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July 8, 2003

OST-99-6345 - US-Brazil All-Cargo Service

Application for Temporary Waiver of Dormancy Conditions

The Department of Transportation in this docket, granted certificate authority on Segment 2 of UPS' Route 795 to serve the Miami-Brazil market with four (4) weekly frequencies. As is customary in limited-entry markets such as Brazil, the Department conditioned the grant of authority on continuous use of the frequencies--whereby failure to use a frequency for 90-days would result in the expiration of the authority for such frequency. It is from this dormancy condition that UPS now seeks a waiver for one half of one (1/2) of its four (4) allocated frequencies. UPS will continue to operate three and one-half (3 1/2) frequencies in accordance with all Department conditions. UPS has discontinued service with one (1) weekly narrow-body aircraft.

Counsel: Kelley Drye, David Vaughan, 202-955-9864, dvaughan@kelleydrye.com

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July 8, 2003

OST-03-15686 - US-Brazil All-Cargo Service

Application for Temporary Waiver of Dormancy Conditions

Hereby applies for a waiver of the 90-day dormancy condition for one-half of one (1/2) of its four (4) allocated weekly all-cargo frequencies between Miami, Florida and Brazil. UPS requests the waiver for a period of one year, from today July 8, 2003, through July 8, 2004.

Counsel: Kelley Drye, David Vaughan, 202-955-9864, dvaughan@kelleydrye.com

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July 16, 2003

OST-99-6345 - US-Brazil All-Cargo Service
OST-03-15686 - US-Brazil All-Cargo Service

Correspondence of Kelley Drye

Counsel: Kelley Drye, David Vaughan, 202-955-9864, dvaughan@kelleydrye.com

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August 1, 2003

OST-03-15838 - Russia Overflight Frequencies

Application for Allocation of Russia Overflight Frequencies

Pursuant to Subpart C of the Procedural Regulations (14 C.F.R. 302.301 et seq.) of the Department of Transportation, United Parcel Service Co. hereby requests the allocation of four (4) one-way weekly eastbound Trans-Tashkent Russia overflight frequencies to be effective October 28, 2003. UPS will operate an MD-11 freighter over a Cologne, Germany - Hong Kong, routing. The service will be operated with aircraft currently in the UPS fleet. UPS understands that there are adequate unallocated frequencies available to accommodate this service.

Counsel: Kelley Drye, David Vaughan, 202-955-9864, dvaughan@kelleydrye.com

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July 21, 2003

OST-95-125 - From 41; Schedule B-7

Motion for Confidential Treatment

Counsel: UPS, Daniel Tenfelde, 502-329-6513

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August 14, 2003

OST-96-1496 - US-Thailand All-Cargo Service

Application for Frequency Allocation

UPS now wishes to utilize the five dormant frequencies and requests that they be reawarded to UPS thereby enabling UPS to commence a full six day per week round-trip operation between UPS' all-points Asian hub at the Diosdado Macapagal International Airport (formerly Clark Air Force Base), the "DMIA Hub," in the Philippines and Bangkok, Thailand. The service will be connected over the DMIA Hub through Anchorage, Alaska to various points in the United States.

Exhibit 1: Affidavit of Ted Lytle
Exhibit 2: Aircraft Route Detail and Route Proposal

Counsel: Kelley Drye, David Vaughan, 202-955-9864, dvaughan@kelleydrye.com

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OST-96-1496 - US-Thailand (All-Cargo)

Filed August 14, 2003 | Issued September 8, 2003

Notice of Action Taken | Word

Allocation of five weekly U.S.-Thailand all-cargo frequencies

By: Paul Gretch

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OST-03-15838 - Russia Overflight Frequencies

Filed August 1, 2003 | Issued September 11, 2003

Notice of Action Taken | Word

Four one-way weekly eastbound flights between Cologne, Germany and Hong Kong, over Tashkent

By: Paul Gretch

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OST-95-125 - Form 41 Confidential Treatment

January 20, 2004

Motion for Confidential Treatment

Counsel: Kelley Drye, David Vaughan, 202-955-9863

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OST-96-1960 - Family Assistance Plans

