BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Joint Application of Delta Air Lines, Inc. et al. 

under 49 U.S.C. § 4130-8 and 4130-9 

For Approval of and Antitrust Immunity for 

Alliance Agreements 

DOT-OST-2009-0155 

ANSWER OF ALASKA AIRLINES INC. AND 

HORIZON AIR INDUSTRIES, INC. d/b/a HORIZON AIR 

Communications with respect to this document should be addressed to: 

Kyle B. Levine, Esq. 

Associate General CounselCommercial Law and Litigation 

Alaska Airlines, Inc. 

19300 International Boulevard 

Seattle, Washington 98188 

Marshall S. Sinick, Esq. 

Edward W. Sauer, Esq. 

Squire Sanders and Dempsey, LLP 

1201 Pennsylvania Ave., NW 

Washington, DC 20004-0407 

202-626-6600 

msinick@ssd.com

esauer@ssd.com

Counsel to Alaska Airlines, Inc. and 

Horizon Air Industries, Inc. d/b/a Horizon Air

Megan Lawrence, Esq. 

Managing Director, Government Affairs 

 & Community Relations 

Alaska Airlines, Inc. 

19300 International Boulevard 

Seattle, Washington 98188 

Dated: October 22, 2010 
BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Joint Application of Delta Air Lines, Inc. et al. 

under 49 U.S.C. § 4130-8 and 4130-9 

For Approval of and Antitrust Immunity for 

Alliance Agreements 

DOT-OST-2009-0155 

ANSWER OF ALASKA AIRLINES INC. AND 

HORIZON AIR INDUSTRIES, INC. d/b/a HORIZON AIR 

Alaska Airlines, Inc. (“Alaska”) and its affiliate Horizon Air Industries, Inc. d/b/a 

Horizon Air (“Horizon”)1

 respectfully answer in support of Delta et al. response explaining why 

the Department should reconsider its Show Cause Order 2010-9-4 and grant antitrust immunity 

to Delta’s U.S.-South Pacific alliance.2

The basis for Alaska and Horizon’s support of Delta et al. enhanced U.S.-South Pacific 

alliance is the corollary importance of Alaska and Horizon’s codesharing and marketing alliance 

with Delta on the West Coast and, in particular, the feed traffic both carriers exchange at the 

LAX gateway. Alaska is mindful that the Department in its Show Cause Order questioned 

whether the overall public benefits flowing from the Delta-South Pacific alliance would be 

enhanced by the exchange of West Coast feed traffic between Alaska and Delta (Show Cause 

Order, 2010-9-4, p. 8). In a word, the answer is yes.3

 

1

 Common airline names are used throughout. 

2

 Delta et al. filed an enhanced alliance agreement with their September 10, 2010 response to the Department’s 

Show Cause Order. We refer to that pending alliance agreement as the enhanced agreement. 

3

 Alaska, Horizon and Delta also enjoy reciprocal frequent flyer program and lounge-sharing agreements which 

further add to the conveniences available to the Alaska/Horizon and Delta feed traffic. 
Alaska and Horizon have a significant presence in West Coast markets. Alaska and 

Horizon presently serve 29 West Coast cities. At LAX, Alaska and Horizon operate 288 weekly 

flights, including new service to major West Coast and Mexico business centers. In the 12 

months ended March 2010, Alaska and Horizon enplaned 1.57 million passengers at LAX. 

When Alaska and Horizon’s presence is combined with the new South Pacific markets Delta et 

al. will be serving under their enhanced South Pacific alliance, the increase in international citypairs and in the volume of exchange traffic will necessarily generate greater benefits to a larger 

number of passengers originating at or destined for cities on Alaska’s and Horizon’s route 

systems. 

CONCLUSION

To be sure, the enhanced opportunity Alaska and Horizon would have to convenience 

passengers traveling between the South Pacific and cities on Alaska’s and Horizon’s systems 

only reflects a small portion of the overall public benefits contemplated by Delta’s enhanced 

South Pacific alliance, but that increment is nonetheless credible and realistic. Alaska and 

Horizon would ask that the Department consider their West Coast exchange traffic benefits in 

evaluating the enhanced alliance agreement – and further ask that the Department confer antitrust 

immunity as Delta et al. have requested. 

Respectfully submitted, 

___________________________________ 

Marshall S. Sinick, Esq. 

Squire Sanders and Dempsey, LLP 

1201 Pennsylvania Ave., NW 

Washington, DC 20004-0407 

202-626-6600 

Counsel to Alaska Airlines, Inc. and 

Horizon Air Industries, Inc. d/b/a Horizon Air

Dated: October 22, 2010 
CERTIFICATE OF SERVICE

I hereby certify that copies of the foregoing Answer of Alaska Airlines, Inc. and Horizon 

Air Industries, Inc. d/b/a Horizon Air has this day been served by electronic mail on the 

following: 

sascha.vanderbellen@delta.com

anita.mosner@hklaw.com 

carl.nelson@aa.com

dan.weiss@coair.com

jhill@dlalaw.com

benjamin.slocum@usairways.com

howard_kass@usairways.com

jeffrey.manley@united.com

steve.morrissey@united.com

hkamen@coair.com

bob.goldner@dot.gov

christa.fornarotto@dot.gov

christopher.mandel@dot.gov

peter.irvine@dot.gov

susan.kurland@dot.gov

susan.mcdermott@dot.gov

robert.rivkin@dot.gov

todd.homan@dot.gov

Jeremy.Parkinson@infrastructure.gov.au

UrsKR@state.gov

info@airlineinfo.com

 

Marshall S. Sinick, Esq. 

Dated October 22, 2010