BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C.

 

 ) 

Joint Application of ) 

 ) 

 CONTINENTAL AIRLINES, INC. ) Dockets DOT-OST-2010-xxxx 

 and ) 

 UNITED AIR LINES, INC. ) 

 ) 

for allocation of seven U.S.-China frequencies ) 

(Los Angeles-Shanghai) ) 

 ) 

JOINT APPLICATION OF CONTINENTAL AIRLINES, INC. 

AND UNITED AIR LINES, INC. FOR ALLOCATION 

OF SEVEN U.S.-CHINA FREQUENCIES AND 

NOTICE OF ROUTE INTEGRATION 

Communications with respect to this document should be sent to the following: 

HERSHEL I. KAMEN 

Vice President 

International, Regulatory and Policy 

UNITED AIR LINES, INC. and 

CONTINENTAL AIRLINES, INC. 

1350 I Street, NW 

Washington, DC 20005-3389 

DANIEL A. WEISS 

Managing Director, International Policy 

 & Regulatory Affairs (HQSGV) 

THOMAS NEWTON BOLLING 

Managing Attorney, Regulatory (HQSLG) 

CONTINENTAL AIRLINES, INC. 

P.O. Box 4607 

Houston, TX 77210-4607 

MARY BARNICLE 

Director – International & 

Regulatory Affairs (HDQIZ) 

UNITED AIR LINES, INC. 

77 West Wacker Drive 

Chicago, IL 60601 

STEVE MORRISSEY 

Managing Director – International & 

Regulatory Affairs (DCAIZ) 

JEFFREY A. MANLEY 

Senior Advisor – Regulatory Affairs (DCAIZ) 

UNITED AIR LINES, INC. 

1025 Connecticut Avenue, N.W.

Washington, D.C. 20036

Phone: (301) 229-8571 

jeffrey.manley@united.com 

DATED: October 12, 2010 

NOTICE: Although answers to this application are technically due on or before 

October 27, 2010, Continental and United are requesting expedited 

treatment of this application. They will, therefore, poll air carrier 

representatives in the attached service list and advise the Department of the 

results.
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

_________________________________________ 

 ) 

Joint Application of ) 

 ) 

 CONTINENTAL AIRLINES, INC. ) Dockets DOT-OST-2010-xxxx 

 and ) 

 UNITED AIR LINES, INC. ) 

 ) 

for allocation of seven U.S.-China frequencies ) 

(Los Angeles-Shanghai) ) 

 ) 

DATED: October 12, 2010 

JOINT APPLICATION OF CONTINENTAL AIRLINES, INC. 

AND UNITED AIR LINES, INC. FOR ALLOCATION 

OF SEVEN U.S.-CHINA FREQUENCIES AND 

NOTICE OF ROUTE INTEGRATION 

 United1/ requests allocation of seven weekly U.S.-China combination service frequencies 

to permit United to operate daily non-stop services between Los Angeles and Shanghai, China 

starting May 20, 2011. Continental gives the Department notice of its integration of Los Angeles 

and Shanghai from two different routes and, to the extent necessary, requests authority to display 

its designator code on these flights pursuant to the same-country code-share arrangement under 

the U.S.-China Air Services Agreement (“U.S.-China Agreement”) approved by the Department 

in Docket DOT-OST- 2009-0193. In support of their requests, Continental and United 

(collectively, “Joint Applicants”) submit the following: 

1. The Joint Applicants were recently permitted by the Departments of Justice and 

Transportation to close their merger agreement in which the two airlines are now owned by a 

single holding company known as United Continental Holdings, Inc. (“UCH”, formerly UAL 

Corp.). Although owned by UCH, Continental and United continue to operate under their 

 

1/ Common names of carriers are used throughout. 
Joint Application of United and Continental 

Page 2

respective operating certificates granted by the Federal Aviation Administration (FAA) until the 

FAA grants them a single operating certificate, which is estimated to occur in late 2011 or in 

2012. United and Continental now wish to secure authority for daily Los Angeles-Shanghai nonstop services pending their receipt of a single operating certificate. Initially, United will operate 

Los Angeles-Shanghai services in its aircraft and Continental will code share on those flights 

using the carriers’ existing same-country code-share arrangement approved by the Department in 

Docket DOT-OST- 2009-0193. After the Joint Applicants receive a single operating certificate, 

the planned service will continue in the name of United. To implement these joint services, 

United hereby requests the allocation to United of seven weekly combination U.S.-China 

frequencies to operate daily services between Los Angeles and Shanghai and Continental 

requests, to the extent necessary, authority to display its designator code on United-operated Los 

Angeles-Shanghai services. 