March 8, 2004

Re: Amended Family Assistance Plan

Counsel: UPS, Robert Reynolds

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OST-95-125 - Form 41; Schedule B-43

March 16, 2004

Motion for Confidential Treatment Pursuant to Rule 12

Counsel: Kelley Drye, David Vaughan, 202-955-9864

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OST-96-1074 - US-Philippines All-Cargo

April 5, 2004

Application for Renewal of Exemption Authority

Hereby applies for renewal of its exemption authority authorizing UPS to engage in the scheduled foreign air transportation of property and mail between Anchorage, Alaska, and Diosdado Marcapagal International Airport, Philippines, via Seoul, Korea, and Taipei, Taiwan, and beyond Manila to Singapore and Kuala Lumpur, Malaysia. UPS further applies for the continued right to integrate such authority with its other certificate and exemption authority to provide foreign air transportation.

Counsel: Kelley Drye, David Vaughan, 202-955-9864

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OST-96-1074 - US-Philippines All-Cargo

April 14, 2004

Amendment No. 1 to Application for Renewal of Exemption Authority

On April 5, 2004, United Parcel Service Co., pursuant to 49 U.S.C. 40109 and Part 302.301 et seq. of the Procedural Regulations of the Department of Transportation, filed an application for renewal of its exemption authority authorizing UPS to engage in the scheduled foreign air transportation of property and mail between Anchorage, Alaska, and Diosdado Marcapagal International Airport ("Clark"), Philippines, via Seoul, Korea, and Taipei, Taiwan, and beyond Manila to Singapore and Kuala Lumpur, Malaysia.

UPS hereby files this Amendment No. 1 to its Renewal Application, and requests that the Department receive and consider this Amendment in the captioned case. Specifically, UPS requests that the following paragraph 3 be added to its Renewal Application:

Counsel: Kelley Drye, David Vaughan, 202-955-9864, dvaughan@kelleydrye.com

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OST-96-1074 - US-Philippines All-Cargo

Filed April 5, 2004 | Amended April 14, 2004 | Issued May 6, 2004

Notice of Action Taken | Word

Scheduled foreign air transportation of property and mail between Anchorage, Alaska, and Manila, the Philippines (Diosdado Marcapagal International Airport), via Seoul, Korea, and Taipei, Taiwan, and beyond Manila to Singapore and Kuala Lumpur, Malaysia, and to integrate this authority with its existing certificate and exemption authority. UPS filed an amendment adding a paragraph to its renewal application, invoking the automatic extension provisions of the Administrative Procedure Act, 5 U.S.C. 558(c), as implemented by 14 CFR Part 377.

By: Paul Gretch

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OST-95-125 - Form 41 Schedule B-7

April 14, 2004

Motion for Confidential Treatment Pursuant to Rule 39

Counsel: Kelley Drye, David Vaughan, 202-955-9864

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OST-00-7282 - Los Angeles-Guadalajara

Filed November 19, 2003 | Issued December 10, 2003

Notice of Action Taken | Word

Scheduled foreign air transportation of property and mail between Los Angeles, California, and Guadalajara, Mexico.

By: Paul Gretch

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OST-95-125 - Form 41 Schedule B-7

April 14, 2004

Motion for Confidential Treatment Pursuant to Rule 39

Counsel: Kelley Drye, David Vaughan, 202-955-9864

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OST-99-6044 - Exemption - Route Integration Authority

October 28, 2004

Application for Renewal of an Exemption

Hereby applies for renewal of its exemption enabling UPS to integrate its existing authority to provide scheduled foreign air transportation of property and mail under its certificates of public convenience and necessity' and its currently held exemptions, so as to permit foreign air transportation services involving any points named on its certificates and exemptions. Route 665 (U.S.-Canada), Route 569 (various U.S. points-Mexico), Route 581 (U.S.-Japan), Route 557 (U.S.-various points worldwide), Route 790 (U.S.-Italy), Route 795 (U.S.-various Latin American points), Route 797 (U.S.-China).

