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U.S.- Turkey Combination Service Third-Country Code-Share Opportunities 

By this notice we invite U.S. certificated air carriers interested in using third-country code-share opportunities in the U.S.-Turkey market to file applications as specified below in the captioned docket.

On May 2, 2000, the United States and Turkey signed an open-skies air transport agreement.  The agreement includes a three-year transition for the operation of third-country code-share combination services. Effective through March 31, 2001, up to three airlines could serve, operating a total of 21 weekly frequencies; we allocated those opportunities last year among the interested U.S. carriers. Effective April 1, 2001, through March 31, 2002, up to five airlines may serve, operating a combined total of 35 weekly frequencies (an increase of two additional airlines and 14 weekly frequencies). Effective April 1, 2002, through March 31, 2003, up to seven airlines may serve, operating a combined total of 49 weekly frequencies (an increase of two additional airlines and 14 weekly frequencies). Effective April 1, 2003, there will be no restrictions on the operation of third-country code-share combination services.

By this notice we request that all U.S. air carriers interested in using the third-country code-share opportunities available April 1, 2001 to file applications for those services with the Department no later than February 8, 2001. Answers to such applications should be filed by February 15, 2001. Replies to answers should be filed by February 20, 2001. We intend to solicit applications from carriers interested in using the 2002 opportunities at a later date.

By:  Paul Gretch

U.S.- Turkey Combination Service Third-Country Code-Share Opportunities 

American Airlines, Inc., in response to the Department's Notice issued on January 26, 2001, hereby applies for a third-country codeshare opportunity to serve between the United States and Turkey. American requests 14 weekly frequencies to provide service with Swissair via Zurich to Istanbul and Izmir. The supporting information required by the Notice is set forth below.

American and Swissair will start codeshare service to Istanbul and Izmir on April 1, 2001, or within 15 days of receiving all necessary governmental authorizations.

American and Swissair will provide nonstop-to-nonstop connections, via Zurich, between 10 gateway cities in the United States, on the one hand, and Istanbul and Izmir, on the other. The U.S. gateway cities are Atlanta, Boston, Chicago, Dallas/Ft. Worth, Los Angeles, Miami, New York (JFK), Newark, San Francisco, and Washington (Dulles).

Under the terms of the transitional open-skies agreement between the U.S. and Turkey, and as stated in the Department's Notice, the awards at issue here are limited to two additional airlines and to 14 weekly frequencies. Accordingly, although Swissair operates two daily frequencies between Zurich and Istanbul, and one between Zurich and Izmir, we have selected the single best Zurich-Istanbul flights operated by Swissair in each direction in order to meet the frequency limitation. Over the Atlantic, American and Swissair operate 14 daily peak season frequencies between U.S. gateways and Zurich. Details of available connections between U.S. gateways and Istanbul and Izmir via Zurich are shown in Exhibit AA-1.

Counsel:  American, Carl Nelson, 202.496.5647, carl_nelson@aa.com 

Under the terms of the U.S.-Turkey transitional open skies agreement, fourteen additional weekly frequencies will become available to U.S. carriers on April 1, 2001 for third-country codeshare services between the United States and Turkey. In accordance with the Department's January 31, 2001 Notice, Delta Air Lines, Inc. hereby applies for an allocation of seven additional weekly frequencies to operate a second daily third-country codeshare flight between Paris, France (CDG), and Istanbul, Turkey (IST). Delta plans to operate its proposed services in conjunction with Delta's SkyTeam Alliance partner, Societe Air France.

Delta and Air France propose to commence additional U.S.-Turkey service on April 1, 2001, or within 15 days of receiving all necessary governmental approvals. Delta and Air France will provide nonstop-to-nonstop connections, via Paris, between eleven U.S. gateway cities and Istanbul. The U.S. gateway cities are Atlanta, Boston, Cincinnati, Dallas/Ft. Worth, Houston, New York, Los Angeles, Miami, Chicago, Philadelphia and San Francisco. Total elapsed travel times for U.S.-Turkey routings via Paris.