2. Under Annex V of the U.S.-China Agreement, there will be 35 weekly U.S. carrier 

combination frequencies available for allocation effective in March 2011.2/ After granting the 

joint application, the Department will still have 28 combination frequencies available next year 

to allocate to other interested U.S. carriers. 

3. Both United and Continental hold the necessary underlying operating authority to 

operate services over this route. Los Angeles-Shanghai is an authorized city pair on United’s 

Certificate of Public Convenience and Necessity for Route 246. See Docket DOT-OST-1997-

3020 (renewal application pending). United requires only the allocation of seven weekly 

combination frequencies in order to implement the services it proposes. Continental holds 

underlying economic authority to offer service to both Los Angeles and Shanghai on separate 

 

2/ This number of available frequencies reflects the seven recently allocated to American. Notice of 

Action Taken dated October 7, 2010 in Docket DOT-OST-2010-0245. 
Joint Application of United and Continental 

Page 3

routes3/ and hereby gives notice to the extent necessary that it will integrate those two points in 

order to offer Los Angeles-Shanghai services by code sharing on United’s non-stop flights 

pursuant to Continental’s route integration authority. See, Order 2006-1-1. 

4. The Department previously awarded the Joint Applicants one of the three U.S. 

same-country code-share opportunities available under paragraph 4.b of Article 11 of the U.S.-

China Agreement.4/ By its terms, that authority allows Continental and United to code share 

to/from China until such time as Air China and Continental conclude a code-share agreement. 

Pursuant to paragraph 4.c of Article 11, once the code-share arrangement involving United, Air 

China and Continental is agreed and approved, the Joint Applicants will automatically cease to 

need a same-country code-share opportunity under paragraph 4.b of Article 11. The Joint 

Applicants have agreed to advise the Department at such time as their arrangement includes Air 

China. Moreover, the Joint Applicants do not anticipate that, even absent an agreement between 

Continental and Air China, they will use the same-country code-share opportunity indefinitely 

since both carriers are working to secure a single operating certificate from the FAA and are 

completing their operational merger, after which there will be no separate code-share operations 

on this route in the name of Continental. 

 

3/ Continental has authority to serve Shanghai under its Certificate of Public and Necessity for Route 821 

(Order 2007-12-26) and to serve Los Angeles under its Certificate Convenience and Necessity for Route 

29-F (Order 2000-8-19). 

4/ See, Notice of Action Taken dated September 4, 2009 (“September 4, 2009 NOAT”), in Docket DOTOST-0193. Although the September 4, 2009 NOAT mentions specific markets in which United and 

Continental will code share, this reference seems informational and not limiting. In the event that the 

Department disagrees and believes that these references limit the Joint Applicants’ code-share to the 

named markets, then United and Continental request that the September 4, 2009 NOAT be amended to 

include Los Angeles-Shanghai as an authorized code-share market.
Joint Application of United and Continental 

Page 4

5. United will utilize B777-200 aircraft currently in its fleet5/ for this service with the 

following schedule: (westbound) depart Los Angeles 13:33/arrive Shanghai 17:55 (+1); and 

(eastbound) depart Shanghai 19:50/arrive Los Angeles 16:47 (all times local). See exhibit 

LAXPVG-1. These flights will be timed to connect with services throughout the combined 

networks of United and Continental as well as other Star Alliance and express carriers. United 

already operates at both Los Angeles and Shanghai and can start the proposed services without 

delay. United has existing fuel suppliers at both stations and has adequate supplies to 

accommodate this new service. United estimates that the fuel consumption for this route will be 

approximately 19,896,705 gallons annually. 

