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Cargo Transfer Opportunities at AlaskaJeffrey N. ShanePartner, Hogan Lovells
August 24, 2010
www.hoganlovells.com
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Air Cargo Transfer Opportunities at Alaska
Alaska offers international air carriers unique
opportunities to operate a flexible and efficient
system of air cargo services, thanks to:
1. Stevens Amendment
2. DOT Exemption Authority
3. Open Skies Agreements
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1. Stevens Amendment
Allows non-US airlines to carry international cargo
between US points as part of an interline itinerary if
and only if the interline connection occurs in Alaska.
Conditions:
(a) Non-US carrier must be authorized to serve
Alaska.
(b) Cargo being carried on the domestic leg of an
interline itinerary must be carried on behalf of a US
airline (code sharing, blocked space, etc.).
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2. DOT Exemption Authority
On August 19, 2010, DOT reinstated exemption
authority making it advantageous to use Alaska as a
cargo hub:
• Flexible on-line transfers
• Change-of-gauge (including “starburst”)
• Commingling US international cargo with non-US
• US and non-US carriers can transfer cargo freely with each other
where origin and destination are outside the US
• Any non-US carrier serving the US allowed to serve Alaska
• Carriers invited to apply for new routes to the US provided new points
to be served will be served via Alaska.
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3. Open Skies agreements
Airlines from countries with which the US has Open
Skies agreements already enjoy the flexibility
provided in DOT’s August 19 order.
• US Open Skies partners include: Singapore, Taiwan, New Zealand,
Brunei, Malaysia, South Korea, Pakistan, Sri Lanka, Samoa,
Indonesia, India, Maldives, Thailand, Cook Islands, Australia, and
Laos.
• Some Open Skies agreements include 7th-freedom rights between the
US and third countries
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On-line transfers
No restrictions.
Even “starburst change-of gauge” permitted.
Example: TG’s BKK-ANC flight transfers cargo
onto 4 continuing segments to US and Europe.
TO EUROPE
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Interline to US: Asian carrier to US carrier
No restrictions.
Example: TG moves cargo from BKK
to ANC and transfers to 4 US carriers.
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Interline from US: Asian carrier to US carrier
Example: Cargo moving ( ) from ORD to NRT. TG carries cargo
from ORD to ANC and transfers to AA for onward flight to NRT. TG
can carry cargo on domestic US segment if (a) under a US
carrier code (e.g., UA) and (b) connection is at Alaska.
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Interline to/from US: Two Asian carriers
Example: TG and JL exchange Asia-US cargo at ANC.
TG and JL can carry cargo on domestic US segments (in
either direction) if (a) under a US carrier code (e.g., UA and
AA) and (b) connection is at Alaska. .
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Commingling US cargo with non-US cargo
TG 1/2/3
TG 1TG 2
TG 3
Example: TG carries both US-bound and Europe-bound
cargo from BKK. TG may freely transfer cargo at ANC
to onward flights to US and Europe.
TO EUROPE
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Transferring non-US cargo at Alaska
No restrictions.
Example: TG and JL can stop at ANC on flights
to/from Canada and Europe and exchange cargo.
TO EUROPE
