LUFTHANSA CITYLINE GMBH 

for a foreign air carrier permit 

pursuant to 49 U.S.C. § 41301 and for 

exemption authority pursuant to 

49 u.s.c. § 40109 

(U.S.-EU Scheduled and Charter 

Air Transportation) 

) ) ) ) ) ) ) 

) ) 

Docket DOT -OST -2015---. 

_____________________________) 

APPLICATION OF LUFTHANSA CITYLINE GMBH 

FOR A FOREIGN AIR CARRIER PERMIT 

AND FOR EXEMPTION AUTHORITY 

Communications with respect to this document should be addressed to: 

Arthur Molins 

General Counsel, the Americas 

Deutsche Lufthansa AG 

1640 Hempstead Turnpike 

East Meadow, NY 11554 

Telephone (516) 296-9234 

E-mail: arthur.molins@dlh.de 

DATED: February 9, 2015 

David Heffernan 

Cozen O'Connor 

The Army & Navy Club Building 

1627 I Street, NW 

Suite 1100 

Washington, DC 20006 

Telephone (202) 463-2537 

E-mail: dheffernan@cozen.com 

Counsel for 

LUFTHANSA CITYLINE GMBH 

NOTE: Any person may support or oppose this Application by filing an answer and 

serving a copy of the answer on counsel for Lufthansa CityLine GmbH and all persons 

listed on the attached service list. Answers to the exemption application are due on or 

before February 24, 2015, and answers to the permit application are due on or before 

March 2, 2015. 
LUFTHANSA CITYLINE GMBH 

for a foreign air carrier permit 

pursuant to 49 U.S.C. § 41301 and for 

exemption authority pursuant to 

49 U.S.C. § 40109 

(U.S.-EU Scheduled and Charter 

Air Transportation) 

) 

) ) ) 

) 

) 

) 

) 

) 

_____________________________ ) 

DATED: February 9, 2015 

Docket DOT-OST-2015-__ 

APPLICATION OF LUFTHANSA CITYLINE GMBH 

FOR A FOREIGN AIR CARRIER PERMIT 

AND FOR EXEMPTION AUTHORITY 

Pursuant to 49 U.S.C. §§ 40109 and 41301, Part 211 of the Department's 

Economic Regulations (14 C.F.R. Part 211 ), Subparts 8 and C of the Department's 

Rules of Practice in Proceedings (14 C.F.R. §§ 302.201 and 302.301, et. seq.), and the 

provisions of the U.S.-EU Reciprocal Recognition Procedures, Lufthansa Cityline 

GmbH ("Cityline") hereby applies for a foreign air carrier permit granting it the full rights 

available to EU Member State air carriers pursuant to the Air Transport Agreement 

between the United States of America and the European Union and its Member States. 1 

Cityline also requests, pursuant to 49 U.S. C. § 401 09, that the Department grant it an 

exemption from 49 U.S.C. § 41301 to the extent necessary to provide the services 

1 Air Transport Agreement Between the United States of America and the European Community and its 

Member States, signed April 25 and 30, 2007, as amended by the Protocol dated June 24, 2010 

(collectively "the U.S.-EU Agreement, as amended"'). 
regulatory procedures and issue a single order: (1) granting the requested exemption 

authority for a two-year period or until the requested permit authority becomes effective, 

whichever occurs first, and (2) granting the corresponding foreign air carrier permit 

request under the "show cause" procedures described in the Notice dated August 23, 

2005. 

In support of this application and in compliance with the Department's 

requirements under 14 C.F.R. § 211 .20 concerning an application for an initial foreign 

air carrier permit and the U.S.-EU Reciprocal Recognition Procedures, Cityline states 

as follows: 

1. Cityline is a private company organized and operating under the laws of 

the Federal Republic of Germany with its principal office at Heinrich-Steinmann-Strasse, 

D-51147 Cologne, Germany. It is wholly owned and controlled by Deutsche Lufthansa 

AG ("Lufthansa") and is a member of the Lufthansa Group. Both Lufthansa and 

Cityline are German-certificated air carriers. 

2. Cityline's operations are regulated by the Government of the Federal 

Republic of Germany. Germany is a contracting state to the Convention on 

International Civil Aviation CChicago Convention") and observes all applicable ICAO 

standards. Cityline is licensed by and subject to the jurisdiction of the German Civil 

Aviation Authority located at: 
Aviation Authority will be provided to the Department. The AOC will authorize Cityline 

to operate international and domestic air transportation services, including the 

international scheduled and charter air transportation services proposed in this 

application. 

3. As an air carrier of Germany and the European Union, Cityline requests 

that the Department grant it a foreign air carrier permit to authorize foreign air 

transportation consistent with the full scope of the U.S.-EU Agreement, as amended. 

