BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

DELTA AIR LINES, INC. 

 

for a frequency allocation 

(Atlanta/Detroit - Brazil) 

) 

) 

) 

) 

) 

) 

) 

Docket DOT-OST-2010- 

APPLICATION OF DELTA AIR LINES, INC. 

Communications with respect to this document should be addressed to: 

 

Glen Hauenstein 

Executive Vice President – 

Network Planning and Revenue Management 

Robert J. Cortelyou 

Senior Vice President – Network Planning 

Andreas Renner 

Director – International Network Planning 

Chris Kennedy 

General Manager – International 

Network Analysis 

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

July 23, 2010 

 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

DELTA AIR LINES, INC. 

 

for a frequency allocation 

(Atlanta/Detroit - Brazil) 

) 

) 

) 

) 

) 

) 

) 

Docket DOT-OST-2010- 

APPLICATION OF DELTA AIR LINES, INC. 

I. Introduction 

Delta Air Lines, Inc. (“Delta”) hereby applies for an allocation of three 

(3) frequencies to support additional nonstop Brazil services between Atlanta and Detroit, 

on the one hand, and Rio de Janeiro and Sao Paulo, Brazil, on the other hand. There 

are three frequencies currently available in the unallocated pool which are eligible for 

service in any U.S.-Brazil city-pair market, subject to the temporary restriction that they 

may not be used at Sao Paulo until certain airport infrastructure constraints are resolved. 

Consistent with these terms, Delta would use the requested frequencies to provide three 

weekly round-trip flights between Atlanta and Rio de Janeiro, effective October 28, 2010. 

Upon the effectiveness of this new authority, Delta plans to redeploy three of its 

existing unrestricted frequencies from the Atlanta-Rio de Janeiro route to Detroit-Sao 

Paulo. This will enable Delta to commence its planned new Detroit-Sao Paulo flight with 

five weekly frequencies, rather than the very limited two frequency pattern currently 

planned. Delta’s existing Atlanta-Rio de Janeiro frequencies are not subject to any citypair limitations, nor are they subject to the temporary airport infrastructure constraints at 
Application of Delta 

Page 2 

Sao Paulo. Thus, these frequencies are currently and immediately eligible for service on 

the Detroit-Sao Paulo route. 

Delta believes that the public interest would be well served by its proposal. It is 

very important that Delta be able to offer a viable service pattern at Detroit, which 

requires at least five weekly frequencies. Detroit is a major industrial-manufacturing 

center and is home to Delta’s second-largest hub, providing extensive coverage of the 

Midwest region and Northern tier of the United Sates. 

Delta previously announced that it plans to introduce Detroit-Sao Paulo service in 

October 2010 at a level of two weekly flights. However, two weekly flights is not enough 

to meet the demands of this important business market, nor to enable Detroit to provide 

effective intergateway competition to existing U.S.-Sao Paulo gateways – all of which 

have at least daily service. Delta’s hope and expectation in making a start-up 

investment in Detroit-Sao Paulo is that Delta would be able to grow the service from the 

initial two weekly flights to provide a more comprehensive and effective service pattern 

as Sao Paulo-eligible frequencies became available. 

Delta’s service proposal will maximize the public benefits attainable from these 

limited entry frequencies. There is greater demand for service to Sao Paulo, Brazil’s 

leading business center, than for Rio de Janeiro, which is primarily a leisure destination. 

By allocating the three available frequencies to Delta for Atlanta-Rio de Janeiro service, 

the Department will, in effect, be able to create three new flights to Sao Paulo. Moreover, 

because Delta is currently constrained to offering a sub-optimal pattern of just two 

weekly flights at Detroit, the benefits attained from these two existing frequencies will be 

substantially enhanced as part of a more effective five-frequency pattern. 
Application of Delta 

Page 3 

II. Service Proposal 

Delta proposes to operate three additional weekly U.S.-Brazil frequencies, 

effective October 28, 2010, or within 90 days of receiving all necessary government 

approvals. Delta will utilize 216-seat Boeing 767-300ER aircraft, equipped with 35 

BusinessElite and 181 economy class seats. 

