Application of Frontier Airlines, Inc. Page 2 action on the carrier's application for certificate authority for these markets filed contemporaneously herewith, whichever comes first. Expedited treatment of this application is requested in order to permit Frontier to begin advertising and selling seats for a planned startup of November 20, 2014. Accordingly, the carrier requests that the Department waive the 15- day comment period; counsel will poll the carriers on the attached service list and advise the Department of the results. In support of its application, Frontier respectfully states as follows: 1. Frontier holds a certificate of public convenience and necessity authorizing it to engage in scheduled foreign air transportation of persons, property, and mail on certain routes between the United States and points in Mexico. 1 service. 2 Frontier also holds exemption authority for additional U.S.-Mexico In addition to its U.S.-Mexico operating authority, Frontier holds certificate and exemption authority to serve points in the Caribbean. 3 2. On or about November 20, 2014, Frontier plans to expand its U.S.- Caribbean service by introducing new scheduled non-stop service between 1 Order Issuing Certificate to Frontier Airlines, Inc. (U.S.-Mexico), Order 2011-6-12, dated April 6, 2011, Docket DOT-OST-2005-22228, authorizing Frontier to engage in scheduled foreign air transportation of persons, property and mail over the following U.S. -Mexico city-pair route segments: Denver-Cancun; Denver-Cozumel; Denver-lxtapa/Zihuatanejo; Denver-Mazatlan; Denver-Puerto Vallarta; Denver-San Jose del Caba; Indianapolis-Cancun; Kansas City-Cancun; Kansas City-Puerto Vallarta; Kansas City-San Jose del Caba; Milwaukee-Cancun; St. Louis Cancun; St. Louis-Puerto Vallarta; and Salt Lake City-Cancun. 2 See Notices of Action Taken, dated November 28, 2011, renewal pending (Docket DOT-OST- 2011-0209); December9, 2011, renewal pending (Docket DOT-OST-2011-0214); June 13, 2013 (Docket DOT-OST-2013-0116); August 16, 2013 (Docket DOT-OST-2013-0144); and January 31, 2014 (Docket DOT-OST-2012-0027). 3 See Order 2007-7-3, dated May 7, 2007 (Docket DOT-OST-2007-27790) (blanket open skies route authority, including service to certain Caribbean points); Notice of Action Taken, dated November 12, 2013 (Docket DOT-OST-2011-0233) (Dominican Republic).
Application of Frontier Airlines, Inc. Page 3 Washington, D.C. (IAD) and Trenton, New Jersey, on the one hand, and Nassau, Bahamas, on the other hand, initially with up to three weekly flights on each route. The Washington, D.C.-Nassau service will be operated using 168-seat Airbus A-320 aircraft. The Trenton-Nassau service will be operated using 138- seat Airbus A-319 aircraft. In addition, ori or about November 22, 2014, Frontier plans to expand its U.S.-Mexico service by introducing new scheduled non-stop service between Washington, D.C. (IAD) and Cancun, Mexico, initially with up to two weekly flights using 168-seat Airbus A-320 aircraft. 3. Frontier's fitness to operate this service has been established and confirmed several times in recent years. 4 Furthermore, updated fitness information has been provided to the Department in support of the carrier's recent change of ownership. Nothing has occurred to impair the carrier's fitness or to change the underlying information on which the Department has based its fitness determinations. 4. Frontier's proposed Washington, D.C.-Cancun service is fully consistent with the U.S.-Mexico Air Transport Agreement, as amended. 5 That agreement permits U.S. air carriers to operate scheduled passenger service from a point or points in the United States to a point or points in Mexico. Annex 1.B.5 of the agreement allows each country to designate up to three airlines to provide scheduled combination services between any point or points in the United States 4 See supra notes 1-3. s See Air Transport Agreement Between the Government of the United States of America and the Government of the United Mexican States, August 15, 1960, as amended and extended most recently on December 12, 2005.