BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

------------------------------------------------------------------------

:

Joint Application of :

:

UNITED AIRLINES, INC. : 

and : Docket DOT-OST-2014-______

ETHIOPIAN AIRLINES ENTERPRISE :

:

for statements of authorization pursuant to Part 212 :

(U.S.-Ethiopia) :

:

------------------------------------------------------------------------

------------------------------------------------------------------------

:

Application of :

:

UNITED AIRLINES, INC. :

: Docket DOT-OST-2004-19148

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

(blanket codeshare authority) :

:

------------------------------------------------------------------------

JOINT APPLICATION OF 

UNITED AIRLINES, INC. AND ETHIOPIAN AIRLINES ENTERPRISE

FOR BLANKET STATEMENTS OF AUTHORIZATION 

AND AMENDED EXEMPTION

Communications with respect to this document should be sent to:
Hershel I. Kamen

Senior Vice President-Alliances,

 Regulatory and Policy

Daniel A. Weiss

Managing Director-International

 Affairs and Regulatory

UNITED AIRLINES, INC.

233 South Wacker Drive

10th Floor – HDQIZ

Chicago, IL 60606

(872) 825-6828

hershel.kamen@united.com

dan.weiss@united.com

Steve Morrissey

Managing Director-Regulatory Affairs 

 and Policy

Karine R. Faden

Managing Counsel-Regulatory, Antitrust &

 Competition

UNITED AIRLINES, INC.

1225 New York Avenue, NW

Suite 1100 – DCAIZ/DCALD

Washington, DC 20005

(202) 521-4373

(202) 521-4363

steve.morrissey@united.com

karine.faden@united.com

May 23, 2014

Thomas Newton Bolling

Vice President and Deputy General Counsel

Abby L. Bried

Associate General Counsel-Regulatory, 

 Alliances & International

UNITED AIRLINES, INC.

233 South Wacker Drive

11th Floor – HDQLD

Chicago, IL 60606

(872) 825-8068

(872) 825-7415

thomas.bolling@united.com

abby.bried@united.com

Gerald F. Murphy

Steven J. Seiden

CROWELL & MORING LLP

1001 Pennsylvania Avenue, NW

Washington, DC 20004

(202) 624-2500

gmurphy@crowell.com

sseiden@crowell.com

Counsel for

United Airlines, Inc. 

Michael F. Goldman

SILVERBERG, GOLDMAN & BIKOFF, L.L.P.

1101 30th Street, NW, Suite 120

Washington, DC 20007

(202) 944-3305

mgoldman@sgbdc.com

Counsel for 

Ethiopian Airlines Enterprise

NOTICE: The Joint Applicants request expedited treatment of this application. They will 

poll U.S. carrier representatives and inform the Department of the results.
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

-----------------------------------------------------------------------

:

Joint Application of :

:

UNITED AIRLINES, INC. : 

and : Docket DOT-OST-2014-______

ETHIOPIAN AIRLINES ENTERPRISE :

:

for statements of authorization pursuant to Part 212 :

(U.S.-Ethiopia) :

:

------------------------------------------------------------------------

------------------------------------------------------------------------

:

Application of :

:

UNITED AIRLINES, INC. :

: Docket DOT-OST-2004-19148

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

(blanket codeshare authority) :

:

------------------------------------------------------------------------

JOINT APPLICATION OF 

UNITED AIRLINES, INC. AND ETHIOPIAN AIRLINES ENTERPRISE

FOR BLANKET STATEMENTS OF AUTHORIZATION 

AND AMENDED EXEMPTION

United1and Ethiopian Airlines (the “Joint Applicants”) apply pursuant to Part 212 of 

the Department’s regulations for blanket statements of authorization to provide reciprocal 

United/Ethiopian Airlines codeshare services in foreign air transportation pursuant to the United 

 

1 Common names are used for airlines.
Joint Application of United and Ethiopian Airlines

Page 2

States-Ethiopia open-skies agreement.2 United also applies, pursuant to 49 U.S.C. § 40109 and 

Rule 302 of the Department’s Rules of Practice, for amendment of its blanket exemption from 

49 U.S.C. § 41101 to authorize United to provide codeshare services on flights operated by 

Ethiopian Airlines to points neither in open-skies countries nor listed in United’s certificate or 

exemption authority upon 30 days’ notification to the Department, as United has been allowed to 

do with its other codeshare partners. See Notice of Action Taken dated May 12, 2014 in Docket 

DOT-OST-2004-19148, at n. 1.

