BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Joint Application of 

DELTA AIR LINES, INC. 

and 

VRG LINHAS AEREAS S.A. d/b/a GOL 

for an amended statement of authorization 

pursuant to 14 C.F.R. Part 212 and related 

exemption (U.S.-Brazil Codesharing)

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Docket DOT-OST-2010-0095 

JOINT APPLICATION OF DELTA AIR LINES, INC. 

AND VRG LINHAS AEREAS S.A. d/b/a GOL

Communications with respect to this document should be sent to: 

Charles F. Donley II 

Squire, Sanders & Dempsey (US) LLP 

1201 Pennsylvania Ave., N.W. 

Suite 500 

Washington, D.C. 20004 

(202) 626-6840 

cdonley@ssd.com 

Counsel for GOL

April 13, 2011 

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

NOTICE: The Joint Applicants are conducting a poll on this application and will 

advise the Department of the results as soon as possible.
 

BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Joint Application of 

DELTA AIR LINES, INC. 

and 

VRG LINHAS AEREAS S.A. d/b/a GOL 

for an amended statement of authorization 

pursuant to 14 C.F.R. Part 212 and related 

exemption (U.S.-Brazil Codesharing)

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

 

 

Docket DOT-OST-2010-0095 

JOINT APPLICATION OF DELTA AIR LINES, INC. 

AND VRG LINHAS AEREAS S.A. d/b/a GOL

Delta Air Lines, Inc. (“Delta”) and VRG Linhas Aereas S.A. d/b/a Gol (“Gol”) 

(collectively, the “Joint Applicants”) hereby jointly apply for an amended statement of 

authorization for Gol and for amended exemption authority for Delta in order to display 

Delta’s DL* code on Gol-operated flights. The requested amended authority is consistent 

with the recently signed U.S.-Brazil Air Transport Memorandum of Consultations, which 

liberalized the route schedule for U.S. and Brazilian airlines. 

Specifically, the Joint Applicants request amended authority to engage in 

codeshare services as follows: 

(1) Gol requests an amended statement of authorization under 14 C.F.R. Part 212 

to display Delta’s DL* designator code in conjunction with foreign air transportation of 

persons, property, and mail on flights operated by Gol between Delta’s Brazil gateways 

and (a) any point or points in Brazil and (b) beyond Brazil to any point or points. 

 (2) Delta requests amended exemption authority under 49 U.S.C. § 40109 to 

provide scheduled foreign air transportation of persons, property, and mail between a 
Joint Application of Delta and Gol 

Page 2 

point or points in the United States, via intermediate points, and (a) any point or points in 

Brazil and (b) beyond Brazil to any point or points, pursuant to Delta’s codeshare 

arrangement with Gol. 

In support of this Application, the Joint Applicants submit the following: 

1. Delta and Gol hold, respectively, an exemption and a statement of 

authorization to engage in codeshare service consistent with the route schedule 

limitations of the previous U.S.-Brazil Air Transport Agreement. See, Notice of Action 

Taken May 11, 2010 in DOT-OST-2010-0095.1

 

2. On March 19, 2011, the U.S. and Brazil signed a Memorandum of 

Consultations (MOC) which, inter alia, liberalized the route schedule for both U.S. and 

Brazilian airlines. Specifically, Section 1, Paragraph 1 of the MOC provides an open route 

schedule for airlines of both sides. The Joint Applicants request amended authority so 

they can take full advantage of these important new rights. 

3. The same public interest considerations that supported the original grant of 

codeshare authority to Delta and Gol apply with equal force to the amended authority 

requested herein. The expanded codesharing opportunities created by the MOC will 

make Delta and Gol more competitive for U.S.-South America traffic, and will further 

expand Delta online service to additional points in Brazil and beyond. 

4. The Joint Applicants request that the amended statement of authorization be 

issued for an indefinite period, so long as their codeshare agreement continues in effect. 

The Joint Applicants will notify the Department if the agreement should cease to be 

effective. 

5. The Joint Applicants previously provided the Department with notice of their 

initial codeshare routes. In order to maximize commercial flexibility and minimize undue 

 

1

 Gol holds the underlying economic authority necessary to conduct the codeshare service 

described herein. See, Notice of Action Taken May 11, 2010 in DOT-OST-2010-0094. 
Joint Application of Delta and Gol 

Page 3 

administrative burdens, and consistent with Department precedent in similar codeshare 

authority dockets,2

 the Joint Applicants hereby provide notice that Delta may codeshare 

on Gol to previously noticed Brazilian points beyond any Brazilian gateway. For ease of 

reference, the Brazilian points for which the Joint Applicants have previously provided 

notice are listed at Attachment A. The Joint Applicants will continue to provide 30 days 

notice of new Brazilian codeshare points and of new codeshare routes beyond Brazil to 

third countries. 

6. The Joint Applicants agree to abide by the consumer notification requirements 

of 14 C.F.R. Part 257 as well as the other conditions applicable to codeshare services 

operated to or sold in the United States. Delta's engagement in these codeshare services 

will not affect its commitment of aircraft to the CRAF program. 

WHEREFORE, the Joint Applicants respectfully request that the Department grant 

them the amended statement of authorization and exemption described above. 

Respectfully submitted, 

/s/ Charles F. Donley II 

__________________________ 

Charles F. Donley II 

Squire, Sanders & Dempsey (US) LLP 

Counsel for GOL

 

___________________ 

Alexander Van der Bellen, 

 Managing Director, Government Affairs 

 and Associate General Counsel 

DELTA AIR LINES, INC. 

 

2

 See, e.g., the administration of Delta, Aeromexico, and affiliate codesharing in Dockets OST1997-3289, OST-2000-7708, and OST-2001-10833. 
Attachment A

Notice of Delta code on Gol operated flights between Delta’s Brazilian gateways and: 

Airport Code Airport City Country

BEL Belem Brazil

CNF Belo Horizonte Brazil

BSB Brasilia Brazil

CGB Cuiaba Brazil

CWB Curitiba Brazil

FLN Florianopolis Brazil

FOR Fortaleza Brazil

GYN Goiania Brazil

IGU Iguassu Falls Brazil

JPA Joao Pessoa Brazil

LDB Londrina Brazil

MAO Manaus Brazil

NAT Natal Brazil

NVT Navegantes Brazil

POA Porto Alegre Brazil

REC Recife Brazil

REC Recife Brazil

GIG/SDU Rio de Janeiro Brazil

SSA Salvador Brazil

GRU/CGH Sao Paulo Brazil

THE Teresina Brazil

VIX Vitoria Brazil

Note: All points listed above were previously noticed to the Department in Docket DOTOST-2010-0095 as part of Delta/Gol’s Joint Application filed on April 13, 2010. 
CERTIFICATE OF SERVICE

A copy of the foregoing document has been served this 13th day of April, 2011, upon the 

following persons via email: 

carl.nelson@aa.com 

howard_kass@usairways.com 

benjamin.slocum@usairways.com 

dan.weiss@coair.com 

jeffrey.manley@united.com 

esta.rosenberg@dot.gov 

george.wellington@dot.gov 

brian.hedberg@dot.gov 

urskr@state.gov 

info@airlineinfo.com