BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

2013/2014 U.S.-Brazil Combination Frequency

Allocation Proceeding

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Docket DOT-OST-2013-0072

CONSOLIDATED REPLY

OF DELTA AIR LINES, INC. 

Communications with respect to this document should be addressed to:

Glen Hauenstein

Executive Vice President, Network Planning & 

Revenue Management

Robert J. Cortelyou

Senior Vice President – Network Planning

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

Chris Walker

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

May 14, 2013
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

2013/2014 U.S.-Brazil Combination Frequency

Allocation Proceeding

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)

)

)

)

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Docket DOT-OST-2013-0072

CONSOLIDATED REPLY

OF DELTA AIR LINES, INC. 

I. Introduction

Delta was a strong supporter of the 2010 negotiations with Brazil which produced 

the transitional open skies agreement with Brazil. The Department’s successful 

negotiation creates a bilateral regime that should ultimately lead to fully liberalized 

market opportunities for all U.S. carriers. In the critical interim period before open skies 

is ratified and implemented, service and competitive benefits for the traveling public 

would be maximized by awarding Delta 21 frequencies to increase service from Atlanta 

and New York, and to maintain service at Detroit. 

II. Summary of the Argument

For the reasons detailed in Delta’s Application Supplement and Answer, we 

respectfully submit that first priority be given to Delta’s 21 frequency request. Delta’s 

proposals produce an optimal combination of public benefits:

• A second Delta flight at Atlanta will open a new time channel at the 

world’s largest airline hub, linking over 150 U.S. cities to Brazil. Atlanta 

provides the most effective intergateway competition to the East Coast 

hubs of American at Miami, and US Airways at Charlotte and 

Philadelphia.
Reply of Delta

Page 2

• A second Delta flight at New York, will also open a convenient new time 

channel and improve intragateway competition in the largest U.S.-Brazil 

O&D market. New York-Sao Paulo is dominated by American/TAM, 

which today out-schedule Delta by three flights to one. JFK is an 

important Northeast connecting hub enabling Delta to compete with the 

other New York incumbents as well as US Airways’ proposal for new 

service at its immediately adjacent Philadelphia hub.

• Preserving Detroit-Sao Paulo service is essential to the public interest. 

This proven and successful service links Detroit, the State of Michigan, 

and the industrial Midwest to Brazil, and provides the only effective 

intergateway competition to United’s service at Chicago.

Importantly, Delta will provide much-needed improvement to the U.S.-Brazil 

competitive market structure. U.S.-Brazil service in general and U.S.-Sao Paulo service

in particular is dominated by American which holds 47 of the total 105 U.S. flag 

unrestricted frequencies. DL-R-102. American and US Airways are merging, and TAM’s 

decision to join the oneworld alliance will lead to even greater concentration of the U.S.-

Brazil service in the hands of a single carrier/alliance group. DL-R-111. Delta holds 23 

Brazil frequencies. Absent an award in this case, Delta would be left with only 16 

following the required transfer of seven frequencies to US Airways. The benefits of 

Delta's service proposals, including more balanced and effective competition between 

U.S. flag carriers in the marketplace, can only be achieved by the full grant of 21 

frequencies to Delta. 

At bottom, this is a simple case with a clear public-benefits maximizing solution. 

Delta should receive the 21 frequencies it has requested, and US Airways should 

receive the seven remaining frequencies to fund service at Charlotte in 2014. The grant 

of seven frequencies to US Airways is sufficient to fund both of its proposals, since it will 

receive seven frequencies from Delta in the immediately following IATA traffic season. 

Indeed, given United’s apparent willingness to extend its frequency lease with US 
Reply of Delta

Page 3

Airways, it is quite possible that US Airways could begin Philadelphia service sooner if 

desired.