6. Allocation of seven frequencies to United for the operation of joint code-share 

service with Continental between Los Angeles and Shanghai is in the public interest. This city 

pair is the largest U.S.-China O&D market and currently has no U.S. carrier operated non-stop 

service despite the fact that it receives daily non-stop services by a Chinese carrier. Although 

another U.S. carrier is also proposing non-stop service (see footnote 2, supra), given the number 

of unused frequencies available and the relatively large size of the market, competitive service 

by U.S. carriers is fully warranted. Moreover, United operates a hub at Los Angeles with 247 

daily operations (including commuter and other code-share services). United and Continental, 

along with their partners, offer services to 70 cities worldwide from Los Angeles. Based on the 

schedule proposed here there would be online connections to 32 cities westbound and 26 cities 

eastbound. See exhibit LAXPVG-2.

6/ Although United has a code-share arrangement with Air 

China, one of the Chinese combination carriers serving the United States, Air China does not 

 

5/ United will initially use B777-200 aircraft configured with 253 seats (10F, 45C, 198Y) and, after 

approximately one month, will utilize B777-200 aircraft configured with 269 seats (8F, 40C, 221Y). 

6/ The connecting cities are those served by United, United Express and Continental, and the number 

would be even larger if connections on Star Alliance code-share partners were included. 

CERTIFICATE OF SERVICE 

I hereby certify that I have this date served a copy of the foregoing document on 

all persons named below by causing a copy to be sent via email: 

byerlyjr@state.gov 

ben.slocum@usairways.com 

carl.nelson@aa.com 

howard_kass@usairways.com 

jeff.morgan@delta.com 

sascha.vanderbellen@delta.com 

gmlindsey@lawa.org 

Annalei Avanceña 

Advisor—Regulatory Affairs 

Dated: October 12, 2010 
Exhibit LAXPVG-1 

UNITED AIR LINES 

Los Angeles – Shanghai Non-Stop Service 

 Effective May 20, 2011 

UA 877 Flight Number UA 878 

 Daily Frequency Daily 

B777-200 Equipment7/ B777-200 

 13:33 Los Angeles (LAX) 16:47

 │ (all times local) ˄ 

 │ │

 │ │

 ˅ │

 17:55 Shanghai (PVG) 19:50 

________ ________ 

 13:22 Elapsed Time 11:57 

 

 

7/ As previously noted, United will utilize two different B777-200 aircraft at different stages of 

this service. See, fn.5, supra.

 
Exhibit LAXPVG-2 

UNITED AIR LINES 

Los Angeles – Shanghai Non-Stop Service 

Online Connections 

Eastbound Westbound

ABQ Albuquerque ABQ Albuquerque 

CLD Carlsbad BFL Bakersfield 

COS Colorado Springs BOI Boise 

DEN Denver BOS Boston 

ELP El Paso BWI Baltimore 

EWR Newark CLD Carlsbad 

FAT Fresno CLE Cleveland 

IAH Houston DEN Denver 

IYK Inyokern EWR Newark 

LAS Las Vegas FAT Fresno 

MRY Monterey IAD Washington-Dulles 

OKC Oklahoma City IAH Houston 

ORD Chicago JFK New York 

PDX Portland LAS Las Vegas 

PHX Phoenix MEX Mexico City 

PSP Palm Springs MRY Monterey 

SAN San Diego OKC Oklahoma City 

SAT San Antonio ORD Chicago 

SBA Santa Barbara PHL Philadelphia 

SBP San Luis Obispo PHX Phoenix 

SEA Seattle PSP Palm Springs 

SFO San Francisco RNO Reno 

SLC Salt Lake City SAN San Diego 

SMX Santa Maria SBA Santa Barbara 

TUS Tucson SBP San Luis Obispo 

YUM Yuma SEA Seattle 

 SFO San Francisco 

 SJC San Jose 

 SMF Sacramento 

 SMX Santa Maria 

 TUS Tucson 

 YUM Yuma