BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

)

Application of )

)

JetBlue Airways Corporation ) Docket OST-2014-

)

For a Statement of Authorization )

Pursuant to 14 C.F.R. Part 212 (Code-sharing) )

)

APPLICATION OF JETBLUE AIRWAYS CORPORATION

FOR A BLANKET STATEMENT OF AUTHORIZATION

Communications with respect to this document should be directed to:

James G. Hnat

Executive Vice President Corporate Affairs, 

 General Counsel & Secretary

Robert C. Land

Senior Vice President for Government 

 Affairs & Associate General Counsel

Adam L. Schless

Director, Aircraft Transactions & 

 International Counsel

JetBlue Airways Corporation

1212 New York Avenue, N.W.

Suite 1212

Washington, DC 20005

(202) 715-2555

Jonathan B. Hill

J. Parker Erkmann

Benjamin M. Berlin

Cooley LLP

1299 Pennsylvania Ave., NW

Washington, DC 20004

(202) 842-7800

jhill@cooley.com

perkmann@cooley.com

bberlin@cooley.com

Counsel for JetBlue Airways Corporation

Dated: March 12, 2014

NOTICE: Answers to this Application are due on or before March 27, 2014.
1

BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

)

Application of )

)

JetBlue Airways Corporation ) Docket OST-2014-

)

For a Statement of Authorization )

Pursuant to 14 C.F.R. Part 212 (Code-sharing) )

)

APPLICATION OF JETBLUE AIRWAYS CORPORATION

FOR A BLANKET STATEMENT OF AUTHORIZATION

JetBlue Airways Corporation (“JetBlue”) hereby applies for a blanket statement of 

authorization under 14 C.F.R. Part 212 in order to engage in the codeshare operations described 

herein.

In support of this Application, JetBlue states as follows:

1. On March 1, 2014, JetBlue and Turkish Airlines (Turk Hava Yollari A.O.)

entered into a Codeshare Agreement (the “Agreement”), which is attached as Exhibit 1.1 In 

order to implement the Agreement, JetBlue requests a blanket Statement of Authorization for

JetBlue to display Turkish Airlines’ TK* designator code in conjunction with air transportation 

of persons, property, and mail on flights operated by JetBlue between (1) points in the United 

States and (2) any point or points in the United States and any point or points in any third 

country.

2. A list of the initial code-sharing routes is attached as Exhibit 2.

3. JetBlue and Turkish Airlines plan to initiate the proposed codeshare services on or 

about May 1, 2014.

 1 Certain commercially sensitive and personal contact information has been redacted. Annexes to 

the Agreement that are technical in nature have been omitted.
2

4. JetBlue holds certificate authority issued by the Department authorizing it to 

engage in scheduled interstate air transportation of persons, property and mail between any 

points in the United States, see Order 2000-2-7, as well as certificate authority for foreign air 

transportation to open skies countries, see Order 2007-7-3.

5. Turkish Airlines holds (a) a foreign air carrier permit authorizing it to engage in 

scheduled foreign air transportation of persons, property and mail between Turkey and the 

coterminal points New York, New York, and Chicago, Illinois, either nonstop or via the 

intermediate points Brussels and Amsterdam, and to conduct charters, see Order 98-6-23, and 

(b) exemption authority authorizing it to engage in scheduled foreign air transportation of 

persons, property and mail from behind Turkey, via Turkey and intermediate points, to a point or 

points in the United States and beyond, see Notice of Action Taken, Sept. 7, 2011, Docket DOTOST-2005-21183.

6. The proposed codeshare services are consistent with the terms of the Air 

Transport Agreement between the Government of the United States of America and the 

Government of the Republic of Turkey (“U.S.-Turkey Bilateral Agreement”). The U.S.-Turkey 

Bilateral Agreement expressly permits designated airlines of one Party to “enter into cooperative 

marketing arrangements such as blocked-space, code-sharing or leasing arrangements, with an 

airline or airlines of either Party.” See U.S.-Turkey Bilateral Agreement Art. 8, Sec. 7. 

7. Approval of this Application is consistent with long-standing precedent and 

Department policy. The Department has consistently granted applications for Statements of 

Authorization involving implementation of various codeshare/block space arrangements where 

those arrangements were pro-competitive and in the public interest. There is no question that this 

Application satisfies that standard, as it will enable Turkish Airlines and JetBlue to offer the 

flying public an enhanced network and more services. In addition, the Department has confirmed 
3

in its international aviation policy statement that codeshare/block space arrangements are in the 

public interest as they provide the benefits of increased service and competition: 

Code sharing and other cooperative market agreements can provide a cost efficient way 

for carriers to enter new markets, expand the system and obtain additional flow traffic to 

support their operations by using existing facilities and scheduled operations.

60 Fed. Reg. 21,841, 21,842 (May 3, 1995).

8. JetBlue and Turkish Airlines will conduct their code-sharing activities in 

compliance with Part 257 of the Department’s economic regulations and any other applicable 

rules and regulations. JetBlue and Turkish Airlines accept the Department’s standard conditions 

on code-sharing services.

