BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

AIR CANADA ROUGE 

for a Statement of Authorization 

pursuant to 14 C.F.R. Part 212 

Application of 

UNITED AIRLINES, INC. 

for an exemption pursuant to 49 

U.S.C. § 40109 (blanket codes hare 

authori ) 

Docket OST -2014----

Docket OST -2004-19148 

APPLICATIONS OF AIR CANADA ROUGE AND UNITED AIRLINES, INC. 

FOR A STATEMENT OF AUTHORIZATION AND AN AMENDED EXEMPTION 

Communications concerning this document may be served upon: 

Anita M. Mesner 

Jennifer M. Nowak 

Holland & Knight LLP 

800 17TH Street, NW 

Suite 1100 

Washington, DC 20006 

Tel: (202) 419-2604 

Fax: (202) 955-5564 

anita. mosner@hklaw. com 

Counsel for Air Canada rouge 

Daniel A Weiss 

Managing Director-International 

Affairs and Regulatory 

United Airlines, Inc. 

233 South Wacker Drive 

1oth Floor- HDQIZ 

Chicago, IL 60606 

(872) 825-6828 

dan.weiss@united.com 

Steve Morrissey 

Managing Director-Regulatory Affairs 

and Policy 

United Airlines, Inc. 

1225 New York Avenue, NW 

Suite 11 00 - DCAIZ/DCALD 

Washington, DC 20005 

(202) 521-4373 

steve. morrissey@united.com 
Thomas Newton Belling 

Vice President and Deputy General 

Counsel 

Abby I. Bried 

Associate General Counsel-Regulatory, 

Alliances & International 

James Conneely 

Counsel-Regulatory 

United Airlines, Inc. 

233 South Wacker Drive 

111

h Floor- HDQLD 

Chicago, IL 60606 

(872) 825-8068 

(872) 825-7 415 

(872) 825-8311 

thomas.bolling@united.com 

abby. bried@united. com 

james. conneely@united. com 

August 8, 2014 

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: ANY PERSON MAY FILE AN ANSWER TO THIS APPLICATION. THE 

APPLICANTS ARE REQUESTING EXPEDITED RELIEF FROM THE DEPARTMENT 

AND WILL POLL ALL INTERESTED PARTIES. 
Application of 

BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

AIR CANADA ROUGE 

Docket CST -2014-

for a Statement of Authorization 

pursuant to 14 C.F.R. Part 212 

Application of 

UNITED AIRLINES, INC. 

for an exemption pursuant to 49 

U.S.C. § 40109 (blanket codes hare 

authori ) 

---

Docket OST -2004-19148 

APPLICATIONS OF AIR CANADA ROUGE AND UNITED AIRLINES, INC. 

FOR A STATEMENT OF AUTHORIZATION AND AN AMENDED EXEMPTION 

Air Canada rouge ("AC rouge") hereby applies for a Statement of Authorization 

pursuant to 14 C.F.R. Part 212 to enable AC rouge to carry the United Airlines, Inc. 

("United") "UA*" code on flights AC rouge operates on behalf of Air Canada. 1 In addition, 

United applies, pursuant to 49 U.S. C. § 40109 and Rule 302 of the Department's Rules 

of Practice, for amendment of its blanket exemption from 49 U.S. C. § 41101 to authorize 

United to provide codeshare services on flights operated by AC rouge to points neither in 

open-skies countries nor listed in United's certificate or exemption authority upon 30 

days' notification to the Department, as United has been allowed to do with its other 

1

Air Canada holds authority to display United's UA* code on flights operated by Air Canada 

between any point or points in Canada or the U.S. and any point or points in any third country. 

See Department Action on Application, Docket No. OST-2009-0095 (May 6, 2009). The 

codeshare agreement to which United and Air Canada are parties was initially approved under 

OST Order 1995-10-27, and the Department subsequently broadened the carriers' transborder 

codeshare authority in undocketed approvals dated June 12, 1998 (UAIAC*) and August 27, 1998 

(AC/UA*). 
Air Canada rouge and United 

Applications for Statement of Authorization 

and Amended Exemption Authority 

codeshare partners. 2 In support of their applications, AC rouge and United state the 

following: 

1. AC rouge requests a Statement of Authorization to display United's UA* 

designator code on flights it operates on behalf of Air Canada between any point or 

points in Canada and any point or points in the U.S. and any point or points in any third 

country. 

2. AC rouge currently holds a Statement of Authorization to display Air 

Canada's code in conjunction with its U.S. services. 3 

3. Initially, AC rouge will carry the UA* code on flights it operates on behalf 

of Air Canada between the points listed in Exhibit A. 

4. AC rouge, Air Canada and United all hold the necessary underlying 

economic authority to engage in the proposed codeshare operations. AC rouge holds a 

foreign air carrier permit that authorizes it, inter alia, to engage in 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. 4 

5. Air Canada holds a foreign air carrier permit that authorizes it, inter alia, 

to engage in 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. 5 

6. United holds a certificate of public convenience and necessity for Route 

838 authorizing United, inter alia, to engage in scheduled foreign air transportation of 

2 Notice of Action Taken, Docket Nos. DOT-OST-2004-19148 and DOT-OST-2014-0082 (Jun. 13, 

2014). 

3 Notice of Action Taken, Docket No. OST-2013-0087 (May 22, 2013). 4 Order 2013-12-19 (Dec. 31, 2013), Docket No. OST-2013-0087. 

