BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

Joint Application of 

IBERIA LÍNEAS AÉREAS DE ESPAÑA 

SOCIEDAD ANÓNIMA OPERADORA (IBERIA) 

 and 

FINNAIR OYJ 

for blanket Statements of Authorization under 14 C.F.R. Part 

212 (Reciprocal Codesharing) 

DOT-OST-2014-______ 

JOINT APPLICATION OF IBERIA LÍNEAS AÉREAS DE ESPAÑA 

SOCIEDAD ANÓNIMA OPERADORA AND FINNAIR OYJ 

FOR STATEMENTS OF AUTHORIZATION 

Don H. Hainbach 

Jason E. Maddux 

Garofalo Goerlich Hainbach PC 

1200 New Hampshire Ave, NW, Suite 590 

Washington, DC 20036 

(202) 776-3970 

dhainbach@ggh-airlaw.com 

jmaddux@ggh-airlaw.com 

Counsel for Iberia

Anita M. Mosner 

Jennifer M. Nowak 

Holland & Knight, LLP 

800 17th Street, NW, Suite 1100 

Washington, DC 20006 

(202) 419-2604 

anita.mosner@hklaw.com 

Counsel for Finnair OYJ 

 

April 10, 2014 

NOTICE: Any person who wishes to support or oppose this application may file an answer 

on or before April 21, 2014. However, the Joint Applicants request expedited 

treatment of this application. The Joint Applicants will poll the U.S. carrier 

representatives served with this application and notify the Department promptly of the 

results of the poll. 
BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

Joint Application of 

IBERIA LÍNEAS AÉREAS DE ESPAÑA 

SOCIEDAD ANÓNIMA OPERADORA (IBERIA) 

 and 

FINNAIR OYJ 

for blanket Statements of Authorization under 14 C.F.R. Part 

212 (Reciprocal Codesharing) 

DOT-OST-2014-______ 

JOINT APPLICATION OF IBERIA LÍNEAS AÉREAS DE ESPAÑA 

SOCIEDAD ANÓNIMA OPERADORA AND FINNAIR OYJ 

FOR STATEMENTS OF AUTHORIZATION 

 Iberia Líneas Aéreas de España Sociedad Anónima Operadora (“Iberia”) and Finnair 

OYJ (“Finnair”) (collectively, the “Carriers”) jointly apply for issuance of blanket statements of 

authorization under 14 C.F.R. Part 212 to the extent necessary to implement codesharing 

arrangements provided for in the Code Share Agreement between Iberia and Finnair. Iberia and 

Finnair request authority to codeshare between points in the United States and points in the 

European Union (EU), both non-stop and via intermediate points, and behind and beyond to third 

country points. The Carriers request expedited treatment for this Joint Application and that the 

requested statements of authorization be granted for an indefinite period. 

 In support of this Joint Application, the Carriers submit the following: 

1. Iberia requests a statement of authorization for blanket codeshare authority to 

display the Finnair AY* designator code on any segment or segments operated by Iberia on the 

following routing: (i) from any point or points behind any Member State of the European Union, 
 

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via any point or points in any Member State and via intermediate points, to any point or points in 

the United States and beyond and (ii) between any point or points in the United States and any 

point or points in any member of the European Common Aviation Area. The specific routes that 

are initially covered by the above codesharing arrangement are described in Appendix A. 

2. Finnair requests a statement of authorization for blanket codeshare authority to 

display the Iberia IB* designator code on any segment or segments operated by Finnair on the 

following routing: (i) from any point or points behind any Member State of the European Union, 

via any point or points in any Member State and via intermediate points, to any point or points in 

the United States and beyond and (ii) between any point or points in the United States and any 

point or points in any member of the European Common Aviation Area. The specific routes that 

are initially covered by the above codesharing arrangement are described in Appendix B. 

3. Iberia currently holds all underlying authority necessary to operate these flights. 

Iberia, a carrier of Spain, currently operates service to the United States pursuant to its foreign air 

carrier permit issued by the Department by Order 2008-6-23, in Docket DOT-OST-2008-0043. 

