BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

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

Application of 

UNITED AIRLINES, INC. : Docket DOT-OST-2014-0196 

for a U.S.-China frequency allocation 

(San Francisco-Shanghai, China) 

MOTION OF UNITED AIRLINES, INC. 

FOR A START-UP EXTENSION AND APPLICATION 

FOR AN AMENDMENT OF FREQUENCY AWARD 

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(a,united. com ~

Daniel A. Weiss 

Managing Director-International 

Affairs and Regulatory 

UNITED AIRLINES, INC. 

233 South Wacker Drive 

l Oth Floor — HDQIZ 

Chicago, IL 60606 

(872) 825-6828 

dan.weissgunited.com 

June 3, 2015 

Thomas Newton Bolling 

Vice President and Deputy General Counsel 

Abby L. Bried 

Associate General Counsel-Regulatory, 

Antitrust & Alliances 

James Conneely 

Counsel-Regulatory 

UNITED AIRLINES, INC. 

233 South Wacker Drive 

l lth Floor — HDQLD 

Chicago, IL 60606 

(872)825-8068 

(872) 825-7415 

(872)825-8311 

thomas.bolling&united.com 

abby. briedn,united. com 

j ames.conneelygunited.com 

Gerald F. Murphy 

Steven J. Seiden 

CROWELL & MORING LLP 

1001 Pennsylvania Avenue, NW 

Washington, DC 20004 

(202) 624-2500 

gmurphy@crowell.com 

sseidengcrowell.com 

Counsel for 

United Airlines, Inc. 

NOTICE: United has requested expedited treatment of this motion and 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-2014-0196 

for a U.S.-China frequency allocation : 

(San Francisco-Shanghai, China) : 

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

MOTION OF UNITED AIRLINES, INC. 

FOR A START-UP EXTENSION AND APPLICATION 

FOR AN AMENDMENT OF FREQUENCY AWARD 

Unitedlrequests an additional 60-day start-up extension, from July 15, 2015 to 

September 13, 2015, to begin operating its second daily nonstop flight between San Francisco 

and Shanghai, China, as well as an amendment of United's frequency award in this docket that 

would give United the flexibility to use the frequencies on an interim basis for service to/from 

Guam if the Chinese government requires immediate use of a slot award sooner than United 

could reasonably be expected to launch long haul service to/from San Francisco. 

Recognizing the important public benefits that United's twice-daily San FranciscoShanghai service will provide, the Department granted United's unopposed application for seven 

additional Zone 1 U.S.-China combination frequencies by Notice of Action Taken dated 

November 21, 2014 in this docket. On March 23, 2015, the Department granted United's 

unopposed motion for a 60-day start-up extension, from May 16, 2015 to July 15, 2015, to allow 

United additional time to coordinate with local Chinese government officials and airport 

authorities to secure slot times at Shanghai that are workable for United's San Francisco service. 

1 Common names are used for airlines. 
Motion and Application of United 

Page 2 of 3 

See Department Action dated April 1, 2015 in this docket. But while United continues to pursue 

diligently slot times at Shanghai that would support its desired operations and hopes these efforts 

will ultimately prove successful, United requires additional time beyond the Department's 

current start-up conditions to resolve this issue. 

Additionally, United requests an amendment of its frequency award in this docket that 

would allow it to operate the frequencies between Guam and Shanghai should the Chinese 

Government allocate slots that require United to begin service on a timeline that is too restrictive 

for United to have all of the necessary infrastructure and advanced ticket sales in place to start 

service to/from San Francisco in a coordinated and economically viable fashion. United remains 

committed to providing twice-daily San Francisco-Shanghai service and has firm plans to do so. 

But United also concedes that, for myriad reasons beyond its control, there is no guarantee that 

the Shanghai slot times to be assigned to United will be operationally workable for San 

Francisco service in the near term. In light of this uncertainty, United seeks to maximize the use 

of its valuable U.S.-China frequencies to meet consumer demand in the Guam-Shanghai market 

during this interim period. 2United would operate this augmented Guam-Shanghai service until 

such time as United has the necessary infrastructure and ticket sales in place to launch service 

to/from San Francisco. 3The Department has also already determined that United's GuamZ United would use these daily frequencies to supplement its current twice-weekly 

Guam-Shanghai service. 

3 There would be no operational overlap between these Guam- and San FranciscoShanghai services — as United would not exceed the limits of the frequency award in this docket. 

Consistent with United's frequency award, however, United may operate some or all of this 

interim Guam-Shanghai service on a seasonal basis. 
Motion and Application of United 

Page 3 of 3 

Shanghai service is in the public interest. 4And ample frequencies would remain available for 

other carriers that may wish to launch new U.S.-China services. 5 

WHEREFORE, United urges the Department to grant a 60-day extension, until 

September 13, 2015, for United to commence its new San Francisco-Shanghai service, as well as 

an amendment of its frequency award in this docket that would allow United to temporarily 

provide significantly enhanced service between Guam and Shanghai if the Chinese government 

requires the immediate use of a slot award sooner than United could reasonably be expected to 

launch long haul service to/from San Francisco. 

Respectfully submitted, 

CROWELL &,MORING LLP 

Gerald V:_'rlSfiy 

Steven J. Seiden 

gmurphykcrowell. com 

sseidenkcrowell.com 

Counsel for 

United Airlines, Inc. 

June 3, 2015 

4 See Notice of Action Taken dated Jun. 13, 2014 in Docket DOT-OST-2014-0087 

and Order 2014-9-23 (granting United's unopposed applications for authority to conduct 

scheduled combination service between Guam and Shanghai). 

5 Should the Department grant United the authority it seeks, there will remain nine 

U.S.-China frequencies available for distribution to U.S. carriers, in addition to the seven 

frequencies available specifically for U.S.-Guangzhou service. See Notice of Action Taken 

dated Jan. 16, 2015 in Docket DOT-OST-2015-0005, at 1(awarding Delta seven U.S.-China 

frequencies for Los Angeles-Shanghai service). 
CERTIFICATE OF SERVICE 

I certify that I have this date served the foregoing document on the following persons in 

accordance with the Department's Rules of Practice. 

robert.wiricka,aa. com sascha.vanderbellen(a~delta. com 

howard. kas sg aa. co m chri s. walker(a,delta. com ~

mommergatlasair. com anita.mosnerghklaw. com 

s l lunsfordg fedex. com jennifer.nowak(a hklaw.com ~

nssparksgfedex.com dwight.mooregtranscom.mil 

gbleopardg fedex. com j ohn.s.duncan(a~,faa.gov 

jhi~coole .y com en lets ,state. og_v 

perkmanngcooley. com 

Jo e Jackson 

~ 

June 3, 2015