BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Application of DELTA AIR LINES, INC. for a frequency allocation ( Atlanta/ Detroit

- Brazil) ) ) ) ) ) ) ) Docket DOT

- OST

- 2010

- 0 186

ANSWER OF WAYNE COUNTY AIRPORT AUTHORITY

Co mmunications with respect to this document should be addressed to: Genelle M. Allen Interim Chief Executive Officer Emily K. Neuberger Senior Vice President and General Counsel Joe M. Cambron Director, Air Service Development Wayne County Airport Auth ority L.C. Smith Terminal Detroit, MI 48242
July 2 9 , 2010Docket OST

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### 2 BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Application of DELTA AIR LINES, INC. for a frequency allocation (Detroit

- Sao Paulo, Brazil) ) ) ) ) ) ) ) Doc ket DOT

- OST

- 2010

- 0 186

ANSWER OF WAYNE COUNTY AIRPORT AUTHORITY

The Wayne County Airport Authority (“WCAA”), which operates Detroit Metropolitan Wayne County Airport (“DTW”) , hereby answers in strong support of the Applicat i on of Delta Air Lines, Inc

. (“Delta”) in the captioned docket which would ultimately allow an increase to five flights per week from Detroit to Sao Paulo. 1

Th e WCAA is extremely pleased that Delta has announced new service from DTW to Sao Paulo commencing in October 2010, but i s concerned that the limited two flights per week schedule is insufficient to serve this important business

- oriented market

. Detroit

- Sao Paulo is Detroit's largest unserved market as ranked by local revenue 2 . With nearly $20 million in annual passenger r evenue , the Detroit

- Sao Paulo market has long needed non

- stop service. Over 15,000 passengers traveled between Detroit and Sao Paulo in the last 12 months.

1 For the purpose of simplicity, henceforth we will refer to “awa rding the frequencies to Detroit”, although it should be stated that we are effectively asking the Department to award the frequencies to Atlanta so that they may be swapped in such a way that results in Detroit gaining the same number of frequencies.

2 S abre MIDT YE1Q2009Docket OST

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### 3 D espite the size of the Detroit

- Brazil market, the two flights per week planned to commence th is October are not only Michigan’s only non

- stop service to Brazil , but Michigan’s first ever non

- stop service to Brazil. As ranked by revenue, Detroit is presently among the four largest unserved Sao Paulo markets from the USA and is the only large hub i n that group. WCAA urges the Department to foster and promote the goal of creating a new viable gateway, by awarding Delta three additional frequencies that would enable Detroit to have five flights per week to Sao Paulo

.

Putting aside the statistics , Br azil is a key market for Detroit's recovering auto industry , and that link has driven steady growth in this route. G eneral M otors officials already have commented publicly that th is new service will be a boon to further business development between Brazil and the United States, but have expressed the need for daily air service to support their routine business travel needs. A n increase from two flights per week to five would go a long way toward resolving those customer issues. As a result, it is importa nt that Detroit not only gain s service to Sao Paulo, but also ha s a schedule suitable for business travelers now connecting via other gateways. As currently proposed, Delta only would be able to operate two flights per week without the award of the additi onal frequencies it is seeking. This "deeper" schedule is particularly important in a business

- oriented market as evidenced by GM's comments. The business ties that a suitable business

- oriented schedule (of five operations per week) would afford would cr eate approximately $1 07 million in annual economic impact , which is of vital importance to the Michigan economy.

Detroit's extensive catchment area , combined with DTW’s modern, state

- of

- the

- art McNamara Terminal, will allow an entirely new region to enjoy the benefits of non

- stop Brazilian service, while maximizing passenger comfort, convenience, and competition.

A Key Link for the Recovering Auto Industry

Detroit's role at the center of the global auto industry has created extensive traffic flows toDocket OST

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### 4 o ther auto production and design centers around the globe . GM's Tech Center in Sao Paulo employs 8,000 people, including 1,300 engineers who routinely need to visit GM's four other Tech Centers around the world to fully coordinate numerous design projects. In the last year , GM has announced plans to invest an additional $1 billion in its Brazilian operations , including a new engine and components plant. GM previously had three production facilities in Brazil with employment largely clustered around Sao Pa ulo. Ford also has four production plants in Brazil , and in 2009 began exporting Ford Escorts from Brazil back to the United States for sale here.

