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(

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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

United l requests 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. 2 United 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. 3 The 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(

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Jo e Jackson

~ June 3, 2015