BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Joint Application of

ALASKA AIRLINES, INC.

AND

AMERICAN AIRLINES, INC.

for transfer of international route authority under

49 U.S.C. § 40109 , 41105

( Los Angeles

- Mexico City ) )

)

)

)

)

)

)

)

)

)

) Docket OST

- 2015

- 0025

MOTOIN FOR LEAVE TO FILE AND

SURREP L Y OF DELTA AIR LINES

Communications with respect to this document should be addressed to:

Robert J. Cortelyou

Senior Vice President

– Network Planning

Joe Esposito

, Vice President

– Network Planning

Americas

Amy Martin, Director, Network Planning, Latin

Amercia

DELTA AIR LINES, INC.

1030 Delta Boulevard

Atlanta, Georgia 30320 Alexander Van der Bellen

Managing Director

– Regulatory and International

Affairs & Associate General Counsel

Christopher Walker

Regional Director

– Regulatory and International

Affairs

DELTA AIR LINES, INC.

1212 New York Avenue, N.W.

Washington, D.C. 20005

(202) 842

- 4184

sascha.vanderbellen@delta.com

chris.walker@delta.com

March 13

, 2015BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Joint Application of

ALASKA AIRLINES, INC.

AND

AMERICAN AIRLINES, INC.

for transfer of international route authority under

49 U.S.C. § 40109, 41105

(Los Angeles

- Mexico City) )

)

)

)

)

)

)

)

)

)

) Docket OST

- 2015

- 0025

MOTOIN FOR LEAVE TO FILE AND

SURREP L Y OF DELTA AIR LINES

Delta Air Lines, Inc. (“Delta”) requests leave to file this Surreply to the Joint Reply

of Alaska Airlines, Inc. (“Alaska”) and American Airlines, Inc. (“American”) . Delta's

Surreply will contribute to a more full and complete record for decision.

Alaska seeks to transfer its Los Angeles ( LAX )

- Mexico City ( MEX ) exemption

and designation authority to American. While the carriers purport to rely on the

certificate transfer provisions of 49 U. S.C. 41105, nowhere in their 10

- page answer are

they able to provide an applicable precedent where the Department permitted a discrete,

focused transfer of limited entry Mexico exemption and designation authority.

T he transfer sought by Alaska and American is directly contrary to the

D epartment’s original public interest determination to award LAX

- MEX authority to

Alaska instead of American . When the Department chose Alaska to operate the route it

stated:

American brings none of the competitive advantages that come with the selection

of Alaska in this case. American currently offers significant foreign scheduled air

transportation services in the U.S.

- Mexico market, and direct

- carrier services in

the U.S.

- Mexico City market. More specifically, American offers direct

- carrier

service to 11 Mexican cities from nine U.S. cities (four of which are American

hubs), and serves Mexico City from three U.S. points.

Order 2005

- 05

- 01 at 6.Delta Surreply

Page 2

The proposed route transfer would eviscerate the Department’s public interest

determination to award LAX

- ME X route to Alaska over American. American continues to

be the dominant carrier on U.S.

- Mexico routes and is the largest hub carrier at Los

Angeles. Delta is a strong and growing challenger at Los Angeles and to Mexico , but

needs important limited entry authority on this route to compete.

The Department has maintained the importance of its carrier selection

proceedings and has even refused to allow carrier s to migrate frequency and exemption

authority within their own portfolios. For example, when Delta sought flexibility to

migrate frequencies from the JFK

- Bogota route to Atlanta

- Bogota the Department

declined because “ doing so would defeat the Department’s rationale for selection of

Delta over other competing applicants. ” Order 2009

- 11

- 3 at 3.

Here, the transfer of route authority from Alaska to American would defeat the

Department’s rationale for selecting the same carrier over the other

. Delta has

proposed a superior application offering three daily flights on the LAX

- MEX route, versus

the one daily frequency operated by Alaska and the two daily frequencies proposed by

American. This is a discrete, simple case , and contrary to the protestations of American

and Alaska will not cause unnecessary delay. A fresh look at the respective merits of

the competing applications is necessary and appropriate to maximize the public interest

benefits on this important U.S.

- Mexico route.

Respectfully submitted,

_____________________

Alexander Van der Bellen

Managing Director, Regulatory and

International Affairs & Associate General

Counsel

DELTA AIR LINES, INC.CERTIFICATE OF SERVICE

A copy of the foregoing Surreply has been served this 13 th day of March , 2015

, upon the following persons via email:

Air Carrier Name Email Address

Alaska Airlines David Heffernan dh e ffernan@cozen.com

Alaska Airlines Marshall Sinick sandysinick@gmail.com

American Howard Kass howard.kass@aa.com

American Robert Wirick robert.wirick@aa.com

Frontier Mark Atwood matwood@cozen.com

Frontier Steve Lachter stephen.lachter@lachterlaw.com

Hawaiian/JetBlue Jonathan Hill jhill@cooley.com

Hawaiian/JetBlue Parker Erkmann perkmann@cooley.com

JetBlue Robert Land robert.lan d@jetblue.com

Republic Bob Cohn robert.cohn@hoganlovells.com

Republic Pat Rizzi patrick.rizzi@hoganlovells.com

Southwest/AirTran Bob Kneisley bob.kneisley@wnco.com

Southwest/AirTran Leslie Abbott leslie.abbott@wnco.com

Spirit Airlines David Kirs tein dkirstein@yklaw.com

Spirit Airlines Joanne Young jyoung@yklaw.com

Sun Country John Fredericksen john.fredericksen@suncountry.com

Sun Country Thomas Ting thomas.ting@suncountry.com

United Dan Weiss dan.weiss@united.com

United Thomas Bol ling thomas.bolling@united.com

Virgin America Barbara Russell barbara.russell@virginamerica.com

Brian Hedberg brian.hedberg@dot.gov

Robert Finamore robert.finamore@dot.gov

Brett Kruger brett.kruger@dot.gov

Reese Davidson r eese. d avidson@dot.gov

Info info@airlineinfo.com