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-

0186

ANSWER OF WAYNE COUNTY AIRPORT AUTHORITY

Communications 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 Authority

L.C. Smith Terminal

Detroit, MI 48242

July 29, 2010
Docket OST-2010-0186

2

BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Application of 

DELTA AIR LINES, INC.

 

for a frequency allocation 

(Detroit-Sao Paulo, Brazil)

)

)

)

)

)

)

)

Docket DOT-OST-2010-

0186

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 Application 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 

The WCAA is extremely pleased that Delta has announced new service from DTW to Sao 

Paulo commencing in October 2010, but is 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 revenue2. With nearly $20 million in annual passenger revenue,

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 “awarding 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

Sabre MIDT YE1Q2009
Docket OST-2010-0186

3

Despite the size of the Detroit-Brazil market, the two flights per week planned to commence 

this 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 in 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, Brazil is a key market for Detroit's recovering auto industry, and 

that link has driven steady growth in this route. General Motors officials already have commented 

publicly that this 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. An increase from two flights per week to five would go a long way toward resolving 

those customer issues. As a result, it is important that Detroit not only gains service to Sao Paulo, but 

also has 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 additional 

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 create approximately $107 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 to 
Docket OST-2010-0186

4

other 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 Paulo. 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 an interminal 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. DTW 

has vaulted 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 United 

States for overall customer satisfaction by J.D. Power & Associates. Other airports 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 Greif

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 helping stem the negative effects of problems in Detroit's other core industries. DTW reported 
Docket OST-2010-0186

5

a five percent increase in year-over-year originating traffic in November 20093(Exhibit DTW-C). By 

comparison, the rest of the country on average saw a 1% reduction during the same period. Only three 

large 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% over 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 $107 million in annual 

economic impact for the State 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 Airlines’ 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 shouldn’t be followed up with another award of three more unrestricted frequencies, 

which would foreclose Delta’s ability to increase Sao Paulo service from Detroit. However, we note 

that American has now submitted an alternate service proposal to utilize the three northern/regional 

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 American’s request.

Closing

Once again the Department of Transportation (“DOT”) has a unique opportunity to support 

the development of viable service at a new Midwestern gateway offering competitive service to Brazil. 

 

3

Sabre MIDT data
Docket OST-2010-0186

6

The improving economy of Michigan needs the additional momentum these flights would bring. Aside 

from auto manufacturing, the potential for greater 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 operations per week. 
Docket OST-2010-0186

7

Certificate of Service

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

sascha.vanderbellen@delta.com

carl.nelson@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