Delta requests seven (7) additional frequencies in this proceeding, which will enable Delta to provide double-daily year-round third-country codeshare service to Istanbul via Paris.

Counsel:  Shaw Pittman, Robert Cohn, 202.663.8060 

Pursuant to the Department's January 31, 2001, Notice inviting applications in this docket~ and Subpart C of the Department's Procedural Regulations, 14 C.F.R. Part 302, Northwest Airlines, Inc. hereby applies for seven (7) additional weekly third--country code-share frequencies, a total of fourteen frequencies, to enable Northwest to provide double daily service between points in the United States and Turkey, via Amsterdam, by code-sharing on flights operated by KLM Royal Dutch Airlines between Amsterdam and Istanbul, Turkey. Northwest asks that the requested third-country code-share frequencies be granted indefinitely.

Northwest hereby applies for seven of the additional frequencies that become available on April 1, 2001. The Department previously awarded Northwest, in conjunction with KIM, one of the U.S.-Turkey third-country code-share carrier opportunities available through March 31, 2001, and seven weekly frequencies (Order 2000-8-17). By this application, Northwest seeks additional seven frequencies, for a total allocation of 14 weekly frequencies. Northwest will utilize the seven additional frequencies to code-share on a second daily flight operated by KLM between Amsterdam and Istanbul.

Counsel:  Northwest, Megan Rosia, 202-842-3193, megan.rosia@nwa.com 

Pursuant to the Department's Notice dated January 31, 2001, United Air Lines, Inc. submits the following application for an allocation of 14 weekly frequencies in order to expand its existing third-country code-share services between the United States and Turkey in conjunction with Lufthansa German Airlines.

By this application, United is requesting: (1) seven weekly frequencies in order to increase its existing third-country code-share service to Istanbul via Frankfurt to a twice-daily schedule; and (2) seven weekly frequencies in order to introduce third-country code-share service to Ankara via Munich.

United and Lufthansa propose to offer code-share service between a total of 15 U.S. gateways, on the one hand, and Istanbul and Ankara, Turkey, on the other, via Frankfurt and Munich, Germany. Those 15 U.S. gateways are: Atlanta, Boston, Chicago, Dallas/Fort Worth, Denver,' Detroit, Houston, Los Angeles, Miami, New York (EWR), New York (JFK), Philadelphia, Phoenix, 2 San Francisco, and Washington (IAD).

Counsel:  Wilmer Cutler, Jeffery Manley, 202.663.6670, jmanley@wilmer.com

U.S.- Turkey Combination Service Third-Country Code-Share Opportunities 

Counsel:  Shaw Pittman, Robert Cohn, 202.663.8060

U.S.- Turkey Combination Service Third-Country Code-Share Opportunities 

Each of the applicants already has on-line access to the U.S.-Turkey market. American has a bilateral codeshare arrangement with Turkish Airlines. Delta provides its own service to Turkey with daily 3767 flights to Istanbul from New York (JFK). Last year, Delta, Northwest, and United were awarded third-country codeshare authority to serve Turkey with their respective European partners in U.S.-Turkey Third-Country Codeshare Opportunities, Order 2000-8-17,.August 18, 2000.

Accordingly, in the present proceeding, American is seeking its first third-country codeshare opportunity to serve Turkey (and its second overall opportunity in light of its arrangement with Turkish Airlines). Delta is seeking its third opportunity to serve Turkey. Northwest and United are seeking their second opportunities.

In these circumstances, Delta should be ranked last among the applicants. Delta already serves Turkey with its own aircraft and crews, and Delta was awarded a third-country codeshare opportunity last year to serve Turkey with Air France via Paris. Moreover, in its application, Delta has proposed relatively poor elapsed times between its U.S. gateway cities and Istanbul. Before Delta is granted a third opportunity, American should receive frequencies for service to Turkey with Swissair via Zurich. That will introduce a new codeshare partnership into the marketplace, with important benefits for consumers, and additional competition against the existing Delta/Air France, Northwest/KLM, and United/Lufthansa arrangements.