Even before considering the fact of its pending merger with US Airways, 

American should have no expectation of a further frequency award in this case. Less 

than a year ago the Department granted a large frequency request by American for 17 

Brazil frequencies. This allowed American to “backfill” frequencies on the Miami-Rio de 

Janeiro route and move those seven unrestricted frequencies to establish a second daily 

Sao Paulo flight at JFK.1

 DL-R-109, 110. American should not be heard to complain 

that the Department has been anything but generous concerning American’s Brazil 

frequency allocations. American has more than ample frequencies and the flexibility to 

move them at will if it wanted to establish nonstop service at Los Angeles or Chicago. 

With or without the merger, additional network competition created by new Sao Paulo 

services at Charlotte, Philadelphia, Atlanta and New York will put competitive pressure 

on American’s Miami stronghold (where it operates four daily Sao Paulo flights) – thus 

providing American with added incentive to consider new nonstop gateways including

Los Angeles and Chicago. 

For the reasons above, the grant of 21 frequencies to Delta is the best public 

interest choice irrespective of the merger. When that critical fact is added to the 

evaluation, the case for Delta is overwhelming. In the Instituting Order, the Department 

called for “[the American/US Airways merger] issue to be developed further on the 

record as the carriers advance the merits of their proposals.” Order 2013-4-9 at 6. 

However, US Airways and American persist in their efforts to dodge the issue, and 

evade the required public interest review of their merger as it relates to transfer and 

consolidation of US Airways’ and American’s Brazil frequency holdings into the “new 

 1 See Notice of Action Taken, Docket OST-2012-0079 (May 24, 2012).
Reply of Delta

Page 4

American.” As Delta has repeatedly stated, it would not be in the public interest to allow 

US Airways and American to acquire new unrestricted frequencies here -- which are 

essential to bring Delta to competitive parity in Brazil -- and then combine those 

frequencies in a new consolidated entity that will be even more dominant than American 

is today. 

Rather than demanding to be “treated as [] standalone carrier[s]”2 US Airways 

and American should want the Department to adjudicate the transferability of Brazil 

frequencies as part of the public interest evaluation of this case. The frequencies at 

issue are not covered by the pending American/US Airways route transfer application.

3

 

DL-R-107. If the frequencies were to be awarded here without consideration of the 

merger, the Department would need to conduct a de novo review of the frequency 

allocations in a new comparative selection proceeding. Frequency awards are not 

covered by the route transfer statute, and are not entitled to the same favorable 

presumptions as certificate authority. See, Order 97-11-35 (finding that FedEx proposed 

acquisition of Argentina all-cargo frequencies not covered by route transfer statute, and 

that frequencies would be subject to comprehensive public interest review in a carrier 

selection case). 

US Airways and American can try to delay the public interest of consideration of 

their merger, but they cannot avoid it. Delta agrees with the Department that those 

issues should be addressed here on the record. To do otherwise would be a waste of 

DOT resources, creates complications for the merger and pending route transfer 

application, and could delay the implementation of Brazil frequencies if Delta were not 

selected for its full 21 frequency proposal and follow-on carrier selection case were 

 2 US Answer at 3; see also AA Answer at 4. 

3 See, Exhibits A&B, AA/US Route Transfer Application, Docket DOT-OST-2013-0082. 
Reply of Delta

Page 5

required.4 In accordance with the Department’s instructions to develop the record, US 

Airways and American should address the following questions:

1. Are American and US Airways merging?5

2. Do American and US Airways expect their merger to be completed in the 

third quarter of 2013?6

3. Have American and US Airways filed a route transfer application seeking to 

consolidate all of US Airways’ international route authorities with 

American’s?7

4. Will the combined entity have at least 61 unrestricted Brazil frequencies 

including the 47 currently held by American, the 7 to be transferred from 

Delta to US Airways, and 7 surplus frequencies remaining after satisfaction 

of Delta’s full request in this case?

