BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

____________________________________________ ) Answer of ) ) PORT OF SEATTLE ) Docket DOT - OST - 2010 - 0018 in support of ) Application of Delta Air Lines Inc. ) 2010 US - Haneda Combination Services ) Allocation Proceeding ) ____________________________________________)

ANSWER OF THE PORT OF SEATT LE

IN SUPPORT OF APPLICATION OF DELTA AIR LINES INC.
Communications with respect to this document should be addressed to: Mark Reis Managing Director Seattle - Tacoma International Airport Kazue Ishiwata Senior Manager Air Service Development Seattle - Tacoma International Airport Port of Seattle P.O. Box 68727 Seattle, WA 98168 (206) 787 - 4698 (tel) (206) 439 - 7782(fax) ishiwata.k@portseattle.org Isabel R. Safora Deputy General Counsel Port of Seattle Legal Department P. O. Box 1209 Seattle, W A 98111 (206) 787 - 3216 (tel) (206) 787 - 3205 (fax) safora.i@portseattle.org

March 1, 2010BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

____________________________________________ ) Answer of ) ) PORT OF SEATTLE ) Docket DOT - OST - 2010 - 0018 in support of ) Application of Delta Air Lines Inc. ) 2010 US - Haneda Combin ation Services ) Allocation Proceeding ) ____________________________________________)

ANSWER OF THE PORT OF SEATTLE

IN SUPPORT OF APPLICATION OF DELTA AIR LINES INC. 2010 US - HANEDA COMBINATION SERVICES ALLOCATION

I. Introduction The Port of Seattle, as the owner

- operator of Seattle

- Tacoma International Airport (“Seattle”), respectfully submits this Answer to the application of Delta Air Lines Inc. (“Delta”) for a slot allocation to engage in daily service between Tokyo’s Haneda In ternational Airport (Haneda), and Seattle, Washington. Seattle needs and deserves nonstop service to Haneda. Seattle has a long and distinguished history as a gateway to Asia, and Seattle is particularly pleased that Delta has made the g rowth and development of international service at Seattle a centerpiece of its West Coast strategy. Haneda is highly preferred by time

- sensitive Tokyo passengers. Accordingly, it is vital to Seattle as a gateway, and to Delta as our largest internationalAnswer of the Port of Seattle DOT - OST - 2010 - 0018

Page 2
service provider, to have access to this critical airport serving downtown Tokyo. Authorizing Haneda service will also benefit our hometown hub carrier, Alaska Airlines, which provides an extensive feed network fueling the growth of international service

. Seattle will be competing for Tokyo passengers up and down the west coast and should not be placed at a competitive disadvantage. II. Allocation to Delta of a Seattle - Haneda Route Would Greatly Benefit the Traveling Public of the Pacific Northwest Regi on Seattle has embraced exceptionally strong trade and business ties with Japan ever since the city enthusiastically welcomed and celebrated the arrival of the Japanese steamship Miike Maru in August 1896, which first set anchor in Seattle’s harbor amid t he yells of thousands of people on the docks and the blowing of every steam whistle for five miles along the waterfront to signify Nippon Yusen Kaisha’s choice of Seattle as its Pacific Coast terminus. Today, Seattle is the Pacific Northwest’s hub for tra velers to and from Asia , anchored by Alaska Airlines and its affiliate Horizon Air

. The State of Washington is home to many international corporations with significant, consistent and rapidly growing business in Japan, such as Boeing, Microsoft, Starbucks, Bill and Melinda Gates Foundation, Costco, and the US headquarters for major Japane se corporations such as Nintendo and various aerospace industry suppliers. The two

- way trade between Washington and Japan surpassed $11.4 billion in 2009. Washington state

- of

- origin exports to Japan totaled nearly $5.6 billion in 2009. Between 2001 and 2 009, exports other than aerospace grew 20%. 2008 was a banner year for Washington state

- Japan trade, with $8.9 billion in Washington state

- of

- originAnswer of the Port of Seattle DOT - OST - 2010 - 0018

Page 3
commodities going to Japan, the highest on record, and a 165% increase over 2001 levels. Given these stro ng communities of interest , Seattle is committed to supporting business travelers seeking convenient non

- stop routes to Asia. Seattle

- Tokyo nonstop has been served successfully and uninterruptedly since October , 1963. Delta’s commitment to provide effici ent and convenient routes to business travelers and to the region is demonstrated with its new Seattle

