BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________

)

Motion of )

 ) 

DELTA AIR LINES, INC. ) Docket DOT-OST-2010-0018

 )

in 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 respect 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

September 13, 2012
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________

)

Motion of )

 ) 

DELTA AIR LINES, INC. ) Docket DOT-OST-2010-0018

 )

in 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.

The Delta Master Executive Council, the Delta chapter of the Air Line Pilots Association, 

International (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 for 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-A407

 United’s request to serve San Francisco-Haneda is also duplicative of 

existing 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 leave 
Reply of Delta Master Executive Council

Page 2

United/ANA with 3 U.S.-Haneda opportunities versus only one for Delta. DL-A201

 The metal-neutral joint venture with ANA enables 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 benefits 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 market would not 

represent the highest and best use of the slot pair and would overwhelmingly 

benefit Japanese tourist traffic rather than U.S. originating passengers.

 The Seattle-Haneda market is the largest U.S.-Tokyo O&D market 

without nonstop service. Exhibit 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 flights. Exhibit DL-A-104

Other employment-related benefits will flow from the award 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 strong 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 applications or by their prior actions that a schedule 

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

Page 3

were either carrier to be awarded Haneda slots.

1

 This will not be the case with Delta, as the 

carrier will 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. There can be no assurance that these needed federal facilities will be made 

available, now or in the future. An award of Haneda slots to Hawaiian 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, effort and expense that goes into a carrier/city selection 

proceeding, the DOT should not 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 facilities. Finally, counting against Hawaiian is the fact that Hawaii presently has 

the greatest number of Haneda flights (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 between 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 suboptimal 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, International
CERTIFICATE OF SERVICE

A copy of the foregoing Reply has been served this 13th 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