BEFORE THE U.S. DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

Application of Portugalia - Companhia Portuguesa de Transportes Aereos S.A. for an exemption from 49 U.S.C. §41301 and statementofauthorization (long-term wet lease to TAP Portugal) ) ) ) ) Docket DOT-OST-2008-0155 ) ) ) ) )



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APPLICATION OF PORTUGALIA- COMPANHIA PORTUGUESA DE TRANSPORTES AEREOS S.A. FORRENEWAL OF AN EXEMPTION
Communications withrespect to this application should be addressed to:

August 29, 2014 William Karas Carol Gosain STEPTOE & JOHNSON LLP 1330 Connecticut Avenue, N.W. Washington, D.C. 20036 Phone: (202) 429-6223 Fax: (202) 261-0651 wkaras@steptoe.com cgosain@steptoe.com Attorneys for PORTUGALIA- COMPANHIA PORTUGUESA

DE TRANSPORTES AEREOS S.A.

NOTICE: Answers supporting or opposing this application are due on September 15, 2014.BEFORE THE U.S. DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C. Application of Portugalia- Companhia Portuguesa de Transportes Aereos S.A. for an exemption from 49 U.S.C. §41301 and statement ofauthorization (long-term wet lease to TAP Portugal) ) ) ) ) DocketDOT-OST-2008-0155 ) ) ) ) )


# ___________________________ ) APPLICATION OF PORTUGALIA- COMPANHIA PORTUGUESA DE TRANSPORTES AEREOS S.A. FORRENEWAL OF AN EXEMPTION
Pursuantto 49 U.S.C. §40109(c), and Subpart C ofthe Department's Rules ofPractice, Portugalia- Companhia Portuguesa de Transportes Aereos S.A. ("PGA") hereby applies for renewal ofits exemption from 49 U.S.C. §41301 to the extentnecessary to enable PGAto perform charters under 14 C.F.R. Part 212 in order to wet lease aircraft to its parent company, TAP Portugal ("TAP"), for use by TAP as described herein. The aircraft wet leased from PGA
are used by TAP for flights within Portugal, betweenpoints within Europe, and between Europeanpoints and points in Africa, connecting to flights to/from the United States, consistent with TAP's existing authority from the Department and TAP's codeshare agreements with United Airlines, Inc. ("United") and US Airways, Inc. ("US Airways"). 1

1The Department granted statements ofauthorization for blanket codesharing authority to TAP and United by aNotice ofAction Taken ("NOAT") issued onAugust 11,2005 in Docket DOT-OST-2005-21686. The Department approved the TAP-US Airways blanket codeshare arrangement by Department Action on Application issued May 17, 2006 in Docket DOT-OST2006-24670.PGA's current exemptionwas granted by Notice ofAction Taken issued on September 27, 2012 in the above-captioned docket? PGA requests renewal ofthe exemption for aperiod of at leasttwo years. It relies upon the provisions of5 U.S.C. § 558(c) and 14 C.P.R. Part 377 as continuing its exemption authority in force pending action by the Departmentonthis renewal application. PGA states as follows in support ofits application: 1. PGA is a Portuguese airline organized and existing under the laws ofPortugal. Its head office is located at Lisbon Airport, Rua C, Building 70, Lisbon, Portugal. 2. The competent air transport authority having regulatoryjurisdiction over PGA is the Instituto Nacional da Avia9ao Civil ("INAC") located at Lisbon Airport, Rua B, Buildings 4, 5 and 6, 1749-034, Lisbon, Portugal. PGA'sPortuguese operating authority is already on file with the Department. 3. PGA commenced operations on July 7, 1990. It is a Portuguese regional carrier, operating scheduled flights on domestic routes within Portugal and international routes within Europe and between Europe and Africa. It also operates charter services within Europe and between Europe and Africa. Its fleet, which consists ofregional aircraft, is used only to operate short-haul flights. 4. PGA does not conduct any operations in the United States; rather, as noted at the outset, it seeks onlyto renew its exemption authority necessary to wet lease aircraft to TAP on a long-term basis for use by TAP for flights within Portugal, within Europe, and betweenEurope and Africa, which may connectwith flights to/from the United States and which may display the
2 By NOAT issued on September 9, 2010 in Docket DOT-OST-2008-0155, the Department also granted to PGA a statement ofauthorizationthatpermits PGA to wet lease aircraft to TAP on a long-term basis for the operations described herein. The statement of authorization was granted for an indefinite period.


### - 2 -UA* and US* codes pursuantto TAP's codeshare agreements with United and US Airways, respectively. 5. PGA's ownership and control are substantially unchanged. 6. PGA operates a fleet of 14 regional aircraft oftwo different types: six Fokker F-100 aircraft and eight Embraer ERJ-145 aircraft. All aircraft operated by PGA are maintained in accordance with European Aviation Safety Agency Part 145 requirements, and all maintenance ofPGA aircraft is performed in compliance withthe provisions ofiCAO Chicago Convention Annexes 1, 6 (Part I) and 8. 7. PGA has not been involved in any safety ortariffviolations or any fatal accidents in the last five years. 8. PGA remains fit, willing and able to provide the services embracedby this application. 9. Approval ofthis renewal application is fully consistent with the terms ofthe Air TransportAgreement Betweenthe United States and the European Community and the Member States ofthe European Community (the "US-EU Air Transport Agreement"). Specifically, section 10.9 ofthe US-EU Air TransportAgreement grants airlines ofa Party broad rights to enter into wet lease arrangements with any airline ofthe Parties. Grant ofthis renewal application is consistent withthe public interest within the meaning of49 U.S.C. §40109(c). The authority sought herein is encompassedbythe US-EU Air Transport Agreement and will allow TAP to engage in Department-approved codesharing services with United and US Airways.

- 3-Forthe foregoing reasons, PGA respectfully requests that the Department renew its exemption authority for a period ofat leasttwo years.

August 29, 2014 Respectfully submitted,



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# z.~s William Karas Carol Gosain STEPTOE & JOHNSON LLP 1330 Connecticut Avenue, N.W. Washington, D.C. 20036 Attorneys for PORTUGALIA- COMPANHIA PORTUGUESA

DE TRANSPORTES AEREOS S.A.

- 4-SERVICE LIST
robert.wirick@aa.com francis.heil@aa.com dan.weiss@united.com sascha.vanderbellen@delta.com howard.kass@usairways.com benjamin.slocum@usairways.com jhill@dowlohnes.com gbleopard@fedex.com nssparks@fedex.com cefelts@fedex.com sllunsford@fedex.com sharon.pasley@fedex.com anita.mosner@hklaw.com jennifer.nowak@hklaw.com jrichardson@johnlrichardson.com jcanny@amerijet.com rsilverberg@sgbdc.com jjohnson@sgbdc.com mcmillin@woa.com mlbenge@zsrlaw.com msinick@ssd.com rpommer@atlasair.com john.palo@evergreenairlines.com charters@evergreenairlines.com slachter@lachter-clements.com agoerlich@ggh-airlaw.com matwood@cozen.com kevin.montgomery@polaraircargo.com bill@mietuslaw.com john.s.duncan@faa.gov urskr@state.gov
I hereby certify that on this 29th day ofAugust, 2014, the foregoing document was served by email uponthe above persons. 

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**t_.~S** Carol Gosain