9. Pursuant to DOT’s Notice in the Matter of Blanket Notification of Code-Share Service to 

Open-Skies Partners and Points dated February 9, 2009, JetBlue hereby provides blanket notice of its 

intent to engage in codeshare services between open skies points. JetBlue also agrees to notify the 

Department no later than 30 days before commencing any codeshare services to non-open skies points 

and to inform the Department of the codeshare market(s) to be served and the date on which the services 

will begin.

10. JetBlue states that this application will have no effect on its Civil Reserve Air 

Fleet commitments. All flights will be operated with Stage 3-compliant aircraft, and approval of 

this application will not result in the near-term consumption of ten (10) million or more gallons 

of fuel.

WHEREFORE, JetBlue respectfully requests that the Department issue a blanket 

Statement of Authorization authorizing JetBlue to display Turkish Airlines’ TK* designator code

in conjunction with air transportation of persons, property, and mail on flights operated by 

JetBlue between (1) points in the United States and (2) any point or points in the United States 

and any point or points in any third country, and that the Department grant such other or further 

relief as it deems appropriate and consistent with the public interest.
4

Respectfully submitted,

____________________________

Jonathan B. Hill

J. Parker Erkmann

Benjamin M. Berlin

Cooley LLP

1299 Pennsylvania Ave., NW, Ste. 700

Washington, DC 20004

(202) 842-7800

jhill@cooley.com

perkmann@cooley.com

bberlin@cooley.com

Counsel for JetBlue Airways Corporation

March 12, 2014
Exhibit 1

Codeshare Agreement








































Exhibit 2

Initial Codeshare Routes

Codeshared Routes Airport 

Code

Marketing

Carrier Operating Carrier

North America Routes

Between New York/Kennedy and JFK

Burlington BTV Turkish Airlines JetBlue

Buffalo BUF Turkish Airlines JetBlue

Charleston CHS Turkish Airlines JetBlue

Charlotte CLT Turkish Airlines JetBlue

Fort Lauderdale FLL Turkish Airlines JetBlue

Jacksonville JAX Turkish Airlines JetBlue

Long Beach LGB Turkish Airlines JetBlue

West Palm Beach PBI Turkish Airlines JetBlue

Phoenix PHX Turkish Airlines JetBlue

Portland, ME PWM Turkish Airlines JetBlue

Raleigh-Durham RDU Turkish Airlines JetBlue

Rochester ROC Turkish Airlines JetBlue

Fort Myers RSW Turkish Airlines JetBlue

Salt Lake City SLC Turkish Airlines JetBlue

San Juan, PR SJU Turkish Airlines JetBlue

Sarasota SRQ Turkish Airlines JetBlue

Syracuse SYR Turkish Airlines JetBlue

Tampa TPA Turkish Airlines JetBlue

Between Boston and BOS

Buffalo BUF Turkish Airlines JetBlue

Baltimore BWI Turkish Airlines JetBlue

Charlotte CLT Turkish Airlines JetBlue

Detroit DTW Turkish Airlines JetBlue

Fort Lauderdale FLL Turkish Airlines JetBlue

Jacksonville JAX Turkish Airlines JetBlue

West Palm Beach PBI Turkish Airlines JetBlue

Philadelphia PHL Turkish Airlines JetBlue

Pittsburgh PIT Turkish Airlines JetBlue

Richmond RIC Turkish Airlines JetBlue

Raleigh-Durham RDU Turkish Airlines JetBlue

San Juan, PR SJU Turkish Airlines JetBlue

Between Washington /Dulles and IAD Turkish Airlines Jetblue

Long Beach LGB Turkish Airlines Jetblue

Oakland OAK Turkish Airlines Jetblue
CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Application of JetBlue Airways Corporation 

for a Statement of Authorization was served this 12rd day of March, 2014 via email transmission 

on the following:

Robert.wirick@aa.com

Howard.kass@aa.com

Benjamin.slocum@aa.com

Francis.heil@aa.com

sascha.vanderbellen@delta.com

jeff.morgan@delta.com

dan.weiss@united.com

steve.morrissey@united.com

lhalloway@crowell.com

gmurphy@crowell.com

nssparks@fedex.com

sllunsford@fedex.com

matwood@cozen.com

jcanny@amerijet.com

jrichardson@johnlrichardson.com

kevin.montgomery@polaraircargo.com

Edward.sauer@squiresanders.com

anita.mosner@hklaw.com

Jennifer.nowak@hklaw.com

rpommer@atlasair.com

mlbenge@zsrlaw.com

urskr@state.gov

esta.rosenberg@dot.gov

robert.finamore@dot.gov

brian.hedberg@dot.gov

john.s.duncan@faa.gov

William.stallings@usdoj.gov

info@airlineinfo.com

/s/

Deborah Kunkle