Counsel: UPS and Kelley Drye, David Vaughan, 202-955-9864, dvaughan@kelleydrye.com

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OST-95-125 - Form 41 Schedule B-7

November 5, 2004

Motion to Withhold Information from Public Disclosure

Counsel: Kelley Drye, David Vaughan, 202-955-9864

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OST-99-6663 - Certificate - Austin/Houston/Louisville/San Antonio-Mexico All-Cargo

November 23, 2004

Application for Renewal of Certificate Authority

Hereby applies for renewal of its certificate authorizing UPS to engage in scheduled foreign air transportation of property and mail between Austin, Houston, Louisville and San Antonio and Monterrey, Guadalajara and Mexico City, Mexico.

Counsel: Kelley Drye, David Vaughan, 202-955-9864, dvaughan@kelleydrye.com

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OST-99-5743 - Exemption - US-Japan Codesharing with Nippon Cargo Airlines

Application for Renewal of an Exemption

The requested authority will be used solely in conjunction with a code‑share agreement between UPS and Nippon Cargo Airlines Co., Ltd. ("NCA"). To continue these code‑share operations, and to enable UPS to place its "5X" designator code on flights operated by NCA, UPS requires renewal of the underlying route authority being requested herein.

Counsel: Kelley Drye, David Vaughan, 202-955-9792, dvaughan@kelleydrye.com

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OST-99-6044 - Exemption - Route Integration Authority

Filed October 28, 2004 | Issued December 10, 2004

Notice of Action Taken | Word

Integrate its existing authority to provide scheduled foreign air transportation of property and mail under its certificates of public convenience and necessity for Route 665 (U.S. – Canada), Route 569 (various U.S. points – Mexico), Route 581 (U.S. – Japan) and Route 557 (U.S. – various points worldwide), Route 790 (U.S.-Italy), Route 795 (U.S. – various Latin American points), and Route 797 (U.S. – China) and under its currently held exemptions, so as to permit foreign air transportation services involving any points named on the above certificates and exemptions.

By: Paul Gretch

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OST-96-1379 - Exemption - Miami/San Juan-Venezuela

December 15, 2004

Application for Renewal of Exemption Authority

Hereby applies for renewal of its exemption authorizing UPS to engage in the scheduled foreign air transportation of property and mail between Miami, Florida and Caracas, Venezuela; via the intermediate point, San Juan, Puerto Rico, and between Miami, Florida and the terminal points Valencia and Maracaibo, Venezuela.

UPS is currently operating regularly scheduled all-cargo service in the Miami-Venezuela market.

Counsel: UPS and Kelley Drye, David Vaughan, 202-955-9792, dvaughan@kelleydrye.com

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OST-99-5743 - Exemption - US-Japan Codesharing with Nippon Cargo Airlines

Filed December 3, 2004 | Issued January 4, 2005

Notice of Action Taken | Word

Scheduled foreign air transportation of property and mail between any point or points in the United States, and any intermediate point or points, and any point or points in Japan, and any point or points beyond Japan. UPS requests the right to integrate such authority with its other existing certificate and exemption authority to provide foreign air transportation. UPS states that the requested authority will be used solely in conjunction with a code-share agreement between UPS and Nippon Cargo Airlines Co., Ltd.

By: Paul Gretch

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OST-95-125 - Form 41 Schedule B-7

January 25, 2005

Motion for Confidential Treatment Pursuant to Rule 39

Counsel: Kelley Drye, David Vaughan, 202-955-9864

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OST-1995-125 - Confidential Treatment Under Section 302.39

March 23, 2005

Motion for Confidential Treatment Pursuant to Rule 39

Counsel: UPS and Kelly Drye, David Vaughan, 202-955-9864

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OST-1995-125 - Form 41, Schedule B-7

May 9, 2005

Motion for Confidential Treatment Pursuant to Rule 39

Counsel: Kelley Drye, David Vaughan, 202-955-9864

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OST-2005-21316 - Allocation of One US-Hong Kong Fifth-Freedom Frequency

May 23, 2005

Application of United Parcel Service

Currently, UPS operates in the Seoul-Hong Kong market six days per week (Monday-Saturday) on a blind sector basis. If awarded the available fifth freedom frequency, UPS would be able to "open the door" one day per week on its Seoul- Hong Kong route. UPS is the only carrier applying for this frequency with daily flights between Hong Kong and Korea with no fifth-freedom frequencies. UPS could initiate service immediately, without any costs or network disruption, and provide shippers and businesses in the Seoul-Hong Kong market with the benefits of UPS' wide spectrum of cargo products-from next-day express packages to over-sized general air freight.