Counsel:  American, Carl Nelson, 202.496.5647, carl_nelson@aa.com 

Four carriers have applied for a total of forty-two third-country codeshare frequencies from an available pool of fourteen frequencies. Significantly, each applicant carrier - American, United, Northwest and Delta -- currently enjoys access to the U.S.-Turkey marketplace on a codeshare basis. The question for the Department, therefore, is which carrier or carriers are most deserving, and will benefit the traveling public to the greatest extent, through an expansion of third-country codeshare services.

Delta's long-standing commitment to the U.S.-Turkey marketplace and its need to match the rising competitive challenge of the American/Turkish Airlines alliance mitigate strongly in favor of an award to Delta. Unlike the other carrier applicants, Delta is the only carrier that is currently exercising any of the unlimited direct service opportunities that are available to U.S. carriers under the U.S.-Turkey transitional open skies agreement. Rather than taking advantage of the direct service opportunities that are available to them, American, United, and Northwest are seeking to bolster their Turkey service offerings by relying exclusively on third-country codeshare opportunities - the only service opportunities that remain restricted under the terms of the transitional agreement.

Counsel:  Shaw Pittman, Alexander Van der Bellen, 202.663.8060

This proceeding is unique to many of the third-country code-share allocation proceedings the Department has conducted in the past in that all of the applicants are already incumbents in some respect in the U.S.-Turkey market. Existing services offered to Turkey by each of the incumbents is summarized as follows:

• American presently offers 15 weekly nonstop frequencies between the U.S. and Turkey involving three U.S, gateways (New York, Miami and Chicago) by code-sharing on flights operated by Turkish Airlines ("THY"), as well as services within Turkey beyond Istanbul.
• Delta presently offers a total of 14 weekly U.S.-Turkey frequencies, including a daily New York-Istanbul nonstop service operated by Delta and seven third-country code-share frequencies offered via Paris in conjunction with Air France.
• Northwest presently offers seven weekly U.S. -Turkey third-country code-share frequencies, via Amsterdam in conjunction with KLM.
• United also operates seven weekly U.S. -Turkey third-country code-share frequencies, via Frankfurt in conjunction with Lufthansa.

Counsel:  Northwest, Megan Rosia, 202-842-3193, megan.rosia@nwa.com 

All of the applicants already offer some service to Istanbul. United and Northwest each offer a single daily U.S.-Istanbul code-share connection, American offers 15 weekly nonstop U.S.-Istanbul code-share services with THY and Delta offers a daily nonstop in its own aircraft plus a daily code-share connection to Istanbul via Paris with Air France. United and Northwest each propose a second daily code-share service to Istanbul, while American and Delta each propose to offer a third daily service to that city. The second daily Istanbul services proposed by United should be given priority over the Istanbul services proposed by the other carriers because United's additional services would offer more competitive benefits than those of the other carriers.

In order to compare services proposed for Istanbul, certain adjustments are needed to assure uniformity. United included only the best connection from each U.S. gateway, whereas Northwest included multiple connections to the same U.S. gateway where they existed. Thus, Northwest includes three Detroit flights and two Los Angeles flights as connections to its new Amsterdam-Istanbul code-share flight. In order to provide a uniform comparison United has counted only those Northwest flights which make the best connection to its AMS-IST flight, putting Northwest on the same basis as United." United also eliminated from its schedules connections which required overnight layovers and has made the same adjustment to other carriers' schedules for purposes of comparison. Such a uniform comparison demonstrates that United's proposed Istanbul services will offer more benefits than the services to that city that would be offered by any other applicant. With a total of seven additional U.S.-Istanbul frequencies, United would serve 14 U.S. gateways offering a total of 196 weekly U.S.-Istanbul code-share connecting frequencies. No other applicant would use the frequencies it seeks to offer a comparable level of competitive services.

Counsel:  Wilmer Cutler, Jeffery Manley, 202.663.6670, jmanley@wilmer.com

U.S.- Turkey Combination Service Third-Country Code-Share Opportunities 

The decision before the Department is clear. American/Swissair will bring another codeshare arrangement to the U.S.-Turkey market, with demonstrable public benefits. American should be selected for a new designation, and for seven of the 14 available frequencies.

