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 Australia; )

Pacific Blue Airlines (NZ) LTD; and ) Docket DOT- OSTPacific Blue Airlines (AUST) PTY LTD ) 2009-0155 

)

Under 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, International (“Delta Pilots’ MEC”) requests leave to submit the attached 

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

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, 2010
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 Australia; )

Pacific Blue Airlines (NZ) LTD; and ) Docket DOT- OST2009- Pacific Blue Airlines (AUST) PTY LTD ) 0155 

)

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

of and Antitrust Immunity for Alliance Agreements )

___________________________________________ )

ANSWER OF DELTA MASTER EXECUTIVE COUNCIL

OF THE

AIR LINE PILOTS ASSOCIATION, INTERNATIONAL

IN SUPPORT OF THE JOINT APPLICATION

The Delta Master 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 Ltd (“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 pilots’ MEC is the governing body within ALPA with direct responsibility 

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

livelihoods 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 the 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 enhanced 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 domestic, New Zealand and 

South Pacific 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 challenge 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 into the U.SAustralia market and provide real possibilities for the expansion of Delta’s international 

flying to Australia and the South Pacific. This expansion of international flying will in 
turn increase the demand for seats on Delta’s domestic flights feeding 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 would bring additional air transportation 

services to communities served throughout 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 ability of Delta to compete effectively in the U.S. –Australia 

and U.S.-South Pacific markets 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 markets 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 

without 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@evergreenairlines.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

jeffrey.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