Counsel: UPS and Kelley Drye, David Vaughan, 202-955-9792, dvaughan@kelleydrye.com

OST-2005-21304 - Federal Express - Allocation of One US-Hong Kong Fifth-Freedom All-Cargo Frequency
OST-2005-21308 - Polar Air Cargo - Allocation of One Hong Kong Fifth-Freedom Cargo Frequency

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OST-2005-21316 - Allocation of One US-Hong Kong Fifth-Freedom Frequency

June 2, 2005

Supplement No. 1 to the Application

UPS applied for one additional weekly all-cargo frequency between Hong Kong and Seoul on May 23, 2005. UPS is prepared to begin the proposed fifth-freedom services immediately and will operate the services year-round once the award is received. If awarded the frequency, UPS would operate it as follows: Louisville-Anchorage-Hong Kong-Seoul-Anchorage-Louisville (SDF-ANC-HKG-ICN- ANC-SDF). UPS would operate the frequency on Thursday which is the busiest day in this market. UPS will use a B-747 freighter aircraft. UPS possesses the underlying route authority, including route integration authority, to serve the route proposed in this Application. (Order 99-12-7; NOAT, Docket OST-99-6044, Dec. 10, 2004).

Counsel: Kelly Dry, David Vaughan, 202-955-9792, dvaughan@kelleydrye.com

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OST-2005-21316 - Allocation of One US-Hong Kong Fifth-Freedom Frequency

June 9, 2005

Amended Application

UPS would operate the frequencies on Thursday, Friday and Saturday commencing service with a B-747 freighter aircraft, converting to an MD-11 freighter aircraft in November of 2005. If awarded the frequencies, UPS would operate all three frequencies as follows: Louisville-Anchorage-Hong Kong-Seoul-Anchorage-Louisville

Counsel: Kelly Drye, David Vaughan, 202-955-9864, dvaughan@kelleydrye.com

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OST-2005-21308 - Polar Air Cargo
OST-2005-21316 - United Parcel Service
OST-2005-21409 - Polar Air Cargo

June 13, 2005

Consolidated Answer of Federal Express Corporation

All three applicants for the newly available Hong Kong fifth-freedom opportunities state that they are presently operating on a blind-sector basis. For that reason, an award will necessarily improve the efficiency of any applicant's operation. However, the applications before the Department establish that a permanent award to Federal Express Corporation of all three frequencies will best promote the public interest.

The record shows that FedEx Express is the only applicant that can couple the three available frequencies with its existing frequencies to create a daily air express/cargo pattern. Six weekly frequencies would give us the critical mass of rights needed to compete more effectively with foreign air express/cargo operators and to expand our share of the global air express/cargo market. Integrating these express opportunities into our global network would also allow us to match supply more closely to demand, increasing the efficiency of that network, with the net result of lowering costs to U.S. shippers and exporters. Finally, it would allow the Department to redress the imbalance between general freight and express opportunities.

Counsel: Federal Express, G. Bailey Leopard, 901-434-6664, gbleopard@fedex.com

OST-2005-21304 - Federal Express
OST-2005-21316 - United Parcel Service

June 13, 2005

Consolidated Answer of Polar Air Cargo

Each applicant seeks all three of the fifth- freedom all-cargo frequencies available. And each would use the frequencies on a yearround basis. Beyond that, however, the relative merits of the proposals sharply diverge. Only Polar proposes to use all three frequencies to operate three weekly Hong KongKorea services in both directions, offering three weekly round trips. Only Polar has a hub at lncheon Airport and requires the frequencies to carry traffic between Hong Kong, Incheon and points on its network beyond Incheon. Only Polar would use B747 freighter equipment that would maximize the capacity available to carry fifth-freedom traffic over this sector and maximize competition with the networks of FedEx, UPS and numerous foreign carriers serving Asia. An award to Polar of the available frequencies will ensure the broadest public benefits in the form of enhanced competition and an alternative freight-of-all-kinds service option to trans-Pacific, intra-Asia and global shippers.

