BEFORE THE UNITED STATES 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

China Eastern Airlines Corporation Limited 

For Renewal of Exemption Authority 

Pursuant to 49 U.S.C. § 40109 

) 

) 

) 

) Docket OST-2011-0065 

) 

) 

) ________________________________ ) 

April 8, 2015 

APPLICATION OF CHINA EASTERN AIRLINES 

CORPORATION LIMITED FOR RENEWAL OF EXEMPTION 

AUTHORITY PURSUANT TO 49 U.S.C. § 40109 

Communications with respect to this 

document should be directed to: 

Evelyn D. Sahr 

Jonathan T. Linde 

Beth A. FitzPatrick 

ECKERT SEAMANS 

CHERIN & MELLOTT, LLC 

1717 Pennsylvania A venue, NW 

Twelfth Floor 

Washington, DC 20006 

Phone: 202-659-6600 

Fax: 202-659-6699 

Attorneys for China Eastern Airlines 

Corporation Limited 

NOTICE: Any person wishing to support or oppose this application must file an answer 

with the Department of Transportation and serve it on the above counsel and all persons 

named on the attached service list no later than April23, 2015. 

{N02101401 } 
BEFORE THE UNITED STATES 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

China Eastern Airlines Corporation Limited 

For Renewal of Exemption Authority 

Pursuant to 49 U.S.C. § 40109 

) 

) 

) 

) Docket OST-2011-0065 

) 

) 

) __________________________________ ) 

APPLICATION OF CHINA EASTERN AIRLINES 

CORPORATION LIMITED FOR RENEWAL OF EXEMPTION 

AUTHORITY PURSUANT TO 49 U.S.C. § 40109 

China Eastern Airlines Corporation Limited ("China Eastern"), in accordance with 49 

U.S.C. § 40109(c), and Subpart C ofthe Department's Rules of Practice, 14 C.F.R. § 302.301 et 

seq., asks that the Department renew its exemption authority authorizing it to engage in scheduled 

foreign air transportation of persons, property and mail, on a codeshare-only basis with Delta Air 

Lines, Inc. ("Delta") and Delta Connection, between points in the United States and behind, 

intermediate, and beyond points in third countries. China Eastern requests renewal of this 

authority for a period of two (2) years so that it may continue to operate codeshare routes with 

Delta/Delta Connection. 

In support of this application, China Eastern submits the following: 

1. By Notice of Action Taken most recently on May 19,2014 in Docket OST-2011-0065, the 

Department granted China Eastern an exemption from 49 U.S.C. § 41301 to provide scheduled 

foreign air transportation of persons, property and mail on a codeshare-only basis with Delta/Delta 

Connection, between points in the United States and behind, intermediate, and beyond points in 

third countries. 

{N0210140.1 } 
Application for Renewal ofExemption Authority of China Eastern Airlines Corporation Limited 

Docket OST-2011-0065 

AprilS, 2015 

2. China Eastern has permit authority to provide scheduled foreign air transportation of 

persons, property and mail between co-terminal points Beijing, Guangzhou and Shanghai, on the 

one hand and Los Angeles, San Francisco, Chicago, and Honolulu or Seattle on the other. (DOT 

Order 92-11-7) 

3. China Eastern holds the following exemption authority to conduct scheduled foreign air 

transportation of persons, property and mail between: 

(i) Beijing, People's Republic of China and Saipan, Commonwealth of the Northern 

Mariana Islands (Notice of Action Taken, March 13, 2015 (Docket OST-2012-0185)); 

(ii) Shanghai, People's Republic of China and Saipan, Commonwealth of the Northern 

Mariana Islands (Notice of Action Taken, March 13, 2015 (Docket OST-2004-17665)); 

(iii) any point or points in the People's Republic of China and San Francisco, California, 

with all flights operating via Shanghai (Notice of Action Taken, March 13, 2015 (Docket 

OST-2013-0079)); 

(iv) any point or points in the People's Republic of China and Los Angeles, with all 

flights operating via Shanghai and/or Beijing (Notice of Action Taken, March 13, 2015 

(Docket OST-2005-23074)); 

(v) any point or points in the People's Republic of China and New York, New York with 

all flights operating via Shanghai and/or Beijing (Notice of Action Taken, September 15, 

2014 (Docket OST-2014-0155)); 

(vi) Chengdu, People's Republic of China, and Los Angeles, via Nanjing (Notice of Action 

Taken, February 12,2015 (Docket OST-2015-0026)); 

Page 3 of6 
Application for Renewal of Exemption Authority of China East em Airlines Corporation Limited 

Docket OST-2011 -0065 

April 8, 2015 

(vii) Beijing and Shanghai, People's Republic of China, on the one hand, and any point or 

points in the United States, on the other hand (Notice of Action Taken, April 10, 2014 

(Docket OST-2004-19010)); and 

(viii) points in the U.S. on a code share only basis with Virgin America (Notice of Action 

Taken, June 30,2014 (Docket OST-2014-0107)). 

