BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Joint Application of 

DELTA AIR LINES, INC., and 

 

Docket DOT-OST-2011- 

CHINA EASTERN AIRLINES CORPORATION LTD. 

for Statements of Authorization 

and Blanket Exemptions 

(U.S.-China Codesharing) 

JOINT APPLICATION OF DELTA AIR LINES, INC., 

AND CHINA EASTERN AIRLINES CORPORATION LTD.

Communications with respect to this document should be sent to: 

Evelyn D. Sahr 

James G. Ehrig 

ECKERT SEAMANS 

CHERIN & MELLOTT, LLC 

1717 Pennsylvania Ave. NW 

Washington D.C. 20006 

(202) 659-6622 

esahr@eckertseamans.com 

jehrig@eckertseamans.com 

for CHINA EASTERN AIRLINES 

CORPORATION LTD. 

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 

March 23, 2011 

Notice: Delta and China Eastern are requesting expedited treatment of this application. 

Delta will poll air carrier representatives on the attached service list and advise the 

Department of the results. 
BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Joint Application of 

DELTA AIR LINES, INC., and Docket DOT-OST-2011- 

CHINA EASTERN AIRLINES CORPORATION LTD. 

for Statements of Authorization 

and Blanket Exemptions 

(U.S.-China Codesharing) 

JOINT APPLICATION OF DELTA AIR LINES, INC., 

AND CHINA EASTERN AIRLINES CORPORATION LTD.

Delta Air Lines, Inc. (“Delta”), and China Eastern Airlines Corporation Ltd. (“China 

Eastern”) (collectively, the "Joint Applicants") hereby apply for Statements of Authorization 

pursuant to 14 C.F.R. Part 212, and for blanket codeshare-only exemptions pursuant to 49 

U.S.C. § 40109 to engage in reciprocal codeshare services. By codesharing across their 

respective networks, Delta and China Eastern will each be able to offer a broader network and 

enhanced service options to U.S.-China customers. The Joint Applicants propose to start 

reciprocal codeshare services on June 1, 2011.1

 

 Under the U.S.-China Air Transport Agreement, U.S. carriers and their Chinese 

codeshare partners may engage in codeshare service to an unlimited number of points in China 

or in third countries: 

 

1

 On March 22, 2011, China Eastern filed a termination notice in Dockets DOT-OST-1998-3622, DOTOST-2005-23471, and DOT-OST-2005-23473 informing the Department that China Eastern's prior 

codeshare arrangement with American Airlines will end on May 31, 2011. 
Joint Application of Delta and China Eastern

Page 2 

“A Chinese airline or airlines may codeshare with any U.S. airline 

or airlines without limitation. Subject to the mutual agreement of 

the participating Chinese and U.S. airlines, such codeshare 

arrangements may also involve airlines of third countries. U.S. 

and Chinese airlines may hold out codeshare services pursuant to 

this subparagraph on routes that include points in the territories of 

the Parties and may also include any behind, intermediate and 

beyond points in third countries.” 

Article 11(5)(1)(a) 

Accordingly, Delta and China Eastern request the following authorities: 

(a) a blanket statement of authorization under 14 C.F.R. Part 212 permitting the 

display of China Eastern’s MU code on flights operated by Delta between the 

U.S. and China, within the United States and China, and to behind, 

intermediate, and beyond points in third countries. Delta requests that this 

blanket statement of authorization extend to its Delta Connection2

 regional 

affiliates which operate service for Delta within North America; 

(b) a blanket statement of authorization under 14 C.F.R. Part 212 permitting the 

display of Delta’s DL code on flights operated by China Eastern between the 

U.S. and China, within China and the United States, and to behind, 

intermediate, and beyond points in third countries; 

(c) a blanket exemption under 49 U.S.C. § 40109 permitting Delta to service (on 

a codeshare-only basis with China Eastern) points in China and behind, 

intermediate, and beyond points in third countries; and 

(d) a blanket exemption under 49 U.S.C. § 40109 permitting China Eastern to 

service (on a codeshare-only basis with Delta/Delta Connection) points in 

United States and behind, intermediate, and beyond points in third countries. 

 

2

 Atlantic Southeast Airlines, Inc., Chautauqua Airlines, Inc., Comair, Inc., Compass Airlines, Inc., Mesaba 

Aviation, Inc., Pinnacle Airlines, Inc., SkyWest Airlines, Inc., and Shuttle America Corporation. 

 
Joint Application of Delta and China Eastern

Page 3 

These blanket authorities will be used to transport only passengers traveling in foreign 

air transportation, and will be subject to the Department’s standard 30 day notice condition. 

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

1. Delta and China Eastern have entered into a reciprocal codesharing agreement 

which will create substantial benefits for passengers traveling between the United States and 

China. A redacted copy of the codeshare agreement is attached. 

2. The Joint Applicants’ initial codeshare markets are set forth in Appendix A. The 

Joint Applicants propose that service to new points be subject to the Department’s standard 30 

day notice condition. However, consistent with the Department’s administration of similar 

blanket statements and codeshare-only exemptions travel via alternative gateways and paths 

would not require additional notice; and, service by Delta or any of the Delta Connection carriers 

would be deemed notice given for all (except in the case of Mexico where operator-specific 

notices will continue to be supplied for Delta/Delta Connection services). 

3. The Joint Applicants request that the Statements of Authorization be issued for 

an indefinite period, so long as their codeshare agreement continues in effect, and will notify the 

Department if that agreement should cease to be effective. 

4. The Joint Applicants request that their codeshare-only exemptions be issued for 

a period of at least two years. 

5. Delta holds various certificates authorizing serve China, both on a nonstop basis 

and via intermediate points. See, e.g., Order 2009-1-8. Delta requests that the Department 

take official notice of the information on file with the Department which establish Delta’s fitness 

to provide the proposed service, pursuant to Rule 24 of the Department’s Rules of Practice. 

