BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Joint Application of 

DELTA AIR LINES, INC. 

CHINA SOUTHERN AIRLINES COMPANY LIMITED 

SKYWEST AIRLINES, INC. 

for a statement of authorization pursuant to 

14 C.F R. Part 212 and amended exemption 

pursuant to 49 U.S.C. § 40109 

(U.S.-China Codesharing) 

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 Dockets DOT-OST-1997-2653 

 DOT-OST-1999-5031 

 DOT-OST-2001-9314 

 DOT-OST-2001-10172 

JOINT APPLICATION OF DELTA AIR LINES, INC., 

CHINA SOUTHERN AIRLINES COMPANY LIMITED AND SKYWEST AIRLINES, INC. 

FOR A STATEMENT OF AUTHORIZATION AND AN AMENDED EXEMPTION

Communications with respect to this document should be sent to: 

Alexander Van der Bellen, 

 Managing Director, Government Affairs 

 and Associate General Counsel 

Jeff Morgan 

 Regional Director, Government Affairs 

DELTA AIR LINES, INC. 

1212 New York Avenue, NW Suite 200 

Washington, DC 20005 

(202) 842-4184 

sascha.vanderbellen@delta.com

George U. Carneal 

HOGAN LOVELLS US LLP 

555 Thirteenth Street, NW 

Washington, DC 20004 

(202) 637-6546 

george.carneal@hoganlovells.com 

Counsel for 

CHINA SOUTHERN AIRLINES 

 COMPANY LIMITED 

September 7, 2011 

Todd C. Emerson, Esq. 

SKYWEST AIRLINES, INC. 

444 South River Road 

St. George, Utah 84790 

temerson@skywest.com 

Lorraine B. Halloway 

Gerald F. Murphy 

CROWELL & MORING LLP 

1001 Pennsylvania Ave, N.W. 

Washington, DC 20004 

(202) 624-2500 

lhalloway@crowell.com 

gmurphy@crowell.com 

Counsel for 

SKYWEST AIRLINES, INC. 

Notice: The Joint Applicants intend to poll the U.S. carrier representatives on the 

attached service list regarding this Application and will notify the Department of the 

results as soon as possible. 
 

BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Joint Application of 

DELTA AIR LINES, INC. 

CHINA SOUTHERN AIRLINES COMPANY LIMITED 

SKYWEST AIRLINES, INC. 

for a statement of authorization pursuant to 

14 C.F R. Part 212 and amended exemption 

pursuant to 49 U.S.C. § 40109 

(U.S.-China Codesharing) 

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Dockets DOT-OST-1997-2653 

 DOT-OST-1999-5031 

 DOT-OST-2001-9314 

 DOT-OST-2001-10172 

JOINT APPLICATION OF DELTA AIR LINES, INC., 

CHINA SOUTHERN AIRLINES COMPANY LIMITED AND SKYWEST AIRLINES, INC. 

FOR A STATEMENT OF AUTHORIZATION AND AN AMENDED EXEMPTION

Delta Air Lines, Inc. (“Delta”), China Southern Airlines Company Limited (“China 

Southern”) and SkyWest Airlines, Inc. (“SkyWest”) (together, the “Joint Applicants”) 

hereby apply for authority to expand China Southern’s existing codesharing on Delta to 

include Delta Connection operations by SkyWest. Specifically, pursuant to 14 C.F.R. Part 

212, SkyWest seeks a blanket statement of authorization allowing SkyWest to display 

China Southern’s “CZ*” code on Delta Connection flights SkyWest operates: (a) within the 

United States (in conjunction with China Southern’s services in foreign air transportation), 

and (b) between the United States and third countries. SkyWest’s requests that its 

statement of authorization be valid for an indefinite period subject to the Department’s 

normal code share conditions.1

 

Furthermore, pursuant to 49 U.S.C. § 40109, China Southern seeks amendment of 

its existing exemption authority for codesharing with Delta to authorize the codesharing 

 

1

 To the extent necessary, the Joint Applicants request a waiver of the 45-day advance filing 

requirement for codeshare statements of authorization under 14 C.F.R. Part 212. 
Joint Application of Delta, China Southern, and SkyWest

Page 2

services under the exemption to be operated by SkyWest or any other authorized U.S. air 

carrier. China Southern requests that the amended exemption authority remain in effect 

for a period of at least one year. 

 In support of this Joint Application, Delta, China Southern, and SkyWest state as 

follows: 

1. SkyWest is a certificated U.S. air carrier that operates flights for marketing 

and sale by Delta. 