 Delta’s Atlanta-Rio de Janeiro service will directly use the requested 

frequencies without any changes to the existing service pattern. 

 Delta will redeploy three unrestricted frequencies from Atlanta to DetroitSao Paulo, enabling Delta to begin new nonstop service on the route at a 

level of five weekly frequencies, rather than two as currently scheduled. 

Delta's proposed nonstop service schedule, operating statistics, and aircraft information 

are set forth in the attached exhibits. 

III. Delta Requires Sufficient Frequencies to Establish Detroit as 

a New and Effective Gateway For U.S.-Sao Paulo Passengers. 

Delta seeks to establish Detroit as a new gateway for U.S.-Sao Paulo service. 

Detroit and Sao Paulo are each major industrial-manufacturing centers with strong 

communities of interest and a significant demand for nonstop service. Detroit is also 

home to Delta’s second-largest hub, where Delta and its regional affiliates operate more 

than 575 peak day departures from the hub and will provide nonstop-to-nonstop service 

for nearly 100 U.S. cities. DL-101. 

Delta plans to start Detroit-Sao Paulo service in October 2010 with two weekly 

flights. However, in order for Detroit to realize its potential and to enable Detroit to 

compete on par with other hubs, Delta needs additional frequencies to operate at least 
Application of Delta 

Page 4 

five weekly (and preferably daily) flights. Indeed, every other U.S.-Sao Paulo hub has 

daily – or greater service: 

Detroit-Sao Paulo will be an important business route, connecting Detroit and the 

Midwestern region to Brazil’s industrial center. Business passengers require frequent 

and more flexible service, and a twice weekly service pattern is not viable in the long run. 

Major U.S. multinational corporations including Ford and General Motors have 

previously expressed their support and desire for regular, daily service on the route. DL201. Those sentiments were also expressed by the Michigan Congressional delegation, 

and the Wayne Country Airport Authority. Id., Docket OST-2010-0090. Delta’s proposal 

provides the Department with the opportunity to satisfy this important unmet service 

need – and to do so on a concrete, time-definite schedule which the Department found 

lacking in the recently concluded prior proceeding. 
Application of Delta 

Page 5 

III. An Allocation of Three Frequencies to Delta Will Enhance 

Inter-Carrier and Inter-Alliance Competition. 

Delta needs additional frequencies to compete effectively with American, 

United/Continental, and the burgeoning oneworld and Star alliance services between the 

United States and Brazil. In terms of the unrestricted frequencies that are necessary to 

serve Sao Paulo, American has now amassed 58 frequencies – compared to just 23 for 

Delta. DL-104. This more than two-fold limited-entry frequency advantage gives 

American leverage in the U.S.-Brazil marketplace. Having attained this advantage, 

American is intent on preserving it – recently offering up DFW-Rio de Janeiro service 

where it had previously expressed no interest. Delta urges the Department to reject 

these tactics which are plainly intended to occupy the last Sao Paulo-eligible frequencies 

and deprive Delta of the rights it needs to offer competitive service at Detroit. 

United/Continental already have antitrust immunity for international services and 

are engaged in a merger transaction with a combined 35 Sao Paulo-eligible frequencies 

between them. Moreover, Star Alliance partners United and US Airways recently put 

forward a joint proposal to swap Sao Paulo-eligible frequencies between one another, 

putting into play all 42 Sao Paulo-eligible frequencies of the U.S. Star partners. See, 

Docket OST-2010-0183; DL-104. By contrast, Delta has only 23 frequencies at its 

disposal and no other means to acquire the rights it needs to expand service at Detroit. 

