BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________ )

Motion s and Application of )

)

AMERICAN AIRLINES , INC. )

HAWAIIAN AIRLINES, INC. ) Docket DOT

- OST

- 2010

- 0018

)

i n the matter of 2010 U.S.

- Haneda )

Combination Services Allocation Proceeding )

__________________________________________)

CONSOLIDATED REPLY OF

THE DELTA MASTER EXECUTIVE COUNCIL OF THE

AIR LINE PILOTS ASSOCIATION, INTERNATIONAL

IN SUPPORT OF DELTA AIR LINES , INC.

Communications with respect to this document should be addressed to:

Michael G. Donatelli

Chairman

Delta Master Executive Council

Air Line Pilots Association, International

100 Hartsfield Centre Parkway, Suite 800

Atlanta, Georgia 30354

Mike.Donatelli@alpa.org

January 20, 2015BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________ )

Motion s and Application of )

)

AMERICAN AIRLINES

, INC. )

HAW AIIAN AIRLINES, INC. ) Docket DOT

- OST

- 2010

- 0018

)

i n the matter of 2010 U.S.

- Haneda )

Combination Services Allocation Proceeding )

__________________________________________)

CONSOLIDATED REPLY OF

THE DELTA MASTER EXECUTIVE COUNCIL OF THE

AIR LINE PILOTS ASSOCIATION, INTERNATIONAL

IN SUPPORT OF DELTA AIR LINES , INC.

Nothing contained in the competing Answers of American and Hawaiian alters the fact

that Seattle

- Haneda service

– and in particular maintaining a unique gateway serving the Pacific

Northwest region

-- is the highest and best public interest use of the se slots. It is clear that Delta

is commit ted to growing its Seattle hub. M aintaining service at Haneda is an important part of

the c arrier ’ s future service plans for Tok yo

-- given Japan’s obvious intent to make Haneda a

major international airport . The growth of Delta’s domestic connecting network at Seattle

pro v ides important new support for the flight as well as high quality avia tion jobs. For these

reasons, t he Delta Master Executive Council, th e Delta chapter of the Air Line P ilots

Association, Int ernational (the “Delta MEC”) reiterates its strong support for Delta’s application.

We note that Delta has committed aircraft res ources and continues to activel y sell the

flight. Removing Seattle

- Haneda slots from Delta and awarding them to another carrier for

service in the already saturated regions of California or Hawaii would be contrary to the publicinterest. And, it would compromise the ability of Delta and its employees to offer a viable

competitive alternative to American/JAL and United/ANA

, which operate large hubs at Haneda.

Seattle

- Haneda service is critical to jobs and economic activity. Not only is the service

very important to the over 12,000 Delta pilots working in concert with the 80,000 dedicated

employees of Delta

– it provides an important catalyst for economic activity for the U.S.

businesses and export industries operating in Seattle and the Pacific Northwest.

T he Department has already found that the public interest is best served by Delta ’s

Seattle

- Haneda service

. 1 The same public interest considerations relied upon by the Department

to make the award for Seattle service over America’s LAX proposal and Hawaiian’s Kona

proposal in 2012 support the continuation of this service

.

Carriers need to be able to make rational service adjustments in response to market

conditions. Delta and its employees should not be subject to forfeiture of Haneda operating

rights when the carrier is operating in compliance with the DOT’s dormancy condition

– and the

Department h as allowed other carriers to take far greater liberties with limited entry authority.

We not e that American is in no position to criticize Delta for a temporary seasonal reduction at

Haneda

– when American has done the same at Haneda and in other interna tional markets

– and

abandoned its JFK

- Haneda flight altogether in 2013. Furthermore, American ceded the entire

JFK

- Tokyo market (including Narita) to its Japanese partner, compromising U.S. jobs and flying

opportunities. While Hawaiian has been able t o operate a more regular pattern of service than

other carriers, there i s significantly less benefit to U.S. travelers and shippers operating a flight

that caters to 95 percent Japanese leisure passengers.

1 Show Cause Order 2012

- 11

- 12; Final Order 2013

- 2

- 4.Delta and its employees have worked hard to develop service from the mainland United

States to Japan under difficult conditions at Haneda (which are improving for the reasons noted

in the earlier filings by Delta for this proceeding )

. We noted that s easonal flight schedule

reductions (especially in the off

- peak winter season) are common in many international markets.

And, as pointed out by Delta, American has taken extensive scheduling liberties with its own

limited entry frequencies in Brazil, allowing them to be dormant for periods of 90 days or more

over the last decade. Given the challenges that all carriers providing mainland U.S.

- Haneda

servi ce have experienced, Delta’s temporary reduction in the 2014/2015 winter season is

appropriate and consistent with this long standing airline industry practice.

Removing service from Seattle is ill advised and would leave Seattle as the largest U.S.

-

Tokyo market without nonstop service. In addition , it would be unfair to award three U.S.

-

Haneda opp ortunities to Los Angeles or four U.S.

- Haneda opportunities to Hawaii, and leave

Seattle and the Pacific Northwest with none

. Importantly, as previously established in this

proceeding t he flight has shown marked improvement and is important to Seattle bu sinesses,

international trade, and employment levels at this important gateway.

A n award of Haneda slots to American would also compromise alliance competition.

Delta has no partner in Japan whereas American and JAL engage in reciprocal antitrust

immunized codesharing, bolstered by the benefits oneworld enjoys at Haneda by virtue of JAL’s

huge slot holdings and large hub operation at this constrained airport. It is also not in the interest

of the tra veling public to put a cloud over Delta’s Seattle

- Haneda slots while Delta is in the

process of build ing its Seattle hub to provide , among other be nefits, maximum connecting

opportunities and additional traffic.Accordingly, we respectfully urge that De lta be allowed to continue Seattle

Haneda service and that the competing application s of American and Hawaiian be denied.

Respectfully submitted,

Michael G. Donatelli

Chairman

Delta Master Executive Council

Air Line Pilots Association, InternationalCERTIFICATE OF SERVICE

A copy of the foregoing document has been served this 20 th day of January, 2015, upon the

following persons via email:

howard.kass@aa.com

abigail.donovan@aa.com

robert.wirick@aa.com

charles.hunnicutt@thompsonhine.com

patricia.snyder@thompsonhine.com

jhill@cooley.com

perkmann@cooley.com

dan.weiss@united.com

thomas.bolling@united.com

steve.morrissey@united.com

gmurphy@crowell.com

Mike.Donatelli@alpa.org

Dino.Atsalis@alpa.org

Doug.Ralph@alpa.org

Ishiwata.K@portseattle.org

Safora.I@portseattle.org

sascha.vanderbellen@delta.com

chris.walker@delta.com

paul.gretch@dot.gov

brian.hedberg@dot.gov

brett.kruger@dot.gov

todd.homan@dot.gov

peter.irvine@dot.gov

englets@state.gov

cristinasa @state.gov

eugene_alford@ita.doc.gov

info@airlineinfo.com