BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

In the matter of

2010 U.S.-Haneda Combination Services Allocation Proceeding ) ) ) ) ) ) ) Docket DOT-OST-2010-0018

MOTION OF DELTA AIR LINES, INC. Communications with respect to this document should be addressed to:

Andrea Fischer Newman Senior Vice President – Government Affairs DELTA AIR LINES, INC. 1212 New York Avenue, N.W. Washington, D.C. 20005

Alexander Van der Bellen Managing Director – Government Affairs & Associate General Counsel Jeff Morgan Regional Director – Government Affairs DELTA AIR LINES, INC. 1212 New York Avenue, N.W. Washington, D.C. 20005 (202) 842-4184 sascha.vanderbellen@delta.com

June 3, 2011BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

In the matter of

2010 U.S.-Haneda Combination Services Allocation Proceeding ) ) ) ) ) ) ) Docket DOT-OST-2010-0018

MOTION OF DELTA AIR LINES, INC. Delta respectfully requests temporary relief from the 90 day dormancy condition applicable to its seven Detroit-Haneda slots, so that Delta can manage its Detroit-Haneda flights in line with current market conditions. Delta resumes daily Detroit-Haneda service on June 16, 2011. However, due to the lingering effects of the Japanese earthquake, U.S.-Tokyo demand remains far below normal levels and forward bookings on Delta’s Detroit-Haneda flight are unusually weak. Delta requests that the Department permit the flexibility to adjust Detroit-Haneda service levels by providing relief from the slot use-or-lose condition until June 1, 2012. In support of this motion, Delta states as follows: 1. U.S.-Tokyo demand has been severely disrupted. According to MIDT data, overall U.S.-Tokyo bookings for the next several months are down by as much as 31 percent versus last year. (DL-1). U.S. point of sale traffic has been impacted to an even greater extent, with bookings dow n by as much as 49 percent (DL-2). And, premium cabin demand has been hard hit, with forward bookings off by up to 43 percent. (DL-3) This is the worst possible combination of temporary marketDelta Motion Page 2

conditions for the new Detroit-Haneda route. Delta’s Detroit-Haneda service is heavily reliant on U.S. point of sale passengers, including premium business demand from the major commercial centers in the Eastern half of the United States. Under normal circumstances Detroit is a proven and successful gateway to Tokyo. However, current U.S.-Tokyo market conditions are anything but normal and U.S. passengers (including essential business tra ffic) are simply not booking travel to Tokyo. 2. Delta’s waiver request is consistent with the public interest and Department precedent. When significant external events have triggered major declines in normal traffic levels, the Department has granted waiver relief so that

carriers can reduce service. See, e.g . Order 2003-4-18 granting a blanket 11 month dormancy waiver to all U.S. carriers for all international routes following the decline in traffic as a result of the Iraq war. The Department’s recent preference is to grant waiver relief on the basis of specific facts and circumstances affecting particular routes. (Order 2008-7-6). Here, the effects of the Japanese earthquake are acute and uniquely focused on U.S.-Tokyo traffic. In these circumstances, Delta submits that there is a strong case for waiver relief. In keeping with the Department’s waiver policy under unusual and distressed market conditions, “[carriers] should not be obligated to reach decisions on [operating] services based on the ‘use-it-or-lose-it’ constraints associated with a dormancy condition.” 2003-4-18 at 2. 3. Delta’s request for a 12 month waiver is consistent with dormancy waiver periods that have been granted in similar cases. 1 Delta still expects to operate daily Detroit-Haneda service for a portion of the current summer season, but

1 See, e.g . NOATs Docket OST-2007-28574 (granting American 12 month start-up waiver for Chicago-Beijing service, and Un ited three successive 12 month start-up waivers for San Francisco-Guangzhou, based on distressed market conditions and high fuel costs).Delta Motion Page 3 would temporarily reduce or suspend service until Tokyo business demand returns to more normal levels. These are important commercial scheduling decisions that Delta believes should be made on the basis of market conditions and not regulatory considerations. The requested waiver will provide Delta the flexibility to quickly add back service as the market improves. 4. In recognition of the unusual circumstances that exist in Japan, there is already a use-or-lose waiver in effect for slots at both the Tokyo airports issued by JCAB, the Japanese Ministry of Land, Infrastructure, Transport and Tourism. This waiver was granted upon the strong recommendation and support of IATA (including U.S. carrier IATA members who participated in the Haneda route case). The U.S. State Department only recently removed its travel warning, which urged U.S. citizens to avoid all non-essential travel to Tokyo. While it is now safe for travelers to resume travel to Tokyo it will take some time before the desire to do so returns. It is clear that demand will remain depressed for the remainder of the summer season, andflexibility is needed to judiciously manage the re-introduction of capacity over the offpeak winter months and shoulder season in the early spring. The requested waiver period will enable the resumption of daily Detroit-Haneda service in time for next year’s peak travel season. 2 5. Delta has more at stake in the U.S.-Tokyo market than any other carrier. We estimate that the effects of the earthquake will cost Delta between $250 and $400 million this year. Delta has been able to mitigate the effects on its Narita operation by increasing the mix of flow traffic through its hub. However, Haneda is an almost exclusively U.S. O&D market for Delta, and the U.S. demand to support

