A DE LTA ^ m CFJh-TOMWiCN Alexander Van der Bellen 

Managing Director and 

Associate General Counsel 

Delta Air Lines, Inc. 

1212 New York Avenue NW 

Washington, DC 20005 

202.842.4184 

sascha.vanderbellen@delta.com 

February 24, 2010 

Ms. Dorothy Beard 

Chief, Docket Operations, iVI-SO 

U.S. Department of Transportation 

West Building Ground Floor, Room W12-140 

1200 New Jersey Ave, SE 

Washington, DC 20590 

Re: DeltaA^irgin Blue Group Antitrust Immunity Application 

Docket DOT-OST-2009-0155 

Dear Ms. Beard: 

Delta and the Virgin Blue parties are submitting data revised to include taxes and fees in 

response to Order 2009-11-20 (data question 2). Additional detail on the Joint Applicants' 

proration methodologies is provided at Attachment A to this letter. 

The Joint Applicants request confidential treatment for this data. The parties adopt and 

incorporate by reference their Rule 12 motion, filed on January 15, 2010, which covers this and 

all materials submitted in response to Order 2009-11-20. 

This data is being submitted in a sealed envelope marked "Confidential Treatment Requested 

under § 302.12." Access is restricted to counsel and outside experts who have filed valid 

confidentiality affidavits. 

Respectfully submitted. 

<:^^ . 

Alexander Van der Bellen 

cc: Anita Mosner, esq. 

Sophy Chen, esq. 

Counsel to the Virgin Blue Parties 

Service List 
Attachment A 

Supplemental Information Regarding Proration Methodology 

Delta 

For Delta's data production, proration is based on the methodologies used by Delta's 

Revenue Pipeline group in the ordinary course of business. The base fare of the ticket, 

commissions, and fuel surcharges are prorated across the coupons of each farebreak 

within a ticket based on proration methodologies that vary with the airlines involved. 

Delta-only international itineraries are prorated using a weighted miles based formula 

designed to give more credit to shorter haul segments as compared to a straight-rate 

mileage prorate. For itineraries that include other airlines (ticketed, marketed, or 

operated). Special Prorate Agreements (SPAs) between the carriers or industry 

proration rules apply. Factors such as the carriers involved, the geography of the 

passenger's journey, and travel and ticket issue dates can be included within each SPA. 

Delta sends all itineraries involving other airlines to a 3rd party proration system to apply 

SPAs or industry proration rules. Taxes and fees are not a part of the base fare, and are 

therefore not included in the proration methodologies that Delta uses in the ordinary 

course of business. However, to comply with the Department's requirement that the 

fare amounts reported in this data production include taxes and fees. Delta has allocated 

ticket level taxes and fees to O&Ds in proportion to each O&D's share of total ticket 

revenue. 

Virgin Blue 

Pro-rate for assigning market directional fare 

All V Australia full itinerary fares are the combination of two separate one-way directional 

base fares, to which applicable taxes, fees and fuel surcharges are added. As a 

consequence, no issue arises for the pro-ration assignment of market directional fares 

for the base fare component. Fuel surcharges only apply to the trans-Pacific legs of an 

itinerary and are symmetrical in each direction. Other taxes and fees have been prorated in proportion to the directional market fare. 

Fares for the behind or beyond legs of trans-Pacific itineraries, either reflect: 

- special fixed rate pro-rates with partner airlines or Virgin Blue in Australia, if the ticket 

has been booked as a through ticket on V Australia; or 

- actual fares for additional sectors flown on other airlines, where the ticket has not been 

booked as a through fare on V Australia. 
CERTIFICATE OF SERVICE 

A copy of the foregoing Document has been served this 24* day of February, 2010, 

upon the following persons via email: 

Marshall S. Sinick 

Counsel for Alaska Airlines 

msinick@ssd.com 

Carl B. Nelson Jr. 

Associate General Counsel 

American Airlines Inc. 

carl.nelson@aa.com 

John L. Richardson 

Counsel for Amerijet International 

jrichardson@johnlrichardson.com 

Angeline Bird 

Sandra Lunsford 

Federal Express Corporation 

anbird@fedex.com 

sllunsford@fedex.com 

Mark Atwood 

Counsel for Kalitta Air 

matwood@sherblackwell.com 

Thomas V. Lydon 

Kelli Bryan 

Evergreen International Airlines, Inc. 

tom.lydon@evergreen.com 

charters@evergreenairlines.com 

Russell E. Pommer 

Associate General Counsel & Director of 

Regulatory Affairs 

Atlas Air, Inc. 

rpommer@atlasair.com 

Kevin P. Montgomery 

Polar Air Cargo, Inc. 

kevin.montgomery@polaraircargo.com 

Lawrence D. Wasko 

ldwasko@starpower.net 

Counsel for Arrow Air, Inc. 

Stephen Lachter 

lachter@starpower. net 

Counsel for ASTAR Air Cargo, Inc. 

Howard Kass 

Benjamin T. Slocum 

US Airways 

howard_kass@usairways.com 

benjamin.slocum@usairways.com 

David L. Vaughan 

Danielle Fisher 

Counsel for United Parcel Service 

dvaughan@kellydrye.com 

dfisher@kelleydrye.com 

Hershel Kamen 

Dan Weiss 

Continental Airlines 

hkamen@coair.com 

dan.weiss@coair.com 

Jeffrey A. Manley 

Julie Oettinger 

United Airlines 

jeffrey.manley@united.com 

julie.oettinger@united.com 

Mark McMillin 

Assistant General Counsel 

World Airways Inc. 

mcmillin@woa.com 

Malcolm Benge 

mlbenge@zsrlaw.com 

Counsel for World Airways Inc. 

Jonathan B. Hill 

jhill@dlalaw.com 

Counsel for Hawaiian Airlines, Inc 
John Byerly 

Deputy Assistant Secretary for Transportation Affairs 

U.S. Department of State 

byerlyjr@state.gov 

John Allen 

Federal Aviation Administration 

john.allen@faa.gov 

Todd Homan 

Peter Irvine 

Christopher Mandel 

U.S. Department of Transportation 

todd.homan@dot.gov 

peter.irvine@dot.gov 

christopher.mandel@dot.gov 

Jill Ptacek 

U.S. Department of Justice 

Jill.Ptacek@usdoj.gov