Counsel:  American, Carl Nelson, 202-496-5647, carl_nelson@aa.com 

A review of the four competing carrier answers yields three observations that are critical to the Department's decision. First, an award to American would produce the fewest public benefits, because American already offers the most U.S.-Turkey nonstop frequencies (15) from three U.S. gateways, including two American hubs. Second, since it is unlikely that any single carrier would receive more than seven of the fourteen available frequencies, the Department must decide which one of the three remaining proposals is the weakest, and eliminate that application. Third, Delta's proposal is markedly superior to Northwest's because Delta would offer much better third-country connections than Northwest for large west coast cities that lack effective third-country connecting options today, as well as offering shorter elapsed travel times from all commonly served U.S. gateways.

Counsel:  Shaw Pittman, Robert Cohn, 202.663.8060

The City of Houston and the Greater Houston Partnership respectfully file this reply in support of the application of Northwest Airlines to operate additional service to Turkey via Amsterdam in cooperation with its partner, KLM, and in support of the application of United Airlines to operate additional service to Turkey via Frankfurt in cooperation with its partner, Lufthansa. Both carriers would offer efficient nonstop-to-non stop connections to Houston. These services would benefit shippers and passengers from the Greater Houston area, as well as from the surrounding regions of the U.S., by expanding the air service options to Turkey.

Counsel:  Leftwich Douglas, Rebecca Taylor, 202.434.9100, rltaylor@ldpllc.com 

In considering the applications of the four incumbents in the U.S.-Turkey market, the Department should focus on maximizing U.S. flag competition in the U.S.-Turkey market. An allocation of seven frequencies each to Northwest and United will best accomplish this objective. Northwest and United each only operate seven weekly frequencies between the U.S. and Turkey, all via third-country code-sharing. American operates 15 weekly nonstop flights and Delta operates 7 weekly nonstop flights and 7 weekly third-country code-share services. Awarding Northwest and United seven additional frequencies each will enable all four U.S. flag incumbents to offer at least 14 weekly U.S.-Turkey roundtrip operations, thereby producing maximum competitive and service benefits in the U.S.-Turkey market.

Counsel:  Northwest, Megan Rae Rosia, 202.842.3193, megan.rosia@nwa.com  

All of the applicants in this proceeding are already offering some form of codeshare or direct service between the U.S. and Turkey. The issue before the Department is which of the proposals offered for use of the 14 newly available weekly third-country code-share frequencies will offer the most additional competitive benefits to consumers. United has demonstrated that its new service to Istanbul would offer more benefits than the similar new daily services to that city proposed by any other applicant. The other applicants concede that United's Istanbul service is either the best or second best among those proposed. With respect to service to points in Turkey other than Istanbul, United is the only carrier now proposing such service. Thus, United proposes daily same-day roundtrip connections between the U.S. and Ankara via Munich. These services would represent the first U.S. carrier online service between the U.S. and the second largest O&D market for U.S. traffic in Turkey. United should be awarded its full request for 14 weekly frequencies so that it can offer a second daily Istanbul service as well as the first U.S. carrier service to Ankara.

Counsel:  Wilmer Cutler, Jeffery Manley, 202.663.6670, jmanley@wilmer.com

U.S.- Turkey Combination Service Third-Country Code-Share Opportunities 

Enclosed for filing in the above-referenced docket are revised pages 6 and 7 and Exhibit UA-Rep.-2 of the Consolidated Reply of United Air Lines, Inc., which was filed on February 20, 2001. Copies of this letter and the enclosure have been served today upon all persons listed on the service list attached to United's application.

Counsel:  Wilmer Cutler, Jeffery Manley, 202.663.6670, jmanley@wilmer.com 

U.S.- Turkey Combination Service Third-Country Code-Share Opportunities 

Order 2001-5-4 tentatively selects Northwest Airlines, Inc., and United Air Lines, Inc., to serve Turkey under code-share arrangements with third-country carriers, and the order tentatively awards each carrier seven weekly frequencies to perform these services. Objections/Comments due May 17, 2001. Answers due May 22, 2001.