Given the pending American/US Airways merger and the large frequency cache 

that will be held by the combined entity, it is not surprising the merger parties would 

stress individual gateway attributes over market structure and competition. However, 

the U.S.-Brazil market is unique due to the large number of frequencies outstanding and 

the flexibility the Department has granted carriers to freely move frequencies among 

 4 American and US Airways each cite the Japan Alliances case to stand for the 

proposition that they should be evaluated separately. (Order 2010-10-4). This reliance is 

misplaced. That case was an antitrust immunity proceeding, not a route case. The 

effect of treating the ATI applicants as separate was to create a more rigorous 

competition review by assuming United and Continental remained competitors on U.S.-

Japan routes until extinguished by ATI. Here, ignoring the fact of the merger would lead 

to less rigorous competitive review of the merging parties - the opposite of the 

Department’s conservative approach in the Japan Alliances case. 

5 See, http://www.usairways.com/enUS/aboutus/pressroom/newamerican.html?cint=update_21132; “Judge signs order 

approving the US Airways-American Airlines merger”

http://aviationblog.dallasnews.com/2013/05/judge-signs-order-approving-the-us-airwaysamerican-airlines-merger.html/

6 http://newamericanarriving.com/investors/whats-happening-next/

7 Docket DOT-OST-2013-0082
Reply of Delta

Page 6

gateways.

8

 These important distinguishing characteristics of the U.S.-Brazil market and 

DOT regulatory policy favor the approach suggested by Delta.

US Airways has a very strange definition of competitive market structure. 

According to US Airways, the competitive market structure for U.S.-Sao Paulo will be 

enhanced if “each and every gateway proposed by US Airways and American” is 

authorized9 -- and Delta is granted no frequencies. The basis for US Airways competitive 

“analysis” is the self serving “figure 1” chart on page five of its Answer that has no DOT 

precedent to support it,10 and is directly contrary to the Department’s stated intent in the 

instituting order to “consider the effects of the applicants service proposals on the overall 

 8 “We . . . grant the . . . U.S. carriers designated for combination services in the U.S.-

Brazil markets flexibility to use their allocated frequencies in markets where the carriers 

hold requisite underlying authority.” (Order 2004-6-25). 

9 US Airways Answer at 5. 

10 US Airways’ contrived definition of market structure in this proceeding consists entirely 

of inter-gateway considerations to the exclusion of intra-gateway factors. US Airways 

position is inconsistent with DOT policy. Depending on the circumstances, the DOT puts 

the necessary emphasis on either inter-gateway or intra-gateway competition, or both, 

as the facts warrant in carrier/city selection cases. US Airways relies on a 27 year old 

pronouncement of DOT policy but then only reading the part that speaks of the principle 

of inter-gateway competition and ignores the portion of the document that refers to 

advancement of intra-gateway competition. Based on its incorrect reading of the policy 

statement, US Airways would have the Department reject entirely Delta’s need for a 

greater number of frequencies at the important New York are gateway to Brazil to better 

compete with incumbent carriers at New York as if intra-gateway factors have never 

been given any weight by the DOT. An example of the DOT’s emphasis on intragateway competition is seen in the 2000 U.S.-Brazil All-Cargo Service Case decision. 

Order 2001-3-27. In this case the Department awarded 10 weekly frequencies to Atlas 

Air Cargo to serve Miami in part because the carrier’s entry into the Miami market would 

be a competitive counter weight to the incumbent services of FedEx, Polar and UPS that 

collectively operated 11 weekly Miami-Brazil cargo flights thereby providing “significant 

structural benefits”. Gemini proposed to serve Brazil though two gateways (from New 

York and Miami but with less service from Miami) but the DOT found that increased 

frequency at a major traffic generating city was more attuned to market needs and 

offered superior benefits. Order 2001-3-27, p. 8. The same conclusion was reached in 

the 1999 U.S.-Argentine Combination Service Case, Order 2001-1-4. In this case, the 

DOT selected Continental to serve Newark-Buenos Aires because it would compete with 

the existing service operated from New York by American and United. By so doing, the 

DOT rejected United’s application for frequencies to serve a new gateway city (Los 

