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. ) ) ) ) ) ) ) ) ) ) Docket FAA

- 201 5

-

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
, 201 5BEFORE 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.) ) ) ) ) ) ) ) ) ) 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 FAA

2015

- 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 f or 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 furth er 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

n onstop 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 t o 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. Secon d, 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 (DC A) and Lansing, Michigan (LAN).