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, 2010 
 

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

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 Atlanta-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 making clear and substantial progress to delivering 
Reply 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 in 
Reply of Delta and Request for Expedited Action 

Page 3 

the future, the Department will have ample opportunity 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