BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_____________________________________

Application of )

)

 AMERICAN AIRLINES, INC. )

) 

for an exemption and allocation of frequencies ) Docket DOT-OST-2014____

pursuant to 49 U.S.C. § 40109 )

(Dallas/Ft. Worth, Texas )

– Beijing, People’s Republic of China) )

)

_____________________________________ )

APPLICATION OF AMERICAN AIRLINES, INC.

FOR AN EXEMPTION AND FREQUENCY ALLOCATION

(Dallas/Ft. Worth, Texas – Beijing, People’s Republic of China)

Communications with respect to this document should be addressed to:

Howard Kass

Vice President – Regulatory Affairs

Robert A. Wirick,

Managing Director, Regulatory and International Affairs

Abigail Donovan

Director, Congressional and Federal Affairs

American Airlines, Inc.

1101 17th Street, N.W.

Washington, DC 20036

(202) 326-5153

howard.kass@aa.com

robert.wirick@aa.com

abigail.donovan@aa.com

September 25, 2014

NOTICE: American Airlines plans to poll on this application and therefore requests

that any parties wishing to support or oppose this application notify 

American Airlines immediately.
1

BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_____________________________________

Application of )

)

 AMERICAN AIRLINES, INC. )

) 

for an exemption and allocation of frequencies ) Docket DOT-OST-2014-____

pursuant to 49 U.S.C. § 40109 )

(Dallas/Ft. Worth, Texas ) September 25, 2014

– Beijing, People’s Republic of China) )

_____________________________________ )

APPLICATION OF AMERICAN AIRLINES, INC. 

FOR AN EXEMPTION AND FREQUENCY ALLOCATION

(Dallas/Ft. Worth, Texas – Beijing, People’s Republic of China)

Pursuant to 49 U.S.C. § 40109 and Subpart C of the Department of 

Transportation’s (“Department”) Rules of Practice (14 C.F.R. Part 302) American 

Airlines, Inc. (“American Airlines”) requests that the Department grant it an exemption 

permitting American Airlines to engage in scheduled foreign air transportation of 

persons, property, and mail between Dallas/Ft. Worth, Texas (“DFW”), and Beijing, 

People’s Republic of China (“PEK”). American Airlines further requests that the 

Department award it seven frequencies for American Airlines’ use in operating daily 

year-round scheduled service, using Boeing 777–200 aircraft, between Dallas/Ft. Worth 

and Beijing. 

American Airlines requests expedited processing of this application so that it can 

begin seeking necessary regulatory approvals from the Chinese authorities as soon as

possible.

In support of this application, American Airlines respectfully states as follows:
Application of American Airlines for an Exemption and Frequencies

(Dallas/Ft. Worth – Beijing)

2

1. American Airlines is a Delaware corporation with its principal office at 

4333 Amon Carter Boulevard, Fort Worth, Texas 76155.

2. The services proposed in this application will serve the public interest by 

enabling American Airlines to offer consumers enhanced U.S.-China services while 

supporting commerce and providing substantial competition to other carriers serving 

China from the United States.

3. In order to initiate this scheduled air service, American Airlines requests 

an exemption from 49 U.S.C. § 41101, permitting it to engage in scheduled foreign air 

transportation of persons, property, and mail between Dallas/Ft. Worth, Texas, and

Beijing, People’s Republic of China. American Airlines also requests seven 

frequencies to operate daily flights in the Dallas/Ft. Worth-Beijing market.

4. American Airlines is a citizen of the United States within the meaning of 49 

U.S.C. § 40102(a)(15)(C) and is fit, willing, and able to provide the services 

contemplated by this application. American Airlines holds various certificates of public 

convenience and exemption authorities. (See, e.g., DOT Order 2007-4-2, April 3, 2007, 

Dockets OST-2000-8516 and OST-2005-22228 (Blanket Open-Skies Route Authority);

Notice of Action Taken, October 30, 2013, Docket DOT-OST-2013-0187 (Dallas/Ft. 

Worth, Texas-Shanghai, People’s Republic of China).) Pursuant to Rule 24 of the 

Department’s Rules of Practice, American Airlines requests that the Department take 

official notice of all information previously filed to establish its fitness. 