Based on our review of the proposals, we tentatively find that the selection of Northwest and United would provide the greatest overall benefits in this case. Northwest and United currently offer seven weekly frequencies in the U.S.-Istanbul market via intermediate points in Europe in conjunction with their third-country code-share partners, KLM and Lufthansa, respectively. We also tentatively conclude that, given the current structure of the market, an award of all the frequencies to United would not best advance our goal to promote competition and afford the public the widest range of competitive services from all of the carriers serving the market. American and Delta operate at least twice-daily service between the United States and Istanbul. Additional awards to Northwest and United, therefore, would afford the public more competitive service options from all of the carriers serving the market. Moreover, an additional award to Northwest would enable the carrier to improve on-line services in the market. Northwest offers on-line connecting service to 14 U.S. cities, throughout the United States, but not all of the cities now receive same-day round-trip connecting services, since they can connect to only one flight between Amsterdam and Istanbul. For example, four U.S. cities (Los Angeles, Miami, Memphis and San Francisco) receive same-day service in only one direction. An additional award to Northwest would enable the carrier to provide same-day round-trip service to all 14 U.S. cities, as there would be two KLM flights with which Northwest's flights between the United States and Amsterdam could connect.

By:  Susan McDermott

U.S.- Turkey Combination Service Third-Country Code-Share Opportunities 

An examination of Northwest's service proposal shows that it would offer new roundtrip service to only two U.S. gateways, Detroit and New York (JFK), and even that service would not be competitively effective, that is, allow for connections in both directions within a six-hour window at Amsterdam. This is because Northwest is proposing to connect to a later KLM flight from Amsterdam to Istanbul, while its present codesharing service to Turkey, based on last year's award, uses an earlier KLM flight that already maximizes its connecting opportunities. American, on the other hand, proposes to introduce new round-trip service with Swissair to 10 U.S. gateways, or five times the number Northwest would serve.

American's proposal will better serve 80 times more passengers than Northwest's, as detailed in Exhibit AA-A5 to American's Answer of February 15, 2001. American will have the best roundtrip elapsed times in nine markets, accounting for 275,823 passenger bookings for the year ended December 31, 2000. Northwest would have the best roundtrip elapsed times in one market, accounting for just 3,469.

The Department's discussion of United's proposal completely ignores the fact that United failed to implement the service it proposed in last year's proceeding. Instead, the Department gives United credit for new roundtrip service to 10 U.S. cities, even though United told the Department it would use last year's award to provide that same service, but never did so.

In our reply of February 20, 2001, we reproduced in Exhibit AA-R2 the proposal United made in U.S.-Turkey Combination Service Third-Country Codeshare Opportunities, OST-007148, submitted by United on April 14, 2000. There, United showed that it would connect in Frankfurt in the westbound direction from LH3403, Lufthansa’s early morning flight that arrives in Frankfurt from Istanbul at 8:05 a.m., in time for onward connections to 15 U.S. cities.

Yet this is the same proposal that United has now made in its application in the current proceeding on February 8, 2001. United never implemented westbound connections from LH3403, but instead is using LH3451, a late afternoon arrival in Frankfurt that misconnects to most of United's and Lufthansa’s U.S. gateways. United defaulted on the proposal that resulted in its initial allocation of frequencies in Order 2000-8-17, August 18, 2000, and yet the Department is now proposing to give United credit for adding new roundtrip service to 10 U.S. gateways.

United should not be rewarded for such behavior with a second allocation of U.S.-Turkey third-country codesharing frequencies. United could immediately remedy the woeful shortcomings of its present service by implementing what it proposed in the first place, that is, westbound connections at Frankfurt from Lufthansa’s early morning arrival from Istanbul For the Department to give United a free pass for such bait and-switch tactics,' as proposed by Order 2001-5-4, would be bad public policy, would compromise the integrity of the Department's selection process, and would ill-serve the public interest in maximizing competitive options in limited-entry markets.

