BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

In the matter of 

2010 U.S.-Haneda Combination Services 

Allocation Proceeding 

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) 

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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, 2011
 

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.

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 down 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 market 
Delta 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 traffic) 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 United 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, and 

flexibility 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 Department 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 conditions 

resulting 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, 2011

U.S.-Tokyo Industry Bookings for This Summer Have Dropped As Much As 31% vs. Last Summer

U.S.-Tokyo Forward Industry Bookings - Year-Over-Year % Change

(25%)

(31%)

(2

(35%)(30%)(25%)(20%)(15%)(10%)

(5%)

0%

June July A

Month

% Year-Over-Year Change
U.S. Point-of-Sale U.S.-Tokyo Industry Bookings Have Fallen By As Much As 49%

U.S.-Tokyo Bookings by Point of Sale (PoS) - Year-Over-Year % Change by Po

(37%)

(49%) (45%)

(14%) (10%)

(60%)(50%)(40%)(30%)(20%)(10%)

0%

June July Au

Month

% Year-Over-Year Change

U.S. PoS Japan PoS

Source: MIDT, as of June 2, 2011
U.S. Point-of-Sale U.S.-Tokyo Industry Premium Cabin Bookings Are Down By As Much As 43%

U.S.-Tokyo Bookings by Point of Sale (PoS) - Premium Cabin Year-Over Year % Cha

PoS

(25%)

(40%) (43%)

(6%) (7%)

(50%)(40%)(30%)(20%)(10%)

0%

June July Aug

Month

% Year-Over-Year Change

U.S. PoS Japan PoS

Source: MIDT, as of June 2, 2011
CERTIFICATE 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