Angeles). The DOT has not hesitated to add carrier service options at existing gateways

when warranted even if it means that new gateway service cannot be offered by an 

applicant. 
Reply of Delta

Page 7

competitive environment . . .” Order 2013-4-9 at 3 (emphasis added). The “overall” 

competitive environment is best served by the full grant of Delta’s proposal. If “each and 

every one” US Airway’s and American’s proposals were granted here, and Delta 

received no frequencies, the “new American” would have 82 unrestricted Brazil 

frequencies, Delta 16, and United 35. DL-R-104. This is the worst possible competitive 

result. On the other hand, if Delta’s proposal is granted in full, American would still be 

the dominant carrier, but with a much more competitive distribution of unrestricted 

frequencies among the U.S. flag carriers: 61 for American, 37 for Delta, and 35 for 

United. DL-R-105. 

US Airways figure 1 chart and purported justification are also revealing as to the

extraordinary lengths US Airways has gone to advocate for American’s application in 

addition to its own. If US Airways and American are “separate competitors” they are 

certainly not acting like it in this case. Now with 148 pages of briefs and exhibits filed in 

the docket between them, still not one word of criticism has been leveled by either US 

Airways or American against the other. All of the criticism has been directed against 

Delta – because Delta is a competitor and US Airway and American do not view each 

other as such. 

Finally, the suggestion by US Airways and American that Delta should be 

prejudiced in this proceeding because of the LGA/DCA slot swap transaction is without 

merit. Delta worked closely with the Department and US Airways to achieve a 

transaction that would generate the enormous consumer benefits of a new Delta hub at 

LaGuardia, and the benefit of providing US Airways (then a new entrant) access to the 

U.S.-Sao Paulo market. Delta has delivered on the public benefits of its new hub, 

increasing DL/US LGA capacity 8 percent, and driving 13 percent more traffic on these 

flights. DL-R-215. Delta was an active participant in the U.S.-Brazil talks that produced 
Reply of Delta

Page 8

the current agreement, and, as the Department knows, securing replacement 

frequencies for Detroit was among Delta’s highest priorities. The historic open skies 

agreement achieved by the Department provides ample frequencies to achieve the 

important public benefits of maintaining service at Detroit, and adding competitive 

service at Atlanta and JFK as Delta has proposed. The public interest equities of the 

frequency transfer to US Airways are vastly different now in the context of the

American/US Airways merger. Favorable action by the Department on Delta’s 

application is necessary to prevent the new American from attaining unacceptable 

market power on U.S.-Sao Paulo routes. 

III. Rebuttal of Other Carrier/Gateway Proposals

A. US Airways – Charlotte

Between them, US Airways and American are assured of receiving 14 

incremental frequencies over the next two years even after full satisfaction of Delta’s 

request. DL-R-103, 104. In these circumstances, there does not appear to be a material 

threat to US Airways ability to continue Charlotte service. As noted, US Airways has 

already extended its lease with United though October 2014 (but does not indicate if it 

sought to extend the lease until the summer 2015 season when it will receive seven 

unrestricted frequencies from Delta). The combined American/US Airways entity will 

have a minimum of 61 unrestricted Brazil frequencies and it would seem likely that the 

new American would use at least 7 of those frequencies to maintain service at Charlotte.

A second daily Atlanta-Sao Paulo flight will compete with Charlotte and help to 

offset the loss of eastern U.S. network competition as the result of the consolidation of 
Reply of Delta

Page 9

US Airways and American.11 DL-R-202. With just a single daily Sao Paulo flight, the 

potential of the Atlanta hub is underutilized. The Department can create substantial 

service and competitive benefits for the traveling public by authorizing an additional 

Atlanta-Sao Paulo frequency. Delta’s U.S.-Sao Paulo network is at a disadvantage to 

the four daily Miami-Sao Paulo flights operated by American, which will soon be 

combined with a fifth daily Charlotte-Sao Paulo flight operated by US Airways. DL-R201. New service at Atlanta will help close this competitive gap. Importantly, additional 

frequencies at Atlanta will help to improve competition in the 48 one-stop overlap 

markets served by both American and US Airways that will lose a competitor as a result 

of the merger. DL-R-202. 