IV. Conclusion 

 The Department can significantly enhance competition and consumer benefits 

by allocating the three available U.S.-Brazil frequencies to Delta. With these rights, 

Delta will preserve its existing network while simultaneously expanding its planned new 

service on the Detroit-Sao Paulo route. The additional frequencies will enable Delta to 

commence Detroit-Sao Paulo service in October 2010 at a level of five weekly 
Application of Delta 

Page 6 

frequencies, rather than two. This provides customers with a much more attractive 

service option, and greatly enhances the competitive viability of the service. 

 Respectfully submitted,

_________________________________ 

Alexander Van der Bellen 

Managing Director, Government Affairs 

 & Associate General Counsel 

DELTA AIR LINES, INC. 
TUL TUL TUL

To HNL To HNL To HNL To HNL To HNL To HNL

To ANC To ANC To ANC

BMI BMI BMI

MDW

ORD ORD ORD

PIA PIA PIAPIA

CID CID CID 

SCE SCE SCE 

III

RORORO

MSN MSN MSN

FNT FNT FNT

MBS MBS MBS

GRR GRR GRR

CLE CLE CLE

GRB GRB GRB CWA CWA CWA

ESC ESC ESC

MQT MQT MQT

SDF SDF SDF

EVV EVV EVV

DLH DLH DLH

MSP MSP MSP

DSM DSM

OMA OMA OMA

FSD FSD FSD RST RST RST

SFO SFO SFO

LAX LAX LAX

APN APN APN

ATW

AZO AZO AZO

BUBUBU

BZN BZN BZN

CAK CAK CAK

CIU CIU CIUCIU

CMH CMH CMH CMI CMI CMI

CRW

CVG CVG CVG

DEN DEN DEN DAY DAY DAY

ERI ERI ERI ERI

FWA FWA FWA

ICT ICT ICT ICT

IND IND INDIND

LAN LAN LAN

LAS LAS LAS

LEX LEX LEX

LSE LSE LSE

MCI MCI MCI

MKE MKE MKE

MLI MLI MLI

PDX PDX PDX

PHX PHX PHX

PIT PIT PITPIT

PLN PLN PLN

RORORO

SAN SAN SAN

SBN SBN SBN

SEA SEA SEA

SGF SGF SGF

SLC SLC SLC SMF SMF SMF

SNA SNA SNA

STL STL STL

TOL TOL TOL

TVC TVC TVC

XNA XNA XNA

Source: July 2010 schedules

DTW

Delta’s Detroit-Sao Paulo Service Will Establish a MajorNew Hub Gateway for the Midwest Region
LAX LAX

ORD ORD

ATL ATL

CLCL

IAH IAHIAH IAH

DFW

Delta’s Detroit-Sao Paulo Service Gives the Underserved Midwest Region A Second U.S. Gateway to Brazil

DTW

Existing Brazil Gateway
Detroit Will Be the Only U.S. Carrier Gateway to Sao Paulo With Less Than Daily Service

23

7777777

05

10152025

AA MIA AA DFW AA JFK CO EWR CO IAH UA IAD UA ORD DL ATL DL 

Weekly U.S. Carrier Sao Paulo Frequencies By Gateway

Source: December 2010 schedules
Oneworld and Star Have Far More U.S.-Brazil FrequenciesThan SkyTeam

58

42

23

0

10203040506070

oneworld (American) Star (United/Continental/US

Airways)

SkyTeam 

U.S. Carrier Unrestricted Brazil Combination Frequencies Allocated b

Note: Counts include Oct. 2009 and Oct. 2010 frequencies that are GRU eligible once infrastructure constraints are removed.
Delta’s Detroit – Sao Paulo Nonstop Schedule 

Proposal – Northern Hemisphere Winter Season

DL 205

We/Th/Fr/Sa/Su

Boeing 767-300ER

Flight Number

Frequency

Equipment

DL 2

Mo/Tu/Fr

Boeing 767

1925

0900

10:35

0835

0025

11:1

Detroit (DTW)

Sao Paulo (GRU)

Elapsed Time

+1

GMT (-5)GMT (-2)

