BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

Application of DELTA AIR LINES, INC. for an allocation of U.S.-China frequencies (Detroit-Beijing and Tokyo-Guangzhou) ) ) ) ) ) ) ) ) Docket DOT-OST-2010-0285

REPLY OF DELTA AIR LINES, INC. AND REQUEST FOR EXPEDITED ACTION

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 Jeff Morgan Regional Director – Government Affairs DELTA AIR LINES, INC. 1212 New York Avenue, N.W. Washington, D.C. 20005 (202) 842-4184 sascha.vanderbellen@delta.com

November 18, 2010BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

Application of DELTA AIR LINES, INC. for an allocation of U.S.-China frequencies (Detroit-Beijing and Tokyo-Guangzhou) ) ) ) ) ) ) ) ) Docket DOT-OST-2010-0285

REPLY OF DELTA AIR LINES, INC. AND REQUEST FOR EXPEDITED ACTION

Delta seeks 12 China frequencies from the available and unallocated pool so that it may open a new east coast gateway to Beijing from Detroit and to provide the only U.S. flag service to Guangzhou. Delta polled all U.S. carriers and received “no objections” from all

but one carrier -- American. American does not propose any new service to China that would require additional frequencies. In fact, American (and United) were each recently awarded seven China frequencies for Los Angeles-Shanghai to fully fund their 2011 schedules. The Department acted on American’s and United’s applications in less than a week. Despite having no competing proposal of its own, American opposes Delta's request “as a matter of sound principle.” American urges that Atlanta and Seattle be stripped of their allocations before Delta is awarded any additional frequencies to fund its new services. There is no merit to American's suggestion, which is contrary to the public interest and contrary to the Department’s intent when it granted the dormancy waivers. The Department previously found that At lanta-Shanghai and Seattle-Beijing service is in the public interest -- and granted waivers specifically to preserve Delta's ability to offer service at those gateways. Delta is maki ng clear and substantial progress to deliveringReply of Delta and Request for Expedited Action Page 2 those benefits -- and is now offering five weekly Seattle-Beijing flights and has just announced the resumption of two weekly Atlanta-Shanghai flights. Given the absence of a competing proposal by American, and the non-objection of every other U.S. carrier authorized to serve China, there is no reason to foreclose Delta's ability to increase service

on these routes. With China Eastern joining SkyTeam, Delta believes there is the significant potential for increased service on the Atlanta-Shanghai hub-to-hub alliance pipeline route. At Seattle, following nearly a year's effort, Delta was able to improve its Beijing slot times, which will improve the performance and viability of additional frequencies on the Seattle-Beijing route. As the Department and American are well aware, commercially viable slot times are an important element of introducing new service at China's congested airports. If Delta is stripped of its Atlanta-Shanghai and Seattle-Beijing frequencies, Delta's ability to proactively engage with CAAC for the necessary slots to accommodate service increases will be undermined -- because it will no longer hold the necessary DOT authority to operate. While it may be in American's commercial interest to frustrate Delta's ability to introduce new China service, it is not in the public interest and is contrary the Department’s purpose in granting the waivers. Delta is not seeking to "warehouse" frequencies. It is seeking the ability to timely introduce new service on important routes where the Department has already found a waiver was justified. There are more than enough frequencies to accommodate Delta's request (and indeed all U.S. carrier China requests). There are substantial frequency increases in each of 2011 and 2012 with a total of 30 available China frequencies in the near term. Delta does not believe there is currently any material issue of scarcity, and should it become an issue inReply of Delta and Request for Expedited Action Page 3 the future, the Department will have ample opport unity to address that in dormancy waiver extensions (if all frequencies are not being operated). Time is of the essence. As noted, American and United were each granted new China frequencies in less than a week's time. It would be unfair to Delta to delay its ability to market new China services. The next GDS load is to take place on Saturday, November 27, 2010, and Delta's marketing efforts will be compromised if it is not able to load its services at that time. Accordingly, Delta respectfully requests a Department decision by close of business on Monday, November 22 to enable Delta to make the Tuesday morning November 23 submission deadline for the Saturday, November 27 GDS load. For the foregoing reasons, Delta urges that it be granted 12 frequencies. If, however, the Department does not grant the request in full, Delta requests in the alternative that its unopposed request for five frequencies be granted -- together with the flexibility to use its allocated Atlanta-Shanghai frequencies on any eligible U.S.-China route.

Respectfully submitted,

_________________________________ Alexander Van der Bellen Managing Director, Government Affairs & Associate General Counsel DELTA AIR LINES, INC.CERTIFICATE OF SERVICE A copy of the foregoing document has been served this 18th day of November, 2010, upon the following persons via email:

carl.nelson@aa.com dan.weiss@coair.com hershel.kamen@coair.com jeffrey.manley@united.com steve.morrissey@united.com howard.kass@usairways.com benjamin.slocum@usairways.com nssparks@fedex.com gbleopard@fedex.com dfisher@kelleydrye.com (for UPS) esauer@ssd.com (for Evergreen) rpommer@atlasair.com kevin.montgomery@polaraircargo.com paul.gretch@dot.gov keith.glatz@dot.gov esta.rosenberg@dot.gov UrsKR@state.gov info@airlineinfo.com