BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

------------------------------------------------------------------ : Application of :
: UNITED AIRLINES, INC. : Docket DOT

- OST

- 2004

- 19148

: for renewal of exemption pursuant to : 49 U.S.C. § 40109 ( b lanket c ode s hare authority ) :

------------------------------------------------------- -----------
APPLICATION OF UNITED AIRLINES, INC. FOR RENEWAL OF 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 10 th 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
April 14, 2014 Thomas Newton Bolling Vice President and Deputy General Counsel Abby I. Bried Associate General Counsel

- Regulatory, Alliances & International UNITED AIRLINES, INC. 233 South Wacker Drive 11th Floor

– HDQLD Chicago, IL 60606 (872) 825

- 8068 (8 72) 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.BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

------------------------------------------------------------------ : Application of :
: UNITED AIRLINES, INC. : Docket DOT

- OST

- 2004

- 19148

: for renewal of exemptions pursuant to : 49 U.S.C. § 40109 ( b lanket c ode s hare authority ) :

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

APPLICATION OF UNITED AIRLINES, INC. FOR RENEWAL OF EXEMPTION

United 1 applies p ursuant to 49 USC §40109 and Rule 302 of the Department’s Rules of

Practice to renew its exemption from 49 U.S.C. § 41101 that allows United to provide scheduled
foreign air transportation of persons, property and mail pursuant to codeshare agreements with
various foreign partn ers 2 between points in the United States and foreign points for which it does

1 Common names are used for airlines.
2 The authority subject to this renewal application covers codeshare services offered with the following foreign air carriers : Aegean ; Aer Lingus ; Air Canada and other carriers operating on its behalf (Air Canada Jazz); Air New Zealand ; A NA , Asiana ; Austrian and other carriers operating on its behalf (Tyrolean and Lauda) ; Avianca ; Blue1 ; Brussels ; COPA ; Croatia ; Eurowings ; EVA ; Jet Airways ; LOT ; Lufthansa and other carriers operating on its beha lf (Lufthansa CityLine, Air Dolomiti, Cirrus, Condor Flugdienst and PrivatAir) ; SAS ; Singapore ; Swiss ; TAP ; and Turkish. In addition, United’s exemption authority encompass es service by any authorized foreign carrier that operates (currently or in the fut ure) on behalf of United’s blanket codeshare partners already named in United’s exemption authority
, provided that such carrier meets two conditions: (1) it h olds the necessary exemption or permit authority and a statement of authorization approving its codeshare with United; and (2) United conducts and keeps current a safety audit of the new foreign carrier approved by the Federal Aviation Administration (“ FAA ”)

. See , e.g., Notice of Action Taken dated Sep

. 11, 2013 in this docket

.Application of United

Page 2

not otherwise hold authority
, 3 subject only to standard codeshare notification requirements.
United asks that its exemption authority be renewed for a period of no less than two years.
United states as follows in support of this renewal a pplication:

1. The authority for which renewal is sought was originally granted by Notice of
Action Taken dated January 24, 2005 and most recently renewed by Notice of Action Taken

dated June 11, 201 2 in this docket

. 4 Absent renewal, United’s exemption authority will expire

on June 11, 2014. 5 United invokes the automatic extension provisions of 5 U

. S

. C

. § 558(c)
, as
implemented by Part 377 of the Department’s Special Regulations
, to continue this authority in
effect pending the Department’s action on this renewal applicatio n.

2. Renewing this exemption authority will serve the public interest because United

will continue to have broad flexibility to provide codeshare services that enhance international
competition, increase service options for passengers and shippers between the U.S. and foreign
points, eliminate the burden on carrier and Department staff s of requiring specific certificate or

3 While United al ready holds blanket route integration authority to combine the authority for which renewal is requested with United’s authority for other points that it is authorized to serve by certificate or exemption ( see Order 2010

- 12

- 24)
, as well as blanket open skies certificate authority ( see Order 2007

- 4

- 19), United continues to require authority to serve points in non

- open skies countries not specifically authorized by the exemption or certificate authorities it already holds.

4 By Order 2011

- 3

- 14, the Department reissued authorities previously issued only to United or Continental in the name of “Continental Airlines, Inc. and/or United Air Lines, Inc.” By Order 2013

- 4

- 11, the Department reissued the United/Continental authorities , inclu ding the exemption authority that is the subject of this renewal application, on a blanket basis to reflect the completion of the United/Continental merger and integration process and United’s new corporate name “United Airlines, Inc.” effective as of Marc h 31, 2013

. United does not seek renewal of the exemption authority granted originally to Continental in Docket DOT

- OST

- 2005

- 20122, as it is entirely duplicative of the exemption authority covered by this application as by virtue of the above

- referenced o rders.

5 Following implementation of the U.S.

- Colombia Open Skies Agreement
, DOT reissued and amended United’s blanket codeshare exemption authority to encompass Avianca and noted that such authority would remain valid through June 11, 2014. See Notice of Action Taken dated Sep

. 11, 2013 in Docket DOT

- OST

- 2004

- 19148 at 1, n. 2 and 3

. Accordingly, this renewal application covers all of United’s foreign codeshare partners from open skies countries. See note 2 supra

.Application of United

Page 3
exemption authority for each codeshare point or new carrier added by an author i zed codeshare

partner , and benefit fully from the rights available to U.S. airlines under the relevant bilateral air

transport agreements. Renewal is also consistent with the open skies agreements governing air
transportation between the U.S. and the homelands of United’s foreign codeshare partners,
including t he EU, Canada, Colombia, India, Japan, Korea, New Zealand, Norway, Panama,
Switzerland, Singapore, Taiwan, and Turkey.

3. United holds various certificates of public convenience and necessity and
exemptions authorizing it to engage in scheduled foreign air transportation of persons, property
and mail and is fit, willing and able to provide the service for which it seeks renewal. See, e.g.,

Order s 2013

- 4

- 11 (reissuing United/Continental authorities to United), 2007

- 4

- 19 (Blanket Open

Skies) and 2010

- 5

- 17 (U.S.

- Mexico), 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 requests that the Department take official notice of all

inf ormation and data that have been filed to establish its fitness.

4. United and its codeshare partners will continue to provide the Department with

30

- day notices for additional codeshare s ervices to non

- open skies countries. In addition, they

will continue to conduct their codesharing activities in compliance with Part 257 of the
Department’s regulations and any other applicable rules and regulations, and t he codeshar ing
authority requested here will have no impact on United’s Civil Reserve Air Fleet commit ments.
United will continue to comply with FAA’s codeshare safety audit requirements.
WHEREFORE, United respectfully requests that the Department renew its exemption
authority provide scheduled foreign air transportation of persons, property and mail pur suant to
codeshare agreements with the foreign partners listed in note 2 of this application between points
in the United States and foreign points for which United does not otherwise hold authority for a