2 Delta appreciates and supports the Department ’s decision to allocate slots for DetroitHaneda service; however, Delta is willing and prepared to operate the slots on an interim basis for beach market service, should the De partment be inclined to allow the temporary use of slots at alternative gateways.Delta Motion Page 4 the new Detroit service has been temporarily interrupted. That said, for Delta and the SkyTeam alliance to remain competitive in the Tokyo marketplace, it is essential that we have a meaningful presence at Haneda. The Department’s decision to authorize Delta service from Los Angeles and from our primary east coast Asia gateway at Detroit provides comprehensive and competitive service for the U.S. market in competition with the oneworld and Star ATI alliances hubbed at Haneda. 6. Detroit-Haneda service requires the use of high value 777 aircraft, and each flight consumes large quantities of fuel. Delta reported a $318 million net loss for the first quarter of 2011, which included only a few weeks of Japan earthquake related impact. To meet the broader challenges of a fragile global economy and high fuel costs, Delta believes it is important for the Department to allow the airlines the regulatory flexibility to manage their resources efficiently. Last month, Delta announced a voluntary early-out program for employees in an effort to reduce staffing levels. The avoidable losses on Detroit-Haneda service over the next

12 months will conserve financial resources. 7. In conclusion, Delta respectfully requests a 12 month waiver of the dormancy condition applicable to its Detroit-Haneda slots. This will provide much needed flexibility to respond to the difficult and unexpected market conditionsresulting from the Japanese earthquake and will promote the prompt and efficient reintroduction of service when U.S.-Tokyo demand returns to normal levels. Respectfully submitted,

_________________________________ Alexander Van der Bellen Managing Director, Government Affairs & Associate General Counsel DELTA AIR LINES, INC.Source: MIDT, as of June 2, 2011Exhibit DL-1Page 1 of 1U.S.-Tokyo Industry Bookings for This Summer HaveDropped As Much As 31% vs. Last SummerU.S.-Tokyo Forward Industry Bookings - Year-Over-Year % Change(25%)(31%)(22%)(35%)(30%)(25%)(20%)(15%)(10%)(5%)0%June July AugustMonth

% Year-Over-Year ChangeExhibit DL-2Page 1 of 1U.S. Point-of-Sale U.S.-Tokyo Industry Bookings HaveFallen By As Much As 49%U.S.-Tokyo Bookings by Point of Sale (PoS) - Year-Over-Year % Change by PoS(37%)(49%)(45%)(14%)(10%)(2%)(60%)(50%)(40%)(30%)(20%)(10%)0%June July AugustMonth

% Year-Over-Year ChangeU.S. PoSJapan PoSSource: MIDT, as of June 2, 2011Exhibit DL-3Page 1 of 1U.S. Point-of-Sale U.S.-Tokyo Industry Premium CabinBookings Are Down By As Much As 43%U.S.-Tokyo Bookings by Point of Sale (PoS) - Premium Cabin Year-Over Year % Change byPoS(25%)(40%)(43%)(6%)(7%)(12%)(50%)(40%)(30%)(20%)(10%)0%June July AugustMonth

% Year-Over-Year ChangeU.S. PoSJapan PoSSource: MIDT, as of June 2, 2011CERTIFICATE OF SERVICE A copy of the foregoing document has been served this 3rd day of June, 2011, upon the following persons via email:

carl.nelson@aa.com dan.weiss@coair.com thomas.bolling@coair.com Annalei.Avancena@united.com howard.kass@usairways.com benjamin.slocum@usairways.com jhill@dowlohnes.com paul.gretch@dot.gov keith.glatz@dot.gov esta.rosenberg@dot.gov todd.homan@dot.gov urskr@state.gov eugene_alford@ita.doc.gov info@airlineinfo.com