BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Joint Application of DELTA AIR LINES, INC. ALITALIA - COMPAGNIA AEREA ITALIANA S.P.A. and COMPASS AIRLINES, LLC
for a statement of authorization pursuant to 14 C.F R. Part 212 ) ) ) ) ) ) ) ) ) Docket DOT-OST-2001-10417

JOINT APPLICATION OF DELTA AIR LINES, INC., ALITALIA - COMPAGNIA AEREA ITALIANA S.P.A., AND COM PASS AIRLINES, LLC

FOR A STATEMENT OF AUTHORIZATION
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

Richard D. Mathias David M. Endersbee ZUCKERT, SCOUTT & RASENBERGER, L.L.P. 888 Seventeenth Street, N.W., Suite 700 Washington, DC 20006 (202) 973-7917 rdmathias@zsrlaw.com dmendersbee@zsrlaw.com

Counsel for ALITALIA - COMPAGNIA AEREA ITALIANA S.P.A.
June 6, 2011 Jennifer Trock PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, NW Washington, DC 20037 (202) 663-8000 jennifer.trock@pillsburylaw.com

Counsel for COMPASS AIRLINES, LLC

Notice: The Joint Applicants intend to poll the U. S. carrier representatives on the attached service list regarding this Application an d 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. ALITALIA - COMPAGNIA AEREA ITALIANA S.P.A. and COMPASS AIRLINES, LLC
for a statement of authorization pursuant to 14 C.F R. Part 212 ) ) ) ) ) ) ) ) ) Docket DOT-OST-2001-10417

JOINT APPLICATION OF DELTA AIR LINES, INC., ALITALIA - COMPAGNIA AEREA ITALIANA S.P.A., AND COM PASS AIRLINES, LLC

FOR A STATEMENT OF AUTHORIZATION

Delta Air Lines, Inc. (“Delta”), Alitalia - Compagn ia Aerea Italiana S.p.A. (“Alitalia”)
and Compass Airlines, LLC (“Compass”) (together, th e “Joint Applicants”) hereby apply for
authority to expand Alitalia’s existing codesharing on Delta to include Delta Connection
operations by Compass. Specifically, pursuant to 1 4 C.F.R. Part 212, Compass seeks a
blanket statement of authorization allowing Compass to display Alitalia’s “AZ*” code on
Delta Connection flights Compass operates: (a) with in the United States (in conjunction
with Alitalia’s services in foreign air transportat ion), and (b) between the United States and

third countries. 1 Compass requests that its statement of authorizat ion be valid for an
indefinite period subject to the Department’s norma l code share conditions. 2
In support of this Joint Application, Delta, Alita lia, and Compass state as follows:
1. Compass is a certificated U.S. air carrier that operates flights for marketing
and sale by Delta.

1 To the extent necessary, the Joint Applicants reque st consolidation of this application into Docket DOT-OST-2001-10417, the Docket established by the D epartment for the administration of the grant of the blanket statements of authorization is sued to Alitalia and Delta.

2 The Joint Applicants request a waiver of the 45-da y advance filing requirement for codeshare statements of authorization under 14 C.F.R. Part 21 2 so that the proposed codeshare services may begin without delay.Joint Application of Delta, Alitalia, and Compass Page 2 2. The Department has previously approved Delta/Ali talia blanket statements
of authorization for reciprocal codesharing. See Notice of Action Taken dated December
23, 2008, Docket DOT-OST-2001-10417. The proposed services are fully consistent with
the Department’s prior codeshare approval and with the U.S.-EU Open Skies Agreement.
3. Delta, Alitalia, and Compass have agreed to expa nd codesharing to
encompass flights operated by Compass on Delta’s be half. Accordingly, the Joint
Applicants request a blanket statement of authoriza tion under 14 C.F.R. Part 212,
permitting Compass to display Alitalia’s “AZ*” desi gnator code on flights operated by
Compass: (a) within the United States (in conjuncti on with Alitalia’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/Alitalia codeshare agreement previously appro ved by the Department and an
ancillary Delta/Alitalia/Compass codeshare agreemen t. A redacted copy of the ancillary
Delta/ Alitalia/Compass codeshare agreement is atta ched to this Application.
5. Alitalia holds a foreign air carrier permit auth orizing it to engage in the full
scope of foreign air transportation permissible und er the U.S.-EU Open Skies Agreement.

See Order 2010-1-5 dated January 21, 2010, Docket DOT- OST-2009-0219.
6. The same public interest considerations that sup ported the grant of
codeshare authority to Alitalia and Delta apply wit h equal force to the services operated by
Compass on behalf of Delta. Alitalia and Delta hav e a longstanding codesharing
relationship, and grant of this application will en able Alitalia to further expand its on-line
service options to additional U.S. and beyond-U.S. cities.
7. The Joint Applicants’ initial codeshare markets are listed at Exhibit A-2 to
the attached codeshare agreement. To the extent ne cessary, the Joint Applicants request
that the authority requested here for Alitalia code sharing on Compass be administered
jointly with the authority for Alitalia codesharing on Delta and other Delta ConnectionJoint Application of Delta, Alitalia, and Compass Page 3 carriers in docket DOT-OST-2001-10417 such that any non-open skies point 30-day
notice given is deemed notice for all of the operat ing carriers authorized in this docket,
except for U.S.-Mexico service where notices will c ontinue to be provided on an operating
carrier specific basis. The Joint Applicants incor porate by reference all previous nonMexico codeshare-point notices provided in this doc ket, including the March 2, 2009
Delta/Alitalia blanket open skies codeshare notice.
8. Compass is not a CRAF participant.
9. The Joint Applicants will conduct these codeshar e services in accordance

with 14 C.F.R. Part 257 and the other conditions no rmally imposed by the Department on
codesharing statements of authorization.
WHEREFORE, Delta, Alitalia, and Compass request th at the Department promptly
grant the authority described herein.

Respectfully submitted,

/s/ Richard D. Mathias /s/ Jennifer Trock

________________________________ __________________ ______________ Richard D. Mathias ZUCKERT, SCOUTT & RASENBERGER, L.L.P.

Counsel for ALITALIA - COMPAGNIA AEREA ITALIANA S.P.A. Jennifer Trock PILLSBURY WINTHROP SHAW PITTMAN LLP
Counsel for COMPASS AIRLINES, LLC

________________________________ 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 th is 6th day of June, 2011, upon the following persons via email:
carl.nelson@aa.com dan.weiss@coair.com (for United and Continental) thomas.bolling@coair.com (for United and Continenta l) howard.kass@usairways.com benjamin.slocum@ usairways.com esta.rosenberg@dot.gov info@airlineinfo.com