BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Joint Application of 

DELTA AIR LINES, INC. 

KOREAN AIR LINES CO., LTD. 

and 

MESABA AVIATION, INC. 

for a statement of authorization pursuant to 

14 C.F.R. Part 212 

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 Docket DOT-OST-2003-14367 

 

JOINT APPLICATION OF DELTA AIR LINES, INC., 

KOREAN AIR LINES CO., LTD., AND MESABA AVIATION, INC. 

FOR A STATEMENT OF AUTHORIZATION

Communications with respect to this document should be sent to: 

Alexander Van der Bellen, 

 Managing Director, Government Affairs 

 and Associate General Counsel 

Jeff Morgan 

 Regional Director, Government Affairs 

DELTA AIR LINES, INC. 

1212 New York Avenue, NW Suite 200 

Washington, DC 20005 

(202) 842-4184 

sascha.vanderbellen@delta.com

William H. Callaway, Jr. 

Jonathon H. Foglia 

ZUCKERT, SCOUTT & RASENBERGER, L.L.P. 

888 Seventeenth Street, NW 

Suite 700 

Washington, DC 20006 

(202) 973-7906 

whcallaway@zsrlaw.com 

jhfoglia@zsrlaw.com 

Counsel for KOREAN AIR LINES CO., LTD. 

September 29, 2011 

Megan Rae Rosia 

Vice President Government & Regulatory Affairs 

PINNACLE AIRLINES CORP. 

One Commerce Square 

40 S. Main St. 

Memphis, TN 38103 

(703) 476-4889 

mrosia@pncl.com 

Counsel for MESABA AVIATION, INC. 

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

attached service list regarding this Application and will notify the Department of the 

results as soon as possible.
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Joint Application of 

DELTA AIR LINES, INC. 

KOREAN AIR LINES CO., LTD. 

and 

MESABA AVIATION, INC. 

for a statement of authorization pursuant to 

14 C.F R. Part 212 

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 Docket DOT-OST-2003-14367 

 

JOINT APPLICATION OF DELTA AIR LINES, INC., 

KOREAN AIR LINES CO., LTD., AND MESABA AVIATION, INC. 

FOR A STATEMENT OF AUTHORIZATION

Delta Air Lines, Inc. (“Delta”), Korean Air Lines Co., Ltd. ("Korean") and Mesaba 

Aviation, Inc. (“Mesaba”) (together, the “Joint Applicants”) hereby apply for authority to 

expand Korean’s existing codesharing on Delta to include Delta Connection operations by 

Mesaba. Specifically, pursuant to 14 C.F.R. Part 212, Mesaba seeks a blanket statement 

of authorization allowing Mesaba to display Korean’s “KE*” code on Delta Connection 

flights Mesaba operates: (a) within the United States (in conjunction with Korean’s 

services in foreign air transportation), and (b) between the United States and third 

countries.1

 Mesaba requests that its statement of authorization be valid for an indefinite 

period subject to the Department’s normal code share conditions.2

 

In support of this Joint Application, Delta, Korean, and Mesaba state as follows: 

 

1 To the extent necessary, the Joint Applicants request consolidation of this Application into Docket 

DOT-OST-2003-14367, the Docket established by the Department for the administration of the 

grant of the blanket statements of authorization issued to Korean, Delta and Delta Connection 

carriers Comair and Atlantic Southeast Airlines.

2

 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 so that the proposed codeshare services may 

begin without delay. 
Joint Application of Delta, Korean, and Mesaba

Page 2

1. Mesaba is a certificated U.S. air carrier that operates flights for marketing 

and sale by Delta. 

2. The Department has previously approved Delta/Korean blanket statements 

of authorization for reciprocal codesharing. See Department action dated August 6, 1998, 

(Undocketed; No. 98-394). The Department also has previously approved blanket 

statements of authorization for Delta Connection carriers Comair and Atlantic Southeast 

Airlines to display Korean’s code. See Department action dated March 11, 2003 in 

Docket DOT-OST-2003-14367. The proposed services are fully consistent with the 

Department’s prior codeshare approvals and with the U.S.-Korea Open Skies Agreement. 

