BEFORE THE UNITED STATES DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.
Application of China Eastern Airlines Corporation Limited For Renewal ofExemption 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 ofTransportation and serve it on the above counsel and all persons named on the attached service list no later than April23, 2015.

{N0210140 1 }BEFORE THE UNITED STATES DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.
Application of China Eastern Airlines Corporation Limited For Renewal ofExemption 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 ofPractice, 14 C.F
.R. § 302.301 et seq., asks thatthe Departmentrenew its exemption authority authorizing it to engage in scheduled foreign air transportation ofpersons, 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 ofthis application, China Eastern submits the following: 1. ByNotice 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 ofpersons, 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 ofExemptionAuthorit y 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 ofpersons, 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 ofChina, and Los Angeles, via Nanjing (Notice of Action Taken, February 12,2015 (Docket OST-2015-0026));

Page 3 of6Applicationfor Renewal of Exemption A uthority of China East emAirlines Corporation Limited Docket OST-2011

-0065 April 8, 2015 (vii) Beijing and Shanghai, People' s Republic ofChina, 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 ofAuthorization 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 ofAuthorization 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 ofthe Statement ofAuthorization
. 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 of6AppliwtionforRenewalof ExemptionAuthority of China Eastern Airlines Corporation Limited Docket OST-2011-0065 April8, 2015 8. In filing this application, China Eastern invokes and intends to rely upon the automatic extension provisions ofthe 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 By



# ~CJ4~ Evelyn 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 of6Application for Renewalof ExemptionAut hority 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 ofthe foregoing Application for Renewal of Exemption Authority for China Eastern Airlines Corporation Limited was served by electronic mail this 8th day ofApril 2015 on the following:

TO COMPANY E-MAIL Thomas S. Engle U.S. Departmen t of englets@state.gov State JohnS. Duncan Federa l Aviation john.s.duncan@faa
.gov Administration Sascha Van der Bellen DeltaAirlines 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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