BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

___________________________________________ Joint Application of )

)

Delta Air Lines, Inc., )

Virgin Blue Airlines PTY LTD; )

Virgin Blue International Airlines PTY )

LTD d/b/a V A ustralia; )

Pacific Blue Airlines (NZ) LTD; and ) Docket DOT

- OST

Pacific Blue Airlines (AUST) PTY LTD ) 2009

- 0155

)

U nder 49 U.S.C. §§ 41308 and 41309 for Approval )

of and Antitrust Immunity for Alliance Agreements )

______________

_____________________________ )

DELTA MASTER EXECUTIVE COUNCIL

OF THE

AIR LINE PILOTS ASSOCIATION, INTERNATIONAL

MOTION FOR LEAVE TO FILE

To the extent necessary, the Delta Master Executive Council of the Air Line Pilots

Association, Intern ational (“Delta Pilots’ MEC”) requests leave to submit the attached

Answer which was submitted to the Department on March 25, 2010 but was inadverte ntly

not served on all parties. No delay or prejudice will result from consideration of the

comments of the Delta Pilots' MEC, which will contribute to a full and complete record

for decision. This document is being served on all parties.

Respectfully submitted,

Captain Donald L. Moak

Chairman

Delta Master Executive Council

Air Line Pilots Association, International

Dated: April 2 , 2010BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

___________________________________________ Joint Application of )

)

Delta Air Lines, Inc., )

Virgin Blue Ai rlines PTY LTD; )

Virgin Blue International Airlines PTY )

LTD d/b/a V Australia; )

Pacific Blue Airlines (NZ) LTD; and ) Docket DOT

- OST

2009

- Pacific Blue Airlines (AUST) PTY LTD ) 0155

)

U nder 49 U.S.C. §§ 41308 and 41309 for A pproval )

of and Antitrust Immunity for Alliance Agreements )

___________________________________________ )

ANSWER OF D ELTA M ASTER E XECUTIVE C OUNCIL

OF THE

A IR L INE P ILOTS A SSOCIATION , I NTERNATIONAL

IN SUPPORT OF THE JOINT APPLICATION

The Delta Mast er Executive Council of the Air Line Pilots Association,

International (“Delta Pilots’ MEC”) strongly supports the Joint Application of Delta Air

Lines, Inc. (“Delta”), Virgin Blue Airlines Pty Ltd (“Virgin Blue”)

, Virgin Blue

International Airlines Pty Lt d (“V Australia”)

, Pacific Blue Airlines (NZ) Ltd, and Pacific

Blue Airlines (Aust) Pty Ltd ( collectively the “Joint Applicants”) for antitrust immunity

for alliance agreements (the “proposed Alliance”) . ALPA represents the pilots at Delta,

and the Delta p ilots’ MEC is the governing body within ALPA with direct responsibility

for matters concerning the Delta pilots. The Delta pilots’ MEC has great interest in thisproceeding because the Department’s decision will have a significant impact on the

livelihood s and career expectations of Delta pilots and all employees of the company.

The Delta Pilots’ MEC urges the Department to act promptly in granting the

requested immunity. We believe it will have the potential to enhance the health and

growth of a U.S. air carrier, expand opportunities for American workers, and provide

significant benefits to the U.S. public.

The Joint Applicants have made a compelling case that antitrust immunity will

enable the proposed Alliance to provide increased competition in t he U.S.

- Australia and

U.S.

- South Pacific markets which are currently dominated by Qantas, United and their

respective One World and Star Alliance partners. The Department has repeatedly found

that anti

- trust immunity for airline alliances can result in enh anced competition,

new/additional services, and improved convenience for travelers. Delta’s comprehensive

U.S. domestic service

, including significant non

- stop service from its Los Angeles

gateway, when combined with the Virgin carriers’ Australian domesti c, New Zealand and

S outh P acific service

, would mesh complementary networks and thus offer increased

competition and concomitant benefits to the traveling public. Neither Delta nor the Virgin

carriers alone, as new entrants in the relevant markets, can cha llenge the incumbent

carriers as effectively as the proposed Alliance could with antitrust immunity.

The Delta Pilots’ MEC is confident that the approval of antitrust immunity

for this proposed alliance will facilitate the success of Delta’s entrance int o the U.S

Australia market and provide real possibilities for the expansion of Delta’s international

flying to Australia and the South Pacific

. T his expansion of international flying will inturn increase the demand for seats on Delta’s domestic flights f eeding its international

gateways, further increasing the opportunities for Delta workers and the benefits to the

U.S. traveling public at large.

Any new or expanded service Delta is able to provide should bring significant

benefits to the traveling public and to American workers. New Australia and South

Pacific flights generate substantial economic, trade, and cultural benefits for the

communities served. The new domestic flying w ould bring additional air transportation

services to communities served th roughout Delta’s network. All such expansion will

create new opportunities for Delta flight crews and other Delta employees throughout the

country.

The requested immunity will also help protect American jobs and American

interests by improving the abi lity of Delta to compete effectively in the U.S.

– Australia

and U.S.

- South Pacific market s against other global carriers and global alliances. As

amply demonstrated in the Joint Application, Qantas and United and their respective

alliances are formidable competitors. It is critical that Delta be equipped to compete

effectively with them

. The requested antitrust immunity will help ensure that Delta is a

vigorous competitor in the U.S.

- Australia and the U.S.

- South Pacific market s benefitting

the traveling public and the thousands of U.S. workers who depend upon Delta for their

livelihoods.

For all of these reasons, Delta Pilots’ MEC urges the Department to approve the

alliance agreements under review and grant antitrust immunity to the Joint Applicants

w ithout further delay.

Respectfully submitted,Captain Donald L. Moak

Chairman

Delta Master Executive Council

Air Line Pilots Association, International

Dated:

__ March 25, 2010

__________CERTIFICATE OF SERVICE

A copy of the foregoing was served on this 2 nd day of April 2010, upon the following

persons via email:

msinick@ssd.com

carl.nelson@aa.com

jrichardson@johnlrichardson.com

anbird@fedex.com

sllunsford@fedex.com

matwood@sherblackwell.com

tom.lydon@evergreen.com

charters@evergreenai rlines.com

rpommer@atlasair.com

kevin.montgomery@polaraircargo.com

ldwasko@starpower.net

lachter@starpower.net

howard_kass@usairways.com

benjamin.slocum@usairways.com

dvaughan@kellydrye.com

dfisher@kelleydrye.com

hkamen@coair.com

dan.weiss@coair.com

jeffre y.manley@united.com

julie.oettinger@united.com

mcmillin@woa.com

mlbenge@zsrlaw.com

jhill@dlalaw.com

byerlyjr@state.gov

john.allen@faa.gov

todd.homan@dot.gov

peter.irvine@dot.gov

christopher.mandel@dot.gov

Jill.Ptacek@usdoj.gov

sascha.vanderbellen@delta.com

jeff.morgan@delta.com

Anita.mosner@hklaw.com

Sophy.chen@hklaw.com

mike.orr@airlineinfo.com