BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________

)

Motions and Application of )

 ) 

AMERICAN AIRLINES, INC. )

HAWAIIAN AIRLINES, INC. ) Docket DOT-OST-2010-0018

 )

in 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, 2015
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________

)

Motions and Application of )

 ) 

AMERICAN AIRLINES, INC. )

HAWAIIAN AIRLINES, INC. ) Docket DOT-OST-2010-0018

 )

in 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 these slots. It is clear that Delta 

is committed to growing its Seattle hub. Maintaining service at Haneda is an important part of 

the carrier’s future service plans for Tokyo -- given Japan’s obvious intent to make Haneda a 

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

provides important new support for the flight as well as high quality aviation jobs. For these 

reasons, the Delta Master Executive Council, the Delta chapter of the Air Line Pilots 

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

We note that Delta has committed aircraft resources and continues to actively 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 public 
interest. 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. 

The 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 has allowed other carriers to take far greater liberties with limited entry authority. 

We note 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 international 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 to operate a more regular pattern of service than 

other carriers, there is 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 seasonal 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 

service 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 opportunities 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 the flight has shown marked improvement and is important to Seattle businesses, 

international trade, and employment levels at this important gateway. 

An 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 traveling public to put a cloud over Delta’s Seattle-Haneda slots while Delta is in the 

process of building its Seattle hub to provide, among other benefits, maximum connecting 

opportunities and additional traffic. 
Accordingly, we respectfully urge that Delta be allowed to continue SeattleHaneda service and that the competing applications of American and Hawaiian be denied. 

Respectfully submitted,

Michael G. Donatelli

Chairman

Delta Master Executive Council

Air Line Pilots Association, International
CERTIFICATE OF SERVICE

A copy of the foregoing document has been served this 20th 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