BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C.

__________________________________________ 

 ) 

In the matter of ) 

 ) 

2007/2008/2009 U.S.-China Air Services ) Docket DOT-OST-2007-28567 

and Combination Frequency Allocation ) 

Proceeding ) 

__________________________________________) 

MOTION OF UNITED AIR LINES, INC. 

 Communications with respect to this document should be sent to: 

MARY BARNICLE 

Manager – International & Regulatory 

Affairs 

UNITED AIR LINES, INC. 

77 West Wacker Drive, HDQIZ 

Chicago, IL 60601 

 

JULIE OETTINGER 

Managing Director – International 

& Regulatory Affairs 

JEFFREY A. MANLEY 

Senior Advisor – Regulatory Affairs 

UNITED AIR LINES, INC. 

1025 Connecticut Avenue, N.W. 

Suite 1210 

Washington, D.C. 20036 

Phone: (301) 229-8571 

jeffrey.manley@united.com

DATED: April 27, 2010 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

__________________________________________ 

 ) 

In the matter of ) 

 ) 

2007/2008/2009 U.S.-China Air Services ) Docket DOT-OST-2007-28567 

and Combination Frequency Allocation ) 

Proceeding ) 

__________________________________________) 

DATED: April 27, 2010 

MOTION OF UNITED AIR LINES, INC.

 By this motion, United Air Lines, Inc. (“United”) requests that Order 2007-9-25 

(as amended by Department action dated March 25, 2009) be further amended to allow 

United to begin non-stop San Francisco-Guangzhou service by June 30, 2011. Like Delta 

Airlines’ (“Delta”) April 21 request for an extension of the dormancy waiver for its 

planned daily Atlanta-Shanghai service and twice weekly Seattle-Beijing service, United 

is submitting this motion because international travel demand is improving but not at the 

level needed for U.S. carriers to implement all planned U.S.-China services for which the 

Department has awarded frequencies. See, Delta’s “Motion for a Dormancy Waiver”, 

dated April 21, 2010 in Dockets DOT-OST-2007-28567 and -2004-18469. 

 Granting United’s request is in the public interest since it will give United the 

ability to promptly and efficiently institute non-stop service between San Francisco and 

Guangzhou when market conditions improve and travel demand in this market increases. 

As the first U.S. carrier to serve Guangzhou on a non-stop service basis, United will 

require additional promotional sales efforts to support this entirely new market, which is 
Motion of United 

Page 2 

difficult to implement in the presently soft aviation market. Moreover, the grant of the 

relief requested is fully consistent with Department precedent granting extensions of 

dormancy waivers when economic conditions so warrant. Last, the grant of United’s 

request will not prejudice any other U.S. carrier since United’s application for the seven 

weekly San Francisco-Guangzhou non-stop frequencies was unopposed and no carrier 

objected to the award of those frequencies to United by Order 2007-9-25. Moreover, no 

carrier objected to United’s March 20, 2009 request seeking a deferral of the start-up date 

for this service. 

 WHEREFORE, on the basis of the foregoing, United respectfully requests that the 

Department amend Order 2007-9-25 to extend the start-up date for the frequencies 

identified above from June 30, 2010 to June 30, 2011, and that the Department grant such 

other and further relief as it may deem necessary and appropriate. 

Respectfully submitted, 

 JULIE OETTINGER 

Managing Director – International & 

Regulatory Affairs 

UNITED AIR LINES, INC. 

DATED: April 27, 2010
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 e-mail. 

carl.nelson@aa.com

hkamen@coair.com

howard_kass@usairways.com

rbkeiner@crowell.com

sascha.vanderbellen@delta.com

byerlyjr@state.gov

john.martin@flysfo.com

 kandace.bender@flysfo.com

Annalei Avanceña 

Advisor—Regulatory Affairs 

DATED: April 27, 2010