5 Order 2008-9-23 (Jul. 18, 2008), Docket No. OST-2007-28768. 

2 
Air Canada rouge and United 

Applications for Statement of Authorization 

and Amended Exemption Authority 

persons, property and mail between points in the U.S. and points in Canada via the U.S. 

and intermediate points and beyond to points in third countries. 6 

7. United, however, requires supplemental exemption authority to fully 

implement the proposed codeshare arrangement and maximize its flexibility to provide 

global codeshare services by placing its code on AC rouge flights serving points for 

which United does not otherwise hold authority. United, therefore, asks the Department 

to amend its worldwide blanket exemption authority in Docket DOT-OST-2004-19148 to 

permit similar codesharing with AC rouge. United requests that its amended exemption 

authority be granted for a period of at least two years. 

8. The proposed codeshare authorization requested herein is consistent 

with the 2007 Open Skies Agreement between the U.S. and Canada, which permits 

carriers of the parties to enter into cooperative marketing arrangements with each other. 7 

9. The codesharing proposed herein is also fully consistent with the public 

interest. The codeshare arrangement will allow the carriers to expand their online 

networks, promoting competition and enhancing service options for travelers. 

10. Pursuant to the Department's Notice In the Matter of Blanket Notification 

of Code Share Service to Open-Skies Partners and Points, dated February 9, 2009, AC 

rouge and United hereby give blanket notification of code share services involving the 

display of the UA* designator code on flights AC rouge operates on behalf of Air Canada 

between any point or points in Canada or the U.S. and any point or points in any open 

skies country. 

11. AC rouge and United agree to abide by the consumer notification 

requirements of 14 C.F.R. Part 257, as well as the other conditions and limitations the 

Department normally attaches to codeshare operations. 

6 Order 2007-4-19 (Apr. 18, 2007), Docket No. OST-2005-22228. 7 U.S.-Canada Open Skies Agreement, Art. 11, 1f 6 (Mar. 12, 2007). 

3 
Air Canada rouge and United 

Applications for Statement of Authorization 

and Amended Exemption Authority 

12. This proposed codesharing arrangement will have no effect on United's 

CRAF obligations. Air Canada rouge has received International Operational Safety 

Audit ("IOSA") certification and United has completed a FAA codeshare safety audit. 

13. AC rouge and United plan to begin codesharing over these routings upon 

receipt of all necessary authority and, therefore, request a waiver of the provision that 

requires carriers to file requests for Statements of Authorization at least 45 days in 

advance of their proposed startup date. 

14. AC rouge also requests that the Statement of Authorization be issued for 

an indefinite period, as long as the relevant codeshare agreement continues in effect, 

and will notify the Department if the agreement should cease to be effective. 

WHEREFORE, AC rouge and United respectfully request that the Department 

grant the Statement of Authorization and amended exemption authority described above 

on an expedited basis, and grant such other and different relief as is consistent with 

these applications and with the public interest. 

ubmitted, 

Anita M. Mesner 

Jennifer M. Nowak 

Holland & Knight LLP 

Counsel for Air Canada rouge 

4 

~(Aerald F. Murphy 

Steven J. Seiden 

Crowell & Moring LLP 

Counsel for United Airlines, Inc. 
Exhibit A 

Initial Codeshare Points 

AC rouge initially will display the UA* codes on flights it operates on behalf of Air Canada 

between the following city pairs: 

YYZ-MCO 

YYZ-TPA 

YYZ-SRQ 

YYZ-SAN 

YYZ-PHX 

YYZ-LAS 

YYZ-ATH 

YYZ-BCN 

YYZ-DUB 

YYZ-EDI 

YYZ-LIS 

YYZ-VCE 

YUL-LAS 

YUL-MCO 

YUL-ATH 

YUL-BCN 

YUL-FCO 

YUL-NCE 

YVR-LAS YYC-LAS 

YVR-LAX YYC-LAX 

YVR-SFO YYC-PHX 

YVR-PHX 
CERTIFICATE OF SERVICE 

I hereby certify that I have this date served the foregoing document on the persons identified 

below by causing a copy to be sent by electronic mail. 

robert.wirick@aa.com 

howard.kass@aa.com 

sharon.pasley@fedex.com 

sllunsford@fedex.com 

sascha. vanderbellen@delta.com 

chris.walker@delta.com 

jyoung@yklaw.com (Counsel for Spirit Airlines) 

dkirstein@yklaw.com (Counsel for Spirit Airlines) 

marshall.sinick@ssd.com (Counsel for Alaska Airlines) 

agoerlich@ggh-airlaw.com(Counsel for Allegiant) 

rpommer@atlasair.com 

kevin.montgomery@polaraircargo.com 

peter. beckett@polaraircargo. com 

anita.mosner@hklaw.com (Counsel for United Parcel Service) 

jennifer.nowak@hklaw.com (Counsel for United Parcel Service) 

mlbenge@zsrlaw.com (Counsel for North American) 

thomas.ting@suncountry.com 

joan .canny@amerijet.com 

jrichardson@johnlrichardson.com (Counsel for Amerijet) 

jhill@cooley.com (Counsel for Hawaiian and JetBiue) 

perkmann@cooley.com (Counsel for Hawaiian and JetBiue) 

matwood@cozen.com (Counsel for Kalitta Air) 

john.s.duncan@faa.gov 

urskr@state.gov 

... ~wak August8,2014