BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

) Application of ) ) ALASKA AIRLINES, INC. ) Docket DOT-OST-2010-_______ ) for an exemption pursuant to 49 U.S.C. 40109 ) (Sacramento-Guadalajara; San Jose-Guadalajara) ) )

APPLICATION FOR EXEMPTION

Communications with respect to this document should be addressed to:

Kyle Levine, Esq. Marshall S. Sinick, Esq. Associate General Counsel, Squire, Sanders & Dempsey L.L.P. Commercial Law and Litigation 1201 Pennsylvania Avenue, N.W. Alaska Airlines, Inc. Washington, D.C. 20004 19300 International Boulevard (202) 626-6651 Seattle, Washington 98188 msinick@ssd.com
Megan Lawrence, Esq. Counsel to Alaska Airlines, Inc. Managing Director, Government Affairs and Community Relations Alaska Airlines, Inc. 19300 International Boulevard Seattle, Washington 98188

DATED: September 17, 2010BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

) Application of ) ) ALASKA AIRLINES, INC. ) Docket DOT-OST-2010-_______ ) for an exemption pursuant to 49 U.S.C. 40109 ) (Sacramento-Guadalajara; San Jose-Guadalajara) ) )

APPLICATION FOR EXEMPTION

Pursuant to 49 U.S.C. 4 0109, 14 C.F.R. 302 and th e Economic and Procedural
Regulations of the Department of Transportati on (the “Department”), Alaska Airlines, Inc.
(“Alaska”) hereby requests an exemption from 49 U.S.C. 41101 a nd, to the extent
necessary, from the Department’s regulations to permit Alaska to engage in the scheduled
year-round foreign air tran sportation of persons, pr operty and mail between:
(i) Sacramento, California, an d Guadalajara, Mexico; and
(ii) San Jose, California, and Guadalajara, Mexico.
Alaska requests that this exemption be granted fo r at least a two-year period. Alaska intends
to begin services on these routes on Decemb er 15, 2010, and requests prompt approval so
that marketing and selling can begin without delay.
In further support of its exemption request, Alas ka states as follows:
1. Alaska’s principal headquarter s are located at 19300 International
Boulevard, Seattle, Washington. Alaska is in corporated under the laws of the State ofApplication of Alaska Airlines, Inc. Docket DOT-OST-2010-____ September 17, 2010

2 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 St ates within the meaning of 49 U.S.C.
40102(a)(15). The president and at least two- thirds of Alaska’s directors and other
managing officers are U.S. citizens. Additionally, to Alaska’s knowledge, U.S. citizens
hold at least seventy-five per cent of Alaska’s voting stock.
3. Alaska has repeatedly been found fit, willing and able to provide interstate
and foreign air transportation. The Department is requested to take official notice of
Alaska’s continuing fitness. See, e.g ., Order 00-5-31.
4. Alaska will operate year-round serv ices in the Sacramento-Guadalajara
and San Jose-Guadalajara markets beginning December 15, 2010. Initial plans call for
the operation of four weekly San Jose-Gua dalajara and three weekly SacramentoGuadalajara roundtrip flights utilizing B737- 800 aircraft seating up to 160 passengers.
Alaska’s proposed schedules are attached to this applica tion as Exhibit A.
5. On December 12, 2005, the United States and Mexico signed an
amendment to the Air Transport Agreement of August 15, 1960, broadening air transport
services between the two countries and perm itting designated U.S. carriers to operate
from “a point or points in the United St ates to a point or points in Mexico.” 1 The routes
covered by this application ar e clearly within the scope of the amendments to the Air
Transport Agreement and Alaska believes sufficient designations are available for its
proposed services. All public interest considerations are th erefore satisfied.

1 Annex I(A)1(a)Application of Alaska Airlines, Inc. Docket DOT-OST-2010-____ September 17, 2010

3 6. Alaska submits that its applicatio n raises no environmental or energy
issues. Alaska’s flights will be operated with aircraft that meet all applicable noise
abatement requirements. Nor will approval of this application result in an increase in fuel
consumption of ten million gallons or more.

WHEREFORE , Alaska Airlines, Inc. respectfully requests that the Department
of Transportation grant Alaska exemption au thority for two years to operate scheduled
services in foreign air transportation as more fu lly described herein, or such other relief as
the Department deems necessary and appropriate.
Respectfully submitted,

____________________________ Marshall S. Sinick, Esq. Squire, Sanders & Dempsey L.L.P. 1201 Pennsylvania Avenue, NW Washington, D.C. 20004 Phone: (202) 626-6651 Msinick@ssd.com
Counsel to Alaska Airlines, Inc.
DATED: September 17, 2010Exhibit A

Alaska Airlines, Inc.

Proposed Year-Round Schedules

San Jose-Guadalajara

Route Dep Arr Aircraft Type Seats Days of Operation Effective Fuel (gals)

SJC-GDL 2355 0555+1 737-800 160 Monday, Wednesday, Friday, Sunday 12/15/2010 3,000

GDL-SJC 0700 0850 737-800 160 Monday, Tuesday, Thursday, Saturday 12/15/2010 3,000

Sacramento-Guadalajara

Route Dep Arr Aircraft Type Seats Days of Operation Effective Fuel (gals)

SMF-GDL 2355 0555+1 737-800 160 Tuesday, Thursday, Saturday 12/15/2010 3,000

GDL-SMF 0700 0850 737-800 160 Wednesday, Friday, Sunday 12/15/2010 3,000CERTIFICATE OF SERVICE

I hereby certify that one copy of the fore going Application for Exemption has this day been served on each of the following individuals via e-mail.

________________________ Marshall S. Sinick, Esq.
DATED: September 17, 2010

hkamen@coair.com ; dan.weiss@coair.com sascha.vanderbellen@delta.com ; sametta.c.barnett@delta.com ; jeff.morgan@delta.com jeffrey.manley@united.com anbird@fedex.com dvaughan@kelleydrye.com ; dfisher@kelleydrye.com efaberman@wrf.com howard_kass@usairways.com ; benjamin.slocum@usairways.com dkirstein@yklaw.com jhill@dowlohnes.com mlbenge@zsrlaw.com pmurphy@lopmurphy.com carl.nelson@aa.com brian.gillman@mesa-air.com Linda.lundell@dot.gov esta.rosenberg@dot.gov brian.hedberg@dot.gov