OST-98-4277 / Challenge Air Cargo / US-Brazil / August 3, 1998
Application of
CHALLENGE AIR CARGO, INC. / Docket OST-98-4277
for additional frequencies (U.S.-Brazil)
APPLICATION OF
CHALLENGE AIR CARGO, INC.
FOR ADDITIONAL FREQUENCIES
Challenge Air Cargo, Inc. ("Challenge") hereby respectfully requests that the Department allocate to it 2.0 additional scheduled all-cargo wide-body frequency allocations (i.e., 4.0 narrow-body equivalents) in the U.S.-Brazil market. Challenge further requests that the Department grant this application at the same time as the Department acts upon the pending application of American International Airways. Inc. ("AIA") in
Docket OST-98-4184 for 1.5 additional wide-body frequencies in the U.S.-Brazil market, /1 and in any event by August SO, 1998. In support of this Application. Challenge respectfully states as follows:1/ As noted in its
answer to AIA's pending application, Challenge originally intended to apply for an additional 2.5 wide-body frequencies (he.. 5.0 narrow-body equivalents) in the U.S.-Brazil market. However. in order to eliminate the need for the Department to institute a comparative selection proceeding to resolve the conflict, Challenge and AIA have decided to scale-back the scope of their respective service proposals. Consequently, Challenge has reduced its instant request from 2.5 wide-body frequencies to 2.0.
APPLICATION OF CHALLENGE AIR CARGO, INC.
Page 2
Challenge has provided scheduled all-cargo service between the United States and Brazil since August 1992. It is currently providing a full pattern of 2.5 weekly wide-body frequencies in the U.S.-Brazil market and has made firm plans to increase the level of its service to accommodate increased market demand. Specifically, beginning on or about September 15, 1998. Challenge plans to add four weekly narrow-body flights in the Miami-Sao Paulo market. The new flights will operate over a Miami-Caracas-Sao Paulo-Caracas-Miami routing and will use B-757 freighter aircraft. This new service will complement Challenge's existing two weekly DC-10 flights in the Miami-Sao Paulo market and its one weekly B-757 flight in the Miami-Manaus-Sao Paulo market. /2 With the additional 2.0 weekly wide-body frequencies (4 narrowbody equivalents). Challenge will be able to offer almost daily service in the largest U.S.-Brazil cargo market and match the frequencies offered by several of Challenge's competitors.
Challenge respectfully submits that the granting of this request for 2.0 additional widebody frequencies (4.0 narrow-body equivalents) is in the public interest since it will permit Challenge to increase the frequency of its existing operations in order to meet rising demand. The granting of this request also w ill increase competition by permitting Challenge
2/ As a result of having to scale-back the scope of its proposed application from 2.5 weekly widebody frequencies (he.. 5.0 narrow-body equivalents) to 2.0 Challenge is likely to re-route some of its existing services so that one or more of its existing wide-body flights will operate via Manaus and its existing B-757 flight will operate over the same routing as the new Miami-Caracas-Sao Paulo flights.
APPLICATION OF
CHALLENGE AIR CARGO, INC.
Page 3
to increase the level of its authorized operations to a level comparable to that of several of its competitors.
WHEREFORE, Challenge Air Cargo. Inc. respectfully requests that the Department allocate to Challenge 2.0 additional scheduled weekly wide-body all-cargo frequencies (i.e., 4.0 narrow-body equivalents) in the U.S.-Brazil market, together with such other. different, and further relief as the Department may deem appropriate under the circumstances.
Respectfully submitted.
ZUCKERT. SCOUTT & RASENBERGER. L.L.P.
William H. Callaway, Jr.
Lonnie Anne Pera
888 Seventeenth Street, N.W.
Suite 600
Washington, D.C. 20006
(202) 298-8660
Counsel for Challenge Air Cargo, Inc.
Dated: August 3. 1998