Counsel:  American, Carl Nelson, 202-496-5647, carl_nelson@aa.com 

Delta Air Lines, Inc. hereby objects to Order 2001-5-4, which tentatively selected United and Northwest to receive additional Turkey codeshare frequencies. Delta is disappointed with the Department's decision, which fails to maximize the public benefits of the limited codeshare frequencies during the transitional phase of the U.S.-Turkey bilateral agreement. Delta's proposal was substantially superior to Northwest's in terms of service benefits, and United should not receive a second Turkey award for the same service it proposed, but failed to implement in the last Turkey case.

Northwest's third-country proposal was the weakest. Delta ranked far ahead of Northwest in terms of elapsed time comparison and the overall value of connecting opportunities. Indeed, Delta would have provided superior eastbound travel times for eight commonly served U.S.-Turkey city-pairs. DL R-3. Delta's proposed third-country connections would have been particularly beneficial for the large west coast cities of Los Angeles and San Francisco, which, under existing schedules, do not receive viable same-day third-country connections on either Delta or Northwest. Delta's proposed eastbound travel time from Los Angeles was 3 hours and 20 minutes faster than Northwest, and from San Francisco was 2 hours and 50 minutes faster than Northwest. DL-R 4. Furthermore, only Delta would have created attractive new same-day round trip connections for Los Angeles. DL-1, NW-1.

United has made ineffective use of its existing Turkey codeshare frequencies - by failing to implement the schedule it proposed in the last case - and should not be awarded new frequencies for the same proposal here. Furthermore, the Show Cause Order gives United the option to use its award for either Istanbul or Ankara service. Ankara generates just 50,000 U.S. O&D passengers to Istanbul's 430,000. DL-R-1. It is not in the public interest to authorize United's service to a tiny secondary point in Turkey at the expense of Delta's Istanbul proposal.

Counsel:  Shaw Pittman, Alexander Van der Bellen, 202.663.8060

U.S.- Turkey Combination Service Third-Country Code-Share Opportunities 

Neither of the objecting parties has provided any new arguments or evidence that would compel the Department to modify its tentative decision. Indeed, the objecting parties have merely reiterated arguments already raised and fully considered in the SCO. As in the recent U.S.-Israel Third-Country Code-Sharing Opportunities, Docket OST-2001-8726, the Department should proceed promptly to a Final Order affirming its tentative allocations.

The Department in its SCO tentatively selected Northwest and United to serve Turkey under their respective third-country codeshare arrangements with KLM and Lufthansa, and allocated seven frequencies to each. The Department correctly concluded that this selection would provide the greatest overall benefits in the case. The Department's tentative allocation will enable Northwest and United to improve their currently available online services between the U.S. and Turkey and maximize the competitive service options from all carriers serving the market. Delta and American already offer at least twice the level of U.S.-Turkey service now provided by Northwest and United. Unlike the proposals of Northwest and United, in neither case would the proposed expanded services of American and Delta offer superior connections to those now offered by the carriers on their existing services. The Department's tentative allocation of seven frequencies each to Northwest and KLM will best advance the Department's goal to promote competition and afford the public the widest range of competitive services from all the carriers serving the market.

Counsel:  Northwest, Megan Rae Rosia, 202.842.3193, megan.rosia@nwa.com 

United had requested an allocation of 14 weekly frequencies so that it could add a second daily flight to Istanbul and introduce daily service to Ankara in conjunction with Lufthansa. Although disappointed that it will not be able to deliver all of the public benefits that its proposal offered, United has opted not to object to the Department's tentative decision. Instead, United will use its proposed allocation of seven frequencies to introduce immediately daily service to Ankara, and will seek a further seven frequencies next year so that it can add a second daily service to Istanbul at that time. In the meantime, United will continue using its existing allocation of seven frequencies to provide the optimal available connections to Istanbul.