Under that Agreement, EU Member State air carriers have the right to engage in: 

• Foreign scheduled and charter air transportation of persons, property and 

mail from any point or points behind any Member State of the European 

Union, via any point or points in any Member State and via intermediate 

points, to any point or points in the United States and beyond; 

• Foreign scheduled and charter air transportation of persons, property and 

mail between any point or points in the United States and any point or 

points in any member of the European Common Aviation Area; 

• Foreign scheduled and charter air transportation of cargo between any 

point or points in the United States and any other point or points; 

• Other charters pursuant to the prior approval requirements set forth in 14 

C. F. R. Part 212 of the Department's Economic Regulations; and 

• Transportation authorized by any additional route rights made available to 

European Union carriers under the U.S.-EU Air Transport Agreement in 

the future. 

4. In the interim, while its application for a foreign air carrier permit is 

pending, Cityline requests that it be granted an exemption from 49 U.S.C. § 41301 to 
transportation of persons, property and mail by displaying the code of any duly 

authorized U.S. air carrier on flights it operates on behalf of Lufthansa between any 

point or points in any Member State of the European Union and beyond the European 

Union to any point or points? Cityline plans to begin operating scheduled air service 

between a point or points in Germany and a point or points in the United States on or 

about September 25, 2015. Cityline will operate these services on behalf of its affiliate 

Lufthansa pursuant to a wet lease agreement. 3 

6. Cityline's insurance coverage meets the liability limits of 14 C.F.R. Part 

205. A copy of the carrier's Foreign Air Carrier Certificate of Insurance (OST Form 

6411) will be provided to the Department and filed with the Federal Aviation 

Administration. 

7. Cityline currently has on file with the Department an executed waiver of 

liability limits under the Warsaw Convention (OST Form 4523) in Docket DOT-OST2 Notice of Action Taken dated September 16, 2013 (Docket DOT-OST-2003-15485). Cityline also holds 

a statement of authorization issued by the Department under 14 C.F.R. Part 212 allowing Cityline to 

display United Airlines' designator code on flights operated by Cityline wholly within Germany, and 

between points in Germany and points in third countries Notice of Action Taken dated July 15, 2003 

(Docket DOT-OST-2003-15485). Cityline has submitted an application to amend that statement of 

authorization so that Cityline may display Un1ted's designator code on flights operated by Cityline 

pursuant to the authority requested herein. 

3 CttyUne has submitted an application for a statement of authorization (pursuant to Part 212 of the 

Department's regulations, 14 C.F.R. Part 212) to engage in wet leasing on behalf of Lufthansa. 
Department's regulations. 

WHEREFORE, CityLine respectfully requests that the Department grant its 

request for a foreign air carrier permit and corresponding exemption authorizing it to 

exercise the full rights available to EU Member State air carriers pursuant to the Air 

Transport Agreement between the United States of America and the European Union 

and its Member States, and such other and further relief as the Department deems 

appropriate. 

DATED: February 9, 2015 

Respectfully submitted, 

David Heffernan 

Cozen O'Connor 

The Army & Navy Club Building 

1627 I Street, NW 

Suite 1100 

Washington, DC 20006 

Telephone (202) 463-2537 

E-mail: dheffernan@cozen.com 

Counsel for 

LUFTHANSA CITYLINE GMBH 

4 See also Application of Lufthansa Citylme GmbH for Exemption and Statement of Authorization, Exhibit 

CLH-5, June 20, 2003 (Docket DOT-OST-2003-15485). 
mail upon the following: 

ABX Air and 

Air Transport lnt'l: 

Alaska Airlines: 

American Airlines: 

Amerijet lnt'l: 

Atlas Air: 

Delta Air Lines: 

Envoy Air: 

Federal Express: 

JetBiue Airways: 

Kalitta Air: 

Polar Air Cargo: 

Southern Air: 

Spirit Airlines: 

Sun Country Airlines: 

United Airlines: 

UPS: 

FAA: 

DATED: February 9, 2015 

rsilverberg@sgbdc.com 

jeremy. ross@alaskaair. com 

howard.kass@aa.com 

robert. wirick@aa. com 

jean ny@amerijet. com 

rpommer@atlasair.com 

sascha.vanderbellen@delta.com 

francis.heil@aa.com 

nssparks@fedex. com 

cefelts@fedex.com 

jhill@cooley .com 

psanderlin@kalittaair.com 

kevin. montgomery@polaraircargo. com 

agoerlich@ggh-airlaw.com 

jyoung@yklaw.com 

thomas. ting@suncountry .com 

gmurphy@crowell.com 

dan .weiss@united .com 

steve. morrissey@ united. com 

anita.mosner@hklaw.com 

john.s.duncan@faa.gov 

Kenneth C. Hines