The Joint Applicants request that the codeshare statements of authorization be granted 

for an indefinite period, and United requests that its exemption authority be granted for a period 

of at least two years. The Joint Applicants urge the Department to act promptly on this 

application3so that they can secure foreign authority, make final operating plans and begin 

marketing the proposed codeshare services, which they plan to commence on or about August 1, 

2014, provided all necessary approvals have been secured.

4

The Joint Applicants state as follows in support of their application:

1. The Joint Applicants request authority to provide valuable U.S.-Ethiopia and 

third-country codeshare services which will serve the public interest. United and Ethiopian

Airlines codeshare service will enhance airline competition on international routes to benefit 

passengers and shippers and expand the United and Ethiopian Airlines networks. Moreover, the 

blanket codeshare statements of authorization requested will “give the applicants flexibility to 

 

2

See Air Transport Agreement between the Government of the United States of 

America and the Government of the Federal Democratic Republic of Ethiopia (signed May 17, 

2005).

3

The Joint Applicants will conduct a poll of all carrier representatives listed on the 

service list and advise the Department of the results.

4

The Joint Applicants are submitting a redacted copy of their Codeshare 

Agreement in these dockets under separate cover. 
Joint Application of United and Ethiopian Airlines

Page 3

meet marketplace demands and . . . enable them to maximize the rights available under . . . openskies agreement[s],” as the Department has concluded in approving other blanket codeshare 

applications. Order 1998-4-8 at 3. 

2. The Joint Applicants request blanket statements of authorization to implement 

their proposed codeshare services and notify the Department that, upon grant of this application, 

they intend to provide open-skies codeshare services in accordance with the Department’s Notice 

In the Matter of Blanket Notification of Code-Share Service to Open-Skies Partners and Points 

dated February 9, 2009. Specifically, the Joint Applicants seek statements of authorization 

permitting United to display the “ET*” designator code on United flights and Ethiopian Airlines

to display the “UA*” designator code on Ethiopian Airlines flights in conjunction with foreign 

air transportation of persons, property and mail: (i) between any point(s) in the United States 

and any point(s) in Ethiopia (on a nonstop basis and on routings via intermediate points); (ii) 

between U.S. points; (iii) between Ethiopian points; (iv) beyond Ethiopia to any point(s); and (v) 

beyond the U.S. to any point(s). The Joint Applicants’ initial codeshare notices appear in 

Appendices A and B,5and they will notify the Department no later than 30 days before 

commencing any codeshare services covered by this application to/from non-open-skies points 

or on routes for which they do not otherwise hold authority.6

 

5

Initially, United’s UA* designator code will be placed on Ethiopian Airlines’ 

flights between Ethiopian Airlines’ North American gateways and Addis Ababa and beyond to, 

N’Djamena, Chad; Mombasa, Kenya; Victoria, Seychelles; Dar es Salaam, Kilimanjaro and 

Zanzibar, Tanzania; Ndola, Zambia; Brazzaville, Lumumbashi and Pointe Noire, Congo; 

Djibouti, Djibouti; and Blantyre and Lilongwe, Malawi, and Ethiopian Airlines’ ET* designator 

code will be placed on United’s flights between Washington (Dulles) and Chicago; Tampa; 

Orlando; Boston; San Francisco; Las Vegas; San Diego; Denver; Los Angeles; Seattle; Atlanta; 

Charlotte; Indianapolis; Cleveland; Knoxville; New York; Columbus; Raleigh/Durham; Newark; 

Pittsburgh; Philadelphia; and Honolulu. 

6

The Joint Applicants accept the Department’s standard conditions on limitedentry third-country codeshare services
Joint Application of United and Ethiopian Airlines

Page 4

3. Similar blanket codeshare authority has been granted to numerous U.S. and 

foreign airline codeshare partners. See, e.g., Notices of Action Taken dated June 11, 2012 in 

Dockets DOT-OST-2012-0088 and DOT-OST-2004-19148 (United/EVA) and March 2, 2010 in 

Dockets DOT-OST-2010-0024 and DOT-OST-2004-19148 (United/Brussels Airlines). The 

Joint Applicants are fit, willing and able to provide the proposed codeshare services and already 

hold underlying route authority to offer such services on open-skies routes as well as on routes 

for which they hold specific authority. See, e.g., United: Order 2013-4-11 (reissuing 

United/Continental authorities to United), Order 2007-4-19 (blanket open skies), and Notice of 

Action Taken dated May 12, 2014 in Docket DOT-OST-2004-19148 (blanket worldwide 

codesharing); and Ethiopian Airlines: Order 2007-5-3 (foreign air carrier permit).