3. Delta, Korean, and Mesaba have agreed to expand codesharing to 

encompass flights operated by Mesaba on Delta’s behalf. Accordingly, the Joint 

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

permitting Mesaba to display Korean’s “KE*” designator code on flights operated by 

Mesaba: (a) within the United States (in conjunction with Korean’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/Korean codeshare agreement previously approved by the Department and an 

ancillary Delta/Korean/Mesaba codeshare agreement. A redacted copy of the ancillary 

Delta/ Korean/Mesaba codeshare agreement is attached to this Application. 

5. Korean holds a foreign air carrier permit authorizing it to engage in the full 

scope of foreign air transportation permissible under the U.S.-Korea Open Skies 

Agreement. See Order 2003-11-20. 

6. The same public interest considerations that supported the grant of 

codeshare authority to Korean and Delta apply with equal force to the services operated 

by Mesaba on behalf of Delta. Korean and Delta have a longstanding codesharing 
Joint Application of Delta, Korean, and Mesaba

Page 3

relationship, and grant of this Application will enable Korean to further expand its on-line 

service options to additional U.S. and beyond-U.S. cities. 

7. The Joint Applicants’ initial codeshare markets are listed at Exhibit A-2 to 

the attached codeshare agreement. To the extent necessary, the Joint Applicants request 

that the authority requested here for Korean codesharing on Mesaba be administered 

jointly with the authority for Korean codesharing on Delta and other Delta Connection 

carriers in Docket DOT-OST-2003-14367 such that any non-open skies point 30-day 

notice given is deemed notice for all of the operating carriers authorized in this docket, 

except for U.S.-Mexico service where notices will continue to be provided on an operating 

carrier specific basis. The Joint Applicants incorporate by reference all previous nonMexico codeshare-point notices provided in this docket, including the March 18, 2009 

Delta/Korean blanket open skies codeshare notice.3

 

8. Mesaba is not a CRAF participant. 

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. 

 WHEREFORE, Delta, Korean, and Mesaba request that the Department promptly 

grant the authority described herein. 

 

3

 In the March 18, 2009 notification, Delta and Korean informed the Department of their intention to 

engage in reciprocal codesharing in any open skies market, thereby simplifying the Department’s 

administration of such routine and non-controversial services, consistent with the Department’s 

regulatory streamlining policy, including the grant of broad economic authority to serve any point(s) 

in open skies countries. That notification relied on previously granted blanket statements of 

authorization in Docket OST-2003-14637 (Mar. 11, 2003) (permitting Delta Connection carriers 

Comair and Atlantic Southeast Airlines to display Korean’s designator code on Delta Connection 

services within the United States and between the United States and third countries) and by 

Department action 98-394 (Aug. 6, 1998) (permitting Delta and Korean to engage in reciprocal 

codesharing). The Joint Applicants understand that Comair and Atlantic Southeast Airlines may 

display Korean’s designator code in open skies markets covered by the March 18, 2009, notice 

without filing notices of additional codesharing in such markets. Through this Application, Delta, 

Korean and Mesaba seek to obtain the same operational flexibility for Delta Connection flights 

operated by Mesaba. 
Joint Application of Delta, Korean, and Mesaba

Page 4

Respectfully submitted, 

/s/ William H. Callaway, Jr. /s/ Megan Rae Rosia 

________________________________ ________________________________ 

William H. Callaway, Jr. 

ZUCKERT, SCOUTT & RASENBERGER, L.L.P. 

Counsel for KOREAN AIR LINES CO., LTD 

Vice President, Government Affairs 

PINNACLE AIRLINES CORP. 

Counsel for MESABA AVIATION, INC. 

________________________________ 

Alexander Van der Bellen 

Managing Director, Government Affairs 

 & Associate General Counsel 

DELTA AIR LINES, INC. 







CERTIFICATE OF SERVICE

A copy of the foregoing document has been served this 29th day of September, 2011, 

upon the following persons via email: 

carl.nelson@aa.com 

dan.weiss@coair.com 

thomas.bolling@united.com 

howard.kass@usairways.com 

benjamin.slocum@usairways.com 

jhill@dowlohnes.com (for Hawaiian) 

esta.rosenberg@dot.gov 

info@airlineinfo.com