Docket OST-97-2578 / Polar / Answer of Challenge / June 11, 1997
Application of
POLAR AIR CARGO, INC.
for all-cargo frequency allocation (U.S.-Argentina)
Dated: June 11, 1997
ANSWER OF CHALLENGE AIR CARGO, INC.
Pursuant to the Department's Rules of Practice, Challenge Air Cargo, Inc. ("Challenge") submits this answer to the
application of Polar Air Cargo, Inc. ("Polar") for additional scheduled all-cargo frequencies in the U.S.-Argentina market. Specifically, Polar asks that the Department re-allocate to it one or more of the frequencies that currently are allocated to Challenge. Challenge strenuously opposes Polar's request and respectfully states as follows:
The sole premise underlying Polar's application is its assertion - based upon vague and unsubstantiated "inquiries" in Argentina - that Challenge may not have utilized one of both of the frequencies that were allocated to it by the Department during the last 90 days. That claim is not correct. Challenge's most recent flight in the U.S.-Argentina market operated on May 17-19, 1997. That particular flight - which was operated with wide-body equipment equating to two narrow-body operations - operated over a Miami-Bogota-Sao Paulo-Buenos Aires-Sao Paulo-Bogota-Miami routing. Consequently, any suggestion that Challenge has failed to exercise its Argentine authority within the last 90 days simply is wrong. To the contrary, Challenge would like to take this opportunity to reassure the Department that it fully intends to retain and operate its Argentine authority. To be sure, Polar is not the only carrier which has experienced significant losses in attempting to maintain its Argentine service in the face of a prolonged slump in the market. However, that fact does not lessen Challenge's enthusiasm for the market nor its commitment to establishing and maintaining a meaningful presence in the market.
WHEREFORE, for the foregoing reasons, the application of Polar Air Cargo, Inc. in this Docket should be denied.
Respectfully submitted,
ZUCKERT, SCOUTT & RASENBERGER, L.L.P.
William H. Callaway, Jr.
Counsel for CHALLENGE AIR CARGO, INC.
June 11, 1997