In terms of comparative metrics, Atlanta is superior to Charlotte both in terms of 

local market size, and as a connecting hub. Delta provides nonstop service from Atlanta 

to 150 U.S. cities – nearly 50 percent more cities than served by US Airways from 

Charlotte. DL-R-203. And, the Atlanta flight serves a metropolitan area with a 

population more than double Charlotte’s. DL-R-204. Atlanta’s location in the 

Southeastern United States provides convenient, competitive, and non-circuitous Sao 

Paulo connections. Delta and its regional affiliates provide nonstop service from Atlanta 

to more than 150 U.S. points, and operate more than 1,000 peak day departures at the 

hub. DL-R-206. The availability of new time of day coverage and increased capacity on 

this route will allow more passengers to take advantage of the Atlanta hub gateway. 

 11 Contrary to US Airways argument, Delta’s case does not rest on the proposition that 

its proposal simply increases the flights Delta can operate from its existing Brazil 

gateways. Permitting Delta to double its service at Atlanta (although still far from gaining 

parity with American’s Miami service levels) satisfies the DOT policy favoring 

enhancement inter-gateway competition among carriers. American and its code share 

partner TAM dominate the Miami gateway. Delta’s request for additional frequencies at 

Atlanta will be a strong competitive spur to the services of American and will be 

supported by the 150 online communities with nonstop Delta service. No other gateway 

city has a much network feed as Atlanta where Delta conducts the world’s largest hub 

operation. 
Reply of Delta

Page 10

DL-R-208. Atlanta offers unsurpassed facilities and convenience for U.S.-Brazil 

passengers. In May, 2012, Delta and Atlanta celebrated the opening of Atlanta's new, 

state-of-the-art $1.4 billion international terminal. DL-R-209. The new Maynard H. 

Jackson Terminal interfaces with Atlanta’s multi-concourse terminal layout that is 

designed to facilitate seamless connections to onward flights. DL-R-210. 

Detroit is also superior to Charlotte because it provides the only competitive 

nonstop flight to Sao Paulo for the entire Midwest region. DL-R-211. Detroit-Sao Paulo 

is a successfully established service linking Detroit and the Midwest industrial base to

the business and manufacturing center of Brazil. Delta’s flight benefits U.S. companies 

doing business abroad and extends the global reach of the U.S. auto industry. From 

Detroit, Delta and the Delta Connection carriers offer nonstop service to 114 U.S. points. 

DL-R-214. Continuation of Detroit-Sao Paulo service is very important to Delta, Detroit, 

and the State of Michigan. 

Unlike American/US Airways which are assured of receiving 14 frequencies, 

Delta would be forced to suspend Detroit service if the Department does not grant 

priority to its request over the competing applications of American and US Airways, 

which collectively seek all 28 frequencies in this case. As previously discussed, Delta is 

contractually obligated to transfer seven weekly unrestricted frequencies to US Airways 

as part of the DOT-approved DCA/LaGuardia slot swap transaction, which would leave

Delta with insufficient frequencies to maintain service at Detroit. DL-R-104. It is very 

important that Delta receive an allocation of frequencies to offset the required transfer to 

US Airways, which is now American’s merger partner, not a stand-alone new entrant to 

Brazil as it was at the time of the slot swap. 

While Delta would obviously have preferred not to transfer any of its unrestricted 

Brazil frequencies to US Airways, this was a necessary part of the consideration needed 
Reply of Delta

Page 11

to close the LGA/DCA transaction and to achieve the enormous benefits of establishing

a new Delta hub at LaGuardia. American’s attack on the slot swap transaction is 

specious. AA Supp at 5. The Department recognized the enormous consumer benefits 

that would be created by the establishment of a new Delta hub at LaGuardia, and the 

benefit of granting US Airways access to an important international market. Delta has 

delivered on the public benefits of its new hub, increasing DL/US LGA capacity 8 percent, 

and driving 13 percent more traffic on these flights. DL-R-215. The fact is that 

circumstances have now changed dramatically by virtue of the American/US Airways 

merger. Favorable action by the Department on Delta’s application is necessary to 

prevent the new American from attaining unacceptable market power on U.S.-Sao Paulo

routes. 

