OST-97-2855 / Southern Air Transport / August 25, 1997

NOTICE: ANYONE WISHING TO SUPPORT OR OPPOSE THIS APPLICATION SHOULD FILE BY SEPTEMBER 2, 1997 AN ANSWER WITH THE DEPARTMENT OF TRANSPORTATION AND SERVE A COPY ON ALL PARTIES ON THE ATTACHED SERVICE LIST.

Application of:

For Exemption Under 49 U.S.C. §40109 (U.S. - Argentina, Scheduled All-Cargo)

In support of its application, Southern states as follows:

I. Southern Air Transport, Inc. is a corporation organized under the laws of Florid I. Its address and telephone number are: P.O. Box 328988, Columbus, OH 43232-8988, (614) 751-1100. Southern Air holds certificates of public convenience and necessity authorizing it to provide scheduled interstate and overseas transportation of property and mail, and to provide scheduled foreign air transportation of property and mail to a number of foreign points. /1 In addition, Southern Air holds various exemptions authorizing scheduled all-cargo air transportation. /2

2. Southern Air is a citizen of the United States as defined by 49 U.S.C. §40102(a)(15). Southern Air is owned and controlled by individuals who are themselves U.S. citizens. Southern Air's owner and all of its directors and managing officers are citizens of the U.S.

3. Southern Air has been previously found to be fit, willing, and able to engage in overseas and foreign scheduled air transportation of property and mail. /3 Southern Air requests

1/ See Order 95-1-6, Order Re-issuing Certificate of Public Convenience and Necessity for transportation from the U.S. to Hong Kong, Australia, South Korea, Taiwan, and Ireland; Order 95-3-31, Chile; Order 95-8-36, U.K. and Prestwick.

2/ See Notice of Action Taken Dated May 21, 1997, Colombia.

3/ See Order 95-1-6, Order Re-issuing Certificate of Public Convenience and Necessity.

that the Department take official notice pursuant to Rule 24 of its Procedural Regulations ot data filed to establish such fitness. Southern Air has no subsidiaries nor any financial interest in any other entity.

4. Southern Air hereby requests that it be awarded four (4) weekly narrow-body frequencies. /4 Southern Air plans to operate twice weekly service from Miami to Buenos Aires using existing B-747-200 aircraft from Southern Air's current fleet. /5 Southern Air's B-747200F's presently operate between the U.S., and Colombia and Brazil, and Southern has sufficient B-747-200F's to conduct the U.S.-Argentina service proposed.

5. The markets to be served are Miami, FL; Buenos Aires, Argentina; with the intermediate point Bogota, Colombia. The planned routing of these services is Miami, FL -Buenos Aires, Argentina - Bogota, Colombia - Miami, FL. This routing would provide a southbound flow of general commodity cargo to Argentina, which historically has a stronger Row of cargo than the flow of Argentina cargo northbound. Shippers would benefit by having an increased flow of exports to Argentina without having to pay for full round-trip aircraft operations. This routing would also accommodate the strong northbound flow of exports from

4/ While Southern Air would accept any award of frequencies granted to it, Southern Air respectfully submits that, since it currently operates B-747-200F equipment to South America and it proposes to use the same type of equipment in its U.S.-Argentina service, any award of less than two (2) weekly frequencies would preclude Southern Air from operating any weekly flights at all.

5/ Southern Air is aware that, under the U.S.-Argentina Air Services Agreement, Southern Air's B-747-200F aircraft are equivalent to two (2) narrow body aircraft.

Colombia to the United States. /6

6. If granted authority to operate four (4) weekly frequencies, Southern Air would commence services to Argentina as soon as commercially feasible, but within ninety (90) days of receiving such authority.

7. Southern Air, under the requested exemption, does not anticipate that these operations will result in a near-term net annual change in aircraft fuel consumption of ten million ( 10,000,000) gallons or more. Accordingly, grant of this exemption authority would not be a "major regulatory action" under 14 C.F.R. §313.4.

8. Southern Air believes that the grant of the authority requested herein would provide significant and immediate benefits to the shipping public and help to maximize the competitive opportunities under the U.S.-Argentina Air Services Agreement. It is, therefore, in the public interest.

WHEREFORE, Southern Air Transport, Inc. respectfully requests that the Department: (I) issue it an exemption authorizing U.S.-Argentina Scheduled All-Cargo Service; and (2) allocate to Southern Air four (4) weekly narrow-body frequencies to perform scheduled all-cargo operations between the U.S. and Argentina. In the alternative, Southern Air requests such oils ..

6/ Southern currently provides daily B-747-200F Miami-Bogota scheduled all-cargo service.

further, or different relief as the Department may deem appropriate.

Respectfully submitted,

August 25, 1997

Pierre Murphy

Elizabeth C. Collins

One Westin Center

2445 M Street, N.W.

Suite 260

Washington, DC 20037

(202) 872- 1679

Attorneys for Southern Air Transport, Inc.