5. American Airlines plans to commence DFW-PEK service on May 7, 2015. 

Service between DFW and PEK will be operated year-round using Boeing 777-200
Application of American Airlines for an Exemption and Frequencies

(Dallas/Ft. Worth – Beijing)

3

aircraft (16F/37J/194Y). American Airlines’ service proposal is attached hereto as 

Exhibit AA-1.

6. The Air Transport Agreement Between the Government of the United 

States of America and the Government of the People’s Republic of China (“Aviation 

Agreement”), as amended, authorizes airlines designated by the Government of the 

United States of America to operate combination services “from any point or points in 

the United States...to any point or points in the People’s Republic of China open to 

scheduled international services.” (See Aviation Agreement, Annex I, Paragraph I(A)). 

American Airlines is designated to provide combination services between the United 

States and China. (See Notice of Action Taken, October 30, 2013, Docket DOT-OST2013-0187, at footnote 2.)

7. Sufficient frequencies are available to accommodate American Airlines’ 

proposed service. As of June 13, 2014, the Department noted that 124 out of 161 

China frequencies are allocated, leaving 37 frequencies available for immediate 

allocation.1

 The Department’s summary of U.S.-China passenger authorities is 

attached as Exhibit AA-2.

8. American Airlines’ service to the People’s Republic of China is steadily 

growing. American Airlines started serving Mainland China in 2006, with service from 

Chicago, Illinois (“ORD”) to PEK. American Airlines then added service from ORD to 

Shanghai, People’s Republic of China in 2010 and service from Los Angeles, California 

to Shanghai in 2011. Finally, American Airlines started service from DFW to Shanghai 

in June 2014. 

 1 No known frequencies have been allocated by the Department since June 13, 2014.
Application of American Airlines for an Exemption and Frequencies

(Dallas/Ft. Worth – Beijing)

4

9. American Airlines states that approval of this application will have no 

effect on its CRAF commitments. Furthermore, American Airlines submits that its 

application raises no environmental or energy issues, and anticipates no difficulty in 

obtaining fuel for this service. 

10. American Airlines will accept and abide by all terms, limitations, and 

conditions that the Department normally attaches to exemption authority for scheduled 

foreign air transportation. American Airlines asks that this requested authority be 

granted for a term of at least two (2) years.

11. American Airlines requests the Department to use expedited procedures 

to approve the authority sought in this application. 

12. The requisite filing fee is enclosed.
Application of American Airlines for an Exemption and Frequencies

(Dallas/Ft. Worth – Beijing)

5

WHEREFORE, American Airlines respectfully requests that its application for an 

exemption and frequency allocation, as discussed herein, be granted, as well as such 

further relief as the Department deems warranted for such services. 

Respectfully submitted,

_______________________

Howard Kass

Vice President – Regulatory Affairs

Robert A. Wirick

Managing Director, Regulatory and 

International Affairs

Abigail Donovan

Director, Congressional and Federal Affairs

American Airlines, Inc.

1101 17th Street, N.W.

Washington, DC 20036

(202) 326-5153

howard.kass@aa.com

robert.wirick@aa.com

abigail.donovan@aa.com

September 25, 2014
Exhibit AA -1

Page 1 of 2

Source: American Airlines Network Planning

Effective 

May 7, 2015

AA 89 Flight Number AA 88 

Daily Frequency Daily

B772 Equipment B772

1030 Dallas/Fort Worth (DFW) 1630

| ^

| |

| |

v |

1345 Beijing (PEK) 1545

13:45 Elapsed Time 13:45

AMERICAN AIRLINES

Dallas/ Fort Worth - Beijing Nonstop Service
Exhibit AA - 1

Page 2 of 2

Source: American Airlines Network Planning

Aircraft B772

Departures 730

Segment Miles 6,971

Plane Miles 5,088,830

ASMs 1,256,941,010

Fuel Burn (Gallons/Hour) 2,281

Fuel Consumption (000 Gallons)1 49,110,567

First Class 16

Business Class 37

Economy Class 194

Total 247

AIRCRAFT AVAILABILITY - American will use aircraft currently in its fleet.

American will have forty seven (47) 772s in its fleet

FUEL AVAILABILITY - American anticipates no difficulty in obtaining fuel 

from its existing suppliers at Dallas/Fort Worth and Beijing

1/ The environmental impact of American’s proposed service is de 

minimis . Although the aggregate annual fuel usage of American’s 

proposed service is expected to exceed 10 million gallons, American 

would use these aircraft in other markets in the absence of an order 

granting the operating authority American seeks in this application.

