Northwest Airlines, Inc. ("Northwest") hereby submits this Answer to the Joint Application of American Airlines, Inc. ("American") and Aero California S.A. de C.V. ("Aero California") for renewal of their respective statements of authorization to engage in certain reciprocal code-share services, filed on October 20, 1997. Contrary to the representations made by American and Aero California in their Joint Application, the code-share authorizations for which renewal is sought are not licenses of a continuing nature for purposes of 5 U.S.C. S 558(c) because those authorizations were last granted for less than 180 days. As such, American and Aero California may not take advantage of the automatic extension provisions of S 558(c), as implemented in the Department's Procedural Rules at 14 CFR S 377.3(a). Rather, the code-share authorizations which are the subject of the above-referenced Joint Application will expire if not renewed by the Department on or before their scheduled expiration dates.

In limiting American's and Aero California's respective authorizations to code-share, the Department cited the Mexican Government's authorization of code-share services of Northwest and Alaska Airlines for only a six month period. (Order 97-7-31 at 7; confirmed by Order 97-9-38). Given the limited term of the Northwest/Alaska code-share authorization, the Department found it in the public interest to limit statements of authorization to code-share involving Mexican carriers for a comparable period.