Application of 

WEST JET 

BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

Docket DOT-OST-2015-

under 14 CFR Part 212 for a statement of 

authorization (blanket codesharing) 

APPLICATION OF WEST JET FOR A STATEMENT OF AUTHORIZATION 

Communications with respect to this document should be sent to: 

April 7, 2015 

DON H. HAINBACH 

Garofalo Goerlich Hainbach PC 

1200 New Hampshire Avenue NW 

Washington, DC 20036 

Phone: (202) 776-3970 

dhainbach((i)ggh-airlaw .com 

Counsel for WestJet 

Notice: Any person who wishes to support or oppose this application may file an answer on or before 

April22, 2015. However, WestJet requests expedited treatment of this application. WestJet will poll the 

U.S. carrier representatives served with this application and notify the Department promptly of the results 

of the poll. 
Application of 

WEST JET 

BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

Docket DOT-OST-2015-

under 14 CFR Part 212 for a statement of 

authorization (blanket codesharing) 

APPLICATION OF WESTJET FORA STATEMENT OF AUTHORIZATION 

WestTet hereby applies for a statement of authorization pursuant to 14 CFR Part 212 to the extent 

necessary to enable it to allow Westlet to display the KLM Royal Dutch Airlines, N.V. (KLM) KL* 

designator code on flights operated by WestTet from any point or points behind Canada, via any point or 

points in Canada, and via intermediate points to any point or points in the United States and beyond. 

Westlet intends to initiate codeshare service as soon as possible following receipt of all required 

government approvals, by listing the KLM KL * designator code on flights operated by WestTet between 

KLM's North American gateways: Calgary, Montreal, Toronto, Vancouver, New York, Los Angeles, 

Chicago, and San Francisco, on the one hand, and the U.S. and Canadian points listed in Attachment A, 

on the other hand, and respectfully requests expedited approval of this application to enable KLM and 

Westlet to begin marketing and sales activities without delay. 1 WestTet furthers request that the statement 

of authorization be issued for an indefinite period. 

In support of this application, Westlet submits the following: 

1. WestTet, a Canadian carrier, currently operates service to the United States pursuant to its foreign 

air carrier permit issued by the Department by Order 2012-6-6, in Docket DOT-OST-2001-11158. That 

foreign air carrier permit authorizes WestJet to operate, inter alia: 

To the extent necessary, WestJet respectfully requests a waiver of the advance filing requirements specified 

in Part 212 of the Department's regulations. 
Scheduled foreign air transportation of persons, property, and mail from points behind 

Canada via Canada and intermediate points to a point or points in the United States and 

beyond 

2. KLM, a carrier of the Kingdom of the Netherlands, currently operates service to the United States 

pursuant to its foreign air carrier permit issued by the Department by Order 2008-5-40, in Docket DOTOST-2007-0127. That foreign air carrier permit authorizes KLM to operate, inter alia: 

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. 

3. WestJet and KLM have entered into a codeshare agreement, and WestJet is requesting blanket 

codeshare authorization for the transportation of persons, property and mail, pursuant to Part 212 of the 

Department's regulations, to allow WestJet to display the KLM KL * designator code on flights operated 

by WestJet from any point or points behind Canada, via any point or points in Canada, and via 

intermediate points to any point or points in the United States and beyond. KLM intends to market such 

codeshare services in accordance with its authority to conduct foreign 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. KLM will not market its codeshare service to local passengers traveling solely between 

Canada and the United States. 

4. The requested authority is consistent with the March 12, 2007 U.S.-Canada Air Transport 

Agreement, Article 11(6) of which authorizes cooperative marketing arrangements including codesharing 

with third-country airlines. The requested authority is also consistent with the 2007 U.S.-EU Open Skies 

Agreement, Article 1 0 of which authorizes cooperative marketing arrangements including code sharing 

with third-country airlines. 

5. Blanket authorizations are in the public interest because they enable codeshare partners to 

develop the full range of services permitted under applicable air services agreements. The services 

contemplated by WestJet and KLM will provide a more efficient use of capacity in the marketplace and 

2 
will help maximize the service options available to the traveling and shipping public. The requested 

authorization is also consistent with the Department's grant of blanket codesharing authority to other 

foreign carriers whose homeland governments have open skies relationships with the United States. See, 

e.g., Department Action on Application, Docket DOT-OST-2010-0248 (October 21, 2010) granting 

blanket codesharing statements of authorization to British Airways and Iberia; and Department Action on 

Application, Docket DOT-OST-2011-0181 (October 3, 2011) granting blanket codesharing statements of 

authorization to JAL and LAN Airlines S.A. 

