BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

1;if~ . r~-

l.•.J .,,- ,-{ -2 I) ) 

- ~:54 

Motion of 

ALASKA AIRLINES, INC. 

For confidential treatment of Part 241 

Submissions under 14 C.F.R. § 302.12 

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Docket OST-96-1637 

MOTION OF ALASKA AIRLINES, INC. 

FOR CONFIDENTIAL TREATMENT OF 

PART 241 SUBMISSIONS UNDER RULE 12 

Please forward all communications concerning this motion to: 

Brandon Pedersen 

VP/Finance and CFO 

ALASKA AIRLINES, INC. 

19300 International Boulevard 

Seattle, Washington 98188 

(206) 392-5763 

Marchd {, 2015 

Jeremy L. Ross 

Senior Attorney 

ALASKA AIRLINES, INC. 

19300 International Boulevard 

Seattle, Washington 98188 

(206) 392-5453 

Counsel for 

ALASKA AIRLINES, INC. 

Page 1 of 4 - MOTION OF ALASKA AIRLINES, INC FOR CONFIDENTIAL TREATMENT OF 

PART 241 SUBMISSIONS UNDER RULE 12 
Motion of 

BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

ALASKA AIRLINES, INC. 

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) 

) 

)" 

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Docket OST-96-1637 

For confidential treatment ofPart 241 

Submissions under 14 C.F.R. § 302.12 

MOTION OF ALASKA AIRLINES, INC. 

FOR CONFIDENTIAL TREATMENT OF 

PART 241 SUBMISSIONS UNDER RULE 12 

Pursuant to section 302.12 of the Department's Rules of Practice, Alaska Airlines, Inc. 

("Alaska") hereby moves to withhold from public disclosure for a period often years certain 

commercially-sensitive information contained in Schedule B-7 ("Airframe and Aircraft Engine 

Acquisitions and Retirements") and Schedule B-43 ("Inventory of Airframes and Aircraft 

Engines") of its Part 241 filings for the quarter ending December 31, 2014. Unredacted versions 

of Schedules B-7 and B-43 are filed simultaneously with this Motion marked "Confidential 

Treatment Requested Under§ 302.12." 

In support of its Motion, Alaska offers the following points and authorities: 

1. The data for which confidential treatment is sought is being disclosed to the 

Department pursuant to Part 241 of the Department's economic regulations. The majority of 

information contained in Alaska's Part 241 filings will enter the public domain, where it will be 

available for inspection and copying by members of the public, including foreign and domestic 

competitors of Alaska and competitors of Alaska's aircraft and engine suppliers. 

Page 2 of 4- MOTION OF ALASKA AIRLINES, INC FOR CONFIDENTIAL TREATMENT OF 

PART.241 SUBMISSIONS UNDER RULE 12 
2. Certain price and cost data contained in Schedules B-7 and B-43 are highly 

sensitive and confidential. More specifically, 

(a) Schedule B-7 reflects the cost of commercial aircraft and engines Alaska 

purchased or leased from The Boeing Company. 

(b) Schedule B-43 discloses the acquisition cost, depreciation or amortization 

values and estimated residual values of numerous commercial aircraft and engines Alaska 

has purchased from The Boeing Company since the 1990s. 

3. The commercially-sensi~ve information found in Schedules B-7 and B-43 should 

be withheld from public disclosure pursuant to Exemptions 3 and 4 of the Freedom of . 

Information Act (5 U.S.C. § 552(b)(3) and (4)) (the "FOlA") and legal authority interpreting the 

FOIA. 

4. Under Exemption 3, information in agency records should be withheld from the 

public if it is specifically exempted from disclosure by a statute, provided that the statute "(A) 

requires that the matters be withheld from the public in such a manner as to leave no ·discretion 

on the issue, or (B) establishes particular criteria for withholding, or refers to particular types of 

matters to be withheld." Specifically, the Department is required to withhold information from 

production under the FOIA if its release would have an "adverse effect on the competitive 

position of any carrier in foreign air transportation." 49 U.S.C. §40115 (a)(2)(B): Public release 

of the aircraft and engine cost data to Alaska's competitors would have exactly this adverse 

effect. 

5. Exemption 4 extends confidential treatment to records that are "commercial or 

financial information obtained from a person and privileged or confidential." 5 U.S.C. § 

552(b)(4); see also Gulf and Western Industries, Inc. v. United States, 615 F.2d 527, 529 (D.C. 

Cir. 1979). These price and cost data contained in Schedules B-7 and B-43 are of this nature and, 

additionally, "would customarily not be released to the public by [Alaska]." See National Parks 

and Conservation Association v. Morton, 498 F. 2d 765, 766 (D.C. Cir. 1974) (citing S. Rep. No. 

813, 89th Cong., 1st Sess. 9 (1965)). Finally, if released under the FOIA, price and cost data 

Page 3 of 4 - MOTjON OF ALASKA 4IRLINES, INC FOR CONFIDENTIAL TREATMENT OF 

PART 241 SUBMISSIONS UNDER RULE 12 

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concerning Alaska's aircraft transactions have the potential "to cause substantial harm to the 

competitive position of the person from whom the information was obtained." ld. at 770. 

WHEREFORE, Alask~ respectfully requests the Department of Transportation to 

withhold the portions of the attached document(s) for which confidential treatment has been 

r~quested from public disclosure for a period often (1 0) years. 

March JY, 2015 

Respectfully submitted, 

Senior Attorney 

ALASKA AIRLINES, INC. 

19300 International Boulevard 

Seattle, Washington 98188 

(206) 392-5453 

Page 4 of 4- MOTION OF ALASKA AIRLINES, INC. FOR CONFIDENTIAL TREATMENT OF 

PART 241 SUBMISSIONS UNDER RULE 12