OST-96-1381 / Korean Air Lines / Exemption Seoul-Denver / September 3, 1997

Application of

for an exemption from 49 U.S.C. § 41301 (Seoul - Denver)

Pursuant to 49 U.S.C. § 40109 and Subpart D of the Department's Procedural Regulations, Korean Air Lines Co., Ltd. ("Korean Air" or "KAL") hereby requests amendment of its exemption from 49 U.S.C. § 41301 authorizing KAL to engage in scheduled foreign air transportation of persons, property and mail between Seoul, Korea and Denver, Colorado via Los Angeles, to permit KAL to operate the service via San Francisco in lieu of Los Angeles. In support of this Application, Korean Air respectfully states as follows:

1. By Notice of Action Taken dated June 27, 1996 (Order 96-8-46), the Department granted Korean Air an exemption under the Department's "Cities Program" to operate scheduled foreign air transportation of persons, property and mail between Seoul and Denver via Los Angeles. l/

l/ Korean Air's exemption was made effective for a period of one year. On June 25, 1997, Korean Air filed a renewal application, invoking the Administrative Procedures Act, 5 U.S.C. § 558(c), as implemented by 14 C.F.R. Part 377. Thus, Korean Air's authority remains in effect pending Department action on KAL's renewal application.

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2. Korean Air inaugurated its new service to Denver earlier this year, providing Denver's first nonstop or single plane service to Korea. By this application, Korean Air seeks to operate the service to Denver via San Francisco rather than Los Angeles.

3. Beginning October 26, 1997, KAL plans to operate three (3) flights per week between Seoul and Denver, via San Francisco, utilizing Boeing 747 and/or Boeing 747 Combo aircraft. KAL holds foreign air carrier permit authority to serve San Francisco (Order 95-4-36) and presently operates six (6) Boeing 747 flights per week between Seoul and San Francisco. Korean Air's proposed new routing would be a continuation of KAL's current service to San Francisco.

4. KAL's application remains consistent with the Department's "Cities Program" criteria, and it will provide important public benefits. In response to KAL's initial application to serve Denver, the City and County of Denver ("Denver") filed an answer affirming that Denver both needs and can support service to Seoul. Denver demonstrated that, despite its strong ties to South Korea and the abundant traffic support for the service, Denver lacked nonstop or single plane service to Korea. KAL's service fills this need and generates valuable

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benefits for businesses, travelers and shippers in the Intermountain West region. Approval of Korean Air's application to operate the Denver service via San Francisco will help ensure that the Denver community continues to receive these important benefits.

5. KAL is fit, willing and able to properly perform the services contemplated by this application. In so doing, KAL will accept and abide by all terms, limitations and conditions that the Department normally attaches to exemption authority for foreign air transportation.

WHEREFORE, Korean Air Lines Co., Ltd. respectfully requests an amendment of its exemption from 49 U.S.C. § 41301 authorizing KAL to engage in scheduled foreign air transportation of persons, property and mail between Seoul, Korea and Denver, Colorado via Los Angeles, to permit KAL to operate the service via San Francisco in lieu of Los Angeles. KAL further requests such different and additional relief as the Department may deem appropriate.

Respectfully submitted,

ZUCKERT, SCOUTT & RASENBERGER, L.L.P.

James L. Devall
William H. Callaway, Jr.
Cathleen P. Peterson
Counsel for Korean Air Lines Co., Ltd.

September 3, 1997