That foreign air carrier permit authorizes Iberia to operate, inter alia: 

Foreign scheduled and charter air transportation of persons, property and mail 

from any point or points behind any Member State of the European Union, via 

any point or points in any Member State and via intermediate points, to any point 

or points in the United States and beyond; and 

Foreign scheduled and charter air transportation of persons, property and mail 

between any point or points in the United States and any point or points in any 

member of the European Common Aviation Area. 

4. Finnair also currently holds all underlying authority necessary to operate these 

flights. Finnair, a carrier of Finland, currently operates service to the United States pursuant to 
 

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its foreign air carrier permit issued by the Department by Order 2008-9-30, in Docket DOTOST-1997-3006. That foreign air carrier permit authorizes Finnair to operate, inter alia: 

Foreign scheduled and charter air transportation of persons, property, and mail 

from any point or points behind any Member State of the European Union, via 

any point or points in any Member State and via intermediate points to any point 

or points in the United States and beyond; and 

Foreign scheduled and charter air transportation of persons, property and mail 

between any point or points in the United States and any point or points in any 

member of the European Common Aviation Area. 

5. Aviation relations between the United States and Spain and Finland are governed 

by the Air Transport Agreement between the United States of America and the European 

Community and Its Member States (“U.S.-EU Agreement”). The U.S.-EU Agreement expressly 

permits designated airlines of one Party to “enter into cooperative marketing arrangements, such 

as blocked-space or code-sharing arrangements, with: a) any airline or airlines of the Parties...” 

(U.S.-EU Agreement, Article 10(7)) 

6. The blanket codeshare authorizations requested herein are consistent with the 

U.S.-EU agreement and, therefore, with the public interest. Blanket authorizations are in the 

public interest because they enable codeshare partners to develop the full range of services 

permitted under applicable air services agreements. The services contemplated by Iberia and 

Finnair will provide a more efficient use of capacity in the marketplace and will help maximize 

the service options available to the traveling and shipping public. 

7. The requested authorities also are consistent with the Department’s policy of 

granting blanket rights to other European codeshare partnerships. See, e.g., Department Action, 

DOT-OST-2002-13958, January 9, 2009 (Air France/Alitalia); Department Action, DOT-OST-
 

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2010-0175, July 30, 2010 (Austrian/Lufthansa); and Notice of Action Taken, DOT-OST-2010-

0199, August 24, 2010 (Aer Lingus/Spanair). 

8. The Carriers hereby provide blanket notification of their intent to engage in 

codeshare services to open skies points as described above. The Carriers agree to notify the 

Department thirty (30) days in advance of any new codeshare operation to non-open skies points 

and to notify the Department of any codeshare operation the carriers have agreed to discontinue. 

9. The Carriers agree to accept the conditions normally applicable to blanket 

codeshare authority such as requested herein. The carriers also will comply with all other 

applicable Department regulations and policies, including the codeshare disclosure regulations of 

Part 257. The Carriers request that the statements of authorization be issued for an indefinite 

period. 

10. The Carriers request that the Department act upon this application as 

expeditiously as possible and, to the extent necessary, request a waiver of the 45-day advance 

filing requirement specified in Part 212. 

WHEREFORE, Iberia and Finnair submit that grant of the authority requested here 

would be consistent with the public interest and respectfully request that the Department grant 

them statements of authorization to enable them to engage in reciprocal blanket open skies 

codesharing to the full extent authorized by the U.S.-EU Agreement in conjunction with foreign 

air transportation of persons, property, and mail, and such other additional relief as the 

Department may deem appropriate. Iberia and Finnair further request that the requested 

authority be granted for an indefinite period, consistent with the Department’s practice. 

Appendix A

Iberia Codeshare on Finnair Operated Flights 

ROUTING 

Helsinki – New York (JFK) 

Helsinki – Miami 
Appendix B

Finnair Codeshare on Iberia Operated Flights 

ROUTING

Madrid – Miami 

Madrid – Boston 

Madrid – Los Angeles 

Madrid – New York (JFK) 

Madrid – Chicago (ORD)