BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

DELTA AIR LINES, INC. 

 

for a frequency allocation 

(Detroit-Sao Paulo, Brazil) 

) 

) 

) 

) 

) 

) 

) 

Docket DOT-OST-2010- 

APPLICATION OF DELTA AIR LINES, INC. 

Communications with respect to this document should be addressed to: 

 

Glen Hauenstein 

Executive Vice President – 

Network Planning and Revenue Management 

Robert J. Cortelyou 

Senior Vice President – Network Planning 

Andreas Renner 

Director – International Network Planning 

Chris Kennedy 

General Manager – International 

Network Analysis 

DELTA AIR LINES, INC. 

1030 Delta Boulevard 

Atlanta, Georgia 30320 

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

April 8, 2010 

 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

DELTA AIR LINES, INC. 

 

for a frequency allocation 

(Detroit-Sao Paulo, Brazil) 

) 

) 

) 

) 

) 

) 

) 

Docket DOT-OST-2010- 

APPLICATION OF DELTA AIR LINES, INC. 

Delta Air Lines, Inc. (“Delta”) hereby applies for an allocation of five 

(5) frequencies to support daily nonstop Detroit-Sao Paulo service. Separately, Delta 

has applied for exemption authority to provide Detroit-Sao Paulo service, and plans to 

operate that service at a level of two weekly flights beginning on November 4, 2010 

using its existing frequency allocation. Increasing Detroit-Sao Paulo from two to seven 

flights a week would provide superior public benefits to any alternative use of the 

frequencies. 

The Available Frequencies Should Be Allocated to Their 

Highest and Best Long-Term Use. 

Delta recognizes that the frequencies at issue may not be used for Sao Paulo 

service until infrastructure-related constrains at the airport are removed. Importantly, 

however, the frequencies are, by their terms, ultimately usable at Sao Paulo -- and Delta 

believes that the long-term allocation of these frequencies should take that highest and 

best use into account. Delta is confident that airport infrastructure constraints at Sao 

Paulo will be addressed, and the frequencies should not be permanently consigned to 

sub-optimal use when they can support Sao Paulo flights for which there is a strong 

public interest need. This is especially important if the Government of Brazil is reluctant 

to negotiate new unrestricted rights for U.S. carriers to serve Sao Paulo in the future. 
Application of Delta 

Page 2 

Delta requests that five frequencies be allocated for Detroit-Sao Paulo service, 

with a start-up condition that requires Delta to commence service within 90 days of 

Brazil’s announcement that airport infrastructure constraints at Guarulhos Airport have 

been lifted.1

 Delta would not object to the interim use by another carrier for service to 

secondary markets in Brazil, provided the frequencies remain available for recall on the 

Detroit-Sao Paulo route. Such a condition is unlikely to result in any disruption to any 

newly established service – since Brazil has been liberal in agreeing to additional 

frequencies for tertiary markets. 

Delta’s Detroit-Sao Paulo Service Will Maximize Public 

Benefits. 

Detroit and Sao Paulo are each major industrial-manufacturing centers with 

strong communities of interest and a significant demand for nonstop service. Detroit will 

provide strong and effective intergateway competition to United at Chicago. Delta and 

its regional affiliates operate more than 575 peak day departures from the hub and will 

provide nonstop-to-nonstop service for nearly 100 U.S. cities. DL-101. Delta’s DetroitSao Paulo service will create significant public benefits, facilitating trade, investment, 

and tourism between the U.S. and Brazil. 

Service Proposal. 

As noted above, Delta plans to commence Detroit-Sao Paulo service at a level of 

two weekly frequencies using its existing allocation. Delta would use the five additional 

frequencies requested in this case to increase operations to daily, nonstop, year-round, 

service as soon as airport infrastructure constraints are lifted. Delta will utilize 216-

 

1 Delta has entered into a transaction with US Airways, which involves, inter alia, the 

mutual transfer of LGA and DCA slots and U.S.-Brazil frequencies. In Docket OST2009-0197, Delta and US Airways propose the contingent transfer of Delta’s Atlanta-Rio 

de Janeiro frequencies, and US Airways’ Charlotte-Rio de Janeiro frequencies, which 

would create new opportunities usable at Sao Paulo. If that transaction is not 

consummated, Delta requests the allocation of five frequencies for Atlanta-Rio de 

Janeiro service, which would free Delta’s unrestricted Atlanta-Rio de Janeiro frequencies 

for use on the Detroit-Sao Paulo route (while maintaining daily Atlanta-Rio de Janeiro 

service). 
Application of Delta 

Page 3 

seat Boeing 767-300ER aircraft, equipped with 35 BusinessElite and 181 economy class 

seats. 

Delta's proposed nonstop service schedule, operating statistics, and aircraft 

information are set forth in the attached exhibits. 

WHEREFORE, Delta requests an allocation of five (5) frequencies to support 

daily nonstop Detroit-Sao Paulo service as described above. 

