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, 2013 

 
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. 

The Wayne County Airport Authority (“WCAA”) is extremely pleased with Delta’s 

Detroit-Sao Paulo service and respectfully urges 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 

15th largest U.S.-Sao Paulo market to the 14th 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 business 
Answer of WCAA 

Page 2 

development 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 to 
Answer 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 local 
Answer 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 numbering 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 AUTHORITY 
CERTIFICATE 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