B EFORE THE D EPARTMENT OF T RANSPORTATION W ASHINGTON , D.C.

____________________________________ ) Application of ) ) A SIANA A IRLINES , I NC . ) ) Docket OST-2014-_______ for a Blanket Statement of Authorization ) Pursuant to 14 C.F.R. Part 212 ) (code-share with Etihad Airways) ) ____________________________________)

A PPLICATION OF A SIANA A IRLINES , I NC . F OR A B LANKET S TATEMENT OF A UTHORIZATION Communications with respect to this document should be addressed to:

Brian D. Smith Covington & Burling LLP 850 Tenth Street, N.W. Washington, D.C. 20001 202-662-5090 bdsmith@cov.com Counsel to Asiana Airlines, Inc.

December 18, 2014

Notice: The Applicant intends to initiate the code-sharing services that are the subject of this Application on or about January 5, 2015. The Applicant therefore re spectfully requests expedited processing of this Application and will poll the air carrier representatives served with this Application and will notify the Department of the results.B EFORE THE D EPARTMENT OF T RANSPORTATION W ASHINGTON , D.C.

____________________________________ ) Application of ) ) A SIANA A IRLINES , I NC . ) ) Docket OST-2014-_______ for a Blanket Statement of Authorization ) Pursuant to 14 C.F.R. Part 212 ) (code-share with Etihad Airways) ) ____________________________________)

A PPLICATION OF A SIANA A IRLINES , I NC . FOR A B LANKET S TATEMENT OF A UTHORIZATION Asiana Airlines, Inc. (“Asiana” or “Applicant”) hereby respectfully request a blanket Statement of Authorization pursuant to 14 C.F.R. Part 212 to enable it to display the “EY*” designator code of Etihad Airways P.J.S.C. (“Et ihad”) on flights Asiana operates in conjunction with foreign air transportation of persons, prope rty, and mail, to the full extent permitted under the open skies agreements between the United St ates and the Republic of Korea. Initially, Asiana plans to carry the EY* designator code on flights it operates between Seoul, Korea (ICN), on the one hand, and Los Angeles (LAX) and Sa n Francisco (SFO), on the other hand, in

connection with Etihad’s U.A.E.-U.S. service. In support of this Application, Asiana submits the following: 1. Asiana and Etihad entered into a Code Share Agreement that was effective as of December 10, 2010, and that was recently amended with reference to the routes identified in this Application. Flights operated by Asiana will or iginate or terminate in Seoul, Korea (ICN). Accordingly, Asiana requests a blanket Statement of Authorization to place Etihad’s EY*Asiana Airlines Docket OST 2014-_____ Application for a Statem ent of Authorization Page 2 designator code on services operated by Asiana fr om a point or points behind Korea, via Korea and intermediate points, to a point or points in the United States, and beyond.

2. Asiana and Etihad intend to initiate th e code-sharing services that are the subject of this Application on or about January 5, 2015. The Applicant therefore respectfully requests expeditious consideration of th is Application and a waiver of the 45-day requirement of the Department’s regulations. 1 The Applicant will poll the ca rriers listed on the certificate of service and will notify the Department of the resu lts. The Applicant requests that the Statement of Authorization be granted for an indefinite period, so long as the Code Share Agreement remains in effect, consistent with the Departme nt’s practice. Should the Agreement cease to be effective, the Applicant will notify the Department. 3. Both Asiana and Etihad hold the necessary authorities for the code-share flights. Asiana’s Foreign Air Carrier Permit authorizes Asiana to engage in scheduled foreign air transportation, carrying persons, pr operty, and mail “[f]rom a point or points behind the Republic of Korea, via the Republic of Korea and intermed iate points, to a point or points in the United States, and beyond.” 2 These rights are also provided in Annex I to the 1998 Air Transport Agreement between the United States and the Repub lic of Korea. Etihad holds a Foreign Air Carrier Permit that authorizes it to engage in sc heduled and charter foreig n air transportation of persons, property and mail “from points behind the United Arab Emirates and intermediate points to a point or points in the United States and beyond.” 3

