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

.
Communications wit h 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 DE LTA 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

– G overnment 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 , 2012BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

In the mat ter 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 mot ion of Delta to authorize it to move its Detroit

- Haneda slot pair to the Seattle

Haneda 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 Por t 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 a llowed 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 res ponse 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 permit ted 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 s tates 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

Nar ita), 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 D epartment 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

neut rality 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 o n 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 t he 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, 2012C ERTIFICATE OF SERVICE

A copy of the foregoing document has been ser ved this 9 th 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

be njamin.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