6. By submitting this application, WestJet hereby provides notice of its intent to display the KL* 

code on the routes described above. Consistent with standard practice, WestJet will notify the 

Department no later than 30 days before commencing any codeshare services to non-open skies points. 

Any notification regarding non-open skies points will inform the Department of the codeshare market(s) 

to be served and the date on which the service will begin. WestJet and KLM will conduct all of their 

codeshare operations in compliance with 14 CFR Part 257 and will accept the Department's standard 

codeshare conditions. 

ACCORDINGLY, WestJet submits that grant of the authority requested would be consistent with 

the public interest, and it respectfully requests that the Department grant it a statement of authorization to 

display the KLM KL * designator code on flights operated by WestJet from any point or points behind 

Canada, via any point or points in Canada, and via intermediate points to any point or points in the United 

States and beyond, and such other additional relief as the Department may deem appropriate. WestJet 

further requests that the requested authority be granted for an indefinite period, consistent with the 

Department's practice. 

~s?k_ 

3 

Don H. Hainbach 

Counsel for WestJet 
North American Gateways: 

Calgary, AB (YYC) 

Montreal, QC (YUL) 

Toronto, ON (YYZ) 

Vancouver, BC (YVR) 

Chicago, IL (ORD) 

Los Angeles, CA (LAX) 

New York, NY (JFK) 

San Francisco, CA (SFO) 

U.S. Points: 

Chicago, IL (ORD) 

Dallas/Fort Worth, TX (D FW) 

Fort Lauderdale, FL (FLL) 

Fort Myers, FL (RSW) 

Honolulu, HI (HNL) 

Houston, TX (IAH) 

Kahului, HI (OGG) 

Kauai Island, HI (LIH) 

Kona, HI (KOA) 

Las Vegas, NV (LAS) 

Los Angeles, CA (LAX) 

Myrtle Beach, SC (MYR) 

New York, NY (JFK) 

New York, NY (LGA) 

Orlando, FL (MCO) 

Palm Springs, CA (PSP) 

Phoenix, AZ (PHX) 

San Diego, CA (SAN) 

San Francisco, CA (SFO) 

Santa Ana, CA (SNA) 

Tampa, FL (TPA) 

ATTACHMENT A 

CODESHARE POINTS 
CERTIFICATE OF SERVICE 

I hereby certify that I have this day served the foregoing document by email on the following 

persons: 

April 7, 2015 

David Heffernan (Alaska Airlines) 

Howard Kass (American) 

Robert Wirick (American) 

John Richardson (Amerijet International) 

Joan Canny (Amerijet International) 

Gerald F. Murphy (ExpressJet/ SkyWest) 

Kevin Montgomery (Polar) 

Russell Pommer (Atlas Air) 

Chris Walker (Delta) 

Alexander Vander Bellen (Delta) 

Nancy Sparks (FedEx) 

Courtney Felts (FedEx) 

Bailey Leopard (FedEx) 

Jonathan Hill (Hawaiian/JetBlue) 

Parker Erkmann (Hawaiian!JetBlue) 

Mark Atwood (Kalitta) 

Joanne Young (Spirit) 

Dan Weiss (United) 

Steve Morrissey (United) 

Anita Mosner (UPS) 

Jennifer Nowak (UPS) 

Robert Finamore (DOT) 

John Duncan (FAA) 

Stephen Cristina (State Department) 

dheffernan(ivcozen.com 

Howard.kass({vaa.com 

robert. wirick(ivaa.com 

ffich~rdson(£.Vjohnlrichardson.com 

jcannvr{i~amerijet .com 

gmurphvrti)crowell.com 

kevin.montgomery(u}polaraircargo.com 

rpommerw!atlasair.com 

chris.walkedlvdelta.com 

sascha.vanderbellenr(vdelta.com 

nssparks((iJfedex.com 

~cfelts(a}fedex.com 

gbleopard((/!tedex.com 

jhj Ilr{i)cooley .com 

perkmann(~L:cooley .com 

m atwood(a)cozen .com 

jyoungr{ilyk Ia w .com 

dan.weisscwunited.com 

steve.morrisseyr(iJunited.com 

Anita.mosner(dihklaw .com 

jennifer.nowakriilhklaw·.com 

robert.finatnore~ildot.gov 

john.s.duncanr~[Jfaa.gov 

cristinasa(£lstate .gov