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 United 1 a ppl ies for seven additional Zone 1 U.S.

- China combination frequencies so that United can expand its China service offerings by add ing 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 F rancisco

- Shanghai service using a Boeing 747 aircraft pursuant to its Route 246 certificate authority 2 and 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 19 93

- 4

- 3 and 19 98

- 4

- 3. 3 See Orders 19 99

- 8

- 9 (five frequencies) and 2001

- 1

- 6 (two frequencies).Application of United

Page 2 demand in this sign i ficant 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 ye ars 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 substant ial 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 Francisco

Shanghai service will enhanc e United’s hub at San Francisco; maximize connectin g service options for consumers; allow for broader time of day coverage with a new, evening departure from Shanghai t hat complement s 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 prompt l y on this application so that it can secure foreign authority, make final operating plans , and begin marketing these ad ditional San Francisco

- Shanghai flights well in advance of operations, which United plans to commence on or about May 6 , 2015 , provide d all necessary approvals have been secured. 4 Flight UA 891 will depart San Francisco International Airport at
2:40 p . m . eac h day and arrive at Shanghai Pudong International Airport at 7:00 p . m . the following day (all times local). On the return, F light UA 890 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 Pe ople’s Republic of China open to scheduled international services” subject, in pertinent part, to the Zone 1 frequency limitations specified in Annex V. 6 There 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 Francisco

Shanghai 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

. U nited holds various certificates of public convenience and necessity and exemptions authorizing it to engage in s cheduled 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., Order s 2014

- 9

- 23 (Guam

- Shanghai), 2014

- 5

- 4 (Newark

Shanghai), 2013

- 4

- 11 (reissuing United/Con tinental authorities to United), 2011

- 3

- 14 (United/Continental route transfer), 2007

- 4

- 19 (Blanket Open Skies), 2007

- 12

- 26 (Newark

Beijing); and Notice of Action Taken da ted 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 Protoc ol 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).