BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Application of

DELTA AIR LINES, INC.

for an exemption pursuant to

49 U.S.C. § 40109

(Los Angeles-Mexico City)

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Docket DOT-OST-2015-______

APPLICATION FOR AN EXEMPTION

Communications with respect to this document should be addressed to:

Robert J. Cortelyou

Senior Vice President – Network Planning

Joe Esposito 

Vice President – Network Planning Americas

Amy Martin

Director – Network Planning, Latin America

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

February 26, 2015
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Application of

DELTA AIR LINES, INC.

for an exemption pursuant to

49 U.S.C. § 40109

(Los Angeles-Mexico City)

)

)

)

)

)

)

)

)

)

)

Docket DOT-OST-2015-______

APPLICATION FOR AN EXEMPTION

Pursuant to 49 U.S.C. § 40109 and Subpart C of the Department’s Rules of 

Practice, Delta Air Lines, Inc. (“Delta”) hereby applies for an exemption from 49 U.S.C. § 

41101 authorizing Delta to engage in scheduled foreign air transportation of persons, 

property, and mail between Los Angeles (LAX) and Mexico City (MEX). Delta requests 

that this exemption be granted for at least a two-year period and that the approval be 

expedited to ensure that all necessary Mexican approvals can be obtained so marketing 

and sale can begin without delay. 

Alaska Airlines, Inc. (“Alaska”) and American Airlines, Inc. (“American”) recently 

informed the Department of their intent to transfer Alaska’s international route authority 

in this market to American. As explained in Delta’s Answer, a route case and public 

interest review are required. Delta proposes superior, year-round, 3x daily service on 

this route starting within 90 days of a Final Order awarding route authority. Delta will

utilize 160-seat Boeing 737-800 aircraft, equipped with 16 first class, 18 economy 

comfort class, and 126 economy class seats. Proposed Schedules and Operating 

Statistics are set forth in attached Exhibits DL-1 to DL-3. 
Delta Application

Page 2

A. Delta’s Proposal Offers Greater Consumer Benefits than American and 

Alaska

Delta’s planned service provides greater benefits to consumers than American 

and Alaska’s by increasing the number of daily flights in the market, beyond American’s 

plan of twice daily operations. This increase in service would result in over 25 percent 

more seats in the market compared to the daily service currently offered by Alaska. It 

would also increase U.S. carrier flights in the market by 100 percent. Delta is a new 

entrant in the Los Angeles-Mexico City route, without the ability to compete in the market 

with own-metal service.

These new services connect to Delta’s LAX hub that in 2015 offers more than 

150 daily flights to 60 destinations in a dozen different countries – more destinations 

than any other carrier. In the past two years Delta has invested hundreds of millions of 

dollars to improve the customer experience at its Los Angeles hub and remains 

committed to expand in the competitive Los Angeles market, offering new service to 

Shanghai, China; San Salvador, Salvador; Manzanillo, Mexico; Managua, Nicaragua; 

Austin, Texas; Boise, Idaho; London-Heathrow, U.K.; Monterrey, Mexico; San Antonio, 

Texas; Ixtapa, Mexico; Vancouver, Canada; Mazatlan, Mexico; and Dallas/Fort Worth, 

Texas. Delta also offers consumers superior long-haul international connections through 

0

50

100

150

200

250

300

350

DL Proposal AA/AS Proposal

Proposed Additional Daily Seats

50% More Seats Added
Delta Application

Page 3

LAX with more than twice the number of destinations outside of North America 

compared to American. 

B. Awarding Delta LAX-MEX Authority Would Enhance Network Carrier 

Competition

Delta built its Los Angeles hub in the last five years to compete with American 

and United Airlines, Inc. (“United”), offering consumers true three-way network carrier 

competition for the first time. Delta increased flights more than 69 percent, from 33,000 

to over 55,000 per year, enhancing customer choice to and from the Western United 

States’ largest market. Delta nearly doubled the number of destinations it served from 

LAX, going from 36 to 60 in this same five year span. 

Despite its growth, Delta is still unable to offer as many daily flights as 

entrenched carriers American and United from LAX, all while offering customers the 

most options in served destinations. American lauds itself on being the largest carrier 

and its growth in Los Angeles (AA and AS Joint Application, p. 5). However, as 

described above, Delta is more active in offering Angelenos new destinations and 

increased service. Instead of furthering the advantage that American enjoys by granting 

it additional restricted entry authority from Los Angeles, the Department would better 

30,000

35,000

40,000

45,000

50,000

55,000

60,000

2011 2012 2013 2014 2015

Delta LAX Annual Fligts
Delta Application

Page 4

serve the public interest by awarding Delta the authority to fly LAX-MEX, thereby 

increasing LAX-hub competition between network carriers.

