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 SEATTL E

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, W A 98111 (206) 787
- 3216 (tel) (206) 787
- 3205 (fax) safora.i@portseattle.org

March 8 , 2010BEFORE 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 Combina tion 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 S hould be O ne of the F our S elected Haneda G ateways to S erve the
I mportant Pacific North west R egion and M aximize the P ublic I nterest and
C ompetitive B enefit
. Seattle is pleased and honored that Delta Air Lines (“Delta”) chose Seattle as its highest priority US

- Haned a 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 fa voring 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 toReply of the Port of Seattle DOT
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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 carrie r 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 H a s Provided the Domestic Traffic Base fo r Seattle’s Strong
I nternational 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 (Un i ted 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 par tneringReply of the Port of Seattle DOT
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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 int ernational 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 Seattle

Tok yo 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 Convenien t and Efficient Throughout the Airport
. Seattle passengers enjoy convenient conne ctions 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 D elta 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 transferr ing to Alaska

. Seattle is on

- time as well as convenient. T he most recent D epartment 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 AviationReply of the Port of Seattle DOT
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S eattle ranked best in on

- time performance for December among the nation’s 31 busiest airports

. 4
IV. Seattle’s T raffic is S trong and S till G rowing
. 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 SEA

2 01

. 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

- A sia passenger traffic strengthened month by month, up 26.3% in
December 20 09, and up 27.5% in January 2010. 5
The demonstrated st r ength 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 N eeds, W ants and D eserves Haneda S ervice
. Seattle is ideally located for U.S.

- Haneda service and has a strategic gateway function to provide competitiv e 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

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# West Coast Airports Passenger Traffic and Percentage Change 2000

- 2009

Seattle outperformed through the decade. Docket DOT

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