BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

2013/2014 U.S.-Brazil Combination Frequency Allocation Proceeding ) ) ) ) ) ) ) Docket DOT-OST-2013-0072

ANSWER OF WAYNE COUNTY AIRPORT AUTHORITY IN SUPPORT OF DELTA AIR LINES, INC.

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

May 3, 2013BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

2013/2014 U.S.-Brazil Combination Frequency Allocation Proceeding ) ) ) ) ) ) ) Docket DOT-OST-2013-0072

ANSWER OF WAYNE COUNTY AIRPORT AUTHORITY IN SUPPORT OF DELTA AIR LINES, INC.

The Wayne County Airport Authority (“WCAA”) is extremely pleased with Delta’s Detroit-Sao Paulo service and respectfully ur ges the Department to award Delta seven frequencies for Detroit to ensure this important service continues without interruption. Since the service began in October of 2010, the local Detroit-Sao Paulo market has doubled from 12,863 passengers (in the year prior to service beginning) to 25,518 in the year ended March 2013 according to MIDT data. Detroit has also moved up from the

15 th largest U.S.-Sao Paulo market to the 14 th largest over that timeframe according to the same data. There are only three U.S. markets that are larger than Detroit that do not already have non-stop service to Brazil and none are involved in this proceeding. Over that same period of time, ticketed O&D revenue in the Detroit-Sao Paulo market has more than tripled from $12 million to $42 million. Maintaining ties between the two cities is also important to the U.S. auto industry as well as the regional economy in Detroit. Brazil is a key market for Detroit’s reinvigorated auto manufacturing industry, and that link has driven the steady growth on this route. At the point the service was originally announced, General Motors officials commented publicly that the new service would be a boon to further businessAnswer of WCAA Page 2 developmen t between Brazil and the United States and expressed the need for daily air service to support their routine business travel needs. GM is in a tight fight for market share in the Brazil market where they are third behind FIAT and Volkswagen, but all have roughly 20% of the auto market. GM’s share of South America auto sales as a whole is 18.5% and is an important growing market. GM’s sophisticated design center in Sao Paulo is part of a tightly connected global network and has responsibility for emerging markets which means that access to Detroit is key. GM’s Cruz Alta facility near Sao Paulo is the largest and most comprehensive proving ground in Latin America, and the second largest for GM at nearly 1,200 acres of testing roads, facilities, and protected forested land. The ties between Sao Paulo and Detroit now extend beyond business to such humanitarian efforts as cancer research. In fall 2012, the University of Michigan sent a delegation to Sao Paulo to facilitate research into adrenal cancer which afflicts a disproportionate number of Brazilians. That research could help determine causal factors for the disease and aid in a potential cure. The University of Michigan reached an agreement with the Sao Paulo Research Foundation to work together to fund the

research.

At the same time of the initial service announcement it was estimated that a daily

Detroit-Sao Paulo service would create approximately $150 million in economic impact and maintaining that economic growth engine is of vital importance to the Michigan

economy. A Key Link for the Recovering Auto Industry Detroit’s role at the center of the global auto industry has created extensive traffic flows to other auto production and design centers around the globe. GM’s Tech Center in Sao Paulo employs 8,000 people, including 1,300 engineers who routinely need toAnswer of WCAA Page 3

visit GM’’s four other Tech Centers around the world to fully coordinate numerous design projects. GM has its employment largely clustered around Sao Paulo. Ford also has four production plants in Brazil. GM has factory production facilities in Brazil at its Gravatai facility where it assembles two Chevrolet models, the São Caetano do Sul facility where three other models are produced, and the São Jose dos Campos factory which assembles trucks and cars. In 2012 GM opened a new engine plant in Brazil which features such green initiatives as solar power and reverse osmosis water processing.

Detroit is the Most Efficient and Customer Friendly Gateway

DTW’s McNamara Terminal offers state-of-the-art customer conveniences including an in-terminal passenger train to ease movement within the facility for passengers with tight connections. The McNamara Terminal opened in 2002 and was joined by the new North Terminal in 2008. DTW has vaulted to the upper echelon of American airports, and has been well reviewed by both passengers and consumer quality rating groups.

The Economic Benefit to Detroit The key issue for Detroit relates to economic impact and its effect of jobs. The WCAA estimates that Detroit-Sao Paulo service produces $150 million in annual economic benefits for the State of Michigan and approximately 300 direct jobs. Additionally, those jobs provide greater than average pay due to the high value nature of airline jobs. Indirectly, hundreds more jobs are fostered by tourism generated by the flight. Other Applications Maintaining Detroit-Sao Paulo service should be a high priority based solely upon the number of passengers now served by the existing service and the size of the localAnswer of WCAA Page 4 market. In the year ended March 2013, the Detroit-Sao Paulo O&D market had reported traffic of 25,518 passengers according to MIDT data. The Charlotte market was 72% smaller at only 7,268 passengers and the Philadelphia market was only 8,212 passengers, or 68% smaller. It is true that the Los Angeles and Chicago markets are larger, but in both cases the markets continue to be served by ongoing non-stop services that are unaffected by this proceeding and the newly allocated services would effectively be second services. Maintaining Detroit’s only non-stop service should be a higher priority.

Conclusion

The Detroit-Sao Paulo market is large and important to the auto industry as well as a broad spectrum of travelers number ing over 25,000 per year before connecting passengers are even considered. The route is key for Detroit’s economy and Michigan’s links to other important industry centers around the world. The economic value to Michigan exceeds $150 million and helps support many jobs important to our State. Detroit’s facilities and terminals are second to none and are routinely mentioned as among the most pleasant travel experiences in the country. The Detroit-Sao Paulo market is large enough to clearly justify service over the services proposed in the other applications. Based upon all of these factors we request Detroit receive allocation of sufficient frequencies to allow Delta to continue daily Detroit-Sao Paulo service.

Respectfully submitted,

_________________________________ Joe Cambron Director, Air Service Development,Answer of WCAA Page 5

WAYNE COUNTY AIRPORT AUTHORITYCERTIFICATE OF SERVICE A copy of the foregoing Answer has been served this 3rd day of May, 2013, upon the following persons via email:

Francis.Heil@aa.com Robert.Wirick@aa.com howard.kass@usairways.com benjamin.slocum@usairways.com dan.weiss@united.com thomas.bolling@united.com paul.gretch@dot.gov esta.rosenberg@dot.gov brian.hedberg@dot.gov brett.kruger@dot.gov urskr@state.gov brubinst@panynj.gov louis.miller@atlanta-airport.com steve.Luben@atlanta-airport.com sascha.vanderbellen@delta.com info@airlineinfo.com