BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

Application of

DELTA AIR LINES, INC.

2010 U.S.-Haneda Combination Services Allocation Proceeding ) ) ) ) ) ) ) Docket DOT-OST-2010-0018

MOTION OF DELTA AIR LINES, INC. FOR A 30 DAY STARTUP EXTENSION

Communications with respect to this document should be addressed to:

Glen Hauenstein Executive Vice President – Network Planning & Revenue Management Robert J. Cortelyou Senior Vice President – Network Planning Andreas Renner Director – International Network Planning DELTA AIR LINES, INC. 1030 Delta Boulevard Atlanta, Georgia 30320 Andrea Fischer Newman Senior Vice President – Government Affairs DELTA AIR LINES, INC. 1212 New York Avenue, N.W. Washington, D.C. 20005

Alexander Van der Bellen Managing Director – Government Affairs & Associate General Counsel Jeff Morgan Regional Director – Government Affairs DELTA AIR LINES, INC. 1212 New York Avenue, N.W. Washington, D.C. 20005 (202) 842-4184 sascha.vanderbellen@delta.com

September 7, 2010BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

Application of

DELTA AIR LINES, INC.

2010 U.S.-Haneda Combination Services Allocation Proceeding ) ) ) ) ) ) ) Docket DOT-OST-2010-0018

MOTION OF DELTA AIR LINES, INC. FOR A 30 DAY STARTUP EXTENSION
Delta is very pleased to have been selected to provide service on the Detroit-Haneda
and Los Angeles-Haneda routes, and looks forward to bringing those important new service
benefits to its customers once the U.S.-Japan open skies agreement is in effect. By this
Motion, Delta seeks a limited 30 day extension of the startup condition of Order 2010-7-2 in
order to allow Delta to more efficiently plan and implement these new services.
In its Final Order, the Department recognized that unique factors associated with the
re-opening of Haneda to international service and the effectiveness of open skies could
impact carriers’ ability to introduce new servic e, and in light of these considerations the
Department would be sympathetic to requests for modified start-up dates. Order 2010-7-2
at n.27. The modest 30 day extension reques ted by Delta will have no impact on the longterm benefits of its services -- but will greatly assist Delta’s ability to effectively market and
successfully introduce its new Haneda service once open skies is in effect. 1

1 Delta appreciates that the Department is working as quickly as possible to complete its review of the antitrust immunity applications which are necessary for U.S.-Japan open skies to come into effect. However, the Department has been clear that it will not prejudge the outcome of these cases, which casts a cloud on the risks and commitments carriers can reasonably take in marketing new Haneda services. This is particularly true in the case of Japan, where large blocks of seats are sold though agency contracts, and Delta cannot be sure of its ability to carry through on commitments for Haneda seats until open skies is in effect.Motion of Delta Page 2
As required by Order 2010-7-2, Delta is planning to commence Haneda service in
late January, so as to maximize advance sales and marketing opportunities after open skies
is expected to enter into effect. 2 However, this places the planned startup date in the lowest
demand period of the year, where it is certain to incur substantial and otherwise avoidable
startup losses. February is one of the lowest demand months for mainland U.S.-Tokyo
passengers with just 158,612 bookings, whereas demand in March is more than 30 percent
greater with 208,387 bookings. 3 While February is a short month, on an adjusted basis,
February generates 2,832 passenger per day each way and March generates 3,361
passengers per day each way. Id.
With two new B-747-400 services, Delta will be introducing substantial new capacity
with more than 800 new daily nonstop seats per day each way to the U.S.-Tokyo market.
By starting service just 30 days later, Delta’ s new service will benefit from this important
seasonal upswing in Tokyo traffic. Delta believes it makes good public interest sense to
introduce new service and capacity when there is public demand to support the flights.

However, Delta reiterates that it will meet any startup condition required by the Department.
The Department has previously granted simila r short term start-up extensions to

Delta and other carriers. For the reasons explained above, Delta believes that it is

appropriate and consistent with the public interest to do so here.

2 Delta notes that American is also planning to begin its JFK-Haneda service in late January.

3 MIDT Data, February, March 2010.Motion of Delta Page 3
Respectfully submitted,

_________________________________ Alexander Van der Bellen Managing Director, Government Affairs & Associate General Counsel DELTA AIR LINES, INC.CERTIFICATE OF SERVICE
A copy of the foregoing document has been served this 7th day of September, 2010, upon the following persons via email:

carl.nelson@aa.com
dan.weiss@coair.com
hershel.kamen@coair.com jeffrey.manley@united.com howard.kass@usairways.com benjamin.slocum@usairways.com jhill@dowlohnes.com paul.gretch@dot.gov keith.glatz@dot.gov esta.rosenberg@dot.gov byerlyjr@state.gov eugene_alford@ita.doc.gov
info@airlineinfo.com