United urges the Department to finalize its tentative decision as quickly as possible. Time is of the essence because, unless a final order is issued promptly, United may be prevented from offering its new Ankara service to passengers traveling during the peak summer season. Although a delay in issuing a final order would benefit American and Delta by protecting their existing competitive advantage, American and Delta have failed to cite any error in the Department's tentative decision warranting such a delay. Thus, the Department should expedite its final order so that the public benefits of United's service may be realized as soon as possible.

Counsel:  Wilmer Cutler, Jeffery Manley, 202.663.6670, jmanley@wilmer.com

U.S.- Turkey Combination Service Third-Country Code-Share Opportunities 

American Airlines, Inc. hereby moves for leave to file this response to the answer submitted by United Air Lines, Inc. on May 22, 2001 to American's objections to show-cause Order 2001-5-4. American's response should be accepted in the interest of a complete record for the Department's consideration.  In our objections, we demonstrated that United failed to implement its codesharing proposal with Lufthansa, via Frankfurt, that was the basis for the Department's award to United of first-round authority in last year's proceeding, Order 2000-8-17, August 18, 2000. Instead of publishing westbound connections to Lufthansa's early morning arrival in Frankfurt from Istanbul, United is using a late afternoon Lufthansa arrival that misconnects to most of United's and Lufthansa's departures from Frankfurt to the U.S.

Counsel:  American, Carl Nelson, 202-496-5647, carl_nelson@aa.com 

U.S.- Turkey Combination Service Third-Country Code-Share Opportunities 

United Air Lines, Inc., ("United") hereby submits this Rejoinder to the unauthorized Response of American Airlines, Inc. ("American"), in which American restates its objection to the Department's tentative decision in Order 2001-5-4 to award seven weekly U.S.-Turkey third-country code-share frequencies to United.  The interim restrictions on third-country code sharing established under the U.S.- Turkey bilateral agreement are a protectionist measure specifically designed to shield American's partner, Turkish Airlines ("Turkish"), from competition. American enjoys the benefit of that protection through its unrestricted bilateral code-share arrangement with Turkish. If that competitive barrier did not exist, United would code share on all three of Lufthansa's Istanbul flights as well as Lufthansa's flights to Ankara and Izmir. Instead, United and other U.S. carriers must closely limit the markets and schedules where their allocated frequencies will create the maximum benefit. United has done just that over the past year by utilizing connections that offer the best service to its two major international hubs -- Chicago and Washington Dulles -- and strong passenger bookings attest to the merit of United's approach.

Counsel:  Wilmer Cutler, Jeffery Manley, 202.663.6670, jmanley@wilmer.com

U.S.- Turkey Combination Service Third-Country Code-Share Opportunities 

Final Order 2001-6-11 makes final the tentative decision in Order 2001-5-4 to select Northwest Airlines, Inc., and United Air Lines,, Inc., to serve Turkey, under code-share arrangements with their respective third-country code-share partners, and to award each carrier seven weekly frequencies to perform its service.

By:  Susan McDermott

U.S.- Turkey Combination Service Third-Country Code-Share Opportunities 

As of today, September 7, 2001, however, United has not received the necessary approvals from Turkey to start these new code-share services. The delay in receiving this approval has effectively cost United the ability to market these services in the peak summer season. This delay stands in sharp contrast to the Department's action in approving the reciprocal expansion of code-share services to the U.S. by Turkish Airlines ("THY"). THY filed a request on February 23, 2001 to expand its code-share services, and the Department approved that request on March 14, 2001, two weeks before the new frequencies became available under the bilateral agreement.

Counsel:  Wilmer Cutler, Jeffery Manley, 202.663.6670, jmanley@wilmer.com 

U.S.- Turkey Combination Service Third-Country Code-Share Opportunities 

Counsel:  Wilmer Cutler, Jeffery Manley, 202.663.6670, jmanley@wilmer.com 

U.S.- Turkey Combination Service Third-Country Code-Share Opportunities and United Air Lines, Inc.

Counsel:  Wilmer Cutler, Jeffery Manley, 202.663.6670, jmanley@wilmer.com 

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