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

BRITISH AIRWAYS PLC

and

FINNAIR OYJ

for blanket Statements of Aut horization under 14 C.F.R. Part 212 (Reciprocal Codesharing) DOT-OST-2014-______

JOINT APPLICATION OF BRITISH AIRWAYS PLC AND FINNAIR OYJ FOR STATEMENTS OF AUTHORIZATION

Richard Mendles General Counsel, Americas James B. Blaney Senior Counsel, Americas 2 Park Avenue, Suite 1100 New York, New York 10016 richard.mendles@ba.com jim.blaney@ba.com

Don H. Hainbach Jason E. Maddux Garofalo Goerlich Hainbach PC 1200 New Hampshire Ave, NW, Suite 590 Washington, DC 20036 (202) 776-3970 dhainbach@ggh-airlaw.com jmaddux@ggh-airlaw.com Counsel for British Airways Plc Anita M. Mosner Jennifer M. Nowak Holland & Knight, LLP 800 17 th Street, NW, Suite 1100 Washington, DC 20006 (202) 419-2604 anita.mosner@hklaw.com Counsel for Finnair OYJ

April 10, 2014 NOTICE: Any person who wishes to support or oppose this application may file an answer on or before April 21, 2014. However, the Joint Applicants request expedited treatment of this application. The Jo int Applicants will poll the U.S. carrier representatives served with this application an d notify the Department promptly of the results of the poll.BEFORE THE U.S. DEPARTMENT OF TRANSPORTATION OFFICE OF THE SECRETARY WASHINGTON, D.C. Joint Application of

BRITISH AIRWAYS PLC

and

FINNAIR OYJ

for blanket Statements of Aut horization under 14 C.F.R. Part 212 (Reciprocal Codesharing) DOT-OST-2014-______

JOINT APPLICATION OF BRITISH AIRWAYS PLC AND FINNAIR OYJ FOR STATEMENTS OF AUTHORIZATION British Airways Plc (“British Airways”) and Finnair OYJ (“Finnair”) (collectively, the “Carriers”) jointly apply for issuance of blanket statements of authorizat ion under 14 C.F.R. Part 212 to the extent necessary to implement codesh aring arrangements provided for in the Code Share Agreement between British Airways and Finnair. British Airway s and Finnair request authority to codeshare between points in the United States and points in the European Union (EU), both non-stop and via intermediate points, a nd behind and beyond to third country points. The Carriers request expedited treatment for th is Joint Application and that the requested statements of authorization be gran ted for an indefinite period. In support of this Join t Application, the Carrie rs submit the following:

1. British Airways requests a statement of authorization for blanket codeshare authority to display the Finnair AY* designato r code on any segment or segments operated by British Airways on the following routing: (i) from any point or points behind any Member State of the European Union, via any poi nt or points in any Member Stat e and via intermediate points,2 to any point or points in the United States and beyond and (ii) between any point or points in the United States and any point or points in any member of the European Common Aviation Area. The specific routes that are initially covered by the above codesharing arrangement are described in Appendix A. 1

2. Finnair requests a statement of authoriz ation for blanket codeshare authority to display the British Airways BA* designator c ode on any segment or segments operated by Finnair on the following routing: (i) from any poi nt or points behind a ny Member 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 Stat es and beyond and (ii) be tween any point or points in the United States and any point or points in any member of the European Common Aviation Area. The specific routes that are initially covered by the above codesharing arrangement are described in Appendix B.

3. British Airways currently holds all underlying authority necessary to operate these flights. British Airways, a ca rrier of the United Kingdom, cu rrently operates service to the United States pursuant to its foreign air carri er permit issued by the Department by Order 2007- 10-1, in Docket DOT-OST-2007-28149. That forei gn air carrier 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; and

1 To the extent necessary, British Airways also reques ts a statement of authorization for blanket codeshare authority to display the Finnair AY* designator code on flights operated by British Airways (BA) Limited, an affiliate of British Airways, pursuant to a wet lease with British Airways. See Notice of Action Taken in Docket DOT-OST-2012-0081 (Jun. 11, 2012).3 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.

4. Finnair also currently holds all underlying authority necessary to operate these flights. Finnair, a carrier of Finland, currently operates service to the United States pursuant to its foreign air carrier permit issued by the Department by Order 2008-9-30, in Docket DOTOST-1997-3006. That foreign air carrier pe rmit authorizes Finnair 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; and 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.

5. Aviation relations between the Unite d States and the United Kingdom and Finland are governed by the Air Transport Agreem ent between the United States of America and the European Community and Its Member Stat es (“U.S.-EU Agreement”). The U.S.-EU Agreement expressly permits designated airlines of one Party to “enter into cooperative marketing arrangements, such as blocked-spac e or code-sharing arrangements, with: a) any

airline or airlines of the Parties....” (U.S.-EU Agreement, Article 10(7))

6. The blanket codeshare authorizations reque sted herein are consistent with the U.S.-EU agreement and, therefore, with the public interest. Blanket authorizations are in the public interest because they enable codeshare pa rtners to develop the full range of services permitted under applicable air services agreem ents. The services contemplated by British Airways and Finnair will provide a more efficient use of capacity in the marketplace and will help maximize the service options availa ble to the traveli ng and shipping public.4 7. The requested authorities also are consis tent with the Department’s policy of granting blanket rights to other Eur opean codeshare partnerships. See, e.g. , Department Action, DOT-OST-2002-13958, January 9, 2 009 (Air France/Alitalia); De partment Action, DOT-OST2010-0175, July 30, 2010 (Austrian/Lufthansa); and Notice of Action Taken, DOT-OST-2010- 0199, August 24, 2010 (Aer Lingus/Spanair).

8. The Carriers hereby provide blanket notific ation of their intent to engage in codeshare services to open skies points as desc ribed above. The Carriers agree to notify the Department thirty (30) days in advance of any new codeshare operati on to non-open skies points and to notify the Department of any codeshare oper ation the carriers have ag reed to discontinue.

9. The Carriers agree to accept the conditi ons normally applicable to blanket codeshare authority such as requested herein. The carriers also will comply with all other applicable Department regulations and policies, including the codesh are disclosure regulations of Part 257. The Carriers request that the statements of authorization be issued for an indefinite period.

10. The Carriers request that the Depart ment act upon this application as expeditiously as possible and, to the extent ne cessary, request a waiver of the 45-day advance filing requirement specified in Part 212.

WHEREFORE, British Airways and Finnair submit 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 U.S.-EU Agreement in conjunction with foreign air transportation of persons, property, and mail, and such other additional relief as theAppendix A Finnair Codeshare on British Airways Operated Flights

ROUTING London (LCY) – New York (JFK) London (LGW) – Las Vegas London (LGW) – Orlando London (LGW) – Tampa London (LHR) – Austin London (LHR) – Atlanta London (LHR) – Boston London (LHR) – Baltimore/Washington London (LHR) – Denver London (LHR) – Dallas-Fort Worth London (LHR) – Newark London (LHR) – Washington-Dulles London (LHR) – Houston London (LHR) – New York (JFK) London (LHR) – Las Vegas London (LHR) – Los Angeles London (LHR) – Miami London (LHR) – Chicago (ORD) London (LHR) – Philadelphia London (LHR) – Phoenix London (LHR) – San Diego London (LHR) – Seattle London (LHR) – San FranciscoAppendix B British Airways Codeshare on Finnair Operated Flights

ROUTING Helsinki – New York (JFK) Helsinki – Miami