- Beijing and Seattle

- Osaka nonstop services that are set to commence this summer, together with Delta’s existing Seattle

- Narita and Seattle

Amsterdam rout es plus the Seattle

- Paris route by its Joint Venture partner Air France. Delta has made major investments and contributed greatly to the region with over 1,400 employees, an aircraft maintenance hangar and cargo facilities at the airport, as well as a

res ervation center. In addition, Delta has committed to build a new Sky Club to accommodate its growing number of premium passengers. Allocation of a Seattle

Haneda route to Delta would maximize the benefits to the Pacific Northwest economy and its travelin g public , and complement Delta’s west coast strategy. Seattle is also a popular destination among the Japanese visitors due to its historical, cultural and business relationships. Seattle and Washington State have been working for many years to cultivate the inbound travel market and enhance the success of the current nonstop Tokyo services. Regional support and enthusiasm for Delta’s proposed Seattle

- Haneda route is evident in th e letters submitted in support of the application, including one by Washington State Governor Christine Gregoire. Copies of the letters are submitted asAnswer of the Port of Seattle DOT - OST - 2010 - 0018

Page 4

Exhibit SEA

- 10 1 to this Answer. Expeditious approval of Delta’s application will allow Seattle to begin the work to promote the new Seattle

- Haneda service for the benefit of the traveling public and our region. III. Seattle is the Pacific Northwest’s Closest Gateway to Asia a nd Merits New Service to Tokyo Haneda. Seattle is the Pacific Northwest Region ’s gateway to Asia. Seattle draws traffic from an even larger Western region with Alaska/Horizon connections to Alaska, Oregon, Idaho, Montana, as well as Delta’s Salt Lake City hub. Exhibit SEA

- 10 2

- Seattle’s Connecting Market s . These cities are best s erved by the S eattle gateway because of substantial circuity for connections via other gateways. Despite serving as the primary and closest United States mainland gateway to Asia, Seattle remains under

- served to Asia, as indicated by the frequency comparis on to Los Angeles, San Francisco and Vancouver

. Exhibit SEA

- 10 3

- West Coast Airports Pacific Gateway Weekly Frequencies by Alliance

. Seattle’s local market has been healthy and its total enplanements in recent years show stronger growth than that of these peer airports

. Exhibit SEA

- 10 4

- West Coast Airports CY2009 Enplanements and Percentage Change vs. CY2000

. Seattle’s geographic location closest to Japan means that its time

- s ensitive business travelers would not connect through Los Angeles or San Francisco to go to Haneda, which requires back

- tracking and negates the convenience of Haneda’s close

- in location

. Instead, they would continue flying nonstop to and from Narita, des pite its lessAnswer of the Port of Seattle DOT - OST - 2010 - 0018

Page 5
convenient Tokyo location. Exhibit SEA

- 10 5

- West Coast Elapsed Trip Times to Tokyo

. Granting Delta’s application to operate nonstop service from Seattle to Haneda will serve to connect cities in the Pacific Northwest and other Western states that are not currently served to Japan. Doing so will further the trade and cultural ties that ha ve long been an integral part of our Western region. IV. Potential Traffic Leakage to Nearby Vancouver, Canada, Could Undermine Seattle’s Role as the Pacific Northwest Gateway

. Seattle is a significantly larger city than its close Canadian neighbor of Vancouver, British Columbia, measured in terms of population and economy

. Exhibit SEA

- 10 6

- Seattle and Vancouver Population and Economy . Yet Vancouver enjoys more than twice as many nonstop services to Asia as previously indicated by Exhibit SEA

- 10 3

. Wi th high

- frequency, 45

- minute flights between Seattle and Vancouver and many travelers within driving distance, Vancouver draws Seattle passengers to and from many cities in Asia, aided also by US pre

- clearance facilitation at its airport. In addition to the new US

- Haneda services authorized for both sides in the 2009 MOU, Japan and Canada also have agreed to allocate two Haneda routes to each country. Currently Japan Airlines and A ir Canada each operat e daily nonstop Vancouver

- Tokyo

Narita services , and are expected later this year either to move those flights to Haneda or start additional daily nonstop Haneda flights. These carriers are members of oneworld and Star Alliance respec tively, adding to the US

- Haneda slot allocations available toAnswer of the Port of Seattle Index of Exhibit s DOT - OST - 2010 - 0018

INDEX OF EXHIBITS

________________________________________________________________________ EXHIBIT NO. TITLE SEA

- 10 1 Letters in Support of Delta Air Lines’ application for Seattle

- Haneda

Allocation ( 14 p ages ) SEA

- 10 2 Seattle’s Connecting Market s (2 p ages ) SEA

- 10 3 West Coast Airports Pacific Gateway Weekly Frequencies by Alliance SEA

- 10 4 West Coast Airports CY200 9 Enplanements and Percentage Change vs.