Counsel: Polar and Wilmer Cutler, Jeffrey Manley, 202-663-6670, jeffrey.manley@wilmerhale.com

OST-2005-21304 - Federal Express - Allocation of US-Hong Kong Fifth-Freedom Frequencies

June 13, 2005

Answer of United Parcel Service to Application of Federal Express

In this proceeding, FedEx says it wishes to obtain a "critical mass" of the twelve available Hong Kong-Korea frequencies. What FedEx in fact wishes is to keep its principal competitor, UPS, out of this important market. FedEx currently has the most U.S.-Hong Kong fifth-freedom frequencies of all U.S. carriers. FedEx should have the flexibility with its current mass of frequencies to enhance service options and lower costs, as it says it wishes to do, without the award of additional frequencies.

Furthermore, an award of three additional frequencies to FedEx will result in less competition among U.S. carriers and between U.S. carriers and powerful foreign incumbents. An allocation of three frequencies to UPS, enabling UPS to "open the door" on existing Hong Kong-Korea flights, would guarantee that both FedEx and Polar would face vigorous competition in the Hong Kong-Korea market. An award to FedEx conflicts with one of the Department's longstanding policy goals of "strengthening competition among U.S. carrier and among U.S. and foreign carriers in the Pacific rim region."

Counsel: Kelley Drye, David Vaughan, 202-955-9792, dvaughan@kelleydrye.com

OST-2005-21308 - Polar Air Cargo - Allocation of US-Hong Kong Fifth-Freedom Frequencies

June 13, 2005

Answer of United Parcel Service to Application of Polar Air Cargo

Hereby answers the Application filed by Polar Air Cargo, Inc. for an allocation of the three (3) available Hong Kong-Korea fifth-freedom all-cargo frequencies. An allocation of three frequencies to Polar would not diversify the shipping options available to consumers and would limit competition in this limited entry market. As is the case with FedEx, Polar already serves the market-UPS currently cannot. The Department should ensure that consumers benefit from the meaningful competition between three U.S. carriers in the Hong Kong-Korea market that can only be achieved through an award of three frequencies to UPS in this proceeding. Such an award would enable UPS to "open the door" on Hong Kong-Korea services it already operates.

Counsel: Kelley Drye, David Vaughan, 202-955-9792, dvaughan@kelleydrye.com

OST-2005-21409 - Polar Air Cargo - Pendente Lite Allocation of US-Hong Kong Fifth-Freedom All-Cargo Frequencies

June 13, 2005

Answer of United Parcel Service

Hereby answers the Application filed by Polar Air Cargo, Inc. for an immediate pendente lite frequency allocation of two Hong Kong-Seoul fifth-freedom all-cargo frequencies previously allocated to Kalitta Air, L.L.C. While UPS agrees that the Department should allow a carrier to utilize these valuable frequencies on a pendente lite basis, an award to Polar would not be the most productive and efficient use of the frequencies. An immediate allocation to Polar fails to maximize the public interest because it would not diversify the shipping options available to consumers and would not increase competition in this limited entry market.

Counsel: Kelley Drye, David Vaughan, 202-955-9792, dvaughan@kelleydrye.com

Index

United Parcel Service Co.

OST-2005-21316 - Immediate Pendente Lite Allocation of Three US-Hong Kong Fifth-Freedom Frequency

June 13, 2005

Application for an Immediate Pendente Lite Allocation of Frequencies

Hereby applies for an award, pendente lite, of the three (3) weekly Hong Kong-Korea fifth-freedom all-cargo frequencies returned by Northwest Airlines, Inc. and Kalitta Air, L.L.C. UPS respectfully requests that it be permitted to operate this authority immediately, and continue to operate these valuable frequencies until the Department issues an order for the long-term allocation of the frequencies.

