Delta and Air France / Statements of Authorization / Blanket Code-Share Authority / June 2, 1998

Dear Mr. Gretch:

Paul L. Gretch

June 2, 1998

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The Joint Applicants are herein seeking blanket authority under Parts 207 and 212 to allow the carriers to implement code-sharing services that are not otherwise authorized by the Department's May 8, 1998 Notice of Action Taken. This expanded authority will enable the carriers to implement the full measure of services covered by their code-share agreement, Specifically, the Joint Applicants hereby apply for the following authority:

1/ This authority would allow Delta and Air France to engage not only in thirdcountry code-share operations, but also in transatlantic U.S.-France codesharing, which is already authorized by the Department's May 8 approval, over third-country intermediate points, which is not specifically authorized. All of Delta's and Air France's third-country authority will be exercised subject to the blind-sector limitations contained in the bilateral.

Paul L. Gretch

June 2, 1998

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The Joint Applicants request that the Statements of Authorization be granted for an indefinite duration, consistent with recent Department practice and the Department's May 8, 1998 approval of the Joint Applicants' initial code-sharing authority. /3 In addition, the Joint Applicants respectfully request expeditious consideration and the issuance of the Statements of Authorization by no later than June 15, 1998, so that the carriers can begin marketing these new code-share services -- including third-country code-share service to the points listed in Exhibit A, attached hereto -- before the peak summer travel season. /4

As the Joint Applicants demonstrate below, grant of this application will enable Delta and Air France to implement important new code-share services consistent with the MOC. Approval of this application will also enable Delta and Air France to respond quickly to service demands and changes in the marketplace, as it will provide the carriers with the flexibility to adjust their

2/ The Department's notice dated May 8, 1998 authorizes Air France to display Delta's designator code on flights between the United States and Paris only, and between Paris only and other points in France. The Joint Applicant's request that this authority under Part 212 be expanded to include flights operated by Air France between the United States and-any point in France (either nonstop or over intermediate points), and between any France city-pairs, as well as third-country code-share service.

3/ The Joint Applicants would accept the condition that the authorities would remain in effect as long as (a) the carriers' underlying authority to serve the markets at issue remains in effect; and (b) the underlying code- sharing/blockedspace agreements remain in effect and approved by the Department.

4/ To the extent required, Delta and Air France request a waiver of the 45-day advance filing requirements for Statements of Authorization under Parts 207 and 212. Delta and Air France intend to begin marketing and sales activities on or about June 15, 1998 and to begin operating service to the points listed in Exhibit A on or about June 19, 1998. Delta and Air France will comply with the requirement that they provide the Department with written notice at least 30 days prior to implementing service to additional points.

Paul L. Gretch

June 2, 1998

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code-share services without the need to obtain Department approval to amend their code-share authority every time they seek to add another point.

In further support of this Joint Application, Delta and Air France state the following:

1. Approval of this application meets the standards applicable to grants of Statements of Authorization under Parts 207 and 212, and is in the public interest for the following reasons:

a) Approval of this application is fully consistent with the terms of the U.S.-France MOC -- specifically Art. 8(7) of the new Air Transport Agreement -- and is consistent with the Department's recent approval of Delta/Air France code-share services. As to third countries, the services are consistent with applicable bilateral agreements and/or are supported by principles of comity and reciprocity.

b) Grant of this application will give the Joint Applicants broad flexibility to revise and expand code-share services that would enhance international competition and service options for travelers who are seeking service between the United States and France, and beyond, without the need to seek additional Department approval. With respect to beyond services, approval of expanded blanket authority under Part 212 would allow Delta to benefit from third-country code-share access to the fullest extent contemplated by the MOC and other applicable bilateral understandings and would allow Delta quickly to enter new markets. The addition of Delta's on-line connections to international destinations beyond France would provide travelers with new service alternatives and would inject new competition between the U.S. and various foreign points.

C) Approval of these Statements of Authorization would be consistent with the Department's recent efforts to reduce the administrative burden both on carrier applicants and on the Department, in that the Joint Applicants would not need to seek new or amended Statements of Authorization every time new code-share services consistent with applicable bilateral agreements are to be implemented. In addition, if granted such blanket authority, Delta and Air France's ability to implement new code-share arrangements would not be delayed by the regulatory process, and the traveling public would be able to benefit from such new services more quickly.

Paul L. Gretch

June 21, 1998

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d) Because the Department has fully evaluated and approved the applicable code-share agreement, and the services contemplated herein are consistent with the terms of the MOC, this application is non-controversial and should be granted expeditiously.

4. The Joint Applicants have previously submitted copies of the relevant code-share agreements for the Department's review and approval.

Paul L. Gretch

June 2, 1998

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6. Delta hereby states that this application will have no impact on Delta's CRAF commitments.

7. Delta and Air France request expeditious consideration of this application and approval by no later than June 15, 1998, to allow the carriers to implement important new services during the peak summer travel season, including specifically the third-country code-share services described in Exhibit A. The Joint Applicants request approval for an indefinite duration, to avoid unnecessary submission and review of non-controversial requests for authority, consistent with recent Department practice.

8. In conclusion, by granting this application, the Department will provide Delta and Air France with the flexibility to implement new code-share services that would result in more efficient operations by the carriers and improved international service options for the traveling public, while reducing the administrative burden on the Joint Applicants and the Department. Moreover, prompt approval of this application will allow both Delta and Air France to enjoy the benefits available to U.S. and French carriers under the recently concluded MOC to the fullest extent possible.

Paul L. Gretch

June 2, 1998

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WHEREFORE, Delta and Air France respectfully request that the Department grant this application for Statements of Authorization to permit Delta and Air France to provide the code-share services discussed above for an indefinite duration, and grant such other and further relief as the Department deems to be in the public interest.

Respectfully submitted,

Michael F. Goldman

BAGILEO, SILVERBERG

Robert E. Cohn

SHAW PITTMAN POTTS & TROWBRIDGE