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, 2015

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

Washington, DC 20004

(202) 624-2500

gmurphy@crowell.com

sseiden@crowell.com

Counsel for

United Airlines, Inc. 

NOTICE: United has requested expedited treatment of this application. 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

United1applies for two weekly U.S.-Ecuador combination frequencies so that United can 

expand its Ecuador service offerings by operating two additional nonstop weekend flights 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 B737 aircraft pursuant to its Route 29-F certificate authority2

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 significant 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 enhance United’s hub at Houston; maximize connecting service options 

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

Houston that complements 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 Bush 

Intercontinental Airport at 11:59 p.m. on Fridays and Saturdays and arrive at Quito Mariscal 

Sucre 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 promptly 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, provided all 

necessary approvals have been secured.5 

3. The requested authority is consistent with the overall 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-Bogota 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 service to Quito, Guayaquil, Latacunga, Manta, and other 

airports as they become available for international service.”7Further, the U.S.-Ecuador 

Agreement provides that designated airlines of each Party may operate 120 round trip 

combination frequencies per week on authorized routes.8There 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 

have 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. United 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 provide the service 

for which it seeks authority. See, e.g., Orders 2014-9-23 (Guam-Shanghai), 2013-4-11 (reissuing 

United/Continental authorities to United), 2011-3-14 (United/Continental route transfer), 2010-5-

17 (U.S.-Mexico) and 2007-4-19 (Blanket Open Skies); and Notices of Action Taken dated 

January 20, 2015 in Dockets DOT-OST-2014-0224 (New Orleans-Cancun, Mexico) and DOTOST-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 recently 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 id. at Annex I, Sec. 3(1). 
Application of United

Page 4

Rules of Practice, United requests that the 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 more and will not, therefore, 

constitute a major regulatory action under Part 313 of the Department’s Procedural Regulations.

WHEREFORE, United respectfully requests that the Department promptly grant this 

application for two additional U.S.-Ecuador frequencies, 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, 2015
CERTIFICATE 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 nssparks@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

___________________________

Steven J. Seiden

February 19, 2015