BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________ ) Motion of ) ) DELTA AIR LINES, INC. ) Docket DOT

- OST

- 2010

- 0018 ) i n the matter of 2010 U.S.

- Haneda ) Combination Services Allocation Proceeding ) __________________________________________)

REPLY OF THE DELTA MASTER EXECUTIVE COUNCIL OF THE AIR LINE PILOTS ASSOCIATION, INTERNATIONAL

IN SUPPORT OF DELTA AIR LINES , INC.

Communications with res pect to this document should be addressed to:

Timothy S. O’Malley Chairman Delta Master Executive Council Air Line Pilots Association, International 100 Hartsfield Centre Parkway, Suite 800 Atlanta, Georgia 30354 Tim.OMalley@alpa.org

Sept ember 13 , 2012BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________ ) Motion of ) ) DELTA AIR LINES, INC. ) Docket DOT

- OST

- 2010

- 0018 ) i n the mat ter of 2010 U.S.

- Haneda ) Combination Services Allocation Proceeding ) __________________________________________)

REPLY OF THE DELTA MASTER EXECUTIVE COUNCIL OF THE AIR LINE PILOTS ASSOCIATION, INTERNATIONAL

IN SUPPORT OF DELTA AIR LINES , INC.

The D elta Master Executive Council, th e Delta chapter of the Air Line P ilots Association,

Int ernational (the “Delta MEC”) hereby replies to the answers submitted by the other applicants

in this matter and reasserts its strong support for the request of Delta fo r the Haneda slot pair to

be used by Delta to provide new nonstop Seattle

- Haneda service . No other application for the

slot pair warrants as much consideration as does the Delta request.

The reasons why the assignment to Delta of the Haneda slot pair to provide nonstop

Seattle

- Haneda service represents the best allocation for the limited resource include:

 American’s request to serve Los Angeles

- Haneda duplicates existing service thereby diminishing the value of American’s application

. Exhibit DL

- A

407

 United’s request to serve San Francisco

- Haneda is also duplicative of exi s ting Haneda service in the market

. Exhibit DL

- A

- 207

 ANA is the largest hub operator at Haneda, giving the Star ATI alliance 221 slot pairs at Haneda, versus only 2 for Delta. DL

- A

- 105

 It would be unfair and detrimental to alliance competition to award United/ANA an additional slot pair at Delta’s expense. This would leaveR eply of Delta Master Executive Council

Page 2

United/ANA with 3 U.S.

- Haneda opportunities versu s only one for Delta. DL

- A

201

 The metal

- neutral joint v enture with ANA enable s United to share in the revenue generated by Haneda flying regardless of who operates the route . Delta and its transatlantic joint venture partners routinely share revenue and swap flying opportunities to ensure that each carrier be nefits within the alliance.

 Delta is the only carrier without an immunized Japanese alliance partner. The Star and oneworld ATI alliances together control 75 percent of Haneda departures. DL

- A

- 105

 Hawaiian’s request to serve the small Haneda

- Kona ma rket would not represent the highest and best use of the slot pair and would overwhelmingly benefit Japan ese tourist traffic rather than U.S. originating passengers.

 The Seattle

- Haneda market is the largest U.S.

- Tokyo O&D market with out nonstop service

. E xhibit DL

- A

- 101

 Awarding Delta the Haneda slot will ensure balanced inter

- gateway competition between each of the west coast gateways with each having one or more Haneda flight s

. Exhibit DL

- A

- 104

Other employment

- related benefits will flow from the awar d of the slot pair to Delta. To start,

the more than 12,000 + members of the Delta chapter of the Air Line Pilots Association will

benefit by the award, along with the other 70,000 plus dedicated employees of Delta. The over

9,600 employees of Delta’s str ong code

- share partner at Seattle , Alaska Airlines, will likewise

benefit by the award of the Haneda slot pair to Delta.

With respect to American and United, employment benefits will be tempered by the fact

that both carriers have indicated in their appl ications or by their prior actions that a schedule

rationalization process may or will result in the elimination of their existing flights to NaritaReply of Delta Master Executive Council

Page 3

w ere either carrier to be awarded Haneda slots

. 1 This will not be the case with Delta, as the

carrier wi ll continue to operate its full Seattle

- Narita flight pattern and add daily Haneda flights

from Seattle. In fact, Delta will offer more flights and seats to Tokyo than will either American

or United. Exhibits DL

- A

- 204, DL

- A

- 404.
Hawaiian’s application is weighed down by the fact that the carrier is proposing service

in the smallest market (Exhibit DL

- A

- 305) and one characterized by tourist traffic originating in

Japan (Exhibit DL

- A

- 307 ) rather than benefiting U.S. travelers

. But unlike any other carrier
seeking Haneda slots, Hawaiian’s proposal requires CBP/FIS facilities at Kona Airport , where

none exist today. T here can be no assurance that these needed federal facilities will be made

available, now or in the future. An award of Haneda slots to Hawaii an would therefore be

contingent on an event that cannot be controlled or even predicted with certainty by Hawaiian.

All that Hawaiian can do is to speculate that these facilities will materialize within the 90

- day

start up period

. Given, the time, effor t and expense that goes into a carrier/city s e lection

proceeding, the DOT should no t select Hawaiian with the risk that the proceeding will need to be

reopened if the carrier cannot commence service due to the lack of necessary customs and

immigration fac ilities. Finally, counting against Hawaiian is the fact that Hawaii presently has

the greatest number of Haneda flight s (3 daily) while Seattle has none. Exhibit DL

- A

- 302.

1 American has already announced a reduction in its Los Angeles

- Tokyo operation from daily to 5 flights weekly. This action portends the rationalization of American’s Los Angeles

- Tokyo service pattern should it receive the slot pair just as it did at JFK when American ceased operating to Narita after the award of a Haneda slot pair. United’s application states that: “United currently operates two daily flights during the summer be tween San Francisco and Tokyo Narita and one daily flight during the winter. United would continue to operate at least one daily Tokyo Narita flight year

- round if awarded the requested Tokyo Haneda slots

. ” United Application at n. 4

.Reply of Delta Master Executive Council

Page 4 Allocation of yet an additional slot pair to the State of Hawaii would clearly be subo ptimal from

the standpoint of a balanced geographical distribution of limited Haneda slots

. With these factors in mind, the Delta MEC strongly urges the Department to exercise its

authority to maximize the benefit of the Haneda slot pair by awarding it to Delta to serve the

nonstop Seattle

- Haneda market.

Respectfully submitted
,

Timothy S. O’Malley Chairman Delta Master Executive Council Air Line Pilots Association, In ternationa lCERTIFICATE OF SERVICE

A copy of the foregoing Reply has been served this 13t h day of September, 2012, upon the following persons via email:

sascha.vanderbellen@delta.com
Francis.Heil@aa.com
Robert.Wirick@aa.com
dan.weiss@united.com thomas.bolling@united.com lhalloway@crowell.com gmurphy@crowell.com howard.kass@usairways. com benjamin.slocum@usairways.com jhill@dowlohnes.com paul.gretch@dot.gov keith.glatz@dot.gov esta.rosenberg@dot.gov
brett. kruger@dot.gov todd.homan@dot.gov urskr@state.gov eugene_alford@ita.doc.gov
info@airlineinfo.com Ishiwata.K@portseattle.org
Safora.I@ portseattle.org Megan.Lawrence@alaskaair.com Kyle.Levine@alaskaair.com