BEFORE THE U.S. DEPARTMENT OF TRANSPORTATION OFFICE OF THE SECRETARY WASHINGTON, D.C.

Joint Application of

BRITISH AIRWAYS PLC and IBERIA LINÉAS AÉREAS DE ESPAÑA, S.A.

under 14 CFR Part 212 for statements of authorization (reciprocal blanket codesharing) Docket DOT-OST-2010-

JOINT APPLICATION OF BRITISH AIRWAYS PLC AND IBERIA LINÉAS AÉREAS DE ESPAÑA, S.A. FOR AUT HORITY TO CONDUCT RECIPROCAL BLANKET CODESHARING

Communications with respect to th is document should be sent to:

For British Airways Plc :

PAUL C. JASINSKI General Counsel, Americas JAMES B. BLANEY Senior Counsel, Americas British Airways Plc 75-20 Astoria Boulevard Jackson Heights, NY 11370 paul.jasinski@ba.com jim.blaney@ba.com

DON H. HAINBACH Garofalo Goerlich Hainbach PC 1200 New Hampshire Avenue NW Washington, DC 20036 Phone: 202-776-3970 dhainbach@ggh-airlaw.com For Iberia Linéas Aéreas de España, S.A.:

WILLIAM KARAS CAROL GOSAIN Steptoe & Johnson LLP 1330 Connecticut Avenue NW Washington, DC 20036 (202) 429-6223 wkaras@steptoe.com cgosain@steptoe.com

October 7, 2010

Notice: Any person who wishes to support or op pose this application may file an answer on or before October 19, 2010 and serve that answer on above-named counsel and all persons served with the application.BEFORE THE U.S. DEPARTMENT OF TRANSPORTATION OFFICE OF THE SECRETARY WASHINGTON, D.C.

Joint Application of

BRITISH AIRWAYS PLC and IBERIA LINÉAS AÉREAS DE ESPAÑA, S.A.

under 14 CFR Part 212 for statements of authorization (reciprocal blanket codesharing) Docket DOT-OST-2010-

JOINT APPLICATION OF BRITISH AIRWAYS PLC AND IBERIA LINÉAS AÉREAS DE ESPAÑA, S.A. FOR AUTHORITY TO CONDUCT RECI PROCAL BLANKET CODESHARING

British Airways Plc (British Airways) and Iberia Linéas Aéreas de España, S.A. (Iberia)

hereby apply for statements of authorization purs uant to 14 CFR Part 212 to the extent necessary

to enable them to engage in reciprocal blanke t codesharing to the full extent authorized by the

US-EU open skies agreement in conjunction with fo reign air transportation of persons, property

and mail. 1 British Airways and Iberia intend to impl ement their codeshare service as soon as

possible following receipt of required government approvals. Applicants consequently request

prompt approval of this application to enable them to begin marketing and sales activities

without delay. British Airways and Iberia further request that the statements of authorization be

issued for an indefinite period.

1 British Airways and Iberia have announced that they are merging with each othe r and intend to complete their merger by the end of this calendar year. However, the two carriers will continue to operate separately.2 In support of this application, British Airways and Iberia su bmit the following:

1. British Airways, a United Kingdom carrier, currently operates service to the United

States pursuant to its foreign air carrier perm it issued by the Departme nt by Order 2007-10-1, in

Docket DOT-OST-2007-28149. That foreign air carri er permit authorizes British Airways to

operate, inter alia :
Foreign scheduled and charter air trans portation of persons, property and mail from any point or points behind any Me mber State of the European Union, via any point or points in any Me mber State and via intermed iate points, to any point or points in the United States and beyond;
Foreign scheduled and charter air trans portation of persons, property and mail between any point or points in the Unite d States and any point or points in any member of the European Common Aviation Area;

2. Iberia, a carrier of Spain, cu rrently operates service to the United States pursuant to its

foreign air carrier permit issued by the Depa rtment by Order 2008-6-23, in Docket DOT-OST2008-0043. That foreign air carrier permit authorizes Iberia to operate, inter alia :
Foreign scheduled and charter air trans portation of persons, property, and mail from any point or points behind any Me mber State of the European Union, via any point or points in any Member State and via intermediate points to any point or points in the United States and beyond;