Currently, UPS operates in the Seoul-Hong Kong market six days per week (Monday -Saturday) on a blind sector basis. If the Department grants UPS' request for pendente lite authority (as well as permanent authority), UPS would be able to commence service immediately and productively, thus maximizing the value of the frequencies. UPS would simply open its currently "closed door" on flights already being operated.

Counsel: Kelley Drye, David Vaughan, 202-955-9792, dvaughan@kelleydrye.com

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OST-2005-21409 - Polar Air Cargo - Immediate Pendente Lite Allocation of US-Hong Kong Fifth-Freedom Frequencies
OST-2005-21308 - Polar Air Cargo - Allocation of US-Hong Kong Fifth-Freedom Frequencies
OST-2005-21316 - United Parcel Service - Allocation of US-Hong Kong Fifth-Freedom Frequencies

June 15, 2005

Motion for Leave to File an Otherwise Unauthorized Document and Consolidated Reply of Federal Express

We object strongly to Polar's suggestion that the Department decide the long-term disposition of the frequencies on the papers before it, although we concur that the issues have been narrowed sufficiently such that "binders full of paper exhibits” are unnecessary to resolve them. FedEx Express has raised a material issue of evidentiary fact regarding Polar's current usage, which the Department will require evidence to resolve.

Counsel: Federal Express, G. Bailey Leopard, 901-434-6664, gbleapard@fedex.com

OST-2005-21409 - Polar Air Cargo - Immediate Pendente Lite Allocation of US-Hong Kong Fifth-Freedom Frequencies
OST-2005-21308 - Polar Air Cargo - Allocation of US-Hong Kong Fifth-Freedom Frequencies
OST-2005-21316 - United Parcel Service - Allocation of US-Hong Kong Fifth-Freedom Frequencies
OST-2005-21304 - Federal Express - Allocation of One US-Hong Kong Fifth-Freedom All-Cargo Frequency

June 15, 2005

Consolidated Response of Polar Air Cargo and Motion for Leave to File

The Department should not be misled by FedEx's reliance on Polar's incomplete internet schedules. Polar is utilizing its existing fifth-freedom frequencies and can be relied upon to use the additional frequencies it seeks consistent with its proposal. Contrary to FedEx's claims, there is no need for a carrier selection proceeding to resolve these issues. Polar has previously reported its frequency utilization to the Department and has updated that information above.

Counsel: Polar and Wilmer Cutler, Jeffrey Manley, 202-663-6670, jeffrey.manley@wilmerhale.com

OST-2005-21316 - United Parcel Service - Allocation of US-Hong Kong Fifth-Freedom Frequencies

June 15, 2005

Re: Polling Results of United Parcel Service to Shorten Answer Period

On behalf of United Parcel Service Co., I have polled representatives of Federal Express Corporation and Polar Air Cargo, Inc. with regard to UPS' request that the Department shorten the answer period to the above‑referenced Application for an Immediate Pendente Lite Allocation of Frequencies. FedEx has advised ITS that it has no objection to the granting of the request to shorten the answering period. Polar has not yet responded to UPS' request to shorten the answer period.

Counsel: Kelley Drye, David Vaughan, 202-955-9864, dvaughan@kelleydrye.com

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OST-2005-21316 - Immediate Pendente Lite Allocation of Three US-Hong Kong Fifth-Freedom Frequencies

June 16, 2005

Answer of Federal Express in Opposition

We have a critical need for those frequencies, both to increase capacity and to improve the efficiency of our AsiaOne network. The bilateral restraints imposed by the government of Hong Kong preclude FedEx Express from offering or carrying Hong Kong-Seoul local traffic on two flights we are currently operating between those two cities (i.e., the flights operate on a blind-sector basis). These restraints impose an efficiency cost on our network. We could implement the frequencies as soon as all government approvals are received.

