BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C. Joint Application of Virgin Atlantic Airways, Ltd. Delta Air Lines, Inc. Société Air France Koninklijke Luchtvaart Maatschappij N.V. Alitalia Compagnia Aerea Italiana S.p.A Under 49 U.S.C. §§ 41308 and 41309 for Approval of and Antitrust Immunity for Alliance Agreements ) ) ) ) ) ) ) ) ) ) ) ) ) Docket DOT-OST-2013-0068

ANSWER OF WAYNE COUNTY AIRPORT AUTHORITY IN SUPPORT OF DELTA AND VIRGIN ATLANTIC

Communications with respect to this document should be addressed to:

Joe Cambron Director, Air Service Development Thomas Naughton Chief Executive Officer Emily Neuberger Senior Vice President

WAYNE COUNTY AIRPORT AUTHORITY L.C. Smith Terminal Detroit, Michigan 48242 (734) 942-3550

June 4, 2013BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

Joint Application of Virgin Atlantic Airways, Ltd. Delta Air Lines, Inc. Société Air France Koninklijke Luchtvaart Maatschappij N.V. Alitalia Compagnia Aerea Italiana S.p.A Under 49 U.S.C. §§ 41308 and 41309 for Approval of and Antitrust Immunity for Alliance Agreements ) ) ) ) ) ) ) ) ) ) ) ) ) Docket DOT-OST-2013-0068

ANSWER OF WAYNE COUNTY AIRPORT AUTHORITY IN SUPPORT OF DELTA AND VIRGIN ATLANTIC

Detroit Metropolitan Airport (DTW) fully supports Delta Air Lines' request for antitrust immunity (ATI) with Virgin Atlantic Airways. Detroit is a major hub for Delta. Delta and its partners currently offer eight daily nonstop transatlantic flights to five European destinations, including London Heathrow Airport (LHR). Through the joint venture with Virgin Atlantic, Delta will gain an important new marketing partner in the U.K., and, for its part, Virgin will gain access to Delta’s North American network, including the large array of U.S., Canadian, and Mexico destinations served by Delta from Detroit. The joint venture will strengthen DTW as a gateway to London, and, in particular, will enhance intergateway competition with Chicago, where AA/BA operate a combined six daily LHR flights. Gaining additional access to Europe is a high priority for the Wayne County Airport Authority (WCAA) as it seeks to expand inter national services from DTW. According to Sabre MIDT data for 2012, the U.K. is the second largest European market for Detroit.Answer of WCAA Page 2 We believe that DTW can readily support a second daily LHR flight, and that the joint venture with Virgin Atlantic makes it more likely that Delta will be able to introduce such service in the future. Delta has indicated in its ATI application that “a second daily flight

from Delta’s Detroit hub to Heathrow would be a high priority.” (ATI Application at 29). The increased scope and scale of the Delta/Virgin Atlantic joint venture, together with a larger combined slot portfolio, make it more likely that the joint venture will increase LHR service at DTW, where neither carrier is able to do so individually today. Auto Industry Ties Michigan firms need access to global markets, and London is one of the top business destinations in Europe. The American auto industry is centered in Detroit with headquarters for General Motors, Ford, and Chrysler/FIAT. Research and engineering locations for many other worldwide auto brands dot the surrounding area, including: Toyota, Hyundai, Kia, Ilmor Engineering, and others. Ilmor is a great example of the business ties between Detroit and the U.K. The company, acquired by American auto magnate Roger Penske in 2005, is based near London, but operates a large facility near Detroit. The company, among other things, supplies engines for Indycar racing under a General Motors badge and won 11 of 15 races in the series last year en route to the manufacturer’s championship for the iconic American brand - Chevrolet. In fact, the U.K. is the site of many automotive firms and the center of the European auto racing industry. U.S. manufacturers and their parts supplie rs participate heavily in that development process and many advances in technology have come from U.S. involvement in auto racing research and development. For exampl e, most modern transmissions can trace their development back to auto racing including: clutchless transmissions, continuousAnswer of WCAA Page 3 variable transmissions, and direct-shift transmissions. The tread pattern and material mix in tires was also largely developed from auto racing engineering as well as numerous other advancements. Easily connecting U.S. engineers to this hotbed of auto innovation allows U.S. companies to maintain a level of involvement in the process as a stakeholder, preventing our companies and manuf acturers from becoming locked out of important advancements through the patent process. Detroit Metro Airport In 2010 DTW was ranked #1 for customer satisfaction among airports of its size by a prestigious quality rating firm and last year served over 32 million travelers. With more than 1,100 flights to 150 destinations it is im portant for Detroit to continually expand its array of travel options both for local travelers and for those passengers connecting through Detroit. The WCAA has invested heavily in the airport with six runways, two new terminals, and an onsite AAA Four-Diamond Westin hotel. These investments make DTW a superior hub and worthy of the opportunity to see expanded services.

Conclusion We strongly believe that approving this request for ATI between Delta and Virgin Atlantic will result in improved service at Detr oit. The expanded North American-UK codeshare network offered by Delta and Virgin Atlantic from Detroit will provide immediate service and competitive benefit, and, as the joint venture is implemented, increased frequency on the DTW-LHR is a priority for the carriers. Each new long-haul flight from Detroit generates well over $100 million in annual economic value to Detroit and the State of Michigan according to our analysis. Those jobs and business ties help maintain Detroit’s position among the world’s automotive center s. Thus, we respectfully ask you approve this request.Answer of WCAA Page 4

Respectfully submitted,

_________________________________ Joe Cambron Director, Air Service Development, WAYNE COUNTY AIRPORT AUTHORITYCERTIFICATE OF SERVICE A copy of the foregoing Answer has been served this 4th day of June, 2013, upon the following persons via email:

francis.heil@aa.com robert.wirick@aa.com sascha.vanderbellen@delta.com howard.kass@usairways.com benjamin.slocum@usairways.com thomas.bolling@united.com dan.weiss@united.com todd.homan@dot.gov peter.irvine@dot.gov reese.davidson@dot.gov bob.goldner@dot.gov paul.gretch@dot.gov esta.rosenberg@dot.gov Jill.Ptacek@usdoj.gov urskr@state.gov Ishiwata.K@portseattle.org joe.cambron@wcaa.us brubinst@panynj.gov louis.miller@atlanta-airport.com steve.luben@atlanta-airport.com info@airlineinfo.com