2. The Department has previously approved Delta/China Southern blanket 

statements of authorization for reciprocal codesharing. See Notice of Action Taken dated 

March 11, 2008, Dockets DOT-OST-1997-2653, DOT-OST-1999-5031, DOT-OST-2001-

9314, and DOT-OST-2001-10172. The proposed services are fully consistent with the 

Department’s prior codeshare approval and also with the Air Transport Agreement, as 

amended, between the United States and the People’s Republic of China. 

3. Delta, China Southern, and SkyWest have agreed to expand codesharing 

to encompass flights operated by SkyWest on Delta’s behalf. Accordingly, the Joint 

Applicants request a blanket statement of authorization under 14 C.F.R. Part 212, 

permitting SkyWest to display China Southern’s “CZ*” designator code on flights operated 

by SkyWest: (a) within the United States (in conjunction with China Southern’s services in 

foreign air transportation), and (b) between the United States and third countries. 

4. The proposed codeshare services will be operated pursuant to the 

Delta/China Southern codeshare agreement previously approved by the Department and 

an ancillary Delta/China Southern/SkyWest codeshare agreement. A redacted copy of 

the ancillary Delta/China Southern/SkyWest codeshare agreement is attached to this 

Application. 

5. China Southern holds broad exemption authority to codeshare on Delta. 

That authority was last renewed for one year by Notice of Action Taken dated 
Joint Application of Delta, China Southern, and SkyWest

Page 3

December 5, 2008 in Docket DOT-OST-1999-5031. A timely renewal application filed on 

December 2, 2009 remains pending. The existing exemption authority is “limited to 

operations conducted only through [China Southern’s] code-share arrangements with 

Continental [which has been discontinued] and Delta, on flights operated by these U.S. air 

carriers.” China Southern requests that this exemption be amended to include flights 

operated not only by Delta and SkyWest but, for the sake of administrative efficiency 

(particularly if additional Delta Connection carriers are added to the arrangement in the 

future), also by any other U.S. air carrier holding the necessary statement of authorization. 

6. The same public interest considerations that supported the grant of 

codeshare authority to China Southern and Delta apply with equal force to the services 

operated by SkyWest on behalf of Delta. China Southern and Delta have a longstanding 

codesharing relationship, and grant of this application will enable China Southern to 

further expand its on-line service options, providing important new service and competitive 

options to U.S.–China travelers and shippers. 

7. To the extent necessary, the Joint Applicants request that the Department 

consolidate this application into the existing Delta/China Southern codeshare dockets 

(DOT-OST-1997-2653, DOT-OST-1999-5031, DOT-OST-2001-9314, and DOT-OST2001-10172). The Joint Applicants further request that the authority requested here for 

China Southern codesharing on SkyWest be administered jointly with the authority for 

China Southern codesharing on Delta such that any beyond U.S. gateway point notice 

given for Delta or SkyWest operations is deemed notice for either carrier. The Joint 

Applicants will continue to rely on the established practice whereby any notice for a 

beyond U.S. gateway point is deemed notice for that point via all authorized gateways. 

The Joint Applicants incorporate by reference all previous codeshare-point notices 

provided in the Delta/China Southern codeshare dockets. The Joint Applicants note that 
Joint Application of Delta, China Southern, and SkyWest

Page 4

their initial codeshare markets (listed at Exhibit A-2 to the attached codeshare agreement) 

have all been previously noticed in the Delta/China Southern codeshare dockets. 

8. SkyWest is not a CRAF participant. 

9. The Joint Applicants will conduct these codeshare services in accordance 

with 14 C.F.R. Part 257 and the other conditions normally imposed by the Department on 

codesharing statements of authorization. 

 WHEREFORE, Delta, China Southern, and SkyWest request that the Department 

promptly grant the authority described herein. 

Respectfully submitted, 

/s/ George U. Carneal /s/ Gerald F. Murphy

________________________________ ________________________________ 

George U. Carneal 

HOGAN LOVELLS US LLP 

Counsel for 

CHINA SOUTHERN AIRLINES 

 COMPANY LIMITED 

Gerald F. Murphy 

Lorraine B. Halloway 

CROWELL & MORING LLP 

Counsel for 

SKYWEST AIRLINES, INC. 

________________________________ 

Alexander Van der Bellen 

Managing Director, Government Affairs 

 & Associate General Counsel 

DELTA AIR LINES, INC. 






 

CERTIFICATE OF SERVICE

A copy of the foregoing document has been served this 7th day of September, 2011, upon 

the following persons via email: 

carl.nelson@aa.com 

dan.weiss@coair.com 

thomas.bolling@united.com 

howard.kass@usairways.com 

benjamin.slocum@usairways.com 

esta.rosenberg@dot.gov 

keith.glatz@dot.gov 

info@airlineinfo.com