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OST-98-4601

Queen Air, Aeronaves Queen, S.A.

Queen Air was formed in order to increase the passenger travel and shipping options in the U.S.-Dominican Republic passenger and cargo market. U.S. carriers continue to dominate the U.S.-Dominican Republic scheduled operations from New York and Miami. Three (3) U.S. carriers (American Airlines, Continental and TWA) operate scheduled combination service from New York and Miami to Santo Domingo. Only two Dominican carriers, APA International and Air Atlantic, provide service to Santo Domingo. While cargo options from Miami have grown in number, American Airlines virtually monopolize the cargo service from New York. Queen Air will therefore enhance the existing scheduled passenger services by offering additional scheduled passenger flights from Miami, New York and San Juan to Santo Domingo. No Dominican carrier is directly serving San Juan. This additional service will provide passengers and shippers from both the Dominican Republic and the United States another carrier option to U.S. gateways.

Answers are due by November 9, 1998, Subpart Q

Counsel:  Mark Dombroff, 202-625-3150

Queen Air, Aeronaves Queen, S.A.

By:  Paul Gretch

Queen Air, Aeronaves Queen, S.A.

Hereby applies for renewal of its exemption authority to conduct scheduled foreign air transportation of persons, property and mail from Santo Domingo, Dominican Republic, on the one hand, and the coterminal. points San Juan, Puerto Rico; Miami, Florida; and New York, NY on the other hand, and to perform charters in accordance with Part 212 of the Department's rules.  Queen Air has successfully been operating Dominican Republic-U.S. scheduled combination operations utilizing modem, fuel-efficient equipment since December 1998. QueenAir continues to be fit, willing, and able to operate the scheduled combination operations referred to herein.

Counsel:  Pierre Murphy, 202.872.1679, pmurphy@lopmurphy.com

Queen Air, Aeronaves Queen, S.A.

By:  Paul Gretch

Queen Air, Aeronaves Queen, S.A.

Hereby applies for renewal of its exemption authority to conduct scheduled foreign air transportation of persons, property and mail from Santo Domingo, Dominican Republic, on the one hand, and the coterminal points San Juan, Puerto Rico; Miami, Florida; and New York, NY on the other hand, and to perform charters in accordance with Part 212 of the Department's rules.  In accordance with the FAA's IASA Program and its assessment of the Dominican Republic as a "Category 2" country, Queen Air would conduct these services only by wet leasing aircraft from a duly authorized and properly supervised U.S. or foreign air carrier.

Counsel:  Pierre Murphy, 202.872.1679, pmurphy@lopmurphy.com

Queen Air, Aeronaves Queen, S.A.

By:  Paul Gretch

Queen Air, Aeronaves Queen, S.A.

Application of Queen Air, Aeronaves Queen, S.A. pursuant to 49 USC Sections 40109, and 41301, requesting a renewal of exemption authority to conduct scheduled foreign air transportation of persons, property and mail from Santo Domingo, Dominican Republic, on the one hand, and the co-terminal points San Juan, Puerto Rico; Miami, Florida;; and New York, New York on the other hand, and to perform charters in accordance with Part 212 of the Department's rules.

Queen Air currently holds authority from its homeland to operate between Santo Domingo, Dominican Republic, on the one hand, and the coterminal points San Juan, Puerto Rico; Miami, Florida; and New York, New York on the other hand.

Queen Air has successfully operated Dominican Republic - U.S. scheduled combination services utilizing modern, fuel-efficient equipment since December 1998 when it initiated operations. Queen Air is currently not operating to the U.S. Queen Air continues to be fit, willing, and able to operate the scheduled combination services referred to herein.

Counsel: Pierre Murphy, 202 822-8050

Queen Air, Aeronaves Queen, S.A.

How come an Air Carrier that has not being operating for several years, that do not own or have an airplane operated, that do not have a wet lease agreement at this moment nor for the last several years, can continue to be fit, willing and able?

Counsel: L.A. Irizarry, Luis Irizarry, 787 752-7621

Queen Air, Aeronaves Quenn, S.A.

Queen Air can only speculate as to why the objecting parties have filed their opposition herein, however, Queen Air respectfully submits that the Opposition should be rejected.

Counsel: Pierre Murphy, 202 822-8050

Queen Air, Aeronaves Queen, S.A.

Reply of Servicios Aereos Profesionales S.A., Air Santo Domingo, Servicios Aereos Profesionales, Inc., and Trans Caribbean Airways, Inc. to the previous opposition to the renewal of exemption authority to Queen Air, Aeronaves Queen.

This is not the case of Queen Air, it do not hold an air carrier certificate issued by the State of Registry, it does not have an aircraft in its certificate, it is not in compliance with the Law 505 of the Dominican Republic which state that an air carrier must be in operation for at least 6 month to maintain a certificate, this is not the case of Queen Air. Queen Air has been without operating for more that two years, does not have an airplane in its certificate and is not legally fit to maintain a certificate nor and exemption from the Department.

Counsel: Luis Irizarry, 787 752-7621

Queen Air, Aeronaves Quenn, S.A.

That with respect to the operational aspect, the CAA is requesting that additional documentation be presented to them indicating who will have operational control of the aircraft between the intentional agreement between Queen Air and Rohr, Inc. In addition the CAA is requesting the documentation of who is the owner of the aircraft to be used by Queen Air. In the document provided(agreement) the aircraft presented as Queen Air aircraft, the same aircraft is being offer for sale to other parties. The CAA allege that if the aircraft is sold before the completion of all requirement for the renewal of the certificate, Queen Air will have no airplane to conduct operations.

The undersigned as representative of the Air Santo Domingo, S.A., Servicios Aereos Profesionales, S. A. , Servicios Aereos Profesionales, Inc. and Trans Caribbean Airways, Inc. , formally request that the Department take notice of the above information and document and we again opposed to Queen Air Renewal of its Exemption.

Counsel: Luis Irizarry, 787 752-7621

Queen Air, S.A.

Counsel: Luis Irizarry, 

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