CY2000 SEA

- 10 5 West Coast Elapsed Trip Times to Tokyo (3 p ages ) SEA

- 106 Seattle and Vancouver Population and Economy SEA

- 107 Seattle and Washington Supplemental Information (1 6 pages )Answer of the Port of Seattle Exhibit SEA - 10 1 DOT - OST - 2010 - 0018

Answer of the Port of Seattle List o f Letter s in Support of Delta Air Lines Seattle - Haneda Application

 Washington State Governor Christine Gregoire

 City of Seattle Mayor Mike McGinn

 Seattle City Council

 King County Executive Dow Constantine

 Trade Development Alliance of Greater Seattle William B. Stafford, President

 Greater Seattle Chamber of Commerce Phil Bussey, President & CEO

 Downtown Seattle Association Kate Joncas, President

 Seattle’s Convention and Visitors Bureau President, Tom Norwalk

 Puget Sound Business Travel Association Chair, Jane Bankester

 Japan America Society of State of Washington Chair, Dennis YamashitaFebruary 24, 2010

The Honorable Ray LaHood United States Department of Transportation 1200 New Jersey Avenue, SE Washington, DC 20590 Dear Secretary LaHood: On behalf of Trade Development Alliance of Greater Seattle, I am writing to express our strong support for the application of Delta Air Lin es for new nonstop service between Seattle and Haneda. Approval of Delta’s new service would be a major be nefit for our region, where many corporations have strong trade and market presence with Japan. In fact, Japan has been one of our region’s largest international business partners for decades. Japan is our thirdlargest trading partner, third-largest export marke t and second-largest trading partner through our ports. Japan is also Washington state’s largest source of international tourists and students and third-largest source of foreign di rect investment. In other words, the large ties and interactions between the Pacific Nor thwest and Japan create demand for increased capacity to Tokyo. Our business traveler s look forward to the convenience of flying into Tokyo’s downtown Haneda Airport. Our largest companies all rely on international cus tomers for their success—70 percent of Boeing’s customers are international, 60 percent of Microsoft’s and half of PACCAR’s. Starbucks has stores throughout Japan. Asia is a cr ucial market for these and the myriad of companies in our region, both small and large, e ngaged internationally. Seattle is a proven and successful gateway to Asia. This summer Delta is adding new service to Beijing, China and Osaka, Japan, buildin g SEA-TAC into an important West Coast gateway. The addition of Haneda as a destina tion is a natural fit that would clearly benefit our business travelers. Thank you for consideration of this request. Best regards,

William B. Stafford President 1301 - 5th Avenue Mr. William B. Stafford

Suite 2500 President Seattle, WA 98101 USA Phone: 206-389-7301 Fax: 206-624-5689 www.seattletradealliance.com BOARD OF DIRECTORS Ms. Diane Aboulafia-D’Jaen Public Affairs Consultant Mr. David Allen McKinstry Company Ms. Nancy Anderson Microsoft Corporation The Honorable Bill Baarsma Mayor of Tacoma Ms. Maggie Brown APCO Worldwide Mr. Phil Bussey Greater Seattle Chamber of Commerce Mr. Dennis Clark Fairmont Olympic Hotel Mr. Gregory Dalzell Wells Fargo Bank Mr. Dan Dixon Swedish Health Services The Honorable Jan Drago Seattle City Council Mr. Timothy Farrell Port of Tacoma Mr. Paul Griffin Amalgamated Transit Union Local 587 The Honorable Lloyd Hara Port of Seattle Commission Mr. Paul Isaki Port of Seattle Mr. Doug Kemper The Honorable Conrad Lee Bellevue City Council The Honorable Pat McCarthy Pierce County Executive The Honorable Richard McIver Seattle City Council Mr. John Mohr Port of Everett The Honorable Greg Nickels Mayor of Seattle The Honorable Julia Patterson Metropolitan King County Council Ms. Sally Poliak Nyhus Communications LLC The Honorable Aaron Reardon Snohomish County Executive Mr. Stan Savage The Commerce Bank The Honorable Raymond Stephanson Mayor of Everett Mr. David K.Y. Tang K & L Gates LLP The Honorable Gael Tarleton Port of Seattle Commission Mr. Thomas Taylor US Bank The Honorable Kurt Triplett King County Executive Mr. Herman Uscategui Starbucks Coffee Company The Honorable Pete von Reichbauer Metropolitan King County Council Mr. Daniel Waggoner Davis Wright Tremaine LLP Mr. Georges Yates Perkins Coie LLP Mr. Tay Yoshitani Port of Seattle CHAIR Mr. Scott Jackson PATH VICE CHAIR Mr. Robert Marcovitch K2 Sports TREASURER The Honorable Dave Gossett Snohomish County Council SECRETARY The Honorable Clare Petrich Port of Tacoma Commission PAST CHAIR Ms. Laura Peterson The Boeing Company