1 14 C.F.R. § 212.10(d)(2). 2 Order 2000-11-10. 3 Order 2010-8-6.Asiana Airlines Docket OST 2014-_____ Application for a Statem ent of Authorization Page 3 4. The Code Share Agreement between Asiana and Etihad and the Statement of Authorization requested in this Application are consistent w ith the applicab le open skies agreements. The Air Transport Agreement between the United States and Korea, and the Air Transport Agreement between the United States a nd the United Arab Emirates similarly provide that any designated airline of either party to the agreements may enter into code-sharing arrangements with an airline of a third country, provided that thir d country authorizes or allows comparable arrangements between the airlines of the other party and other airlines on services to, from and via such third country. 4 5. The code-sharing services for which Asia na seeks authorization are in the public interest. The grant of authority requested in th is Application will expand travel opportunities for U.S. and foreign passengers, as well as allow th e Applicant to use its capacity more efficiently, while promoting competition and service options for consumers. As the Department has long recognized, “[i]ncreased international code sharing and ot her cooperative arrangements can benefit consumers by increasing internationa l service options and enhancing competition between carriers, particularly for traffic to or from cities behind major gateways.” 5 6. The Applicant will conduct its code-s haring services in compliance with the requirements in Part 257 regardi ng the disclosure of code-shari ng arrangements, as well as the other conditions and limitations the Department nor mally attaches to code -share operations. 7. Under the Department’s Notice in th e Matter of Blanke t Notification of Codeshare Service to Open-Skies Partners a nd Points, dated February 9, 2009, Asiana hereby

4 U.S.-Korea Air Transport Agreement, Art. 8, § 7 (June 9, 1998); U.S.-United Arab Emirates Air Transport Agreement, Art. 8, § 7 (Mar. 11, 2002). 5 Statement of United States International Air Tr ansportation Policy, 60 Fed. Reg. 21841 (May 3, 1995).Asiana Airlines Docket OST 2014-_____ Application for a Statem ent of Authorization Page 4 provides blanket notification of its intent to engage in code-sharing services to open skies points.The Applicant will notify the Department no later than 30 days before beginning any new codeshare service to non-open skies points, identifyin g the markets to be served and the date the service will begin.

W HEREFORE , Asiana respectively requests that the Department issue the blanket

Statement of Authorization described herein for an indefinite period, and gr ant Asiana such other

and different relief as is consistent with this Application and with th e public interest. The Applicant further requests the De partment grant the requested Statement of Authorization on an expedited basis, waiving the 45-da y filing requirement in Part 212. Respectfully submitted,

____________________________ Brian D. Smith Covington & Burling LLP 850 Tenth Street, N.W. Washington, D.C. 20001 202-662-5090 bdsmith@cov.com Counsel to Asiana Airlines, Inc.

December 18, 2014C ERTIFICATE OF S ERVICE I certify that I caused one copy of the foregoi ng Application of Asia na Airlines, Inc. for a Blanked Statement of Authorization to be served via electronic mail on December 18, 2014, upon the following individuals:

American Airlines robert.wirick@aa.com howard.kass@aa.com

FedEx sharon.pasley@fedex.com sllunsford@fedex.com

United Airlines dan.weiss@united.com gmurphy@crowell.com

Delta Airlines sascha.vanderbellen@delta.com chris.walker@delta.com Polar Air Cargo kevin.montgomery@polaraircargo.com peter.beckett@polaraircargo.com

United Parcel Service anita.mosner@hklaw.com jennifer.nowak@hklaw.com

Hawaiian Airlines jhill@cooley.com perkmann@cooley.com

JetBlue jhill@cooley.com perkmann@cooley.com Spirit Airlines jyoung@yklaw.com dkirstein@yklaw.com

Alaska Airlines marshall.sinick@squirepb.com charles.donley@squirepb.comAllegiant agoerlich@ggh-airlaw.com jmaddux@ggh-airlaw.com Sun Country thomas.ting@suncountry.com Amerijet joan.canny@amerijet.com

Kalitta Air matwood@cozen.com

Atlas Air rpommer@atlasair.com Etihad Airways anita.mosner@hklaw.com jennifer.nowak@hklaw.com

Federal Aviation Administration john.s.duncan@faa.gov Department of Transportation robert.finamore@dot.gov brett.kruger@dot.gov Department of State cristinasa@state.gov

AirlineInfo info@airlineinfo.com

_____________________ Brian D. Smith