6. China Eastern has long held permit Authority to serve the United States (see, 

e.g. Order 92-11-7) and currently provides nonstop service from Shanghai to Los Angeles and 

New York. China Eastern requests that the Department take official notice of the information 
Joint Application of Delta and China Eastern

Page 4 

on file with the Department which establish China Eastern’s fitness to provide the proposed 

service, pursuant to Rule 24 of the Department’s Rules of Practice. 

7. The proposed codeshare services are fully consistent with the U.S.-China Air 

Transport Agreement, as described above. 

8. The requested blanket authorities are similar to those previously granted to other 

U.S.-China codeshare partnerships including Delta/China Southern,3

 United/Air China,4 and 

American/China Eastern.5 

9. The codeshare services proposed by the Joint Applicants are consistent with the 

public interest and DOT policy: 

Code sharing and other cooperative marketing arrangements can provide 

a cost-efficient way for carriers to enter new markets, expand their 

systems and obtain additional flow traffic to support their other operations 

by using existing facilities and scheduled operations. Because these 

cooperative arrangements can give the airline partners new or additional 

access to more markets, the partners will gain traffic, some stimulated by 

the new service, and some diverted from incumbents. In this way, 

cooperative arrangements can enhance the competitive positions of both 

partners in such a relationship. 

Increased international code sharing and other cooperative arrangements 

can benefit consumers by increasing international service options and 

enhancing competition between carriers, particularly for traffic to or from 

cities behind major gateways. By stimulating traffic, the increased 

competition and service options should expand the overall international 

market and increase overall opportunities for the aviation industry.6

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

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

operated to or sold in the United States. 

11. Delta's engagement in these codeshare services will not affect its commitment of 

aircraft to the CRAF program. 

 

3

 Dockets OST 97-2653; OST-99-5031; OST-01-9314 and 01-10172. 

4

 Docket OST-2003-16213. 

5

 OST-05-23471 and OST-04-19010. 

6

 U.S. International Air Transportation Policy Statement, 60 Fed. Reg. 21841, 21842 (May 3, 1995). 
Joint Application of Delta and China Eastern

Page 5 

12. Delta’s compliance statement on China Eastern’s IOSA codeshare safety audit 

was presented to and approved by the Federal Aviation Administration. The FAA has rated 

China a Category 1 country. 

WHEREFORE, the Joint Applicants respectfully request the Department to grant them 

the blanket statements of authorization and exemptions described above. 

Respectfully Submitted, 

/s/ Evelyn D. Sahr 

____________________________

Evelyn D. Sahr 

For CHINA EASTERN AIRLINES 

CORPORATION LTD. 

___________________________ 

Alexander Van der Bellen 

For DELTA AIR LINES, INC 

 
Appendix A: Initial Codeshare Markets 

Delta on China Eastern 

Shanghai, China (PVG) - Los Angeles, USA (LAX) 

Shanghai, China (PVG) - New York City, USA (JFK) 

To and From Shanghai, China PVG: 

- Beijing, China (PEK) 

- Guangzhou, China (CAN) 

- Fuzhou, China (FOC) 

- Shenyang, China (SHE) 

- Chengdu, China (CTU) 

- Qingdao, China (TAO) 

- Dalian, China (DLC) 

- Xiamen, China (XMN) 

- Kunming, China (KMG) 

- Xian, China (XIY) 

- Nanjing, China (NKG) 

- Chongqing, China (CKG) 

- Wenzhou, China (WNZ) 

- Harbin, China (HRB) 

- Shenzhen, China (SZX) 

- Changchun, China (CGQ) 

- Nanchang, China (KHN) 

- Hefei, China (HFE) 

- Haikou, China (HAK) 

- Changsha, China (CSX) 

- Wuhan, China (WUH) 

China Eastern on Delta/Delta Connection 

Detroit, USA (DTW) - Shanghai, China (PVG) 

Seattle, USA (SEA) - Beijing, China (PEK) 

Atlanta, USA (ATL) - Shanghai, China (PVG) 

To and From Los Angeles, USA (LAX): 

- Honolulu, USA (HNL) 

- New York City, USA (JFK) 

- Salt Lake City, USA (SLC) 

- Atlanta, USA (ATL) 

- Orlando, USA (MCO) 

- San Diego, USA (SAN) 

- Las Vegas, USA (LAS) 

- Phoenix, USA (PHX) 

- San Francisco, USA (SFO) 

- Detroit, USA (DTW) 

- Memphis, USA (MSP) 
To and From New York City, USA (JFK): 

- Washington D.C., USA (IAD) 

- Washington D.C., USA (DCA) 

- Boston, USA (BOS) 

- Miami, USA (MIA) 

- Atlanta, USA (ATL) 

- Chicago, USA (ORD) 

- Orlando, USA (MCO) 

- Portland OR, USA (PDX) 

- Toronto, Canada (YYZ) 

- Detroit, USA (DTW) 

- Minneapolis, USA (MSP) 

Note: Delta and China Eastern request flexibility to serve any of the above-named 

codeshare points via any U.S.-China gateway or intermediate routing flown by the 

carriers. 

















































CERTIFICATE OF SERVICE

A copy of the foregoing Joint Application has been served this 23rd day of March, 2011 

upon the following persons via email: 

carl.nelson@aa.com 

dan.weiss@coair.com 

hershel.kamen@coair.com 

jeffrey.manley@united.com 

steve.morrissey@united.com 

howard.kass@usairways.com 

benjamin.slocum@usairways.com 

paul.gretch@dot.gov 

keith.glatz@dot.gov 

esta.rosenberg@dot.gov 

UrsKR@state.gov 

info@airlineinfo.com