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)

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Docket OST-2015-0025

MOTOIN FOR LEAVE TO FILE AND 

SURREPLY 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, 2015
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 

SURREPLY 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. 

The transfer sought by Alaska and American is directly contrary to the 

Department’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-MEX 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 carriers 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 13th day of March, 2015, 

upon the following persons via email:

Air Carrier Name Email Address

Alaska Airlines David Heffernan dheffernan@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.land@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 Kirstein 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 Bolling 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 reese.davidson@dot.gov

Info info@airlineinfo.com