Note: All times are local. Schedule includes 2 weekly flights that Delta will operate using existing U.S.-Brazil unrestricted frequen

operate southbound on Sunday and Thursday and northbound on Tuesday and Saturday. Additional frequencies effective Octobreceipt of all required government approvals.
Delta’s Detroit – Sao Paulo Nonstop Schedule 

Proposal – Northern Hemisphere Summer Season

DL 205

We/Th/Fr/Sa/Su

Boeing 767-300ER

Flight Number

Frequency

Equipment

DL 2

Mo/Th/Fr

Boeing 767

1745

0515

10:30

0720

2115

11:0

Detroit (DTW)

Sao Paulo (GRU)

Elapsed Time

+1

GMT (-4)GMT (-3)

Note: All times are local. Schedule includes 2 weekly flights that Delta will operate using existing U.S.-Brazil unrestricted frequen

operate southbound on Sunday and Thursday and northbound on Monday and Friday. 
Annual Operating Statistics

Delta’s Detroit – Sao Paulo Nonstop Service Proposal

AircraftAnnual DeparturesSegment Miles (sm)Plane Miles (sm)ASMsFuel Burn (gallons/hour)Fuel Consumption (millions of gallons)

Boeing 767-300ER

520

5,105

2,645,600

573,393,600

1,658

9.2

Statement on fuel availability: Delta anticipates no difficulty in obtaining fue

from its current suppliers at Detroit and Sao Paulo.

BusinessElite ClassEconomy ClassTotal

35

181216

Seating Configuration

Note: Statistics include 2 weekly flights that Delta will operate using existing U.S.-Brazil unrestricted frequencies. 
Aircraft Statement

• Delta will use aircraft on hand from among the 56 Boeing 767-300ER aircits fleet. These aircraft are in widespread use throughout Delta’s internatnetwork. All of Delta’s aircraft are FAR 36 compliant. 
Exhibit DL-201
May 7, 2010 

The Honorable Ray LaHood, Secretary 

United States Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Re: Delta Air Lines Application for 

Detroit – Sao Paulo Frequencies 

Docket OST-2010-0090 

Dear Secretary LaHood; 

On behalf of Ford Motor Company, I am writing to express our strong support for the 

application of Delta Air Lines for additional frequencies usable on the Detroit-Sao Paulo 

route. 

Ford Motor Company has an important and growing presence in Brazil, and we are very 

pleased that Delta has announced nonstop Detroit-Sao Paulo service beginning in 

October, 2010. Unfortunately, Delta is restricted to offering just two flights a week. The 

needs of international business travelers and international commerce would be better 

served if Delta were able to operate a daily service. 

I understand that Delta has applied to DOT for authority that will enable the expansion 

of service between Detroit and Sao Paulo as soon as airport infrastructure constraints 

are resolved. I urge you to take this opportunity to provide Detroit with additional 

service on this important new route. 

Thank you for consideration of this request. 

Sincerely, 

KENNETH W. SHARPE 

Global Strategy & Communications Manager 

Ford Motor Company 

1 American Road 

Dearborn, Michigan 48126 




CERTIFICATE OF SERVICE 

 A copy of the foregoing Application has been served this 23rd day of July, 2010, 

upon the following persons via email: 

 

carl.nelson@aa.com 

howard_kass@usairways.com 

benjamin.slocum@usairways.com 

hkamen@coair.com 

dan.weiss@coair.com 

rbkeiner@crowell.com 

jeffrey.manley@united.com 

steve.morrissey@united.com 

robert.land@jetblue.com 

jhill@dlalaw.com 

dkirstein@yklaw.com 

jyoung@yklaw.com 

paul.gretch@dot.gov 

esta.rosenberg@dot.gov 

brian.hedberg@dot.gov 

byerlyjr@state.gov 

john.allen@faa.gov 

Emily.Neuberger@wcaa.us 

Joe.Cambron@wcaa.us 

mgoldman@sgbdc.com 

info@airlineinfo.com