BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Motion of DELTA AIR LINES, INC.
In the matter of 2010 U.S.
- Haneda Combination Services Allocation Proceeding ) ) ) ) ) ) ) Docket DOT
- OST
- 2010
- 0018

C ORRECTED REPLY OF THE PORT OF SEATTLE Communications with respect to this document should be addressed to:
Mark Reis Managing Director Seattle
- Tacoma International Airport
Kazue Ishiwata Senior Manager Air Service Development Seattle
- Tacoma International Airport Port of Seattle P.O. Box 68727 Seattle, WA 98168 (206) 787
- 6857 (tel) (206) 787
- 7782 (fax) ishiwata.k@portseattle.org Isabel R. Safora Deputy General Counsel Port of Seattle Legal Department P. O. Box 1209 Seattle, WA 98111 (206) 787
- 3216 (tel) (206) 787
- 3205 (fax) safora.i@portseattle.org

September 13 , 2012BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Motion of DELTA AIR LINES, INC.
In the matter of 2010 U.S.
- Haneda Combination Services Allocation Proceeding ) ) ) ) ) ) ) Docket DOT
- OST
- 2010
- 0018

CORRECTED REPLY OF THE PORT OF SEATTLE

The Port of Seattle, the owner

- operator of Seattle

- Tacoma International Airport, (“Seattle”) respectfully re plies in strong support of Delta Air Lines (“Delta”) motion to transfer one Haneda slot pair to the Seattle gateway. Seattle recognizes that Haneda is a limited entry market whose scarcely available slots must be allocated for the public benefit. In the 2010 Haneda proceeding Delta, after carefully evaluating all aspects of potential scenario, indicated that Seattle was its top priority gateway . U nfortunately , Seattle was not afforded the opportunity
at the time and , y et , today it is the largest U

. S

. - Tok yo O&D market among those without Haneda
service

. Delta should be permitted to reallocate the slots to Seattle, its top priority gateway , thereby provid ing the public with gateway parity i n the U.S.

- Haneda marketplace. By granting Delta ’s motion to transfer its Haneda slot authority to Seattle , the Department will make possible incremental increase s in U.S.

– Haneda traffic from regions not currently served by existing Haneda gateways , and achiev e its objective of best meeting the
needs of the trav eling and shipping public

. Seattle and the entire Pacif i c Northwest region are currently disadvantaged relative to San Francisco and Los Angele s whose connectingReply of the Port of Seattle DOT

- OST

- 2010

- 0018

Page 3 of 4

markets already enjoy U.S.

- Haneda service

. Seattle’s proven success as Delta’s premiere Western gateway , as well as the continuing strength and growth of the local market , will ensure
the long

- term success of the new service

. I . Granting Delta Seattle
- Haneda S ervice is the Only Result that Will Maximize
Benefits for the Traveling and Shipping Public .

A number of filings in this proceeding have argued to dismiss Seattle , characterizing it as a Delta non - hub gateway that cannot support the new Haneda service. The filings in opposition failed to acknowledge that while Seattle does not fit the simplified notion of

a traditional hub, Delta currently operates five long

- haul international routes successfully here

– more than at its long

- established traditional hubs , such as Cincinnati, Minneapolis, Memphis and Salt Lake City. Delta also serves more international routes at Seattle than it does at San Francisco and Los Angeles, further validating its successful formula in a market that has a number of other competing carriers present. Exhibit SEA

- 206

. Delta’s international service success in Seattle is a testament to it s effective partnership
with our hometown carrier, Alaska Airlines. The successful long

- term relationship of these two
carriers should not be measured purely by on

- line connectivity, as expressed in the Answer filed by Alaska Airlines in this proceedin g. Furthermore, Alaska Airlines ’ network reaches those regions not served conveniently by circuitous gateways at San Francisco and Los Angeles. Coupled with the proven on

- time performance of Seattle, the proposed Haneda service will provide new opportunities to flow traffic over the Seattle gateway to and from points behind. The Department should not ignore that c onvenien t access is the key to the close

- in Haneda