Foreign scheduled and charter air trans portation of persons, property, and mail between any point or points in any me mber of the European Common Aviation Area and any point or points in the United States;

3. British Airways and Iberia have entered into a codeshare agreement and are now seeking

reciprocal blanket codeshare authorizations, pursuant to Pa rt 212 of the Department’s

regulations, to allow British Airways to display the Iberia “IB” designator code on flights

operated by British Airways, and to allow Iberia to display the British Airways “BA” designator

code on flights operated by Iberia: (1) from any poi nt or points behind any Member State of the

European Union, via any point or points in any Me mber State and via intermediate points to any3 point or points in the United States and beyond; and (2) between any point or points in the

United States and any point or points in any me mber of the European Common Aviation Area.

4. The blanket codeshare author izations requested herein are consistent with the US-EU

open skies agreement, and with the public interest. The requested authorities are also consistent

with the Department’s policy of granting bl anket rights to other European codeshare

partnerships. See, e.g. , Department Action, DOT-OST -2002-13958, January 9, 2009 (Air

France/Alitalia); Department Action, DOT-OST- 2010-0175, July 30, 2010 (Austrian/Lufthansa);

Notice of Action Taken, DOT-OST-2010- 0199, August 24, 2010 (Aer Lingus/Spanair).

5. Blanket authorizations are in the public intere st because they enable codeshare partners to

develop the full range of services permitted unde r applicable air services agreements. The

services contemplated by British Airways and Iberia will provide a more efficient use of capacity

in the marketplace, and will help maximize the service options available to the traveling and

shipping public.

6. Consistent with standard practice, British Airways and Iberia will notify the Department

no later than 30 days before commencing any codesh are services to non-open skies points. They

will inform the Department of the codeshare market (s) to be served, the identity of the carrier

operating the aircraft in the market(s) being added, and the date on which the service will begin. 2

British Airways and Iberia will conduct all of their codeshare operations in compliance with 14

CFR Part 257 and will accept the Departme nt’s standard codeshare conditions.

2 By submitting this application, British Airways and Iberia hereby provide notice of their intent to engage in codeshare services to open skies points as described above.4 ACCORDINGLY, British Airways and Iberia su bmit that grant of the authority requested

here would be consistent with the public interest and respectfully request that the Department

grant them statements of authorization to enable them to engage in reci procal blanket open skies

codesharing to the full extent authorized by the US-EU open skies agreement in conjunction with

foreign air transportation of pe rsons, property and mail, and such other additional relief as the

Department may deem appropriate. British Airways and Iberia further request that the requested

authority be granted for an inde finite period, consistent with the Department’s practice.

Respectfully submitted,

Don H. Hainbach Garofalo Goerlich Hainbach PC Counsel for British Airways Plc William Karas Carol Gosain Steptoe & Johnson LLP Counsel for Iberia Linéas Aéreas de España, S.A.CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing document by email on the following persons:

_______________________________ Vanessa C. Krasniewicz

October 7, 2010

sascha.vanderbellen@delta.com jhill@dlalaw.com scott.mcclain@delta.com bill@mietuslaw.com sametta.c.barnett@delta.com mgoldman@sgbdc.com kquinn@pillsburywinthrop.com rsilverberg@sgbdc.com bkeiner@crowell.com carl.nelson@aa.com mrosia@crowell.com mcmillin@woa.com bruce.rabinovitz@wilmerhale.com mchopra@jamhoff.com jeffrey.manley@united.com russell.bailey@alpa.org bob.kneisley@wnco.com dkirstein@yklaw.com robert.land@jetblue.com jyoung@yklaw.com msinick@ssd.com cdonley@ssd.com anbird@fedex.com dvaughan@kelleydrye.com kevin.montgomery@polaraircargo.com recohn@hhlaw.com jrichardson@johnlrichardson.com cjsimpson@zsrlaw.com lhalloway@crowell.com pmurphy@lopmurphy.com efaberman@wileyrein.com lachter@starpower.net mroller@rollerbauer.com anita.mosner@hklaw.com howard.kass@usairways.com rpommer@atlasair.com benjamin.slocum@usairways.com gmurphy@crowell.com sophy.chen@hklaw.com jim.ballough@faa.gov byerlyjr@state.gov