BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

Application of DELTA AIR LINES, INC.

2010 U.S.-Haneda Combination Services Allocation Proceeding ) ) ) ) ) ) ) Docket DOT-OST-2010-0018

ANSWER OF DELTA AIR LINES, INC. TO OBJECTIONS OF HAWAIIAN, CONTINENTAL AND UNITED

Communications with respect to this document should be addressed to:

Glen Hauenstein Executive Vice President – Network Planning & Revenue Management Robert J. Cortelyou Senior Vice President – Network Planning Andreas Renner Director – International Network Planning DELTA AIR LINES, INC. 1030 Delta Boulevard Atlanta, Georgia 30320 Andrea Fischer Newman Senior Vice President – Government Affairs DELTA AIR LINES, INC. 1212 New York Avenue, N.W. Washington, D.C. 20005

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

May 24, 2010BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

Application of DELTA AIR LINES, INC.

2010 U.S.-Haneda Combination Services Allocation Proceeding ) ) ) ) ) ) ) Docket DOT-OST-2010-0018

ANSWER OF DELTA AIR LINES, INC. TO OBJECTIONS OF HAWAIIAN, CONTINENTAL AND UNITED The Department’s selection of Detroit-Haneda and Los-Angeles-Haneda is supported by the record. There is nothing in the Objections of United, Continental or Hawaiian that would justify any changes to the findings and conclusions of the Show Cause Order. Delta respectfully requests that Department confirm its decision in a Final Order, which will enable the selected carriers to establish the necessary facilities at Haneda and begin advance marketing efforts to ensure the successful start of these important new services. Hawaiian is “most pleased” with its award for Honolulu-Haneda. HA at 1. While Hawaiian asserts that it should have received two slot pairs, Hawaiian’s paper is more a “statement of its views on the proceeding . . .” than it is a substantive objection. Id . n.1. The Department carefully considered Hawaiian’s application, but found that Honolulu did not merit a second award at the expense of important mainland gateways including Los Angeles, Detroit, and New York. Continental’s objections are devoted entirely to a request for backup authority. However, as is its modern trend, the Department declined to select a backup carrier: “We have tentatively decided not to award backup authority in this case. Our awards here are directly tied to the diverse public interest concernsDelta Answer to Objections Page 2 needing to be addressed in the circumstances presented, taking into account the relative merits of the specific proposals before us in terms of addressing those concerns. Against this background, should any of the selected carriers not begin its proposed services, we tentatively find that the public interest would be best served by allowing us to award any unused rights on the basis of a fresh record.” Order 2010-5-7 at 12

Delta believes the Department’s decision was a correct one, especially taking into account the unique circumstances of this case. First, the selected carriers are well positioned to begin these important new services and the potential need for a backup carrier is very remote. Second, the Department’s decision was based on “eachapplication’s merits and have not been considered in conjunction with, nor have we prejudged the outcome of the oneworld (American/JAL) and Star (Continental/United/ANA) applications for antitrust immunity pending before the Department.” Id . n.28. Should the United/Continental/ANA antitrust application be approved, Continental’s Star ATI alliance will be the largest player in the U.S.-Japan marketplace. This is a consideration that the Department would understandably want to evaluate on the basis of a fresh record in the unlikely event it needs to select a backup carrier. United’s objections are without merit. United does not dispute that Los Angeles is a larger market than San Francisco. But, United persists in its specious claim that Delta would offer no connections beyond Los Angeles, other than to Las Vegas. This claim is clearly false, and, as recognized by the Department, Delta and Alaska/Horizon have a comprehensive domestic marketi ng alliance that will enhance connecting opportunities for Delta passengers. Id. at 9. While United argues that Delta would offer too few connections at Los Angeles, it then argues, incongruently, that Delta would offer too many connections at Detroit relative to the local market. Delta agrees with the Department that “there is a need to provide central and eastern U.S. passengers with access to Tokyo’s downtown airport. Detroit has proven for decades to be a strong hub for Japan and Asia services, and isDelta Answer to Objections Page 3 well-situated geographically to maximize connecting services. The broad catchment area, in combination with traffic from the local Detroit-Tokyo O&D market, should further provide a substantial traffic base to support Delta’s proposed Detroit-Haneda service.”

Show Cause Order at 10.The vast majority of Delta’s Detroit-Haneda connections are convenient, welltimed and non-circuitous. DL-112, DL-117-120. In its exhibits, Delta provided all available connections within a six hour window to fully illustrate the breadths of service from the hub. But this does not imply, as United suggests, that any significant number of passengers would have “to wait five or more hours for a connection at Detroit . . .” UA at 9. Rather, the Detroit service the Department has authorized will ensure maximum Haneda convenience and connectivity for the greatest number of U.S. cities. Finally, United argues that Delta should be disfavored because it has a large hub a Narita. Once again, United contradicts its own argument, claiming, a few pages earlier that “all of the applicant in the pr oceeding would be ‘new entrants’ at HND, so

Hawaiian is not entitled to favored treatment in the U.S.-Haneda market . . .” UA at 4. Moreover, as noted above, should the 3-way United/Continental/ANA ATI application be approved, United’s Star alliance would be the largest player in the U.S-Tokyo market. In sum, the Objections of United, Continental and Hawaiian provide no basis to disturb the Department’s tentative findings, wh ich Delta urges be confirmed as quickly as possible in a Final Order. Respectfully submitted,

_________________________________ Alexander Van der Bellen Managing Director, Government Affairs & Associate General Counsel DELTA AIR LINES, INC.CERTIFICATE OF SERVICE A copy of the foregoing document has been served this 24th day of May, 2010, upon the following persons via email:

carl.nelson@aa.com dan.weiss@coair.com hershel.kamen@coair.com rbkeiner@crowell.com mrosia@crowell.com gmurphy@crowell.com jeffrey.manley@united.com julie.oettinger@united.com howard.kass@usairways.com benjamin.slocum@usairways.com jhill@dowlohnes.com ldeavers@dowlohnes.com perkmann@dowlohnes.com dmendersbee@zsrlaw.com todd.homan@dot.gov paul.gretch@dot.gov keith.glatz@dot.gov esta.rosenberg@dot.gov byerlyjr@state.gov eugene_alford@ita.doc.gov joe.cambron@wcaa.us ishiwata.k@portseattle.org safora.i@portseattle.org mike.orr@airlineinfo.com