BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

____________________________

In the matter of )

) Docket DOT-OST-2010-0018

2012 Detroit-Haneda Slot Pair )

Transfer from Delta Air Lines )

)

____________________________

PUBLIC ANSWER OF 

THE CONTINENTAL MASTER EXECUTIVE COUNCIL

OF THE AIR LINE PILOTS ASSOCIATION, INTERNATIONAL

IN SUPPORT OF THE MOTION OF UNITED 

Communications with respect to this document should be served on:

Jay A. Pierce

Chairman – Continental Master Executive Council

Air Line Pilots Association, International

3808A World Houston Parkway

Houston, TX 77032

jay.pierce@alpa.org

(281)987-3636

September 6, 2012
2

BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C

________________________________

In the matter of )

2012 Detroit-Haneda Slot Pair )

Transfer from Delta Air Lines )

______________________________

PUBLIC ANSWER OF 

THE CONTINENTAL MASTER EXECUTIVE COUNCIL

OF THE AIR LINE PILOTS ASSOCIATION, INTERNATIONAL

The Continental Master Executive Council of the Air Line Pilots Association

(“MEC”), representing over 4,800 pilots in service of the new United, express strong 

support for United’s motion to deny Delta Air Lines the transfer of its existing DetroitHaneda service to the Seattle gateway and to instead grant the slots in question to United 

to operate San Francisco – Tokyo Haneda service. 

In the 2010 proceedings, the Department granted two slot pairs to Delta Air Lines, 

one to American Airlines and one to Hawaiian Airlines, ultimately denying a single slot 

to either Continental or United and placing both carriers at a competitive disadvantage

with other U.S. carriers.

In comparison to each airline operating between the U.S. mainland and Tokyo, 

Delta continues to enjoy the largest market share at 27%. Granting Delta’s motion will 

continue to cement that position while discouraging new entrants and healthy competition

at Tokyo Haneda, and increased travel options that provide benefit to consumers. 

Permitting Delta the opportunity to operate from a Seattle gateway to Tokyo Haneda 
3

once again denies non-stop service from San Francisco, the second largest U.S. West 

Coast gateway, to Tokyo and the heart of the second largest city in the world.

United has indicated it stands ready and willing to begin service to Tokyo Haneda 

within 90 days, with its own aircraft and crews. This would generate opportunities for the

combined 12,000-plus members of the Continental and United chapters of the Air Line 

Pilots Association and additionally create jobs currently not available for the more than 

1,400 pilots in layoff status. 

Permitting United to serve Tokyo Haneda from San Francisco may have a 

potentially significant effect on wages and working conditions for U.S. airline workers, 

which is a public interest factor the Department must consider in a meaningful way when 

evaluating route authority requests. In the Show Cause Order (DOT-OST-2010-0059),

the Department stated that “Continental and United have the incentive to increase 

capacity if possible....” Show Cause Order at 17. 

Granting United the slot pair for the proposed San Francisco service will also 

greatly benefit both the local Asian community and the many businesses in the area that 

have ties to Japan, as United is the only U.S. carrier able to offer connecting traffic with 

multiple options on its own brand and aircraft from San Francisco. 

Since the initial DOT slot pair awards in 2010, Delta has exercised its right to 

serve Tokyo Haneda from Detroit for only 9 out of 20 months. While all carriers were 

economically harmed by the unfortunate Tsunami events in 2011, United continued to 

serve Tokyo with its own aircraft and crews, displaying a commitment to the region, to

U.S. consumers and its 80,000-plus United coworkers that would undoubtedly be 

extended through service to Haneda.
4

For the foregoing reasons, the MEC strongly supports United’s request to serve 

Tokyo Haneda from its San Francisco hub and urges the Department to promptly deny 

Delta’s motion.

Respectfully submitted,

Jay A. Pierce

Chairman, Continental Master Executive Council

Air Line Pilots Association, International
5

CERTIFICATE OF SERVICE

I hereby certify that on this 6

th day of September, 2012 the foregoing PUBLIC ANSWER 

OF THE CONTINENTAL MASTER EXECUTIVE in support of United’s Motion, has 

been served by email on the following persons:

dan.weiss@united.com

carl.nelson@aa.com

francis.heil@aa.com

sascha.vanderbelle@delta.com

thomas.bolling@united.com

howard.kass@usairways.com

benjamin.slocum@usairways.com

jhill@dowlohones.com

todd.homan@dot.gov

keith.glatz@dot.com

paul.gretch@dot.gov

esta.rosenberg@dot.gov

urskr@state.gov

Eugene_alford@ita.doc.gov

info@airlineinfo.com

msinick@ssd.com

cdonley@ssd.com

robert.wirick@aa.com

robert.cohn@hoganlovells.com

patrick.rizzi@hoganlovells.com

sascha.vanderbellen@delta.com

sametta.c.barnett@delta.com

jhill@dowlohnes.com

brein@wileyrein.com

jrichardson@johnlrichardson.com

rpommer@atlasair.com

bill@mietuslaw.com

BTHunt@pncl.com

charters@evergreenairlines.com

anita.mosner@hklaw.com

nssparks@fedex.com

rsilverberg@sgbdc.com

cjsimpson@zsrlaw.com

robert.land@jetblue.com

agoerlich@ggh-airlaw.com

matwood@cozen.com

bob.kneisley@wnco.com

kevin.montgomery@polaraircargo.com

mlbenge@zsrlaw.com

dkirstein@yklaw.com

jyoung@yklaw.com

john.fredericksen@suncountry.com

pmurphy@lopmurphy.com

howard.kass@usairways.com

benjamin.slocum@usairways.com

barbara.russell@virginamerica.com

lee.moak@alpa.org

safora.i@portseattle.org

ishiwata.k@portseattle.org

kandace.bender@flysfo.com

governor@mail.gov.gu

dmair@mmstlaw.com

brett.kruger@dot.gov

john.allen@faa.gov