OST-98-3441 / Northwest Airlines / New or Amended Certificate, US-Japan-Asia/Pacific / February 6, 1998

NOTICE: Any person may support oppose this application by filing an answer and serving a copy of the answer on counsel for Northwest Airlines, Inc., and upon persons served with this application, no later than March 6, 1998.

In re Application of

NORTHWEST AIRLINES, INC. / OST-98-3441

for a New or Amended Certificate of Public Convenience and Necessity Authorizing Scheduled Foreign Transportation of Persons, Property and Mail (U.S.-Japan-Asia/Pacific)

Pursuant to 49 U.S.C. §§ 41108 and 41102 and Subpart Q of the Department's Rules of Practice, Northwest Airlines, Inc. ("Northwest") hereby requests issuance of a new certificate of public convenience and necessity, or an amended certificate of public convenience and necessity for Route 129, authorizing Northwest to provide scheduled foreign air transportation of: (a) persons, property and mail between a point or points in the United States, on the one hand, and a point or points in Japan, on the other, via a point or points in the countries listed in Attachment A hereto, and beyond Japan to a point or points in the countries listed in Attachment A hereto; and (b) property and mail between a point or points in the United States, on the one hand, and a point or points in Japan, on the other, via any intermediate point or points and beyond Japan to any

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point or points. Northwest asks the Department to process this application expeditiously under Subpart Q through the use of non-oral procedures.

In support of this application, Northwest states as follows:

1. On January 30, 1998, the United States and Japan signed a Memorandum of Consultations ("MOC") providing for an expansion of U.S. and Japanese carrier operating rights. Among other things, the incumbent U.S. carriers, including Northwest, secured the immediate right to operate combination services between any point or points behind the United States, any point or points in the United States, any intermediate point or points, any point or points in Japan, and any point or points beyond Japan. Fifth freedom traffic rights beyond Japan are subject to certain traffic composition requirements, which vary according to the International Air Transport Association ("IATA") region to which the flight is being operated.

2. In the same agreement, the incumbent U.S. airlines obtained the right to operate all-cargo services between any point or points behind the United States, any point or points in the United States, any intermediate point or points, any point or points in Japan, and any point or

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points beyond Japan. There are no traffic composition formulae for incumbent all-cargo services.

3. Northwest already has extensive Japan and beyond-Japan certificate and exemption authority. It wishes, however, to ensure that in the future it has maximum flexibility to add and alter services to, from and beyond Japan. Initially, Northwest expects to exercise its expanded rights in connection with services to and from Asia and the Pacific, as defined in the U.S.-Japan MOC by reference to IATA Traffic Conference Area TC3, where fifth freedom traffic composition requirements are not as restrictive as traffic composition requirements for Europe and Africa services. Accordingly, Northwest is applying herein for broad authority to operate scheduled combination services beyond Japan to a point or points in Asia and the Pacific, as delineated in Attachment A hereto, which lists the countries currently included in IATA Traffic Conference Area TC3. Northwest also wishes to be able to serve Japan via those points and is requesting inclusion of such authority.

4. In addition, Northwest seeks broad flexibility to operate freighter service to and from Japan. Accordingly, it seeks authority to carry property and mail between the

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United States and Japan, via any intermediate point or points and beyond Japan to any point or points.

5. Northwest's current transpacific authority is contained in its certificate of public convenience and necessity for Route 129. The authority sought herein can be included in that certificate as a new route segment or segments. Alternatively, the Department can issue Northwest a new U.S.-Japan-beyond certificate.

6. Northwest is a corporation organized under the laws of the State of Minnesota with its principal offices located at 5101 Northwest Drive, St. Paul, MN 55111-3034.

7. Northwest is a citizen of the United States within the meaning of 49 U.S.C. § 40102(15)(C).

8. Northwest is well-qualified to serve the route for which it seeks authority. The Department has repeatedly found Northwest fit, willing and able to provide scheduled foreign air transportation of persons, property and mail.

9. The use of expedited, non-oral procedures under Subpart Q is clearly warranted. The issues are straight-forward /l and the Department already has concluded that this

1/ The award of the authority sought herein will not conflict with limitations contained in bilateral agreements between the United States and countries in IATA Traffic Conference Area TC3. Northwest will be bound by those restrictions because this certificate, like other certificates issued by the Department, presumably will include a condition requiring any service to be consistent with all applicable agreements between the United States and the foreign countries involved.

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type of application is ripe for expedited treatment. In its February 3, 1998 notice inviting U.S.-Japan applications, the Department stated:

Notice at 2 (emphasis added).

WHEREFORE, Northwest Airlines, Inc. respectfully requests issuance of a new certificate of public convenience and necessity, or an amended certificate of public convenience and necessity for Route 129, to engage in scheduled air transportation of: (a) persons, property and mail between a point or points in the United States, on the one hand, and a point or points in Japan, on the other, via a point or points in the countries listed in Attachment A hereto, and beyond Japan to a point or points in the countries listed in Attachment A hereto; and (b) property and mail between a point or points in the United States, on

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the one hand, and a point or points in Japan, on the other, via any intermediate point or points and beyond Japan to any point or points, as well as such other and different relief as may be necessary and proper.

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

February 6, 1998