OST-96-990 (49317) / Northwest / Sierra Leone/Tanzania/Zimbabwe / January 6, 1998

NOTICE: Answers supporting or opposing this application are due on or before Wednesday, January 21, 1998.

Application of :

for an exemption pursuant to 49 U.S.C. § 40109

(U.S.-sierra Leone/Tanzania/Zimbabwe)

Northwest Airlines, Inc. ("Northwest"), pursuant to 49 U.S.C. Section 40109 (formerly Section 416(b) of the Federal Aviation Act of 1958) and 14 C.F.R. Section 302.400 et seq., hereby requests renewal of its exemption from 49 U.S.C. Section 41101, last renewed for a two-year period by Order 96-3-17, to permit Northwest to provide scheduled service between, on the one hand, points in the United States and, on the other hand, the following African points: Freetown, Sierra Leone; Kilimanjaro and Dar es Salaam, Tanzania; and Harare, Zimbabwe. /1 Northwest proposes to serve these markets via Amsterdam pursuant to its code-share arrangement with KLM Royal Dutch Airlines ("KLM") under which KLM will operate the aircraft on segments beyond

1/ By Order 96-3-17, the Department also renewed Northwest's exemption authority to provide code-share service, in conjunction with KLM via Amsterdam, between the United States and the following additional African points: Conakry, Guinea; Tunis, Tunisia; and Lilongwe, Malawi. Northwest is not seeking renewal of its exemption authority to serve Conakry, Tunis, or Lilongwe as KLM no longer operates its own aircraft between Amsterdam and these African cities.

Amsterdam. Northwest requests that the exemption be renewed for a period of two years. /2

In support of this application, Northwest submits the following:

1. Northwest seeks renewal of its authority to engage in the transportation of persons, property and mail in foreign air transportation between points in the United States, and the following points in Africa, via Amsterdam: Freetown, Sierra Leone; Kilimanjaro and Dar es Salaam, Tanzania; and Harare, Zimbabwe. Northwest proposes to serve these markets via Amsterdam pursuant to its code-share arrangement with KLM under which KLM will operate aircraft on each of the segments beyond Amsterdam. /3

2. There are no air transport agreements between the United States, on the one hand, and the countries of Sierra Leone, Tanzania and Zimbabwe, on the other hand. When the Department originally granted Northwest and KLM authority to offer codeshare services to these countries, however, it found the proposed services to be consistent with the overall aviation relationship between the United States and each country. Northwest is aware

2/ In submitting this renewal application, Northwest invokes the automatic extension provisions of the Administrative Procedure Act, 5 U.S.C. 558(c), as implemented in Part 377 of the Department's Rules.

3/ To the extent necessary, Northwest requests a waiver of the requirement to submit illustrative service data given the nature of the services proposed in this application.

of no intervening events which should alter the Department's original findings.

3. Neither Northwest nor KLM presently serves Sierra Leone. Northwest received approval from the Government of Sierra Leone for the proposed code-share services in the Summer of 1994 and implemented service on February 17, 1996. KLM and Northwest subsequently suspended service, however, due to the civil unrest which developed in Sierra Leone. Unfortunately the civil unrest in that country persists today. Northwest nevertheless seeks renewal of its exemption authority to provide code-share service in the U.S.-Freetown market so that Northwest is positioned to promptly re-enter that market in the event circumstances improve.

4. To date, Northwest has been unable to implement service to Kilimanjaro and Dar es Salaam, Tanzania, due to the Government of Tanzania's refusal to authorize the proposed code-share service. Northwest and KLM, however, intend to continue their attempts to persuade the Government of Tanzania to authorize the proposed code-share service. Northwest therefore seeks renewal of its underlying exemption authority so that Northwest will be in a position to promptly implement U.S.-Tanzania code-share service in the event the Government of Tanzania changes its position and approves the proposed code-share service. Some of KLM's Amsterdam-Dar es Salaam flights may operate via Kilimanjaro and other of KLM's Amsterdam-Dar es Salaam flights may operate via Nairobi. Northwest does not seek traffic rights between Kilimanjaro and Dar es Salaam, nor does Northwest seek traffic rights between Nairobi and Dar es Salaam.

5. Northwest has been providing code-share service between the United States and Harare, Zimbabwe, via Amsterdam, since October 14, 1995. KLM's Amsterdam-Harare service presently operates via Johannesburg. Northwest does not seek traffic rights between Johannesburg and Harare.

6. Renewal of Northwest's application to serve the above referenced markets clearly is in the public interest. Northwest's code-share service will provide important consumer benefits in the form of new and expanded service options through seamless online service between each of the African points covered by this application and nearly 200 points Northwest serves throughout the United States. At present, no U.S.-flag carrier provides direct service to any of the African countries covered herein. The proposed Northwest/KLM code-share services are an important first step towards accomplishing Department of Transportation Secretary Rodney E. Slater's initiative to increase air transport between the United States and Africa.

7. The flights that are the subject of this renewal application will be listed under both the KLM and Northwest designator codes pursuant to all government regulations and the parties will comply with all requirements for code-share operations set forth in 15 C.F.R. § 399.88. As required by the Department, the parties agree that the carrier selling the transportation service will accept all obligations established in its contract of carriage with its passengers for the entire through service. In addition, Northwest's designator code will not be displayed on any flight that enters, departs, or transits the airspace of any area for whose airspace the Federal Aviation Administration has issued a flight prohibition.

8. In response to the Department's letter of June 1, 1995 to participants in the Civil Reserve Air Fleet Program ("CRAF"), Northwest hereby states that the code-share arrangement covered by this application should have no impact on Northwest's CRAF commitments.

WHEREFORE, Northwest Airlines, Inc. requests that the Department renew Northwest's aforementioned exemption from 49 U.S.C. Section 41101 authorizing Northwest to provide code-share service, in conjunction with KLM via Amsterdam, in the U.S.-Sierra Leone, U.S.-Tanzania and U.S.-Zimbabwe markets. Northwest asks that its renewed exemption continue in effect for a two-year period.

Respectfully submitted,

Megan Rae Poldy

Associate General Counsel

NORTHWEST AIRLINES, INC.

901 15th Street, N.W.

Suite 310

Washington, D.C. 20005

(202) 842-3193

January 6, 1998