BEFORE THE 

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Joint Application of

DELTA AIR LINES, INC.

CHINA SOUTHERN AIRLINES COMPANY LIMITED

COMAIR, INC. and

PINNACLE AIRLINES, INC. 

for a statement of authorization pursuant to

14 C.F R. Part 212 

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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, COMAIR, INC.

and PINNACLE AIRLINES, INC.

Communications with respect to this document should be sent to:

Alexander Van der Bellen, 

 Managing Director, Government Affairs 

 and Associate General Counsel

DELTA AIR LINES, INC.

1212 New York Avenue, NW Suite 200

Washington, DC 20005

(202) 842-4184

sascha.vanderbellen@delta.com

for Delta Air Lines, Inc. and 

Special Counsel for Comair, Inc.

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

June 26, 2012

Brian T. Hunt

Senior Vice President & General Counsel

PINNACLE AIRLINES CORP.

One Commerce Square

40 South Main Street, 14th Floor

Memphis, TN 38103

(901) 346 6145

BTHunt@pncl.com

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

attached service list and will notify the Department of the results.
 

BEFORE THE 

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Joint Application of

DELTA AIR LINES, INC.

CHINA SOUTHERN AIRLINES COMPANY LIMITED

COMAIR, INC. and

PINNACLE AIRLINES, INC. 

for a statement of authorization pursuant to

14 C.F R. Part 212 

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)

)

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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, COMAIR, INC.

and PINNACLE AIRLINES, INC.

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

Southern”), Comair, Inc. (“Comair”) and Pinnacle Airlines, Inc. (“Pinnacle”) (together, the 

“Joint Applicants”) hereby apply for authority to expand China Southern’s codesharing 

with Delta to include Delta Connection flights operated by Comair and Pinnacle.

Pursuant to 14 C.F.R. Part 212, Comair and Pinnacle seek blankets statement of 

authorization allowing them to display China Southern’s “CZ*” code on Delta Connection 

flights operated: (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. Comair and Pinnacle request that their statements of authorization be valid for 

an indefinite period subject to the Department’s normal code share conditions.1

 

 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 

Page 2

In support of this Joint Application, Delta, China Southern, and Comair and 

Pinnacle state as follows:

1. Comair and Pinnacle are certificated U.S. air carriers that operate 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. The Joint Applicants have agreed to expand codesharing to encompass 

flights operated by Comair and Pinnacle on Delta’s behalf. Accordingly, the Joint 

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

permitting Comair and Pinnacle to display China Southern’s “CZ*” designator code on 

Delta Connection flights: (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/Comair and Delta/China Southern/Pinnacle codeshare 

agreements. Redacted copy of the ancillary codeshare agreements are attached to this 

Application.

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

which was expanded last year to include flights operated by other U.S. carriers, i.e. Delta 

Connection carriers. See, Notice of Action Taken Dated October 11, 2011 in the abovecaptioned dockets. 
Joint Application 

Page 3

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 Comair and Pinnacle 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 Pinnacle and Comair 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 Delta Connection operations is deemed notice for all 

statement of authorization holders. 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 their initial codeshare markets (listed 

on the respective Exhibits A-2 to the attached codeshare agreements) have all been 

previously noticed in the Delta/China Southern codeshare dockets. 

8. Comair and Pinnacle are not CRAF participants.

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.
Joint Application 

Page 4

WHEREFORE, Delta, China Southern, Comair and Pinnacle request that the 

Department promptly grant the authority described herein. 

Respectfully submitted,

/s/ George U. Carneal /s/ Brian T. Hunt

________________________________ ________________________________

George U. Carneal

HOGAN LOVELLS US LLP

Counsel for 

CHINA SOUTHERN AIRLINES

 COMPANY LIMITED

Brian T. Hunt

Senior Vice President & General Counsel

PINNACLE AIRLINES CORP.

________________________________

Alexander Van der Bellen

Managing Director, Government Affairs

 & Associate General Counsel

for Delta Air Lines, Inc. and 

Special Counsel for Comair, Inc.
 

CERTIFICATE OF SERVICE

A copy of the foregoing document has been served this 26th day of June 2012, upon the 

following persons via email:

carl.nelson@aa.com

francis.heil@aa.com

robert.wirick@aa.com

dan.weiss@united.com

thomas.bolling@united.com

howard.kass@usairways.com 

benjamin.slocum@usairways.com

jhill@dowlohnes.com

esta.rosenberg@dot.gov

info@airlineinfo.com