In support of this Application, Delta states as follows:

1. The proposed service will provide significant benefits to travelers and 

shippers and is clearly in the public interest. The requested exemption authority is fully 

consistent with the terms of the U.S.-Mexico Air Transport Agreement (“Agreement”) as 

amended by the agreement signed by the two governments on December 12, 2005. 

Route 1(a) of the Agreement authorizes carriers designated by the U.S. to operate 

“[f]rom a point or points in the United States to a point or points in Mexico.” Annex 

I(A)(1)(a). Two U.S. carrier designations are authorized for this route. Agreement 

Annex I(B)(4-5). After Alaska ceases its service the Los Angeles-Mexico City route will 

have one designation available, with one already awarded to United. Delta requests that 

the Department promptly notify the Government of Mexico of Delta’s designation on this 

route.

2. Delta is a citizen of the United States within the meaning of 49 U.S.C. 

40102(a)(15)(C) and holds various certificates of public convenience and necessity and 

exemptions authorizing it to engage in scheduled foreign air transportation of persons, 

property and mail, including between the United States and Mexico. See, e.g., Delta’s 

Certificate for Route 901, issued by Order 2010-3-12. Pursuant to Rule 24 of the 

Department’s Rules of Practice, Delta asks the Department to take official notice of all 

data on file with the Department necessary to establish Delta’s fitness.

3. Delta affirms that its operation of these routes will have no impact on 

Delta’s Civil Reserve Air Fleet (“CRAF”) commitment.

4. The environmental impacts of Delta’s proposed services are de minimis, 

and Delta does not anticipate that the proposed services will cause a near-term net 

annual change in aircraft fuel consumption of 10 million gallons or more. 
Delta Application

Page 5

WHEREFORE, Delta requests issuance of exemption authority to engage in 

scheduled foreign air transportation of persons, property, and mail on the Los AngelesMexico City route. 

Respectfully submitted,

_____________________

Alexander Van der Bellen

Managing Director, Regulatory and 

International Affairs & Associate General 

Counsel

DELTA AIR LINES, INC.
Delta’s 3x Daily LAX – MEX Nonstop Service Offers 

Consumers an Attractive and Convenient Schedule

Year-round

Daily

Boeing 737-800

Frequency

Equipment

Daily

Boeing 737-800

DL343 0030

DL329 0945

DL337 1630

3:45 4:10

Los Angeles (LAX)

Mexico City (MEX)

Elapsed Time

GMT (-8)

GMT (-6)

Note: All times are local.

Exhibit DL-1

DL344 0830

DL330 1630

DL338 2000

DL343 0615

DL329 1530

DL337 2215

DL344 1040

DL330 1840

DL338 2210
Delta’s LAX – MEX 

Nonstop 3X Daily Service Proposal

Annual Operating Statistics

Aircraft

Departures

Segment Miles (sm)

Plane Miles (sm)

ASMs

Fuel Consumption (millions of gallons)

Boeing 737-800 

2,190

1,553

3,401,070

544,171,120

6.1

Statement on fuel availability: Delta anticipates no difficulty in obtaining fuel 

from suppliers at Los Angeles or Mexico City.

Exhibit DL-2
Delta’s Boeing 737-800 Seating Configuration

First Class

Economy Comfort Class

Economy Class

Total

16

18

126

160

Seating Configuration

Exhibit DL-3
CERTIFICATE OF SERVICE

A copy of the foregoing Application has been served this 26th day of February, 2015, 

upon the following persons via email:

Air Carrier Name Email Address

Alaska Airlines David Heffernan dheffernan@cozen.com

Alaska Airlines Marshall Sinick sandysinick@gmail.com

American Howard Kass howard.kass@aa.com

American Robert Wirick robert.wirick@aa.com

Frontier Mark Atwood matwood@cozen.com

Frontier Steve Lachter stephen.lachter@lachterlaw.com

Hawaiian/JetBlue Jonathan Hill jhill@cooley.com

Hawaiian/JetBlue Parker Erkmann perkmann@cooley.com

JetBlue Robert Land robert.land@jetblue.com

Republic Bob Cohn robert.cohn@hoganlovells.com

Republic Pat Rizzi patrick.rizzi@hoganlovells.com

Southwest/AirTran Bob Kneisley bob.kneisley@wnco.com

Southwest/AirTran Leslie Abbott leslie.abbott@wnco.com

Spirit Airlines David Kirstein dkirstein@yklaw.com

Spirit Airlines Joanne Young jyoung@yklaw.com

Sun Country John Fredericksen john.fredericksen@suncountry.com

Sun Country Thomas Ting thomas.ting@suncountry.com

United Dan Weiss dan.weiss@united.com

United Thomas Bolling thomas.bolling@united.com

Virgin America Barbara Russell barbara.russell@virginamerica.com

Brian Hedberg brian.hedberg@dot.gov

Robert Finamore robert.finamore@dot.gov

Brett Kruger brett.kruger@dot.gov

Reese Davidson reese.davidson@dot.gov

Info info@airlineinfo.com