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

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Docket DOT-OST-2010-0018 

CORRECTED 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, 2012
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 

CORRECTED REPLY OF THE PORT OF SEATTLE

The Port of Seattle, the owner-operator of Seattle-Tacoma International Airport, 

(“Seattle”) respectfully replies 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. Unfortunately, Seattle was not afforded the opportunity 

at the time and, yet, today it is the largest U.S.-Tokyo O&D market among those without Haneda 

service. Delta should be permitted to reallocate the slots to Seattle, its top priority gateway, 

thereby providing the public with gateway parity in the U.S.-Haneda marketplace. 

By granting Delta’s motion to transfer its Haneda slot authority to Seattle, the 

Department will make possible incremental increases in U.S.–Haneda traffic from regions not 

currently served by existing Haneda gateways, and achieve its objective of best meeting the 

needs of the traveling and shipping public. Seattle and the entire Pacific Northwest region are

currently disadvantaged relative to San Francisco and Los Angeles whose connecting 
Reply 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 Service 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 its 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 proceeding. 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 convenient access is the key to the close-in Haneda