BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

-------------------------------------------------------------- - Application of :
: UNITED AIRLINES, INC. : Docket DOT

- OST

- 2015

-

____ : for a U.S.

- Ecuador frequency allocation : ( Houston

- Quito, Ecuador ) :

-------------------------------------------------------------- -
APPLICATION OF UNITED AIRLINES, INC. FOR A FREQUENCY ALLOCATION

Communications with respect to this document should be sent to:

Steve Morrissey Vice President

- Regulatory & Policy UNITED AIRLINES, INC. 1225 New York Avenue, NW Suite 1100

– DCAIZ Washington, DC 20005 (202) 521

- 4373 steve.morrissey@united.com

Daniel A. Weiss Managing Director

- International Affairs and Regulatory UNITED AIRLINES, INC. 233 South Wacker Drive 10th Floor

– HDQIZ Chicago, IL 60606 (872) 825

- 6828 dan.weiss@united.com

February 19
, 201 5 Thomas Newton Bolling Vice President and Deputy General Counsel Abby L. Bried Associate General Counsel

- Regulatory, Alliances & International James Conneely Counsel

- Regulatory UNITED AIRLINES, INC. 233 South Wacker Drive 11th Floor

– HDQLD Chicago, IL 60606 (872) 825

- 8068 (872) 825

- 7415 (872) 825

- 8311 thomas.bolling@united.com abby.bried@united.com james.conneely@united.com
Gerald F. Murphy Steven J. Seiden CROWELL & MORING LLP 1001 Pennsylvania Avenue, NW Was hington, DC 20004 (202) 624

- 2500 gmurphy@crowell.com sseiden@crowell.com

Counsel for United Airlines, Inc.

NOTICE : United has requested expedited treatment of this a pplication. It will poll U.S. carrier

representatives and inform the Department of the results.BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

------------------------------- -------------------------- Application of :
: UNITED AIRLINES, INC. : Docket DOT

- OST

- 2015

-

____ : for a U.S.

- Ecuador frequency allocation : (Houston

- Quito, Ecuador) :

---------------------------------------------------------

APPLICATION OF UNITED AIRLINES, INC. FOR A FREQUENCY ALLOCATION

United 1 a ppl ies for two weekly U.S.

- Ecuador combination frequencies so that United can
expand its Ecuador service offerings by operating two additional nonstop weekend flight s on a

seasonal basis between its Houston hub and Quito . United proposes to commence this enhanced

seasonal service on or about July 3, 2015 using a Boeing B

- 737 aircraft from its existing fleet
, provided all necessary approvals have been secured . United asks that this Houston

- Quito
frequency allocation remain in effect indefinitely.
United states as follows in support of this application :

1. United currently offers daily nonstop Houston

- Quito service using a Boeing B

737 aircraft pursuant to its Route 29

- F certificate authority 2 and corresponding allocation of

seven Houston

- Quito combination frequencies

. 3 United seeks two additional Houston

- Quito

1 Common names are used for airlines.
2 See Order 2000

- 8

- 19.
3 See Notices of Action Taken dated Feb. 20, 2004 and Nov. 17, 2004 in Docket DOT

- OST

- 2004

- 16941.Application of United

Page 2
frequencies to provide enhanced weekend service on a seasonal basis to meet increasing demand
in this sign i ficant U.S.

- Ecuador market.

2. Allocation of these additional frequencies will allow United to provide substantial
benefits to the U.S. traveling and shipping public by offering expanded nonstop U.S.

- Ecuador
service, and is clearly in the public interest. United’s augmented weekend service between

Houston and Quito will enhanc e United’s hub at Houston ; maximize connectin g service options

for consumers; allow for broader time of day coverage with a new, evening departure from

Houston t hat complement s United’s current midday departure ; facilitate the development of

additional trade and tourism between the United States and Ecuador ; and provide similar benefits
throughout United’s Houston hub network

. Flight UA1293 will depart Houston George Bu sh
Intercontinental Airport at 11:59 p.m. on Fridays and Saturdays and arrive at Quito Mariscal

S ucre International Airport at 5 :19 a.m. the following day (all times local). On the return, Flight

UA1294 will depart Quito at 7 : 35 a.m. and arrive at Houston at 1:00 p.m. the same day. 4 United
urges the Department to act prompt l y on this application so that it can secure foreign authority,
make final operating plans
, and begin marketing these additional Houston

- Quito flights well in
advance of operations, which United plans to commence on or about July 3
, 2015 , provide d all
necessary approvals have been secured. 5

3

. The requested authority is consistent with the o verall state of aviation relations

between the United States and Ecuador and the U .S.