B. US Airways – Philadelphia

US Airways requests 14 frequencies from the Department: 7 to fund CharlotteSao Paulo and 7 to fund Philadelphia-Sao Paulo. Yet, US Airways inexplicably ignores 

the seven frequencies it will receive from Delta – which can be used to fund its 

Philadelphia proposal. DL-R-103, 104. US Airways should not receive two sets of 

frequencies in this case, and be allowed to warehouse the 7 frequencies it will receive 

from Delta for some unspecified future use. At most US Airways requires an award of 

seven frequencies, which will enable it to continue service at Charlotte and launch new 

service at Philadelphia following the transfer of the Delta frequencies.

US Airways’ Philadelphia gateway is immediately adjacent to Delta’s proposed 

New York gateway. But, New York-Sao Paulo is the largest U.S.-Brazil market with 

nearly 340,000 annual O&D passengers – far larger than any competing gateway at 

issue in this proceeding. DL-R-301. New York is nearly 50 times larger than 

Philadelphia or Charlotte, 3.5 times larger than Los Angeles, and 6.5 times larger than 
Reply of Delta

Page 12

Chicago. Id. Given the importance of the New York market, a second daily flight at 

Delta’s large and well established New York hub is likely to produce greater benefits 

than speculative proposals for smaller O&D gateways than have never been able to 

sustain U.S. flag scheduled service to Sao Paulo. 

Delta’s second daily New York (JFK) - Sao Paulo flight will compete with the 

merged US Airways/American entity, and the fact that US Airways will likely have the 

resources to fund Philadelphia service in the region makes an additional Delta flight all 

the more important. American already operates two daily New York-Sao Paulo flights, 

and an additional flight is offered by its partner, TAM, giving oneworld a 3:1 schedule 

advantage over Delta. DL-R-302. An award of seven additional frequencies to Delta will 

open a new time channel and help close the competitive gap with American and the 

oneworld alliance at JFK. DL-R-303. 

In addition to serving the largest local market in this case, Delta’s JFK hub will

provide significant connecting benefits with online service to 48 U.S. points. DL-R-304.

Whether passengers are originating in New York or connecting from other cities, their 

experience will be enhanced by Delta’s new Terminal 4 facility opening in May 2013. 

DL-R-306, 307. This $1.4 billion investment features the largest SkyClub in Delta’s 

system, and will allow international arrivals to be concentrated in the new facility. 

C. American – Los Angeles

With 47 unrestricted Brazil frequencies at its disposal, American should not 

receive any additional frequencies in this proceeding and the expense of new 

competitive service by Delta. Less than a year ago the Department granted a large

frequency request by American for 17 Brazil frequencies, which allowed American to 

“backfill” frequencies on the Miami-Rio de Janeiro route and move those seven
Reply of Delta

Page 13

unrestricted frequencies to establish a second daily Sao Paulo flight at JFK.12 DL-R109, 110. Even without an award in this case, the Department has been very generous 

to American with regard to Brazil authority. The Department has provided American with 

unlimited “flexibility to use [its] allocated frequencies in markets where [American] hold[s] 

requisite underlying authority.” (Order 2004-6-25). Thus, while American has the 

flexibility to serve the Los Angeles-Sao Paulo market today, it prefers to operate

quadruple daily Sao Paulo flights at Miami, and double daily service at New York. DL-R401. By granting Delta’s proposals in this case and establishing more effective 

intergateway competition versus American at Miami, and intragateway competition at 

New York, American will have added incentive to explore new gateway alternatives, 

such as Los Angeles and Chicago. 

