BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

__________________________________________ ) Application of ) ) DELTA AIR LINES, INC. ) Docket DOT-OST-2010-0208 and ) DELTA CONNECTION CARRIERS ) ) for an exemption from 14 C.F.R. Part 212 ) __________________________________________)

ANSWER OF UNITED AIR LINES, INC. Communications with respect to th is document should be sent to:

MARY BARNICLE Director – International &

Regulatory Affairs UNITED AIR LINES, INC. 77 West Wacker Drive, HDQIZ Chicago, IL 60601 STEVE MORRISSEY Managing Director – International & Regulatory Affairs JEFFREY A. MANLEY Senior Advisor – Regulatory Affairs UNITED AIR LINES, INC. 1025 Connecticut Avenue, N.W. Suite 1210 Washington, D.C. 20036 Phone: (301) 229-8571 jeffrey.manley@united.com DATED: August 31, 2010BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

__________________________________________ ) Application of ) ) DELTA AIR LINES, INC. ) Docket DOT-OST-2010-0208 and ) DELTA CONNECTION CARRIERS ) ) for an exemption from 14 C.F.R. Part 212 ) __________________________________________) DATED: August 31, 2010

ANSWER OF UNITED AIR LINES, INC. United Air lines, Inc. (“United”) here by submits the following answer to the Application of Delta Air Lines, In c. and the Delta Connection Carriers 1 (hereinafter “Delta application”) dated August 16, 2010, in the above-captioned docket: 1. In its application Delta seeks a blanke t exemption from Part 212 to enable the Delta Connection carriers operating aircraft with between 61 and 76 seats to display the codes of Delta’s approved foreign code-sha re partners without the need to obtain

individual statements of authorization for each Delta Connection/foreign partner arrangement. The carriers’ request is premised on the desire to harmonize the longstanding regulatory exemption from Part 212 for commuter and regional aircraft with the modern trend toward larger regional jets. It is also consistent with the Department’s

1 These carriers are: Atlantic Sout heast Airlines, Inc., Chautauqua Ai rline, Inc., Comair, Inc., Compass Airlines, Inc., Mesaba Aviation, Inc., Pinnacle Airlines , Inc., SkyWest Airlines, Inc., and Shuttle America. Three of these carriers (Atlantic Southeast, SkyWest and Shuttle America) also have similar arrangements with United when operating as United Express carriers.Answer of United Page 2

streamlining initiative. See DOT Notice dated August 26, 2005 in Docket DOT-OST2005-22228. 2. As the Department is fully aware, Un ited is a strong supporter of its efforts to streamline the regulatory licensing and approva ls process. For this reason, United believes that the same relief requested by Delta should be granted by the Department sua sponte to all U.S. commuter ca rriers operating under code -share arrangements with foreign partners of a U.S. carrier. Such bla nket relief would be more in keeping with the Department’s streamlining efforts and woul d avoid the need to process numerous repetitive applications of other carriers. Su ch relief would also have the advantage of avoiding the need to amend or update the list of commuter carriers offering code-share service under the exemption with a major U.S. car rier partner. Since there are frequently changes in the list of participating commute r carriers, avoiding such amendments or updating would relieve the carrier s and the Department of an additional burden. This

would also be consistent with the treatment of commuters code-sharing for foreign carrier partners in 60-seat or smaller aircraft for which the Department requires no notification

or other documentation with re spect to such arrangements. 3. If, notwithstanding the foregoing, the Department decides to proceed on a carrier-by-carrier basis, then United does not oppose the Department’s approval of Delta and Delta Connection Carriers’ August 16 appl ication so long as the Department is prepared to grant comparable relief to ot her carriers. United would, however, oppose any grant of such relief to Delta and its commuter s unless comparable relief is granted to their competitors, including United Express carriers offering code-share services for United and its foreign partners. United reserves th e right to submit an application for specificAnswer of United Page 3

relief on its own behalf and on behalf of its United Express commuter carriers should the Department decide to proceed on an ad hoc basis. 4. United Express carriers 2 operate aircraft on behalf of United, including aircraft with 60 seats or less as well as larg er aircraft, presently up to 70 seats. Consistent with its agreements with these carriers, United not only handles the marketing of United Express flights but it also owns and controls the full capacity and inventory for these flights, including those in which United’ s foreign code-share partners 3 may code share. United’s code-shares with its 25 foreign code-share partners have been, up to the present time, subject to the statement of authorization requirement of Part 212, and numerous such applications have been previously approved c onsistent with the public interest. However, since code sharing between the United Expre ss partners and United’s foreign code-share partners may require additional statements of authorization as new foreign and commuter carriers are added and as existing United foreign partners a nd United’s commuters expand their cooperation, the continued requirement for ad hoc statements of authorization would prove burdensome to both the carriers and the Department, and would, in addition, be an unfair and discrimina tory burden if compe ting carriers were to be selectively exempted from this requireme nt. It would also delay the public benefit derived from expanding the flights options of the traveling public. Thus, the

2 These carriers are Atlantic Southeas t Airlines, Inc., ExpressJet Airlines, Inc., GoJet Airlines, LLC, Mesa Airlines, Inc., Shuttle America Corporation, SkyWest Airlines, Inc, and Trans States Airlines, Inc. Although not all of these carriers curr ently operate aircraft in excess of 60 seats, by applying the blanket relief to all of them they will each ha ve the flexibility to operate aircraft in excess of 60 seats should they elect to do so. 3 These currently are: Aer Lingus, Air Canada, Air Ch ina, Air New Zealand, ANA, Asiana, Austrian, bmi, Croatia Airlines, EgyptAir, Jet Airw ays, LOT, Lufthansa, Qatar, SAS, Singapore Airlines, SN Brussels, South African Airway s, Spanair, Swiss, TACA, TAM, TAP, Thai Airways and Turkish Airlines.

.Answer of United Page 4

Department’s grant of a blanket exemption from Part 212 to all carriers that code share with approved foreign code-share partners would not only save resources and time for the carriers and the Department but would also benefit the traveling public. WHEREFORE, for the foregoing reasons, United urges the Department to grant the relief requested by Delta sua sponte to all U.S. commuter carriers operating under code-share arrangements with foreign partners of a U.S. carrier and to grant them such

other and different relief as is consistent with their request and with the public interest. Respectfully submitted,

Steve Morrissey Managing Director, International & Regulatory Affairs UNITED AIR LINES, INC.

DATED: August 31, 2010CERTIFICATE 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 e-mail.

anita.mosner@hklaw.com barbara.russell@virginamerica.com benjamin.slocum@usairways.com bill@mietuslaw.com bob.kneisley@wnco.com brian.gillman@mesa-air.com byerlyjr@state.gov carl.nelson@aa.com cdonley@ssd.com charters@evergreenaviation.com dhayes@transstates.net dwight.moore@ustranscom.mil hkamen@coair.com howard_kass@usairways.com john.allen@faa.gov john.fredericksen@suncountry.com jrichardson@johnlrichardson.com jyoung@yklaw.com kevin.montgomery@polariarcargo.com matwood@sherblakwell.com mroller@rollerbauer.com patrick.rizzi@hoganl ovells.com (ASA) robert.cohn@hoganlovells.com (ASA) ronald.williams@ustranscom.mil rpommer@atlasair.com rsilverberg@sgbdc.com sascha.vanderbellen@delta.com suzi.johnson@expressjet.com sdurgin@rjet.com slachter@lachter-clements.com temerson@skywest.com

Annalei Avanceña Advisor—Regulatory Affairs

DATED: August 31, 2010