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 

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 Docket DOT-OST-2001-10417 

 

JOINT APPLICATION OF DELTA AIR LINES, INC., 

ALITALIA - COMPAGNIA AEREA ITALIANA S.P.A., AND COMPASS 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 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. 

ALITALIA - COMPAGNIA AEREA ITALIANA S.P.A. 

and 

COMPASS AIRLINES, LLC 

for a statement of authorization pursuant to 

14 C.F R. Part 212 

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 Docket DOT-OST-2001-10417 

 

JOINT APPLICATION OF DELTA AIR LINES, INC., 

ALITALIA - COMPAGNIA AEREA ITALIANA S.P.A., AND COMPASS AIRLINES, LLC 

FOR A STATEMENT OF AUTHORIZATION

Delta Air Lines, Inc. (“Delta”), Alitalia - Compagnia Aerea Italiana S.p.A. (“Alitalia”) 

and Compass Airlines, LLC (“Compass”) (together, the “Joint Applicants”) hereby apply for 

authority to expand Alitalia’s existing codesharing on Delta to include Delta Connection 

operations by Compass. Specifically, pursuant to 14 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) within the United States (in conjunction 

with Alitalia’s services in foreign air transportation), and (b) between the United States and 

third countries.1 Compass requests that its statement of authorization be valid for an 

indefinite period subject to the Department’s normal code share conditions.2

 

 In support of this Joint Application, Delta, Alitalia, 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 request consolidation of this application into Docket 

DOT-OST-2001-10417, the Docket established by the Department for the administration of the 

grant of the blanket statements of authorization issued to Alitalia and Delta.

2

 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 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/Alitalia 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 expand codesharing to 

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

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

permitting Compass to display Alitalia’s “AZ*” designator code on flights operated by 

Compass: (a) within the United States (in conjunction 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 approved by the Department and an 

ancillary Delta/Alitalia/Compass codeshare agreement. A redacted copy of the ancillary 

Delta/ Alitalia/Compass codeshare agreement is attached to this Application. 

5. Alitalia holds a foreign air carrier permit authorizing it to engage in the full 

scope of foreign air transportation permissible under 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 supported the grant of 

codeshare authority to Alitalia and Delta apply with equal force to the services operated by 

Compass on behalf of Delta. Alitalia and Delta have a longstanding codesharing 

relationship, and grant of this application will enable 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 necessary, the Joint Applicants request 

that the authority requested here for Alitalia codesharing on Compass be administered 

jointly with the authority for Alitalia codesharing on Delta and other Delta Connection 
Joint 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 operating carriers authorized in this docket, 

except for U.S.-Mexico service where notices will continue to be provided on an operating 

carrier specific basis. The Joint Applicants incorporate by reference all previous nonMexico codeshare-point notices provided in this docket, 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 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, Alitalia, and Compass request that 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 this 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 Continental) 

howard.kass@usairways.com 

benjamin.slocum@usairways.com 

esta.rosenberg@dot.gov 

info@airlineinfo.com