# Seattle’s Connecting Markets The Gateway for the Pacific Northwest

Atlanta Anchorage

Los Angeles LAX, BUR, LGB, ONT , SNA Boston

San Diego

Orlando Miami Juneau Ketchikan

New York JFK
Cincinnati Detroit San Francisco SFO, OAK, SJC Las Vegas
Phoenix Vancouver Fairbanks

Palm Springs

Monterey Santa Rosa Redding Sitka Edmonton Calgary

Minneapolis Chicago

Dallas Salt Lake City Denver
Memphis 

## Seattle Docket DOT - OST - 2010 - 0018 

### Exhibit SEA - 102 Page 1 of 2

Fresno Reno Sacramento Portland

Source: Application of Delta Air Lines, Exhibits DL
- 108 through DL
- 111Lewiston

Eugene Redmond Walla Walla

Pasco Yakima Pullman 

# Portland

Medford Boise Helena

Bozeman Bellingham

Wenatchee 

## Seattle Missoula Spokane Kalispell Great Falls Edmonton Kelowna 

### Vancouver Victoria Calgary

Billings 

### Docket DOT

- OST - 2010 - 0018 

### Exhibit SEA - 102 Page 2 of 2 

# Seattle’s Connecting Markets The Gateway for the Pacific Northwest

Source: Application of Delta Air Lines, Exhibits DL
- 108 through DL
- 111Source: OAG Schedules Database , August 2010 Does not include Australia or New Zealand.



# West Coast Airports Weekly Frequencies 

# West Coast Airports Pacific Gateway Weekly Frequencies by Alliance

Pacific Gateway oneworld

Frequency Star Alliance

Frequency SkyTeam

Frequency Others Total 

## Los Angeles 31 54 46 51 182 San Francisco 21 81 14 26 142 Vancouver 21 94 5 23 94 

# SEATTLE 0 12 24 9 45 Portland 0 0 7 0 7 

# Total 73 192 96 109 470 Docket DOT

- OST - 2010 - 0018 

### Exhibit SEA - 103

# Seattle has sustained strong growth in the past decade.

4 Sources: ACI
- NA and Airport Data 

# West Coast Airports CY2009 Enplanements and Percentage Change vs. CY2000

N. America Ranking Airport CY 2009 Passengers % Change vs

2000 3 Los Angeles 56,520,843 - 16.0% 

# 10 San Francisco 37,224,250 - 7.6% 18 Seattle 31,227,512 +9.9 % 29 Vancouver 16,177,438 +0.9% Docket DOT

- OST - 2010 - 0018 

### Exhibit SEA - 104

## Seattle - Haneda Elapsed Trip Times in Winter Westbound Eastbound Proposed by Delta, Nonstop 10:50 9:00 Proposed by United, via SFO 15:29 13:03 Proposed by American, via LAX 16:58 13:59
Seattle - Haneda Elapsed Trip Times in Summer Westbound Eastbound Proposed by Delta, Nonstop 10:35 9:35 Proposed by United, via SFO 15:13 13:03 Proposed by American, via LAX 14:50 15:10 

# West Coast Elapsed Trip Times to Tokyo (Page 1 of 3) Docket DOT - OST - 2010 - 0018 

### Exhibit SEA - 105 Page 1 of 3

### Docket DOT - OST - 2010 - 0018 

### Exhibit SEA - 105 Page 2 of 3 

# West Coast Elapsed Trip Times to Tokyo (Page 2 of 3)

Source: Great Circle Mapper www.gcmap.comSource: Great Circle Mapper www.gcmap.com 

### Docket DOT

- OST - 2010 - 0018 

### Exhibit SEA - 105 Page 3 of 3 

# West Coast Elapsed Trip Times to Tokyo (Page 3 of 3)Sources: U.S. Department of Commerce, Statistics Canada, Airport data. 

