BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C.

 

 ) 

Application of ) 

 ) 

 UNITED AIR LINES, INC. ) Dockets DOT-OST-2009-0192 

 ) 

for an exemption pursuant to 49 U.S.C. § 40109 ) 

(Continental Code Share) ) 

 ) 

APPLICATION OF UNITED AIR LINES, INC. 

TO AMEND AN EXEMPTION 

Communications with respect to this document should be sent to: 

MARY BARNICLE 

Director – International & 

Regulatory Affairs 

UNITED AIR LINES, INC. 

77 West Wacker Drive, HDQIZ 

Chicago, IL 60601 

STEVE MORRISSEY 

Managing Director – International & 

Regulatory Affairs 

JEFFREY A. MANLEY 

Senior Advisor – Regulatory Affairs 

UNITED AIR LINES, INC. 

1025 Connecticut Avenue, N.W. 

Suite 1210 

Washington, D.C. 20036 

Phone: (301) 229-8571 

jeffrey.manley@united.com 

Dated: July 23, 2010 

Notice: Any party wishing to answer this application should do so on or before 

August 9, 2010, and serve a copy on the persons listed above as well as all 

persons on the attached Service List. 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C.

 

 ) 

Application of ) 

 ) 

 UNITED AIR LINES, INC. ) Dockets DOT-OST-2009-0192 

 ) 

for an exemption pursuant to 49 U.S.C. § 40109 ) 

(Continental Code Share) ) 

 ) 

Dated: July 23, 2010 

APPLICATION OF UNITED AIR LINES, INC. 

TO AMEND AN EXEMPTION 

 United Air Lines, Inc. (“United”) hereby applies pursuant to 49 U.S.C. § 40109 to 

amend its exemption from 49 U.S.C. § 41101 issued in the above-referenced docket to 

include authority to offer services between points in the United States and points in 

Ecuador under its code-share arrangement with Continental Airlines (“Continental”). 

United is seeking this amendment in order to utilize rights now available to U.S. carriers 

under the newly amended U.S.-Ecuador Air Services Agreement. In support of this 

application, United states the following: 

1. By Notice of Action Taken dated September 18, 2009 (“September 18, 

2009 NOAT”) in the above-captioned docket, the Department issued United a two-year 

exemption authorizing the display of the “UA” designator code on flights operated by 

Continental and, where applicable, Continental’s affiliated network carriers (ExpressJet 

and Continental Micronesia) in select international markets for which United did not hold 

certificate or exemption authority. 
Application of United 

Page 2

2. Pursuant to 49 U.S.C. § 40109, United now seeks to amend the exemption 

authority granted in the September 18, 2009 NOAT in order to permit the display of the 

“UA” designator code on flights operated by Continental between the United States and 

Ecuador.1 The proposed code-share services are fully consistent with the amended 

agreement concluded on June 4, 2010 by representatives of the United States and 

Ecuador, which became effective upon signature on July 21, 2010. 

3. These services will provide substantial consumer benefits by expanding 

the service options of U.S. passengers and shippers through United’s ability to offer online services to Ecuador, which it currently does not serve. United provides frequent 

services to Continental’s Houston gateway from all of its U.S. hubs, offering one-stop 

connections to Quito. The service will also offer online connections to points on 

United’s network served from its hubs. Benefits to consumers will also include one-stop 

check-in, frequent flyer program enhancements, improved interline services for baggage 

and more convenient, coordinated connections. 

4. United and Continental intend to begin code-share services under this 

exemption when all regulatory approvals are obtained. United will comply with the 

Department’s rules on codesharing set forth in Part 257 of the Department’s Regulations. 

The amended exemption authority to serve Ecuador should be issued for a term to expire 

at the same time as the other exemption authority in the September 18, 2009 NOAT—i.e., 

September 18, 2011. A common expiration date will facilitate United’s renewal of all 

 

1 United in a Joint Application filed with Continental on June 24, 2010, in Docket DOT-OST2010-0163 requested, inter alia, that exemption authority such as that issued in this docket be 

reissued to allow operations by United and/or Continental pending their merger. In that joint 

application they asked that the authority requested therein include any amendments, such as that 

requested herein, issued subsequent to June 24, 2010. Joint Application, supra, Attachment B, 

p.1, n.1. 
Application of United 

Page 3

exemption authorities for its code share with Continental in a consolidated application 

prior to the common expiry date. 

5. United holds various certificates of public convenience and necessity and 

exemptions authorizing it to engage, inter alia, in scheduled foreign air transportation of 

persons, property and mail. See, Orders 2010-05-17 (U.S.-Mexico), 2007-4-19 (Blanket 

Open Skies Route Authority), and 2006-1-1 (Certificate for Blanket Route Integration) 

and Notice of Action Taken dated June 15, 2009 in DOT-OST-2004-19148 (renewing 

United’s broad code-share exemption authority). United is fit, willing and able to 

perform scheduled air transportation at issue in this application. United requests that the 

Department take official notice, pursuant to Rule 24 of its Rules of Practice (14 CFR Part 

302), of all data filed to establish United’s fitness. 

 WHEREFORE, on the basis of the foregoing, United respectfully requests the 

Department to amend its existing exemption authority in this docket to allow the display 

of United’s “UA” designator code on services operated by Continental between points in 

the United States and points in Ecuador as described above and such other and further 

relief as the Department deems to be consistent with the public interest. 

Respectfully submitted, 

 Steve Morrissey 

 Managing Director, International & 

Regulatory Affairs 

UNITED AIR LINES, INC. 

DATED: July 23, 2010
CERTIFICATE OF SERVICE 

I hereby certify that I have this date served a copy of the foregoing document on 

all persons named below by causing a copy to be sent via email: 

byerlyjr@state.gov

carl.nelson@aa.com

donna.kooperstein@usdoj.gov

dwight.moore@ustranscom.mil

hkamen@coair.com

howard_kass@usairways.com

john.allen@faa.gov

sascha.vanderbellen@delta.com

rbkeiner@crowell.com

gmurphy@crowell.com

Annalei Avanceña 

Advisor—Regulatory Affairs 

Dated: July 23, 2010