7 Accordingly, 

the Joint Applicants only require statements of authorization to institute most of the proposed 

codeshare services. 

4. United, however, also requires supplemental exemption authority to fully 

implement the proposed codeshare agreement and maximize its flexibility to provide global 

codeshare services by placing its code on Ethiopian Airlines flights serving points for which 

United does not otherwise hold authority. United has worldwide blanket exemption authority to 

codeshare on a third-country basis with other foreign carriers. See Notice of Action Taken dated 

May 12, 2014 in Docket DOT-OST-2004-19148, at n. 1. United asks the Department to amend 

this exemption authority to permit similar United codeshare services on flights operated by

Ethiopian Airlines.

 

7

Pursuant to Rule 24 of the Department’s Rules of Practice, the Joint Applicants 

request that the Department take official notice of all information and data that have been filed to 

establish their fitness. 
Joint Application of United and Ethiopian Airlines 

Page 5 

5. The proposed United and Ethiopian Airlines codesharing is consistent with the 

U.S.-Ethiopia open-skies agreement, which authorizes liberal codesharing between airlines from 

the U.S. and Ethiopia. Granting this application is in the public interest because it will provide 

substantial consumer benefits by enhancing the service options available to the U.S. traveling 

public for travel between the U.S. and Ethiopia, including the online connections via United's 

extensive North American route network and Ethiopian Airlines' hub at Addis Ababa. 

6. The Joint Applicants will conduct their codesharing activities in compliance with 

Part 257 of the Department's regulations and any other applicable conditions, rules and 

regulations. The codesharing authority requested here will have no impact on United's Civil 

Reserve Air Fleet commitments. Ethiopian Airlines is IOSA-certified, and United will 

coordinate with the Federal Aviation Administration on the safety audit process. 

WHEREFORE, the Joint Applicants urge the Department to grant immediately the 

requested statements of authorization and amended exemption authority and any other relief the 

Department may deem necessary or appropriate. 

Respectfully submitted, 

SILVERBERG, GOLDMAN CROWELL & MORING LLP 

& BIKOFF, L.L.P. 

„be-e-s24 

Michael F. Goldman 

imIzoldm.an.(4)sgbdc.com. Steven J. Seiden 

gmurphva,crowell.com Counsel for sseiden(a),crowell.com 

Ethiopian Airlines Enterprise 

Counsel for 

United Airlines, Inc. 

May 23, 2014 
APPENDIX A

INITIAL CODESHARE NOTICE (OPEN-SKIES)

The Joint Applicants provide blanket notice to engage in reciprocal open-skies codeshare 

services as follows beginning on or about August 1, 2014, provided all necessary approvals have 

been secured: 

 Between any point(s) in the United States and any point(s) in Ethiopia, on a nonstop basis 

and intermediate routings via open-skies points; 

 Between points in the United States; 

 Between points in Ethiopia;

 Beyond Ethiopia to any open-skies point(s); and

 Beyond the United States to any open-skies point(s)
APPENDIX B

INITIAL CODESHARE NOTICE (NON-OPEN-SKIES)

The Joint Applicants plan to begin codeshare service on the following non-open-skies

route segments on or about August 1, 2014, provided all necessary approvals have been secured. 

Route Segments Marketing/Operating Carrier

Addis Ababa - Brazzaville, Congo UA* on ET

Addis Ababa - Lumumbashi, Congo UA* on ET

Addis Ababa - Pointe Noire, Congo UA* on ET

Addis Ababa - Djibouti, Djibouti UA* on ET

Addis Ababa - Blantyre, Malawi UA* on ET

Addis Ababa - Lilongwe, Malawi UA* on ET
CERTIFICATE OF SERVICE 

I certify that I have this date served the foregoing document on the following persons in 

accordance with the Department's Rules of Practice: 

msinick@ssd.com 

howard.kass@aa.com 

robert.wirick@aa.com 

sascha.vanderbellen@delta.com 

sametta.c.barnett@delta.com 

chris.walker@delta.com 

jrichardson@johnlrichardson.com 

jcanny@amerijet.com 

jhill@cooley.com 

perkmann@cooley.com 

nssparks@fedex.com 

sllunsford@fedex.com 

gbleopard@fedex.corn 

mlbenge@zsrlaw.com 

jhfoglia@zsrlaw.com 

jyoung@yklaw.com 

dkirstein@yklaw.com 

anita.mosner@hklaw.com 

jennifer.nowak@hklaw.com 

john.s.duncan@faa.gov 

dwight.moore@ustranscom.mil 

urskr@state.gov 

May 23, 2014