republic of Azerbaijan 

11 Azadlig Avenue, Baku, AZ-1095, Republic of Azerbaijan 

3. Silk Way West requests that the evidentiary materials contained in 

Exhibits SWWEST-1 through SWWEST-18 submitted by it in Docket DOT-OST-2014-0111 as 

part of the initial Application, be incorporated herein by reference, and confirms that they remain 

true and accurate. Silk Way West also confinns that it remains fit, willing, and able to operate 

the services proposed by this amended application. 

4. Silk Way West will utilize its Boeing 747-400F and Boeing 747-SF 

equipment for its proposed operations. All of the aircraft Silk Way West intends to operate 

to the United States are registered in Azerbaijan. Maintenance of Silk Way West's aircraft 

intended for US operations is done by appropriately certificated Aircraft Maintenance 

Organizations in Luxemburg and Azerbaijan. Silk Way West will also enter into 

appropriate contracts in the United States for line maintenance of its aircraft used for US 

operations as necessary. 

5. Silk way West's proposed services that are the subject of this Request 

to Amend are based upon comity and reciprocity between the Government of the United 

States and the Government of Azerbaijan. Silk Way West has been formally designated by 

the State Civil Aviation Administration ofthe Republic of Azerbaijan (SCAA) to operate the 

proposed services. A formal letter from the State Civil Aviation Administration of the 

Republic of Azerbaijan confirming Silk Way West's designation for the specific route 

requested herein, as well as reiterating SCAA 's adherence to the principles of comity and 

reciprocity in considering any similar applications from US carriers, is being currently 

transmitted to the Department. 

- 5 -
6. As has been demonstrated by the issued initial Exemption, Silk Way 

West is qualified to operate to the United States. Silk Way West has assembled an 

experienced team of individuals to manage and develop the unique market opportunities 

associated with the establishment of its U.S. service. Silk Way West has the financial and 

technical resources to maintain its domestic and international service. 

7. An expedited consideration and grant of Silk Way West's instant Request to 

Amend is in the public interest as Silk Way West wi11 provide the much needed services in the 

U.S.-Azerbaijan aviation market, as well as in the broader international market of cargo air 

transportation by providing additional capacity and helping to meet the requirements for cargo 

air transportation services in the high season and peak demand. Silk Way West's ability to 

timely implement its service during the high season will also serve as a justification and 

incentive for its recent acquisition ofbrand new Boeing 747-8F aircraft. 

Silk Way West represents a high quality operation that is capable of implementing 

a high level cargo scheduled and charter operation to the U.S.-Azerbaijan market. Silk Way 

West is a well-known operator in Azerbaijan looking to expand its operations to the United 

States in the nearest possible term and provide a high quality service to the US and international 

shipping public. As such, the Department should act expeditiously in granting the authority 

requested herein by Silk Way West. 

8. A grant of Silk Way West's application would not constitute a "major 

regulatory action" under 14 C.F.R. Part 313. Specifically, Silk Way West's annual fuel 

consumption will not exceed 10 million gallons. Thus, a grant of the permit application will 

not constitute a "major regulatory action" within the meaning of Section 1 02(2)( c) of the 

National Environmental Policy Act as implemented by 14 C.F.R. § 313.4. As a result, Silk 

Way West is not required to submit additional information about the energy consumption 

and energy efficiency consequences of its service proposal. 

******* 

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WHEREFORE, Silk Way West respectfully requests that the Department grant 

this request for a foreign air carrier permit and exemption, as amended, to allow it to 

implement scheduled air transportation of property and mail on the route Baku-Hong KongChicago-New York-Luxemburg -Baku (with no US domestic cargo transportation between 

the points of Chicago and New York), or such other or further relief as the Department 

determines to be appropriate and consistent with the public interest. Silk Way West also 

respectfully motions the Department for expedited consideration of the instant request 

EKATERINA A. GRIMES 

Consultant for Silk Way West Airlines 

- 7 -
CERTIFICATE OF SERVICE 

I hereby certify that I have on this day served a copy of the foregoing document upon 

each of the following electronic mail addresses: 

sascha. vanderbellen@delta.com 

sametta.c.bamett@delta.com 

chris.walker@delta.com 

dshort@fedex.com 

sllunsford@fedex.com 

nssparks@fedex.com 

gbleopard@fedex.com 

msinick@ssd.com 

enisson@nac.aero 

mwiegele@nac.aero 

kevin.montgomery@polaraircargo.com 

peter. beckett@polaraircargo.com 

dan. weiss@coair.com 

dan. weiss@united.com 

pdoell@naca.cc 

robert. wirick@aa.com 

francis.heil@aa.com 

howard kass@usairways.com 

benjamin.slocum@usairways.com 

rsilverberg@sgbdc.com 

jjohnson@sgbdc.com 

j richardson@j ohnrichardson.com 

mriordan@j ohnrichardson.com 

jcanny@amerijet.com 

j ohn@mietuslaw .com 

rpommer@atlasair.com 

matwood@cozen.com 

nwallace@wallaceair.com 

agoerlich@ggh-airlaw .com 

dhainbach@ggh -airlaw .com 

judy@lac.lvnden.com 

rzerkel@lac.lvnden.com 

gwhite@lac.lynden.com 

jdavis@lac. Lynden.com 

TGillies@southemair.com 

info@airlineinfo .com 

anita.mosner@hklaw .com 

j ennifer.nowak@hklaw .com 

dsmalls@ups.com 

stephen.lachter@lachterlaw .com 

Engl eTS@state. gov 

Ekaterina A. Grimes Dated: October 8, 2014