BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

Motion of DELTA AIR LINES, INC. and NORTHWEST AIRLINES, INC. for a dormancy waiver (U.S.-China Combination Frequencies) ) ) ) ) ) ) ) ) Dockets OST-2007- 28567 OST-2004-18469

REPLY OF DELTA AIR LINES, INC. TO UNITED AIR LINES, INC.

Communications with respect to this document should be addressed to:

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

April 28, 2010BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

Motion of DELTA AIR LINES, INC. and NORTHWEST AIRLINES, INC. for a dormancy waiver (U.S.-China Combination Frequencies) ) ) ) ) ) ) ) ) Dockets OST-2007-28567 OST-2004-18469

REPLY OF DELTA AIR LINES, INC. TO UNITED AIR LINES, INC.

On April 21, 2010, Delta sought a dormancy waiver for two of its Seattle-Beijing frequencies, and seven of its Atlanta-Shanghai frequencies. Delta believes that its waiver request is in the public interest and is supported by important new factual developments applicable to the subject routes. Delta is implementing new nonstop service on the Seattle-Beijing route, which commences on June 4, 2010. These services are currently open and available for sale to the public. Delta’s Seattle-Beijing flight will operate at a level of five weekly frequencies this summer. Delta hopes to expand this service and believes that it is in the public interest to provide Delta with the waiver relief it needs to establish a daily service pattern in the future.Atlanta is the world’s largest airline hub, and Delta previously operated AtlantaShanghai nonstop service prior to the precipitous fall of traffic associated with the global

financial crisis. Those conditions are now improving. In addition, on April 16, 2010, China Eastern announced that it was joining SkyTeam. Delta’s CEO welcomed China

Eastern to the alliance: China Eastern is an outstanding airline with a strong leadership team and a proud history of serving its customers. We areReply of Delta Page 2

honored that another leading global airline has chosen to link its future growth and success with Delta and our SkyTeam partners," said Delta Chief Executive Officer Richard Anderson. "China Eastern's extensive network and growing hub in Shanghai will complement Delta's existing service to China and improve our customers' access to destinations across one of the world's fastest-growing regions. (See, Attached Press Release Dated April 16, 2010).

The significant additional traffic flows that are enabled by the new Delta-China Eastern partnership on this key hub-to-hub route will promote the restoration of Atlanta-Shanghai service, and Delta submits that it is in the public interest to grant Delta the waiver it requires to plan and implement this service. ` On April 27, United Air Lines filed an Answer to Delta’s waiver request. United asserts that Delta’s waiver should not be granted unless the Department also approves United’s waiver request for San Francisco-Guangzhou service. While Delta takes no position on United’s waiver, Delta believes that these waiver requests need to be decided on their own merits. Delta believes that its request merits favorable consideration by DOT and should be granted. The United and Delta waivers are distinct and there is no basis for the linkage which United seeks to impose. This approach is consistent with the Department’s longstanding policy and precedent, which is to weigh each waiver request on its own particular facts and public interest merits. In contrast to Delta, which has immediate service plans (in the case of Seattle-Beijing) and a prior history of nonstop service (in the case of Atlanta-Shanghai), United has never operated nonstop service on San Francisco-Guangzhou. Nor has United asserted any significant new factual developments – such as a major new alliance partner hubbed at its intended China gateway. Accordingly, while Delta does not oppose United’s request, Delta submits that each request should be judged separately, on its own merits.Reply of Delta Page 3

WHEREFORE, Delta respectfully requests that its waiver requests for SeattleBeijing and Atlanta-Shanghai be granted.

Respectfully submitted,

_________________________________ Alexander Van der Bellen Managing Director, Government Affairs & Associate General Counsel DELTA AIR LINES, INC.

## Delta Air Lines Welcomes China Eastern's Application to Join SkyTeam Alliance

Apr 16, 2010 SHANGHAI, April 16 /PRNewswire-FirstCall/ -- Delta Ai r Lines (NYSE: DAL) today issued the following statement in support of China East ern's signing of a memorandum of understanding to join the SkyTeam global airline alliance. (Logo: http://www.newscom.com/ cgi-bin/prnh/20090202/DELTALOGO ) "China Eastern is an outstanding air line with a strong leader ship team and a proud history of serving its customers. We are honored that another leading global air line has chosen to link its future growth and success with Delta and our SkyTeam partners," said Delt a Chief Executive Officer Ri chard Anderson. "China Eastern's extensive network and grow ing hub in Shanghai will complement Delta's existing service to China and improve our customers' access to destinations across one of the world's fastest-growing regions."

Delta Air Lines serves more than 160 million customers each year. With its unsurpassed global network, Delta and the Delta Connection carriers offer service to 355 destinations in 65 coun tries on six continents. Delta employs more than 70,000 employ ees worldwide and operates a main line fleet of nearly 800 aircraft. A founding member of the SkyTeam global alliance, Delta participates in the indust ry's leading trans-Atlantic j oint venture with Air France KLM. Including its worldwide alliance part ners, Delta offers customers more than 16,000 daily flights, with hubs in Amsterdam, Atlanta, Cincinnati, Detroit, Memphis, Minneapolis-St. Paul, New York-JFK, Paris-Charles de Gaulle, Salt Lake City and Tokyo-Nar ita. The airline's service includes the SkyMiles frequent flier progra m, the world's largest airline loy alty program; the award-winning BusinessElite service; and more than 50 Delta Sky Club s in airports worldwide. Customers can check in for flights, print boarding passes, check bags and review flight status at delta.com.

SOURCE Delta Air Lines 

### Pa g e 1 of 1 Delta Air Lines Welcomes China Eastern's A pp lication to Join Sk y Team Alliance - A p r 1...

4/28/2010 htt p ://news.delta.com/index. p h p ?s=43&item=1002& p rintableCERTIFICATE OF SERVICE A copy of the foregoing Reply has been served this 28th day of April, 2010, upon the following persons via email:

carl.nelson@aa.com dan.weiss@coair.com hkamen@coair.com rbkeiner@crowell.com jeffrey.manley@united.com julie.oettinger@united.com howard.kass@usairways.com benjamin.slocum@usairways.com esta.rosenberg@dot.gov keith.glatz@dot.gov mike.orr@airlineinfo.com