BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

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

Application of :

 : 

UNITED AIRLINES, INC. : Docket DOT-OST-2014-____

 :

for a U.S.-China frequency allocation :

(San Francisco-Shanghai, China) :

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

APPLICATION OF 

UNITED AIRLINES, INC.

FOR A FREQUENCY ALLOCATION

Communications with respect to this document should be sent to:

Steve Morrissey

Vice President-Regulatory & Policy

UNITED AIRLINES, INC.

1225 New York Avenue, NW

Suite 1100 – DCAIZ

Washington, DC 20005

(202) 521-4373

steve.morrissey@united.com

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

dan.weiss@united.com

November 13, 2014

Thomas Newton Bolling

Vice President and Deputy General Counsel

Abby L. Bried

Associate General Counsel-Regulatory, 

 Alliances & International

James Conneely

Counsel-Regulatory

UNITED AIRLINES, INC.

233 South Wacker Drive

11th Floor – HDQLD

Chicago, IL 60606

(872) 825-8068

(872) 825-7415

(872) 825-8311

thomas.bolling@united.com

abby.bried@united.com

james.conneely@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. 

NOTICE: United has requested expedited treatment of this application. It will poll U.S. carrier 

representatives and inform the Department of the results. 
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

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

Application of :

 : 

UNITED AIRLINES, INC. : Docket DOT-OST-2014-____

 :

for a U.S.-China frequency allocation :

(San Francisco-Shanghai, China) :

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

APPLICATION OF 

UNITED AIRLINES, INC. 

FOR A FREQUENCY ALLOCATION

United1applies for seven additional Zone 1 U.S.-China combination frequencies so that 

United can expand its China service offerings by adding a second daily nonstop flight between 

its San Francisco hub and Shanghai. United proposes to commence this enhanced service on or 

about May 6, 2015, using a Boeing B-777 aircraft from its existing fleet, provided all necessary 

approvals have been secured. United asks that its San Francisco-Shanghai frequency allocation 

remain in effect indefinitely. 

United states as follows in support of this application:

1. United currently offers daily nonstop San Francisco-Shanghai service using a 

Boeing 747 aircraft pursuant to its Route 246 certificate authority2and corresponding allocation 

of seven Zone 1 U.S.-China combination frequencies.

3 United seeks seven additional

frequencies so it can offer twice-daily nonstop San Francisco-Shanghai flights to meet increasing 

 

1 Common names are used for airlines. 

2

See Orders 1993-4-3 and 1998-4-3. 

3

See Orders 1999-8-9 (five frequencies) and 2001-1-6 (two frequencies). 
Application of United

Page 2

demand in this significant U.S.-China market. On November 10, 2014, the U.S. and China 

announced reciprocal enhancements to their respective visa policies, extending the validity of 

visas up to 10 years in some cases. United again congratulates both countries on taking these 

significant steps to promote increased travel, trade and tourism between the U.S. and China. 

2. Allocation of these additional frequencies will allow United to provide substantial 

benefits to the U.S. traveling and shipping public by offering expanded nonstop U.S.-China 

service, and is clearly in the public interest. United’s twice-daily nonstop San FranciscoShanghai service will enhance United’s hub at San Francisco; maximize connecting service 

options for consumers; allow for broader time of day coverage with a new, evening departure 

from Shanghai that complements United’s current midday departure; facilitate the development 

of additional trade and tourism between the United States and China; and provide similar 

benefits throughout United’s San Francisco hub network. United urges the Department to act 

promptly on this application so that it can secure foreign authority, make final operating plans,

and begin marketing these additional San Francisco-Shanghai flights well in advance of 

operations, which United plans to commence on or about May 6, 2015, provided all necessary 

approvals have been secured.4 Flight UA891 will depart San Francisco International Airport at 

2:40 p.m. each day and arrive at Shanghai Pudong International Airport at 7:00 p.m. the 

following day (all times local). On the return, Flight UA890 will depart Shanghai at 9:00 p.m.

and arrive at San Francisco at 5:40 p.m. the same day. 

 

4 United will poll airline representatives and advise the Department of the results. 
Application of United

Page 3

3. The requested authority is consistent with the U.S.-China Air Services Agreement 

(“U.S.-China Agreement”), as amended.5 Under Annex I of the U.S.-China Agreement, U.S. 

airlines are authorized to operate “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” subject, in 

pertinent part, to the Zone 1 frequency limitations specified in Annex V.6There are currently 30 

weekly Zone 1 U.S.-China combination frequencies available to U.S. carriers. After granting 

United’s request for seven frequencies to support United’s proposed expanded San FranciscoShanghai service, the Department will still have 23 Zone 1 U.S.-China combination frequencies 

available for allocation. United requests the ability to operate these frequencies on a seasonal 

basis so that it has the flexibility to tailor service levels during periods of reduced demand. 

4. United holds various certificates of public convenience and necessity and 

exemptions authorizing it to engage in scheduled air transportation of persons, property, and mail 

between the U.S. and foreign countries, and United is fit, willing, and able to provide the service 

for which it seeks authority. See, e.g., Orders 2014-9-23 (Guam-Shanghai), 2014-5-4 (NewarkShanghai), 2013-4-11 (reissuing United/Continental authorities to United), 2011-3-14 

(United/Continental route transfer), 2007-4-19 (Blanket Open Skies), 2007-12-26 (NewarkBeijing); and Notice of Action Taken dated September 6, 2013 in Docket DOT-OST-2013-0164 

(San Francisco-Chengdu). Pursuant to Rule 24 of the Department’s Rules of Practice, United 

 

5

The U.S.-China Agreement was originally signed September 17, 1980, and most 

recently amended July 9, 2007. 

6

 Protocol to the Agreement Between the Government of the United States of 

America and the Government of the People’s Republic of China Relating to Civil Air Transport 

(Jul. 24, 2004).