BEFORE THE

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, D.C.

Application of 

 DELTA AIR LINES, INC. 

For an exemption from 14 C.F.R. 93.123

(Lansing, Michigan – Washington D.C.) 

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Docket FAA-2015-

 

 

APPLICATION OF DELTA AIR LINES, INC. 

Communications with respect to this document should be addressed to:

Robert J. Cortelyou

Senior Vice President – Network Planning

Joe Esposito

Vice President Network Planning

DELTA AIR LINES, INC.

1030 Delta Boulevard

Atlanta, Georgia 30320

Alexander Van der Bellen

Managing Director – Regulatory 

and International Affairs & 

Associate General Counsel

Christopher Walker

Regional Director – Regulatory and 

International Affairs

DELTA AIR LINES, INC. 

1212 New York Avenue, N.W. 

Washington, D.C. 20005

(202) 842-4184

sascha.vanderbellen@delta.com

chris.walker@delta.com

September 15, 2015
BEFORE THE

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, D.C.

Application of 

 DELTA AIR LINES, INC. 

For an exemption from 14 C.F.R. 93.123

(Lansing, Michigan – Washington D.C.) 

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)

)

)

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)

Docket FAA-2015-

 

 

APPLICATION OF DELTA AIR LINES, INC. 

Delta Air Lines, Inc. (“Delta”), herby petitions for an exemption from 14 C.F.R. 

93.123 in order to provide nonstop DCA-Lansing service.1

 DCA-Lansing service is 

currently provided by Sun Country under FAA Exemption No. 10466. As explained in 

Delta’s contemporaneously filed Answer to the Petition of American in Docket FAA2015-3491, it is unclear whether the exemption relief granted by FAA to Sun Country as 

a new entrant at DCA is available to DCA incumbents. 

To the extent FAA is willing to consider such applications, Delta would be the 

superior public interest choice. Delta urges the FAA, in conjunction with DOT, to 

establish a carrier selection case for the allocation of this DCA capacity, should it be 

deemed available.

Delta is proud to serve Lansing and would welcome the opportunity to provide 

nonstop service to DCA. Unfortunately, due to its limited slot holdings Delta is already 

sub-optimized at DCA and cannot commence Lansing services without unacceptable 

harm to its current DCA network. Delta and its partners operate 49 daily departures at 

1 Delta requests that the exemption be issued to Delta Air Lines, Inc., but allow 

operations to be conducted by Shuttle America or any other carrier duly authorized to 

conduct “Delta Connection” service under the Delta brand. 

 
Application of Delta

Page 2

DCA, compared to 235 for American. As such, Delta is in much greater need of 

exemption authority than American if it is to provide Lansing with nonstop service.

Delta has a strong commitment to Lansing and currently operates 7 daily 

departures serving Minneapolis/St. Paul and Detroit. Delta is actively engaged with the 

Lansing community about the potential for further increased service offerings. Relief 

from the High Density Rule to add DCA service would complement Delta’s other service 

offerings.

Delta’s service proposal is as follows:

Aircraft

Embraer E-170 aircraft (operated by Shuttle America)

9 First Class, 12 Comfort+, 48 Main Cabin seats (69 total)

Schedule

LAN-DCA

0715-0845

DCA-LAN

1745-1920

Start Date

Start date within 60 days of receipt of exemption authority

Delta’s proposal provides well-timed services to meet the needs of DCA-Lansing 

travelers.2

 Importantly, unlike American, virtually 100 percent of Delta’s DCA-Lansing 

capacity will be dedicated to local passengers who reap the most important benefits of 

nonstop service. Lansing-DCA is an O&D route for Delta, whereas American operates 

DCA as a hub with its large portfolio of slots. This means that a substantial portion of 

2 Should the requested times not be available, Delta will work with FAA and make 

adjustments within its portfolio to facilitate the services. 

 
Application of Delta

Page 3

American’s capacity is wasted on transfer passengers that are largely indifferent to their 

connecting point.3

 

Accordingly, should the FAA be willing to entertain relief from the HDR rule at 

DCA, Delta requests exemption authority to provide nonstop service to Lansing. 

Respectfully submitted,

_________________________________

Alexander Van der Bellen

Managing Director – Regulatory and 

International Affairs & Associate General 

Counsel

DELTA AIR LINES, INC.

3 It is disingenuous for American to claim that “introduction of any service to LAN is 

contingent on receiving an exemption. American need to offer LAN passengers 

competitive options via its East and West connecting hubs.” AA application at n.5. First, 

American has the ability to fund DCA-Lansing service today if it was so inclined. 

Second, if American has the ability to serve Lansing from its larger, unconstrained East 

coast hub at Philadelphia. American’s attempt to hold Lansing service hostage to FAA 

exemption authority is without merit.

 
FEDERAL REGISTER SUMMARY

Petitioner: Delta Air Lines, Inc.

Rules from which relief is sought: 14 C.F.R. 93.123(a)

Description of Relief Sought: Delta Air Lines Inc. (“Delta”) requests relief from 14 C.F.R. 

93.123(a) to enable Delta or any of its duly authorized “Delta Connection” carriers to 

operate nonstop service between Washington (DCA) and Lansing, Michigan (LAN).