Detroit is the Most Efficient and Customer Friendly Gateway

DTW 's McNamara Terminal offers state

- of

- the

- art customer conveniences including a n in

terminal passenger train to ease movement within the facility for passengers with tight connections. The McNamara Terminal opened in 2002 and was joined by the new North Terminal in 2008. D TW has vault ed to the upper echelon of American airports , and has been well reviewed by both passengers and the pundits. On February 21, 2010, DTW was recognized as the #1 large airport in the U nited States for overall customer satisfaction by J.D. Power & Associates. Other a irports like Newark landed near the bottom of the list. "If you are flying from Newark and you're frustrated for some reason or another, and you land in Detroit, you say, 'Wow,' and scratch your head and ask 'Why can't Newark be like this?'"

- Stuart Grei f VP and general manager of the Global Travel and Hospitality Practice at J .D. Power

The Economic Benefit to Detroit

Throughout Southeast Michigan's economic ups

- and

- downs, DTW has remained an economic anchor help ing stem the negative effects of problems in Detroit's other core industries. DTW reportedDocket OST

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### 5 a five percent increase in year

- over - year originating traffic in November 2009 3 (Exhibit DTW

- C). By comparison, the rest of the country on average saw a 1% reduction during the same period. Only three la rge U.S. airports saw increases in originating revenue in November 2009 compared to the prior year. Positive trends continue into 2010 as Detroit O&D revenue continues to turn around. In June 2010 , Sabre reports that Detroit O&D revenue grew by 14.1% ove r the same month in the prior year.

The key issue for Detroit relates to economic impact and its effect on jobs. The WCAA believes that five times per week Detroit

- Sao Paulo service will produce around $1 07 million in annual economic impact for the Stat e of Michigan and as many as 215 direct jobs. Additionally, those new jobs would see high average pay typical of airline jobs. Indirectly, hundreds more jobs would be fostered by tourism generated by the flight.

Application of American Airlines

With American Airline s ’ existing allocation of an unprecedented 58 unrestricted Brazil frequencies, it would almost seem unnecessary to argue why the recent award of 11 more frequencies to American should n’t be followed up with another award of three more unre stricted frequencies, which would foreclose Delta’s ability to incre a se Sao Paulo service from Det r oit

. However, we note that American has now submitted an alternate service proposal to utilize the three northern/regio n al frequencies recently returned by Delta. Thus, the Department has the opportunity to fund Delta’s proposal for three additional Detroit

- Sao Paulo flights, while also accommodating Americ a n’s request.

Closing Once again t he D epartment of Transportation (“DOT”) has a unique opportunity t o support the development of viable service at a new Midwestern gateway offering competitive service to Brazil

.

3 Sabre MIDT dataDocket OST

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### 6 T he improving economy of Michigan needs the additional momentum these flights would bring. Aside from auto manufacturing, the potential for g reater ties between the two areas is as boundless as the imagination. From agriculture to ethanol to coffee, new business connections have the potential to create many more jobs in Michigan. This highway in the sky will foster other businesses in exactly the same way a new exit from a major interstate would , but to much greater effect. Therefore, we respectfully ask that the DOT allocate Delta three additional frequencies as proposed by Delta allowing Detroit to operate a competitive schedule of five op erations per week

.Docket OST

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### 7 Certificate of Service

The foregoing document has been served by email on the following persons:


### sascha.vanderbellen@delta.com carl.nelso n@aa.com howard_kass@usairways.com benjamin.slocum@usairways.com hkamen@coair.com dan.weiss@coair.com rbkeiner@crowell.com jeffrey.manley@united.com steve.morrissey@united.com robert.land@jetblue.com jhill@dlalaw.com dkirstein@yklaw.com jyoung@yklaw.com paul.gretch@dot.gov esta.rosenberg@dot.gov brian.hedberg@dot.gov byerlyjr@state.gov john.allen@faa.gov mgoldman@sgbdc.com info@airlineinfo.com