The fact that American does not chose to operate nonstop service at Sao Paulo 

is not surprising given that Los Angeles has not been able to sustain U.S. flag scheduled 

service to Sao Paulo. Two prior attempts to serve the market failed after less than eight 

months. DL-R-402. While Los Angeles does have nonstop service by Korean Air, this is 

due in large part to the fact that Seoul-Sao Paulo is too far to fly nonstop, and Korean’s 

load factors on the LAX-GRU segment average less than 70 percent. Id. It is unlikely 

that American’s flight would be viable, and that American would seek to pocket the 

frequencies and move them to new gateway using the unrestricted flexibility that is 

standard for Brazil awards. 

American has excellent schedule coverage in the LAX-GRU market with at least 

six different service options via its DFW and Miami gateways. DL-R-403. Because of its 

west coast location, Los Angeles provides little in the way of connecting benefits 

because all points east of Phoenix require unacceptable backhaul. DL-R-404. In 

 12 See Notice of Action Taken, Docket OST-2012-0079 (May 24, 2012).
Reply of Delta

Page 14

addition, American provides nonstop-to-nonstop connections via DFW to 37 of 43

western U.S. cities it serves from Los Angeles. DL-R-405. 

American’s suggestion that Delta is “underutilizing” its Brazil frequencies is 

without merit. Delta operates a full pattern of three daily services – the maximum 

number daily services that can be operated with its existing allocation of 23 frequencies. 

If American thinks that an irregular service pattern of just two weekly flights is useful in a 

major business market such as Sao Paulo, it is free to move one or two Miami 

frequencies and see how it fares at Los Angeles. American also criticizes Delta for 

operating B767 aircraft. However, as the Department knows, Delta previously sought 

approval from the Brazilian authorities to operate larger aircraft and was denied. The 

frequencies available here provide Delta the important opportunity to grow its footprint at 

the restricted Sao Paulo airport, and Delta will continue to evaluate upgauge 

opportunities as market conditions and infrastructure allow. 

American’s dominance in the U.S.-Brazil marketplace is formidable in its own 

right, and is even more concerning when the effects of the US Airways merger and 

oneworld alliance are considered. Together, these carriers will control 64 percent of 

U.S.-Sao Paulo capacity. DL-R-111. American holds antitrust immunity with LAN,13 and 

LAN has now completed its take-over of TAM, the largest airline in Brazil.14 TAM has 

announced that it will be part of oneworld, and given American’s immunized relationship 

with LAN, those ties are likely to be especially close. The award of 21 frequencies to 

Delta in this case will help to offset the growing dominance of oneworld in Brazil and

Latin America. 

 13 Order 2005-10-8.

14 http://www.economist.com/blogs/gulliver/2012/06/south-american-airlines
Reply of Delta

Page 15

D. American – Chicago

As with Los Angeles, American has sufficient frequencies and the flexibility to 

serve Chicago-Sao Paulo today if it was in American’s commercial interest to do so. DLR-401. American should not receive a further award for Chicago service at Delta’s 

expense. 

American proposes to add a second nonstop Sao Paulo flight at Chicago (a route 

already served by United) whereas Delta seeks frequencies to maintain Detroit’s only 

nonstop flight – which is also the only competing gateway in the entire Midwest region. 

DL-R-501. As noted above, Delta’s Detroit-Sao Paulo flight is an important service 

linking Detroit and the Midwest industrial base to the business and manufacturing center 

of Brazil. 

Detroit is a superior connecting hub. From Detroit, Delta and the Delta 

Connection carriers offer nonstop service to 114 U.S. points. DL-R-502. By contrast, 

American serves 101 points from Chicago. DL-R-504. And, Delta’s state-of-the-art 

McNamara terminal was designed with simplicity and ease of passenger transfers in 

mind, featuring an elevated monorail, moving sidewalks and integrated customs facility –

a welcome relief to American’s dated facilities at Chicago. DL-R-505, 506.
Reply of Delta

Page 16

V. Conclusion

Delta’s request for frequencies to increase and maintain Sao Paulo service at 

Atlanta, New York, and Detroit will create important benefits for the traveling public and 

enhance competition on U.S.-Brazil routes. Delta respectfully submits that the 

Department’s objective to maximize public benefits would be best served by the grant of 

21 frequencies to Delta necessary to implement its full service proposal. 