- Ecuador Air Transport Agreement (“U.S.

-

4 These planned flight times parallel those for United’s Houston

- Bo g o ta and Houston

- Caracas overnight services, both of which have been markedly successful.

5 United will poll airline representatives and advise the Department of the results.Application of United

Page 3

Ecuador Agreement”), as amended. 6 Under Annex I of the U.S.

- Ecuador Agreement, designated
U.S. airlines “may provide direct servic e to Quito, Guayaquil, Latacunga, Manta, and other
airports as they become available for international service.” 7 Further, the U.S.

- Ecuador
Agreement provides that designated airlines of each Party may operate 120 round trip
combination frequencies per week on authorized routes. 8 There are currently 57 weekly U.S.

-

Ecuador combination frequencies available to U.S. carriers . After granting United’s request for

two frequencies to support United’s expanded Houston

- Quito service , the Department will still

h ave 55 U.S.

- Ecuador combination frequencies that remain available for allocation. United
requests the ability to operate these frequencies on a seasonal basis so that it has the flexibility to
tailor service levels during periods of reduced demand

.
4

. U nited holds various certificates of public convenience and necessity and
exemptions authorizing it to engage in scheduled air transportation of persons, property
, and mail
between the U.S. and foreign countries, and United is fit, willing
, and able to prov ide the service
for which it seeks authority. See, e.g., Order s 2014

- 9

- 23 (Guam

- Shanghai), 2013

- 4

- 11 (reissuing

United/Con tinental authorities to United), 2011

- 3

- 14 (United/Continental route transfer), 2010

- 5

-
17 (U.S.

- Mexico) and 2007

- 4

- 19 (Blanket Open S kies) ; and Notice s of Action Taken dated
January 20, 2015 in Docket s DOT

- OST

- 2014

- 0224 ( New Orleans

- Cancun, Mexico ) and DOT

OST

- 2005

- 21949 (Houston

- Buenos Aires, Argentina) . Pursuant to Rule 24 of the Department’s

6 The U.S.

- Ecuador Agreement was originally signed on September 26
, 1986
, and most re cently amended on July 21
, 2010

.

7 Protocol to Modify the Annexes to the Air Transport Agreement Between the Government of the United States of America and the Government of the Republic of Ecuador (Jul. 21
, 2010) , Annex I, Sec. 2(1)(A)(i), n. 1.

8 See i d . at Annex I, Sec. 3(1).Application of United

Page 4

Rules of Practice , United requests that t he Department take official notice of all information and

data that have been filed to establish its fitness.

5

. Grant of the requested authority will not cause a near

- term net annual change in
United’s aircraft fuel consumption of 10 million gallons or m ore and will not, therefore,
constitute a major regulatory action under Part 313 of the Department’s Procedural Regulations.

WHEREFORE, United respectfully request s that the Department promptly grant this
application for two additional U.S.

- Ecuador frequen cies, and such other relief as the Department
may deem appropriate.
Respectfully submitted,

CROWELL & MORING LLP

____________________________________ Gerald F. Murphy Steven J. Seiden gmurphy@crowell.com sseiden@crowell.com

Counsel for United Airlines, Inc

.

February 19
, 201 5CERTIFICATE OF SERVICE

I hereby certify that I have this date served a copy of the foregoing document on all
persons named below by causing a copy to be sent via email:

howard.kass@aa.com sllunsford@fedex.com robert.wirick@aa.com gbleopard@fedex.com sascha.vanderbellen@delta.com nssp arks@fedex.com sametta.c.barnett@delta.com rpommer@atlasair.com chris.walker@delta.com john.s.duncan@faa.gov anita.mosner@hklaw.com dwight.moore@transcom.mil jennifer.nowak@hklaw.com englets@state.gov

___________________________ Steve n J. Seiden

February 19 , 2015