BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, DC

Joint Application of AMERICAN AIRLINES, INC. and GULF AIR COMPANY, G.S.C under l4 CFR Part 2l2 for statements of authorization and under 49 USC 41109 for related exemption (blanket code-sharing) Docket DOT-OST-2008-0195

APPLICATION OF GULF AIR COMPANY FOR RENEWAL OF EXEMPTION

Communications with respect to this document should be sent to: Moffett B. Roller ROLLER & BAUER, PLLC Washington Dulles International Airport 45005 Aviation Drive; Suite 200 Dulles, VA 20166 Phone: (202) 331-3300 Fax: (202) 331-3322 Email: mroller@rollerbauer.com Attorneys for Gulf Air Company August 3, 2010 NOTICE: Answers supporting or opposing this Application are due on or before

August 18, 2010.BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, DC

Joint Application of AMERICAN AIRLINES, INC. and GULF AIR COMPANY, G.S.C under l4 CFR Part 2l2 for statements of authorization and under 49 USC 41109 for related exemption (blanket code-sharing) Docket DOT-OST-2008-0195 August 3, 2010

APPLICATION OF GULF AIR COMPANY FOR RENEWAL OF EXEMPTION Gulf Air Company hereby applies for renewal of its exemption from 49 U.S.C. § 41301 to permit Gulf Air to conduct scheduled foreign air transportation of persons, property, and mail from points behind Abu Dhabi, Bahrain, Oman, and Qatar, on the one hand, via points in Abu Dhabi, Bahrain, Oman, and Qatar and via intermediate points, to a point or points in the United States and beyond, on the other hand, pursuant to a codesharing arrangement with American Airlines. Pursuant to the authority granted by this exemption Gulf Air places its GF* designator code on flights operated by American or American Eagle. DOT granted this exemption to Gulf Air on August 4, 2008, in its Notice of Action Taken in this docket granting the Joint Application of American Airlines and Gulf Air for reciprocal statements of authorization for blanket code-sharing and for the corresponding exemption authority for Gulf Air. The statements of authorization toApplication of Gulf Air Company Page 2

for Renewal of Exemption

1 / Gulf Air hereby invokes 5 U.S.C. § 558(c), as implemented by 14 C.F.R. § 377, to continue the present exemption in effect until the Department makes a determination on this Application for Renewal.

2/ The American-Gulf Air Codeshare Agreement is on file in No. 98-104 (undocketed).

3 / Gulf Air is currently owned by the Government of Bahrain. Although the Governments of Abu Dhabi, Oman, and Qatar no longer hold ownership interests in Gulf Air, the terms of the open skies Air Transport Agreements between the United States and the United Arab Emirates (of which Abu Dhabi is a constituent emirate), Oman, and Qatar are identical to those of the Agreement between the United States and Bahrain. As the Department has previously approved in this docket and in others (see, e.g., DOT-OST-2005-20097), Gulf Air requests, based on its longstanding history of operations to Abu Dhabi, Oman, and Qatar, that its renewed codeshare exemption authority continue to include Abu Dhabi, Oman, and Qatar as coterminal points with Bahrain. American and to Gulf Air have indefinite effectiveness subject to specified conditions. The exemption to Gulf Air expires on August 4, 2010. 1 / Renewal of the authority in question is in the public interest because it will allow Gulf Air and American to continue to provide competitive air travel options between the United States and the Persian Gulf region pursuant to the long-standing codesharing agreement between the two companies. 2/ Renewal of the exemption to Gulf Air continues to be fully consistent with applicable open skies agreements. The Air Transport Agreement between the United States and the Kingdom of Bahrain authorizes airlines of Bahrain, such as Gulf Air, “to perform scheduled international air transportation” “[f]rom points behind Bahrain, via Bahrain, and intermediate points to a point or points in the United States and beyond.” Annex I, Section 1, Route B.1, of the U.S.-Bahrain Air Transport Agreement. 3 / The Air Transport Agreement further provides, in Article 8(7), that a designatedairline of one party "may enter into cooperative marketing arrangements such as blockedspace, code-sharing or leasing arrangements" with an airline of the other party. The Air Transport Agreement anticipates that each party -- in this case the Government of theApplication of Gulf Air Company Page 3

for Renewal of Exemption United States -- will grant the authority that is necessary for carriers of the other party to implement “code-sharing arrangements.” Renewal of Gulf Air’s exemption is thus necessary for Gulf Air to continue to provide its bilaterally-authorized codeshare service. Renewal of Gulf Air’s exemption authority is also consistent with the Department's established policy of authorizing broad codesharing partnerships in open sky regimes. See, e.g. , Department Action, DOT-OST-99-6547, January 7, 2000 (American/Lan Chile); Department Action, DOT-OST-99-6544, January 7, 2000 (American/Finnair); Order 98-4-8, April 5, l998 (United/ Lufthansa); and Order 2010-7- 8, July 20, 2010 (American/British Airways).
CONCLUSION For the foregoing reasons, it is in the public interest for the Department of Transportation to renew the exemption granted to Gulf Air to conduct scheduled foreign air transportation of persons, property, and mail from points behind Abu Dhabi, Bahrain, Oman, and Qatar, on the one hand, via points in Abu Dhabi, Bahrain, Oman, and Qatar and via intermediate points, to a point or points in the United States and beyond, on the other hand, pursuant to a codesharing arrangement with American Airlines. Respectfully submitted, ROLLER & BAUER, PLLC Attorneys for Gulf Air Company

By:

______________________ Moffett B. Roller
August 3, 2010CERTIFICATE OF SERVICE I certify that a copy of the Application of Gulf Air for Renewal of Exemption was this day served by email upon the following parties.

__________________________ Moffett Roller August 3, 2010 scott.mcclain@delta.com sametta.c.barnett@delta.com kquinn@pillsburywinthrop.com bkeiner@crowell.com hkamen@coair.com sascha.vanderbellen@delta.com bruce.rabinovitz@wilmerhale.com jeffrey.manley@united.com bob.kneisley@wnco.com robert.land@jetblue.com msinick@ssd.com cdonley@ssd.com anbird@fedex.com dvaughan@kelleydrye.com kevin.montgomery@polaraircargo.com jrichardson@johnlrichardson.com lhalloway@crowell.com efaberman@wileyrein.com howardkass@usairways.com benjamin.slocum@usairways.com jhill@dlalaw.com bill@mietuslaw.com mgoldman@sgbdc.com rsilverberg@sgbdc.com dhainbach@ggh-airlaw.com mcmillin@woa.com eskraft@jamhoff.com dpdean@jamhoff.com russell.bailey@alpa.org dkirstein@yklaw.com jyoung@yklaw.com donna.kooperstein@usdoj.gov dwight.moore@ustranscom.mil jim.ballough@faa.gov byerlyjr@state.gov