Accordingly, the proposed service will not cause a near-term net 

annual change in aircraft fuel consumption of 10 million gallons or 

more of fuel consumption if the request were not granted.

Seating Configuration 

AMERICAN AIRLINES

Dallas/Fort Worth - Beijing Nonstop Service

Annual Operating Statistics 

Effective May 7, 2015
Exhibit AA-2

 SUMMARY OF U.S.-CHINA PASSENGER AUTHORITIES

(as of 6/13/14)

Air Carrier

(frequencies) Route Currently Operating

Dormancy Docket

American (28) Chicago-Shanghai (7 freq) Y N DOT-OST-2004-

19077

Chicago-Beijing (7 freq) Y N DOT-OST-2007-

28567

Los Angeles-Shanghai (7 

freq)

Y N DOT-OST-2010-0245

Dallas/Ft. Worth-Shanghai (7 

freq)

Y N DOT-OST-2013-0187

Delta (35) U.S.-Tokyo-Beijing

(Previously held 7 freq which 

reverted to Dept when DL 

discontinued service)

N N DOT-OST-1999-4539 

(6 frequencies) 

49494 (2 frequencies)

U.S.-Tokyo-Shanghai1 (7 

freq)

Y N 49670(5 frequencies)

Seattle-Beijing (7 freq) Y (with 5 

freq)2

Y (for 2 

freq)

DOT-OST-2004-

18469

Detroit-Shanghai (7 freq) Y3 N DOT-OST-2007-

28567

Detroit-Beijing (7 freq) Y N DOT-OST-2010-0285

Seattle-Shanghai (7 freq) Y4 N DOT-OST-2012-0167

United (58) Chicago-Beijing (7 freq) Y N DOT-OST-1996-1915

Chicago-Shanghai (7 freq) Y N DOT-OST-2004-

18469

San Francisco-Beijing (7 freq) Y N DOT-OST-1996-1915

San Francisco-Shanghai (7 

freq)

Y N DOT-OST-1999-6323

(2 frequencies)

DOT-OST-1999-5539 

(5 frequencies)

Washington, D.C.-Beijing (7 

freq)

Y N DOT-OST-2006-

25275

Los Angeles-Shanghai (7 

freq)

(started on May 21, 2011)

Y N DOT-OST-2010-0256

Newark-Beijing (7 freq) Y N DOT-OST-2004-

19077

Newark-Shanghai (7 freq) Y N DOT-OST-2007-

28567

Guam-Shanghai (2 freq) N5 N DOT-OST-2014-0087

Hawaiian (3) Honolulu-Beijing (3 freq) Y N DOT-OST-2013-0071

• 124 out of 161 frequencies are allocated, leaving 37 frequencies available 

for immediate allocation.

 1 Delta provides nonstop-to-nonstop China connections over Tokyo from the following U.S. points: Detroit, 

Minneapolis, Seattle, Portland, San Francisco, Los Angeles, Atlanta, John F. Kennedy, Salt Lake City 

(seasonal) and Honolulu.

2 Delta operates three (3) of seven (7) frequencies on a seasonal basis, effective September 1, 2011.

3 Delta operates 5 of the 7 frequencies on a seasonal basis.

4 Four of the seven frequencies are authorized for seasonal use.

5 United proposes to begin this service on or about October 28, 2014.
CERTIFICATE OF SERVICE

I certify that, on September 25, 2014, I caused to be served a copy of the 

foregoing Application of American Airlines, Inc. for an Exemption and Frequency 

Allocation, by email upon those addressees listed below:

englets@state.gov (Department of State)

cristinasa@state.gov (Department of State)

paul.gretch@dot.gov (Department of Transportation)

brian.hedberg@dot.gov (Department of Transportation)

todd.homan@dot.gov (Department of Transportation)

peter.irvine@dot.gov (Department of Transportation)

laura.remo@dot.gov (Department of Transportation)

brett.kruger@dot.gov (Department of Transportation)

john.allen@faa.gov (Federal Aviation Administration)

dan.weiss@united.com (United)

steve.morrissey@united.com (United)

gmurphy@crowell.com (Counsel for United)

sascha.vanderbellen@delta.com (Delta)

chris.walker@delta.com (Delta)

__________________________

Howard Kass