### SEA YVR 2008 State / Province Population 6,549,000 4,382,000 2008 State / Province GDP (US$ Millions) $322,778 $195,827 

### 2009 Air Cargo (Metric Tons) 269,337 198,422 Docket DOT

- OST - 2010 - 0018 

### Exhibit SEA - 106 

# Seattle and Vancouver 

# Population and Economy

# Docket DOT - OST - 2010 - 0018 2010 US - Haneda Combination Services 

# Allocation Proceeding

_____________________________________ 

# Exhibit SEA - 107 (Total 16 Pages) Seattle and Washington State Supplemental Information Docket DOT - OST - 2010 - 0018 Exhibit SEA - 107 Page 1 of 16

# Seattle is a Center for Global Corporations with International Travel Needs Docket DOT - OST - 2010 - 0018 Exhibit SEA - 107 Page 2 of 16Source: Puget Sound Business Journal, 2010 Book of Lists. 

# Washington State’s Largest Companies Docket DOT

- OST - 2010 - 0018 Exhibit SEA - 107 Page 3 of 16

# Washington State’s Largest Companies ( Cont’d 

# ) Docket DOT - OST - 2010 - 0018 Exhibit SEA - 107 Page 4 of 16

Source: Puget Sound Business Journal, 2010 Book of Lists.

# Seattle’s Leading Employers High
- Tech Manufacturing, Software, Medical Care, e
- Retail

Source: Puget Sound Business Journal, 2010 Book of Lists. 

### Docket DOT

- OST - 2010 - 0018 Exhibit SEA - 107 Page 5 of 16

# Washington State’s Jobs Predominantly in Strong, Growing Service Sectors and High
- Tech Industries

Source: Employment Security Department and the Washington Research Council. 

### Docket DOT

- OST - 2010 - 0018 Exhibit SEA - 107 Page 6 of 16

# Population Growth Washington Leads the Pacific Northwest

Sources: US Census Bureau and Statistics Canada



### Docket DOT

- OST - 2010 - 0018 Exhibit SEA - 107 Page 7 of 16$178.3 $195.8 $214.4 $222.0 $225.8 $231.5 $240.0 $253.2 $272.7 $289.1 $310.3 $322.8



## 0 50 100 150 200 250 

## 300 350

1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 GDP (US$ Billions)



### Washington 

# Washington State Steady Economic Growth Docket DOT - OST - 2010 - 0018 Exhibit SEA - 107 Page 8 of 16

## 17 

# Total Air Passenger Traffic 31.2 Million in 2009

Source: Port of Seattle, Reports from Air Carriers 

### Docket DOT

- OST - 2010 - 0018 Exhibit SEA - 107 Page 9 of 16

## 18 

# International Air Passenger Traffic 2.6 Million in 2009

Source: Port of Seattle, Reports from Air Carriers 

### Docket DOT

- OST - 2010 - 0018 Exhibit SEA - 107 Page 10 of 16

# Seattle Enplanements by Carrier Share CY2009 SkyTeam Total 13.1% 4,100,000 Passengers

Source: Port of Seattle, reports by airlines, 2009. 

### Docket DOT

- OST - 2010 - 0018 Exhibit SEA - 107 Page 11 of 16Puerto Vallarta 

### Taipei San Jose del Cabo 

### Toronto Amsterdam 

### Paris Tokyo 

# Seattle 

# Seattle’s International Services

London Heathrow Calgary

Mexico City 

### Frankfurt
Beijing *
Cancun Mazatlan 

### Reykjavik

SkyTeam routes Star Alliance route oneworld route Other * Scheduled to inaugurate on June 4, 2010 ** Scheduled to inaugurate on June 7, 2010 Dotted lines to Mexico indicate seasonal service. 

### Osaka** Seoul Victoria Edmonton Kelowna Vancouver 

### Docket DOT - OST - 2010 - 0018 Exhibit SEA - 107 Page 12 of 16

### Docket DOT - OST - 2010 - 0018 Exhibit SEA - 107 Page 13 of 16

### Docket DOT
- OST
- 2010
- 0018 Exhibit SEA
- 107 Page 14 of 16

### Docket DOT
- OST
- 2010
- 0018 Exhibit SEA
- 107 Page 15 of 16

### Docket DOT
- OST
- 2010
- 0018 Exhibit SEA
- 107 Page 16 of 16