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 FOR LEAVE TO FILE AND 

REPLY 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 17, 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 FOR LEAVE TO FILE AND 

REPLY OF DELTA AIR LINES, INC.

Delta respectfully requests leave to file this brief reply to the answers of 

Hawaiian, American, and United. As established in Delta’s Motion, U.S.-Tokyo 

demand has been seriously disrupted. 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 is down by as much as 49 percent (DL-2). Premium cabin 

bookings are off by up to 43 percent. (DL-3). Haneda is a predominantly U.S. O&D 

market for Delta, and the U.S. demand to support the new Detroit service has been 

temporarily interrupted. Delta’s request is consistent with the Department’s waiver 

policy and precedent. Under unusual and distressed market conditions, “[carriers] 

should not be obligated to reach decisions on [operating] services based on the ‘useit-or-lose-it’ constraints associated with a dormancy condition.” 2003-4-18 at 2. 

None of the responding carriers dispute the factual basis of Delta’s motion. 

American does not oppose Delta’s motion. In fact, American “agree[s] that Delta 
Delta Reply 

Page 2 

has provided compelling reasons for the Department to review the Haneda 

situation.”1

 (AA at 2). 

Hawaiian attempts to use the current distressed market conditions affecting 

mainland U.S. business markets to argue for a second pair of Haneda slots for 

Honolulu-Tokyo service. While beach market demand from Tokyo may have been 

less disrupted than mainland markets in the short term, that does not alter the validity 

of the Department’s decision to award slots for mainland service. Delta’s Detroit hub 

provides comprehensive coverage of the major Eastern U.S. business markets -- 

and promotes SkyTeam’s ability to compete with the Star and oneworld alliances at 

Haneda. 

If the Department wants to authorize additional Haneda beach market flying 

in the interim, Delta is prepared to provide that service.2

 Delta was also an applicant 

for Honolulu-Haneda service, but, unlike Hawaiian, Delta did not receive any slots for 

Honolulu. This places Delta at a disadvantage against its major rivals in the TokyoHonolulu market, including JAL and ANA, both of which use their Haneda slots to 

serve Honolulu. For years, Hawaiian has eschewed the opportunities that were 

provided for it to begin Tokyo service at Narita, and Hawaiian continues to be 

interested in adding service only at the preferred downtown airport.3 

 

1 With regard to the Haneda operating window, Delta will provide comments on this 

and other issues at the appropriate time for the next round of bilateral consultations. 

2 See Delta Motion at n.2. 

3

 Under open skies, Hawaiian has the ability to increase Tokyo service (at Narita) 

without additional Haneda slots. The fact that it does not do so is reflective of the 

unique premium commanded at Haneda for beach market service. By contrast, in 

the San Francisco Bay area, Hawaiian serves three separate airports: San 

Francisco, Oakland, and San Jose. 
Delta Reply 

Page 3 

United has been a major beneficiary of the new agreement with Japan. On 

the basis of the open skies agreement, United was able to secure antitrust immunity 

with ANA to form a “metal neutral” transpacific joint venture. ANA is a major hub 

operator at Haneda, and United shares in the benefits of ANA’s transpacific flights 

through its joint venture. There is no separate public interest rationale for United 

flights “with its own U.S. aircraft.” (UA at 5). 

United and ANA have the ability to jointly plan their transpacific services, and 

to utilize ANA’s Haneda slots to the best advantage of the joint venture. If United 

believes that San Francisco is a better alternative than the current selection of Star 

Haneda gateways, United and ANA are free to make changes. A fundamental 

prerequisite to the grant and continuance of antitrust immunity is that the open entry 

provisions of the open skies agreement provide sufficient new entry and competition 

to prevent harm to consumers. Those conditions would be violated if Haneda slots 

were taken from Delta and given to United. 

United criticizes Delta for making adjustments to its Haneda capacity, and 

reducing service in the face of reduced demand following the earthquake. Yet, that 

is exactly the type of market-based decision carriers are entitled to make under open 

skies. We note that United also reduced capacity in numerous U.S.-Tokyo markets 

in response to the earthquake, including Chicago-Tokyo (adjacent to Detroit) and 

San Francisco-Tokyo. 
Delta Reply 

Page 4 

In conclusion, Delta believes that this request for relief is well substantiated 

on the basis of the factual record and is consistent with Department policy and 

precedent. 

 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 17th 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