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, 2011BEFORE 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 brie f 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 ve rsus last year. (DL-1). U.S.
point of sale traffic is down by as much as 49 perc ent (DL-2). Premium cabin
bookings are off by up to 43 percent. (DL-3). Han eda is a predominantly U.S. O&D
market for Delta, and the U.S. demand to support th e new Detroit service has been
temporarily interrupted. Delta’s request is consis tent with the Department’s waiver
policy and precedent. Under unusual and distressed market conditions, “[carriers]
should not be obligated to reach decisions on [oper ating] services based on the ‘useit-or-lose-it’ constraints associated with a dorman cy 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 DeltaDelta 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 mar ket conditions affecting
mainland U.S. business markets to argue for a secon d 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 t erm, that does not alter the validity
of the Department’s decision to award slots for mai nland service. Delta’s Detroit hub
provides comprehensive coverage of the major Easter n 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 Han eda beach market flying
in the interim, Delta is prepared to provide that s ervice. 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 agai nst its major rivals in the TokyoHonolulu market, including JAL and ANA, both of whi ch use their Haneda slots to
serve Honolulu. For years, Hawaiian has eschewed t he opportunities that were
provided for it to begin Tokyo service at Narita, a nd Hawaiian continues to be
interested in adding service only at the preferred downtown airport. 3

1 With regard to the Haneda operating window, Delta w ill provide comments on this and other issues at the appropriate time for the ne xt round of bilateral consultations.

2 See Delta Motion at n.2.

3 Under open skies, Hawaiian has the ability to incr ease 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 s eparate airports: San Francisco, Oakland, and San Jose.Delta Reply Page 3 United has been a major beneficiary of the new agre ement with Japan. On
the basis of the open skies agreement, United was a ble to secure antitrust immunity
with ANA to form a “metal neutral” transpacific joi nt venture. ANA is a major hub
operator at Haneda, and United shares in the benefi ts of ANA’s transpacific flights
through its joint venture. There is no separate pu blic interest rationale for United
flights “with its own U.S. aircraft.” (UA at 5).
United and ANA have the ability to jointly plan the ir 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 ch anges. A fundamental
prerequisite to the grant and continuance of antitr ust immunity is that the open entry
provisions of the open skies agreement provide suff icient new entry and competition
to prevent harm to consumers. Those conditions wou ld be violated if Haneda slots
were taken from Delta and given to United.
United criticizes Delta for making adjustments to i ts Haneda capacity, and
reducing service in the face of reduced demand foll owing the earthquake. Yet, that
is exactly the type of market-based decision carrie rs 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-To kyo (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 consisten t 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, 2011Exhibit DL-1Page 1 of 1U.S.-Tokyo Industry Bookings for This Summer HaveDropped As Much As 31% vs. Last SummerU.S.-Tokyo Forward Industry Bookings - Year-Over-Year % Change(25%)(31%)(22%)(35%)(30%)(25%)(20%)(15%)(10%)(5%)0%June July AugustMonth

% Year-Over-Year ChangeExhibit DL-2Page 1 of 1U.S. Point-of-Sale U.S.-Tokyo Industry Bookings HaveFallen By As Much As 49%U.S.-Tokyo Bookings by Point of Sale (PoS) - Year-Over-Year % Change by PoS(37%)(49%)(45%)(14%)(10%)(2%)(60%)(50%)(40%)(30%)(20%)(10%)0%June July AugustMonth

% Year-Over-Year ChangeU.S. PoSJapan PoSSource: MIDT, as of June 2, 2011Exhibit DL-3Page 1 of 1U.S. Point-of-Sale U.S.-Tokyo Industry Premium CabinBookings Are Down By As Much As 43%U.S.-Tokyo Bookings by Point of Sale (PoS) - Premium Cabin Year-Over Year % Change byPoS(25%)(40%)(43%)(6%)(7%)(12%)(50%)(40%)(30%)(20%)(10%)0%June July AugustMonth

% Year-Over-Year ChangeU.S. PoSJapan PoSSource: MIDT, as of June 2, 2011CERTIFICATE OF SERVICE

A copy of the foregoing document has been served th is 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