BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

------------------------------------------------------

Application of :

:

UNITED AIRLINES, INC. :

: Docket DOT-OST-2014-0196

for a U.S.-China frequency allocation :

(San Francisco-Shanghai, China) :

------------------------------------------------------

MOTION OF UNITED AIRLINES, INC.

FOR A 60-DAY START-UP EXTENSION

Communications with respect to this document should be sent to:

Steve Morrissey

Vice President-Regulatory & Policy

UNITED AIRLINES, INC.

1225 New York Avenue, NW

Suite 1100 – DCAIZ

Washington, DC 20005

(202) 521-4373

steve.morrissey@united.com

Daniel A. Weiss

Managing Director-International

 Affairs and Regulatory

UNITED AIRLINES, INC.

233 South Wacker Drive

10th Floor – HDQIZ

Chicago, IL 60606

(872) 825-6828

dan.weiss@united.com

March 23, 2015

Thomas Newton Bolling

Vice President and Deputy General Counsel

Abby L. Bried

Associate General Counsel-Regulatory, 

 Alliances & International

James Conneely

Counsel-Regulatory

UNITED AIRLINES, INC.

233 South Wacker Drive

11th Floor – HDQLD

Chicago, IL 60606

(872) 825-8068

(872) 825-7415

(872) 825-8311

thomas.bolling@united.com

abby.bried@united.com

james.conneely@united.com

Gerald F. Murphy

Steven J. Seiden

CROWELL & MORING LLP

1001 Pennsylvania Avenue, NW

Washington, DC 20004

(202) 624-2500

gmurphy@crowell.com

sseiden@crowell.com

Counsel for

United Airlines, Inc. 

NOTICE: United has requested expedited treatment of this motion. It will poll U.S. 

carrier representatives and inform the Department of the results. 
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

------------------------------------------------------

Application of :

:

UNITED AIRLINES, INC. :

: Docket DOT-OST-2014-0196

for a U.S.-China frequency allocation :

(San Francisco-Shanghai, China) :

------------------------------------------------------

MOTION OF UNITED AIRLINES, INC.

FOR A 60-DAY START-UP EXTENSION

United1requests a 60-day start-up extension, from May 16, 2015 to July 15, 2015, to

begin operating its second daily nonstop flight between San Francisco and Shanghai, China. 

Recognizing the important public benefits that United’s enhanced San FranciscoShanghai service will provide, the Department granted United’s unopposed application for seven 

additional Zone 1 U.S.-China combination frequencies by Notice of Action Taken dated 

November 21, 2014 in this docket (the “NOAT”). The frequencies are subject to a start-up 

condition that requires United to begin service “within 10 days of May 6, 2015 (i.e., by May 16, 

2015),” or else the frequencies will revert to the Department. NOAT at 1. In order to allow 

United additional time to coordinate with local Chinese government officials and airport 

authorities to secure slot times at Shanghai Pudong International Airport that are compatible with 

United’s operations, United requests a 60-day extension of the Department’s start-up condition.2 

This modest extension will allow United to more efficiently plan, market and implement its

 

1 Common names are used for airlines. 

2 United intends to commence its San Francisco-Shanghai service as soon as 

practicable, but in no event later than July 15, 2015. 
Motion of United

Page 2 of 2

expanded San Francisco-Shanghai service just two short months after the date that is required 

currently, and will have no impact on the long-term benefits that this service will provide.

United’s request is also consistent with similar relief that the Department has granted

other carriers with respect to start-up deadlines for U.S.-China frequencies. See, e.g.,

Department Action dated August 29, 2011 (242-day extension for Delta’s Tokyo-Guangzhou 

service); Notice of Action Taken dated November 24, 2009 in Dockets DOT-OST-2007-28567 

and DOT-OST-2004-18469 (82-day start-up extension for Delta’s and Northwest’s DetroitShanghai service); and Department Action dated October 7, 2009 in Docket DOT-OST-2007-

28567 (27-day start-up extension for American’s Chicago-Beijing service). 

WHEREFORE, United urges the Department to grant a 60-day extension, until July 15, 

2015, for United to commence its enhanced San Francisco-Shanghai service. 

Respectfully submitted,

CROWELL & MORING LLP

____________________________

Gerald F. Murphy

Steven J. Seiden

gmurphy@crowell.com

sseiden@crowell.com

Counsel for 

United Airlines, Inc.

March 23, 2015
CERTIFICATE OF SERVICE

I certify that I have this date served the foregoing document on the following persons in 

accordance with the Department’s Rules of Practice.

robert.wirick@aa.com

howard.kass@aa.com

rpommer@atlasair.com

sllunsford@fedex.com

nssparks@fedex.com

gbleopard@fedex.com

jhill@cooley.com

perkmann@cooley.com

sascha.vanderbellen@delta.com

sametta.c.barnett@delta.com

chris.walker@delta.com

anita.mosner@hklaw.com

jennifer.nowak@hklaw.com

dwight.moore@transcom.mil

john.s.duncan@faa.gov

englets@state.gov

__________________________________

Steven J. Seiden

March 23, 2015