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BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Application of

MESA AIRLINES, INC.

for an exemption under 49 U.S.C. § 40109

(Dallas/Ft. Worth – Leon/Guanajuato, Mexico)

(Dallas/Ft. Worth – Queretaro, Mexico)

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Docket DOT-OST-2014-____

APPLICATION OF MESA AIRLINES, INC.

FOR EXEMPTION AUTHORITY

Communications with respect to this document should be addressed to:

Brian Gillman

Executive Vice President,

General Counsel and Secretary

Mesa Air Group, Inc.

410 North 44th Street, Suite 700

Phoenix, AZ 85008

TEL: 602-685-4000

FAX: 602-685-4350

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

MESA AIRLINES, INC.

October 14, 2014

NOTICE: Mesa will be polling the carriers on the attached service list

about this Application and will report the polling results to the Department.
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BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Application of

MESA AIRLINES, INC.

for an exemption under 49 U.S.C. § 40109

(Dallas/Ft. Worth – Leon/Guanajuato, Mexico)

(Dallas/Ft. Worth – Queretaro, Mexico)

)

)

)

)

)

)

)

)

Docket DOT-OST-2014-____

October 14, 2014

APPLICATION OF MESA AIRLINES, INC.

FOR EXEMPTION AUTHORITY

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

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

exemption authority to engage in scheduled foreign air transportation of persons,

property, and mail between Dallas/Ft. Worth, Texas, and Leon/Guanajuato,

Mexico (“BJX”), and between Dallas/Ft. Worth, Texas, and Queretaro, Mexico

(“QRO”), beginning on or about November 6, 2014, as soon as all requisite

regulatory approvals are obtained. Mesa requests that this authority become

effective as soon as possible for a period of at least two years, subject to the

Department’s standard conditions.

In addition, Mesa requests (i) a U.S.-Mexico operating carrier designation

for these two routes and (ii) that the Department notify the Mexican authorities

confirming Mesa’s authority to serve these two routes.

In support of this Application, Mesa respectfully states as follows:

1. Mesa is a Nevada corporation with its principal office at 410 North

44th Street, Suite 700, Phoenix, Arizona, 85008.
Application of Mesa Airlines, Inc. for Exemption Authority

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2. Mesa is a citizen of the United States within the meaning of

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

contemplated by this application. Mesa holds various certificates of public

convenience and exemption authorities (including exemption authority to serve

certain points in Mexico). See, e.g., Notice of Action Taken, dated April 8, 2013

(Phoenix–Ixtapa/Zihuatanejo, Mexico) (Docket DOT-OST-2009-0109). Pursuant

to Rule 24 of the Department’s Rules of Practice, Mesa requests that the

Department take official notice of all information previously filed to establish its

fitness.

3. Mesa intends to operate scheduled air service in the DFW–BJX

and DFW–QRO markets using regional jet aircraft operating under the

“American Eagle” brand.1 Awarding the requested exemption authority to Mesa

will enable Mesa and American Airlines to offer public interest benefits by

providing competition to other carriers offering transborder U.S.–Mexico services,

as well as supporting commerce and maintaining and enhancing travel options to

the public. It will also enable American to tailor capacity to demand on these

transborder routes.

4. The exemption authority and designations sought herein are fully

consistent with the U.S.–Mexico Air Transport Services Agreement, as amended

(“the Agreement”). Annex I(A) of the Agreement authorizes carriers designated

1 Mesa understands that American Airlines, Inc. has DOT authority for DFW-BJX and will

be applying for DFW-QRO authority separately.
Application of Mesa Airlines, Inc. for Exemption Authority

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by the U.S. under Route 1(a) to operate from “a point or points in the United

States to a point or points in Mexico” and permits the U.S. to designate two U.S.

carriers to operate scheduled combination services between any point in the

U.S. and Leon/Guanajuato and between the U.S. and Queretaro. American and

Envoy currently hold designations for DFW-BJX, and Envoy and American Eagle

hold a designation for DFW-QRO. Current plans call for Mesa to substitute for

Envoy on the DFW-BJX route and to operate the DFW-QRO route previously

served by American Eagle. Therefore, Mesa requests that Envoy’s designation

for DFW-BJX and American Eagle’s designation for DFW-QRO be re-designated

to Mesa, albeit without any interruption in service. Inasmuch as Mesa’s service

will replace Envoy’s DFW-BJX and American Eagle’s DFW-QRO service, no

additional designation will be required.2

WHEREFORE, Mesa respectfully requests that the Department grant

Mesa’s Application for exemption authority and designations to engage in

scheduled foreign air transportation of persons, property, and mail between

2

To ensure that the services on the DFW-QRO and DFW-BJX routes are not disrupted,

Envoy’s DFW-BJX designation and American Eagle’s DFW-QRO designation should not be

revoked until Mesa’s Application has been approved, the new service is commenced, and

American Eagle and Envoy have given notice that their respective designations are no longer

required. The process by which Mesa will replace American Eagle and Envoy on these respective

routes is similar to that previously approved by the Department on several recent occasions. See,

e.g., Notices of Action Taken, dated May 27, 2014 (Dockets DOT-OST-2014-0058 and 2014-

0059); dated May 12, 2014 (Dockets DOT-OST-2014-0060 and 2013-0114); and dated July 29,

2014 (Dockets DOT-OST-2014-0100 and 2014-0101). American Eagle service operated by

American Eagle and Envoy will be replaced in the DFW-QRO and DFW-BJX markets,

respectively, with American Eagle service operated by Mesa commencing on or about November

6, 2014, as soon as all regulatory approvals are received. The Department should withdraw the

designations of American Eagle and Envoy effective upon the departure of their respective last

scheduled flights in the DFW-QRO and DFW-BJX markets, respectively.
Application of Mesa Airlines, Inc. for Exemption Authority

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Dallas/Ft. Worth and Leon/Guanajuato, Mexico, and between Dallas/Ft. Worth

and Queretaro, Mexico, for at least two years, as requested herein.

Respectfully submitted,

_____________________________

Robert E. Cohn

Patrick R. Rizzi

HOGAN LOVELLS US LLP

555 Thirteenth Street, NW

Washington, DC 20004

+1 202 637 4999/5659

Counsel for

MESA AIRLINES, INC.
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CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Application of Mesa Airlines, Inc.

for Exemption Authority has been served this 14th day of October, 2014, upon each

of the following addressees:

marshall.sinick@squiresanders.com; howard.kass@aa.com; robert.wirick@aa.com;

sascha.vanderbellen@delta.com; chris.walker@delta.com ; matwood@cozen.com;

stephen.lachter@lachterlaw.com; jhill@cooley.com; perkmann@cooley.com;

bob.kneisley@wnco.com; leslie.abbott@wnco.com;

dkirstein@yklaw.com; jyoung@yklaw.com; thomas.ting@suncountry.com;

dan.weiss@united.com; steve.morrissey@united.com;

barbara.russell@virginamerica.com; brian.hedberg@dot.gov; brett.kruger@dot.gov;

englets@state.gov; info@airlineinfo.com

______________________________

Patrick R. Rizzi