FedEx Express has consistently maintained its immediate need for these frequencies and readiness to use them at any time. The Department should grant FedEx Express's application and deny UPS's application to the extent granting UPS's application would preclude a grant of FedEx Express's application.

Counsel: Federal Express, G. Bailey Leopard, 901-434-6664, gbleapard@fedex.com

June 16, 2005

Answer of Polar Air Cargo

On June 13, 2005, UPS answered in opposition to the requests of Polar and FedEx for both permanent and pendente lite allocations. In addition, although the date for such applications had passed, UPS itself belatedly requested an immediate pendente lite allocation of all three frequencies. Since UPS filed its late application on the day answers to such applications were due, acceptance of its application would unnecessarily delay what is intended to be an expedited proceeding. UPS has not offered any good cause for the late filing of its application nor has it even requested any leave to file it late.

Counsel: Polar and Wilmer Cutler, Jeffrey Manley, 202-663-6670, jeffrey.manley@wilmerhale.com

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OST-2005-21316 - Immediate Pendente Lite Allocation of Three US-Hong Kong Fifth-Freedom Frequencies

June 21, 2005

Motion for Leave to File an Otherwise Unauthorized Document and Consolidated Reply of United Parcel Service

In its Answer, Polar asserts that UPS' pendente lite Application was filed late. Polar is mistaken. On June 3, 2005, the Department issued a Notice inviting interested carriers to file exemption and frequency applications for the three available U.S.-Hong Kong frequencies. The Department stated that applications must be filed by June 9, 2005 and answers to these applications be filed by June 13, 2005. Both common sense and Department precedent support the interpretation that these dates applied to the applications for permanent authority. Nowhere in the Notice does the Department set a deadline for applications for pendente lite authority.

In its Answer, FedEx opposes UPS' application because UPS did not file its application on the same day that FedEx requested pendente lite authority. UPS is unaware of any Department precedent that considers the days on which a carrier chooses to file its application as a factor in the Department's determination for pendente lite authority. Regardless of when FedEx filed its application, meaningful competition between three U.S. carriers in the Hong Kong ‑ Seoul market can only be achieved through an award of three frequencies to UPS in this proceeding.

Counsel: UPS and Kelley Drye, David Vaughan, 202-955-9864

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OST-1995-125 - Confidential Treatment, Form 41 Schedule B-7

August 8, 2005

Motion for Confidential Treatment

United Parcel Service Co. hereby submits this motion to withhold from public disclosure, certain information contained in UPS's Schedule B-7, Airframe and Aircraft Engine Acquisitions and Retirements Report, for the period ending June 30, 2005, submitted herewith under seal, pursuant to Rule 39 of the Rules of Practice of the Department of Transportation. UPS believes that the information contained in its Schedule B-7 report is confidential and commercially-sensitive data, the premature public disclosure of which would cause substantial injury to UPS. UPS requests that the data at issue be withheld from public disclosure for a period of ten years.

Counsel: Kelley Drye, David Vaughan, 202-955-9864

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OST-2000-7282 - Exempiton - Los Angeles-Guadalajara All-Cargo

September 9, 2005

Application for Renewal of an Exemption

Respectfully files this application for renewal of exemption authority pursuant to Section 40109 of the Federal Aviation Act of 1958 requesting renewal of its exemption from Section 41101 of the Act authorizing UPS to provide certain scheduled non-stop all-cargo service between Los Angeles, California, and Guadalajara, Mexico.

Counsel: UPS and Kelley Drye, David Vaughan, 202-955-9792, dvaughan@kelleydrye.com

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OST-1999-6323 - US-China All-Cargo Service

September 29, 2005

Application for Renewal and Amendment of Certificate Authority

United Parcel Service Co., pursuant to 49 U.S.C. 40102 and Part 302.201 et seq. of the Procedural Regulations of the Department of Transportation, hereby applies for renewal and amendment of its Certificate of Public Convenience and Necessity for Route 797, authorizing UPS to provide scheduled U.S.-China all-cargo services.

The Department originally granted certificate authority to UPS for Route 797 by Order 2001-1-6 in the above-cap