4. Delta was issued a Statement of Authorization on May 6, 2011 permitting Delta to display 

China Eastern's "MU" designator code on flights operated by Delta between the United States and 

China, within the United States and China, and to behind, intermediate, and beyond points in third 

countries. This also extends to Delta Connection regional affiliates which operate service for Delta 

within North America. (Notice of Action Taken, May 6, 2011 (Docket OST-2011-0065)) 

5. China Eastern was issued a Statement of Authorization on May 6, 2011 permitting China 

Eastern to display Delta's "DL" designator code on flights operated by China Eastern between the 

United States and China, within the United States and China, and to behind, intermediate, and 

beyond points in third countries. (Notice of Action Taken, May 6, 2011 (Docket OST-2011-0065)) 

6. The Statements of Authorization were issued for an indefinite period of time. Blanket 

exemption authority will allow China Eastern to place its "MU" designator code on Delta flights, 

pursuant to its codeshare arrangement with Delta, and subject to the terms and conditions of the 

Statement of Authorization. 

7. China Eastern is fit, willing and able to perform the services for which the exemption is 

sought. The requested exemption authority is consistent with the United States - People's 

Republic of China Air Transport Agreement, as amended on May 22, 2007. Granting this 

exemption authority is in the public interest as it will permit China Eastern to continue providing 

enhanced services for persons traveling and shipping goods between the United States and China. 

Page 4 of6 
Appliwtionfor Renewal of Exemption Authority of China Eastern Airlines Corporation Limited 

Docket OST-2011-0065 

April 8, 2015 

8. In filing this application, China Eastern invokes and intends to rely upon the automatic 

extension provisions of the Administrative Procedures Act, 5 U.S.C. § 558(c), as implemented by 

14 C.F.R. Part 377, so that it may continue by operation oflaw to operate this service until the 

Department makes a determination on this request. China Eastern's exemption authority would 

expire May 19, 2015 absent this renewal application, which is timely filed pursuant to 14 C.F.R. 

§ 377.10(c). 

WHEREFORE, China Eastern respectfully requests that the Department grant China 

Eastern's request for renewal of exemption authority to perform scheduled foreign air 

transportation pursuant to its codeshare arrangement with Delta Airlines. 

Date: April 8, 2015 Respectfully submitted, 

ECKERT SEAMANS CHERIN & MELLOTT, LLC 

Evelyn 

By ~CJ4~ D. Sahr 

Jonathan T. Linde 

Beth A. FitzPatrick 

1717 Pennsylvania Avenue, N.W. 

Twelfth Floor 

Washington, D.C. 20006 

(202) 659-6622 (telephone) 

(202) 659-6699 (facsimile) 

Attorneys for 

China Eastern Airlines Corporation Limited 

Page 5 of6 
Application for Renewal of Exemption Authority of China EttStern Airlines Corporation Limited 

Docket OST-2011-0065 

Apri/8, 2015 

CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing Application for Renewal of 

Exemption Authority for China Eastern Airlines Corporation Limited was served by electronic 

mail this 8th day of April 2015 on the following: 

TO COMPANY E-MAIL 

Thomas S. Engle U.S. Department of englets@state. gov 

State 

JohnS. Duncan Federal Aviation john.s.duncan@faa.gov 

Administration 

Sascha Van der Bell en Delta Airlines Sascha.vanderbellen@delta.com 

Christopher Walker Chris. walker@delta.com 

Robert Wirick American Airlines robert. wirick@aa.com 

Howard Kass Inc. howard.kass@aa.com 

Dan Weiss United Air Lines, dan. weiss@united.com 

Inc. 

Jonathan Hill Cooley LLP jhill@cooley.com 

Parker Erkmann (Hawaiian Airlines) perkmann@cooley .com 

Kevin Montgomery Polar Air Cargo kevin.montgomery@polaraircargo.com 

Russell E. Pommer Atlas Air, Inc. rpommer@atlasair.com 

Bailey Leopard Federal Express gbleopard@fedex.com 

Nancy Sparks nssparks@fedex.com 

Anita Mosner Holland & Knight anita.mosner@hklaw.com 

Jennifer Nowak (United Parcel jennifer.nowak@hklaw.com 

Service) 

Mark Atwood Kalitta Air matwood@cozen.com 

Aaron Goerlich Southern Air agoerlich@ggh-airlaw .com 

Frank Avent Airline Info fbavent@airlineinfo.com 

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