BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

____________________________________________

 )

Reply of )

 )

PORT OF SEATTLE ) Docket DOT-OST-2010-0018

in support of )

Application of Delta Air Lines Inc. ) 

2010 US-Haneda Combination Services )

Allocation Proceeding )

____________________________________________)

REPLY OF THE PORT OF SEATTLE 

IN SUPPORT OF 

APPLICATION OF DELTA AIR LINES INC.

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) 787-4698 (tel)

(206) 439-7782(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

March 8, 2010
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

____________________________________________

 )

Reply of )

 )

PORT OF SEATTLE ) Docket DOT-OST-2010-0018

in support of )

Application of Delta Air Lines Inc. ) 

2010 US-Haneda Combination Services )

Allocation Proceeding )

____________________________________________)

REPLY OF THE PORT OF SEATTLE 

IN SUPPORT OF 

APPLICATION OF DELTA AIR LINES INC.

2010 US-HANEDA COMBINATION SERVICES ALLOCATION

I. Seattle Should be One of the Four Selected Haneda Gateways to Serve the 

Important Pacific Northwest Region and Maximize the Public Interest and 

Competitive Benefit.

Seattle is pleased and honored that Delta Air Lines (“Delta”) chose Seattle as its 

highest priority US - Haneda gateway in this contested proceeding. Delta is Seattle’s 

largest international carrier and connects effectively with hometown Alaska Air Group 

(“Alaska”). The Seattle market and its regional connections will readily justify the 

Department’s decision favoring Delta’s choice. 

Seattle is the only gateway considered in this proceeding that can connect its 

metropolitan area, Washington State and the entire Pacific Northwest region directly to 
Reply of the Port of Seattle

DOT-OST-2010-0018

Page 2

Asia with minimum circuity. The convenience of the Seattle gateway will complement 

the convenience of Tokyo’s close-in Haneda Airport for representatives of the many 

companies doing business between the region and Japan.

The award of Haneda slots for Seattle service will also enable the airport to keep

pace with Vancouver in the competition to attract international passengers to and from 

the entire West Coast, including Washington, Oregon and part of Canada. By the end of 

2010, Vancouver is expected to have at least one Canadian and one Japanese carrier

providing nonstop Haneda service. The residents of and visitors to the Pacific Northwest 

deserve the opportunity to choose U.S.-flag service and a U.S. gateway without 

backtracking through California.

II. Alaska Has Provided the Domestic Traffic Base for Seattle’s Strong 

International Route Development of the Last Decade.

Seattle functions effectively as a regional connecting hub for the Pacific 

Northwest and a trans-Pacific gateway for much of the West. Alaska’s connecting 

network has proven successful and is a key element of Seattle’s international 

development contrary to the negative assertions about the interline connections (United

Answer, p.14 and Continental Answer, p. 16). 

By taking over the close marketing relationship legacy carrier Northwest had 

enjoyed for more than 20 years with Alaska, Delta now enjoys Alaska’s vast connections. 

As noted by Delta CEO Richard Anderson at a joint press conference of the partnering
Reply of the Port of Seattle

DOT-OST-2010-0018

Page 3

carriers on November 19, 2008:

Alaska Air Group is a perfect alliance partner for Delta as we 

pair our expansive international network with Alaska's leading 

presence across the West Coast to build a platform for 

international growth from the West."

1

An example of this partnership is evident where Delta’s Seattle-Tokyo route 

consistently enjoys a high load factor and recorded a year-round average of 86.8%, fully 

9 points higher than the combined US-48 average of 77.7%

2

. In 2009, Delta’s SeattleTokyo segment traffic included 31% connecting passengers behind Seattle. The top 5 

markets are Las Vegas, Anchorage, Fairbanks, Phoenix and Spokane – all of which are 

Alaska’s key cities.3 

III. Seattle’s Satellite Transit System Makes Connections Convenient and 

Efficient Throughout the Airport.

Seattle passengers enjoy convenient connections throughout the airport with the 

Satellite Transit System (“STS”), the subway that provides quick transfers for all 

passengers in a comprehensive secure (sterile) area. International passengers, including 

United Air Lines (“United”) Tokyo passengers, arrive at the South Satellite, where Delta 

currently operates all of its international and domestic flights. Both United and Alaska

currently operate at the North Satellite, where STS makes connecting convenient and 

efficient for online United passengers as well as Delta passengers transferring to Alaska. 

Seattle is on-time as well as convenient. The most recent Department statistics show

 

1

: http://www.alaskasworld.com/Newsroom/ASNews/ASstories/AS_20081119_092854.asp

2 T100 YE August 2009

3 Airline Bookings Data, CY2009 OAG Aviation
Reply of the Port of Seattle

DOT-OST-2010-0018

Page 4

Seattle ranked best in on-time performance for December among the nation’s 31 busiest 

airports.

4

IV. Seattle’s Traffic is Strong and Still Growing.

Seattle has been growing as a gateway to Asia during the last decade, supported 

both by local traffic and by the strong network connections of the hometown carrier 

Alaska. During a difficult decade for the airline industry, when other West Coast 

gateways lost traffic, Seattle’s passenger volume increased by 9.9% 2000 to 2009 SEA201. During the same period, thanks to effective connecting services and new facilities, 

Seattle’s international passenger traffic was up 7.7%. This growth has continued and in 

2008-2009, Seattle-Asia passenger traffic strengthened month by month, up 26.3% in 

December 2009, and up 27.5% in January 2010.5

The demonstrated strength of the Seattle and Pacific Northwest markets, together 

with the cooperative efforts of Delta, Alaska and Seattle are strong predictors of success 

for the new Seattle-Haneda service.

V. Seattle Needs, Wants and Deserves Haneda Service.

Seattle is ideally located for U.S. - Haneda service and has a strategic gateway 

function to provide competitive balance in West Coast markets. We urge the Department

to award Delta daily Seattle-Haneda slots and allow Seattle to begin promoting this 

 

4

http://airconsumer.ost.dot.gov/reports/2010/February/2010FEBATCR.pdf

5

Seattle-Tacoma International Airport data as reported by air carriers.

1

Sources: ACI-NA and Airport Data

N. America 

Ranking Airport CY 2009 Passengers

% Change vs 

2000

3 Los Angeles 56,520,843 -16.0%

10 San Francisco 37,224,250 -7.6%

18 Seattle 31,227,512 +9.9%

29 Vancouver 16,177,438 +0.9%

Docket DOT-OST-2010-0018 West Coast Airports Exhibit SEA-xxx

Passenger Traffic and Percentage Change 2000-2009

Seattle outperformed through the decade.

Docket DOT-OST-2010-0018

Exhibit SEA-201