 Respectfully submitted,

_________________________________ 

Alexander Van der Bellen 

Managing Director, Government Affairs 

 & Associate General Counsel 

DELTA AIR LINES, INC. 
TUL TUL TUL

To HNL To HNL To HNL To HNL To HNL To HNL

To ANC To ANC To ANC

BMI BMI BMI

MDW

ORD ORD ORD

PIA PIA PIAPIA

CID CID CID 

SCE SCE SCE 

III

RORORO

MSN MSN MSN

FNT FNT FNT

MBS MBS MBS

GRR GRR GRR

CLE CLE CLE

GRB GRB GRB CWA CWA CWA

ESC ESC ESC

MQT MQT MQT

SDF SDF SDF

EVV EVV EVV

DLH DLH DLH

MSP MSP MSP

DSM DSM

OMA OMA OMA

FSD FSD FSD RST RST RST

SFO SFO SFO

LAX LAX LAX

APN APN APN

ATW

AZO AZO AZO

BUBUBU

BZN BZN BZN

CAK CAK CAK

CIU CIU CIUCIU

CMH CMH CMH CMI CMI CMI

CRW

CVG CVG CVG

DEN DEN DEN DAY DAY DAY

ERI ERI ERI ERI

FWA FWA FWA

ICT ICT ICT ICT

IND IND INDIND

LAN LAN LAN

LAS LAS LAS

LEX LEX LEX

LSE LSE LSE

MCI MCI MCI

MKE MKE MKE

MLI MLI MLI

PDX PDX PDX

PHX PHX PHX

PIT PIT PITPIT

PLN PLN PLN

RORORO

SAN SAN SAN

SBN SBN SBN

SEA SEA SEA

SGF SGF SGF

SLC SLC SLC SMF SMF SMF

SNA SNA SNA

STL STL STL

TOL TOL TOL

TVC TVC TVC

XNA XNA XNA

Source: July 2010 schedules

DTW

Delta’s Detroit-Sao Paulo Service Will Establish a MajorNew Hub Gateway for the Midwest Region
LAX LAX

ORD ORD

ATL ATL

CLCL

IAH IAHIAH IAH

DFW

Delta’s Detroit-Sao Paulo Service Gives the Underserved Midwest Region A Second U.S. Gateway to Brazil

DTW

Existing Brazil Gateway
Delta’s Detroit – Sao Paulo Nonstop Schedule 

Proposal – Northern Hemisphere Winter Season

DL 205

Daily

Boeing 767-300ER

Flight Number

Frequency

Equipment

DL 2

Dail

Boeing 767

1745

0715

10:30

0715

2330

10:4

Detroit (DTW)

Sao Paulo (GRU)

Elapsed Time

+1

GMT (-5)GMT (-2)

Note: All times are local. Schedule includes 2 weekly flights that Delta will operate using existing U.S.-Brazil unrestricted frequen

operate southbound on Sunday and Thursday and northbound on Monday and Friday. 
Delta’s Detroit – Sao Paulo Nonstop Schedule 

Proposal – Northern Hemisphere Summer Season

DL 205

Daily

Boeing 767-300ER

Flight Number

Frequency

Equipment

DL 2

Dail

Boeing 767

1745

0505

10:20

0705

2130

10:3

Detroit (DTW)

Sao Paulo (GRU)

Elapsed Time

+1

GMT (-4)GMT (-3)

Note: All times are local. Schedule includes 2 weekly flights that Delta will operate using existing U.S.-Brazil unrestricted frequen

operate southbound on Sunday and Thursday and northbound on Monday and Friday. 
Annual Operating Statistics

Delta’s Detroit – Sao Paulo Nonstop Service Proposal

AircraftDeparturesSegment Miles (sm)Plane Miles (sm)ASMsFuel Burn (gallons/hour)Fuel Consumption (millions of gallons)

Boeing 767-300ER

730

5,105

3,726,650

804,956,400

1,658

12.9

Statement on fuel availability: Delta anticipates no difficulty in obtaining fue

from its current suppliers at Detroit and Sao Paulo.

BusinessElite ClassEconomy ClassTotal

35

181216

Seating Configuration

Note: Statistics include 2 weekly flights that Delta will operate using existing U.S.-Brazil unrestricted frequencies. 
Aircraft Statement

• Delta will use aircraft on hand from among the 55 Boeing 767-300ER aircits fleet. These aircraft are in widespread use throughout Delta’s internatnetwork. All of Delta’s aircraft are FAR 36 compliant. 
CERTIFICATE OF SERVICE 

 A copy of the foregoing Application has been served this 8th day of April, 2010, upon 

the following persons via email: 

 

carl.nelson@aa.com 

howard_kass@usairways.com 

benjamin.slocum@usairways.com 

hkamen@coair.com 

dan.weiss@coair.com 

rbkeiner@crowell.com (for Continental) 

mrosia@crowell.com (for Continental) 

jeffrey.manley@united.com 

julie.oettinger@united.com 

robert.land@jetblue.com 

jhill@dlalaw.com (for JetBlue) 

dkirstein@yklaw.com (for Spirit) 

jyoung@yklaw.com (for Spirit) 

paul.gretch@dot.gov 

esta.rosenberg@dot.gov 

brian.hedberg@dot.gov 

byerlyjr@state.gov 

john.allen@faa.gov 

lester.robinson@wcaa.us 

emily.neuberger@wcaa.us 

joe.cambron@wcaa.us 

mike.orr@airlineinfo.com