BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

In the matter of 

2010 U.S.-Haneda Combination Services

Allocation Proceeding

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Docket DOT-OST-2010-0018 

CONSOLIDATED RESPONSE OF DELTA AIR LINES, INC.

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

DELTA AIR LINES, INC. 

1212 New York Avenue, N.W. 

Washington, D.C. 20005

(202) 842-4184

sascha.vanderbellen@delta.com

August 9, 2012
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

In the matter of 

2010 U.S.-Haneda Combination Services

Allocation Proceeding

)

)

)

)

)

)

)

Docket DOT-OST-2010-0018 

CONSOLIDATED RESPONSE OF DELTA AIR LINES, INC.

Delta hereby responds to the answers submitted by American, Hawaiian and United 

to the motion of Delta to authorize it to move its Detroit-Haneda slot pair to the SeattleHaneda route.1 Delta further notes that its motion has the support of the entire 

Congressional delegation of Washington State, the Governor of the State of Washington, 

the Port of Seattle, the Master Executive Counsel of the Airline Pilots Association, 

International, Delta Chapter and Alaska Airlines. 

Delta is a strong competitor in the U.S.-Tokyo market, but faces unique challenges at 

Haneda, because Delta is the only major alliance carrier without a Japanese ATI partner 

operating at that airport. Haneda is heavily dominated by the hub operations of ANA (Star), 

and JAL (oneworld). To maintain effective competition at the Haneda airport, it is very 

important that Delta be allowed to maintain its Haneda slots and improve its service offering 

by operating at the Seattle gateway.

While Delta believes that the Department would be well justified in approving Delta’s 

flexibility request on the basis of the existing record, Delta stands ready to demonstrate the 

 1 Delta seeks leave to file this response as its acceptance will enhance the record on which 

the Department will render a decision on Delta’s motion.
Delta Consolidated Response

Page 2

merits of its Seattle proposal in any further carrier selection proceedings that the 

Department deems necessary. 

American states that if gateway flexibility is granted Delta, other carriers serving 

Haneda should be permitted to change gateways based on prevailing market conditions. 

Delta has no objection were the DOT to take this approach and authorize all Haneda 

carriers the flexibility to assign Haneda slots to the best gateway as determined by each 

carrier.

Hawaiian states that the Delta motion should be denied, and indicates its desire to 

seek additional slots for Haneda-Honolulu service. At this stage, Delta would simply note 

that Hawaiian has unlimited open skies authority to provide Honolulu-Tokyo service (at 

Narita), but Hawaiian appears interested only in serving the limited entry airport. Delta is 

prepared to demonstrate why maintaining effective alliance competition through its Seattle 

proposal is a superior public interest choice. 

United would have the Department ignore the fact that United is in an immunized 

joint venture arrangement with ANA, the carrier with the single largest hub operation at 

Haneda. ANA is free to use its Haneda slots to serve any gateway in the U.S. -- and to that 

extent United has unparalleled flexibility to offer Haneda service to its customers at San 

Francisco or any other gateway of its choosing through its partner ANA. United, however, 

states that it seeks to serve Haneda “with its own aircraft” as if the concept of metal 

neutrality had no meaning. 

It is worth recalling the benefits of metal neutrality found by the DOT, as urged upon 

it by United and ANA:

Metal neutrality eliminates these barriers [to investing in service improvements] by 

allowing carriers to value revenue on the network instead of revenue on their 

individual aircraft (metal). With immunity, carriers can achieve these efficiencies and 

pass benefits on to consumers. (Order 2010-10-4, Docket OST-2010-0059, page 14)
Delta Consolidated Response

Page 3

United now acts as if its immunized alliance relationship is of no benefit to it and that there is 

an economic difference depending on which of the alliance carriers serve the San 

Francisco-Haneda route. If United is now of the view that metal neutrality in the United-ANA 

alliance is not producing the public benefits the DOT found to be the case, as urged upon it 

by United, this would be a serious cause for concern requiring further careful scrutiny by the 

Department.

 Respectfully submitted,

_________________________________

Alexander Van der Bellen

Managing Director, Government Affairs

 & Associate General Counsel

DELTA AIR LINES, INC.

August 9, 2012
CERTIFICATE OF SERVICE

A copy of the foregoing document has been served this 9th day of August, 2012, upon 

the following persons via email:

Francis.Heil@aa.com

Robert.Wirick@aa.com

dan.weiss@united.com

thomas.bolling@united.com

lhalloway@crowell.com

gmurphy@crowell.com

howard.kass@usairways.com

benjamin.slocum@usairways.com

jhill@dowlohnes.com

paul.gretch@dot.gov

keith.glatz@dot.gov

esta.rosenberg@dot.gov

todd.homan@dot.gov

urskr@state.gov

eugene_alford@ita.doc.gov

info@airlineinfo.com

Tim.OMalley@alpa.org

Ishiwata.K@portseattle.org

Safora.I@portseattle.org

Kyle.Levine@alaskaair.com

Megan.Lawrence@alaskaair.com