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

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
, 2015BEFORE 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 th e Department’s Rules of

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

4 1101 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 Airline s , Inc. (“Alaska”) and American Airlines, Inc. (“American”) recently
informed the Department o f their intent to transfer Alaska’s international route authority

in this market to Amer ican. 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 starti ng 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 fort h 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 g reater b enefits to c onsumers than American

and Alaska’s by increasing the number of daily flights in the market, beyond American’s
plan of twice daily operations. Th is 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 incre ase U.S. carrier flights in the market by 100 percent. Delta is a new
entrant in the Los Angeles

- Mexico C ity 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 an d remains

committed to expand in the competitive Los Angeles market, offering new service to
Shanghai, China; San Salvador, Salvador; Manzanillo, Mexico; Man a gua, 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 AddedDelta Application Page 3

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

compa red 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 ca rrier
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 itse lf 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 Angele nos 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 FligtsDelta Application Page 4

serve the public interest by a warding Delta the a uthority to fly LAX

- MEX, thereby
increasing LAX

- hub competition between network carriers.
In support of this Application, Delta state s as follows:

1. The proposed service will provide significant benefits to travelers and
shippers and is clearly in the public interest

. The re quested exempt ion 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 ). T wo U.S. carrier designations are authorized for t h is route

. Agreement
Annex I(B)(4

- 5 )

. After Alaska ceases its service t he 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 ma il, 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. D elta affirms that its operation of these route s 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 i ssuance of exemption authority to engage in
scheduled foreign air tra nsportation of per sons, property, and mail on the Los Angeles

Mexico 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

- 3CERTIFICATE OF SERVICE

A copy of the foregoing Application has been served this 26 th day of February, 2015
, upon the following persons via email:

Air Carrier Name Email Address

Alaska Airlines David Heffernan dh e ffernan@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 pat rick.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@virginam erica.com
Brian Hedberg brian.hedberg@dot.gov Robert Finamore robert.finamore@dot.gov Brett Kruger brett.kruger@dot.gov Reese Davidson r eese. d avidson@dot.gov Info info@airlineinfo.com