BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

 DELTA AIR LINES, INC. 

 

2010 U.S.-Haneda Combination Services 

Allocation Proceeding 

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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, 2010 
 

BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

 DELTA AIR LINES, INC. 

 

2010 U.S.-Haneda Combination Services 

Allocation Proceeding 

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) 

) 

) 

) 

) 

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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 concerns 
Delta 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 “each 

application’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 marketing 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 is 
Delta 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 proceeding 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, which 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