 Respectfully submitted,

_________________________________

Alexander Van der Bellen

Managing Director, Government Affairs

 & Associate General Counsel

DELTA AIR LINES, INC.
CERTIFICATE OF SERVICE

A copy of the foregoing Application has been served this 14th day of May, 2013, 

upon the following persons via email:

Francis.Heil@aa.com 

Robert.Wirick@aa.com

howard.kass@usairways.com

benjamin.slocum@usairways.com

dan.weiss@united.com

thomas.bolling@united.com

paul.gretch@dot.gov

esta.rosenberg@dot.gov

brian.hedberg@dot.gov

brett.kruger@dot.gov

urskr@state.gov

joe.cambron@wcaa.us

brubinst@panynj.gov

louis.miller@atlanta-airport.com

info@airlineinfo.com
Delta Reply Exhibits

Section I: Competitive Overview the of U.S.-Brazil Marketplace

Section II: US Airways – Charlotte

Section III: US Airways – Philadelphia

Section IV: American – Los Angeles

Section V: American – Chicago
Section I: Competitive Overview the of U.S.-Brazil Marketplace
The “New American” Will Dominate U.S.-Sao Paulo Service 

with a Minimum of 61 Frequencies from 5 Gateways

• Distribution of frequencies assuming 7 awarded to U.S. Airways together with 7 transferred 

from Delta

Docket DOT-OST-2013-0072

Exhibit DL-R-101

DFW (7)

MIA (26)

CLT (7)

PHL (7)

JFK (14)
An Award of 21 Frequencies to Delta is Required to Improve 

the Competitive Market Structure

• American currently dominates Brazil, with nearly half of the U.S. total of unrestricted Sao 

Paulo frequencies.

47

7

23

35

AA US DL UA

US-Brazil 

Unrestricted Weekly Frequencies by Airline

*

MIA 26x

JFK 14x

DFW 7x

EWR 7x

IAD 7x

IAH 7x

ORD 7x

*7x leased to US

ATL 7x

JFK 7x

DTW 7x

Docket DOT-OST-2013-0072

Exhibit DL-R-102

CLT 7x*

leased from UA

Note: 2 DL Unrestricted Frequencies Support Atlanta-Rio de Janeiro
Delta’s Proposal Improves the Competitive Market Structure Docket DOT-OST-2013-0072

Exhibit DL-R-103

23

7

47

DL US AA

16 7

47

DL US AA

37

14

47

DL US AA

37

7

54

DL US AA

DL frequencies to US 

to backfill leased UA

DL awarded 21 

frequencies, US or AA 

receive 7

37

61

DL AA/US

AA/US merge, 

increase frequency 

advantage 

37

61

DL AA/US

Current allocation of 

unrestricted 

frequencies

DOT DOT
American and US Airways Proposals

Exacerbate Competitive Imbalance Docket DOT-OST-2013-0072

Exhibit DL-R-104

23

7

47

DL US AA

16 7

47

DL US AA

16 21

61

DL US AA

DL frequencies to US 

to backfill leased UA

DL awarded no 

frequencies, US and 

AA receive 14 each

AA/US merge, 

increase frequency 

advantage 16

82

DL AA/US

Current allocation of 

unrestricted 

frequencies

DOT
An Award of 21 Frequencies to Delta Will Create the Optimal 

Competitive Distribution of Frequencies 

• AA will remain the largest U.S. carrier to Brazil, but with two credible challengers of equal 

strength

61

37 35

AA/US DL UA

U.S.-Brazil Unrestricted Frequency 

Distribution if Delta’s Proposal is Granted

MIA 26x

JFK 14x

CLT 7x

DFW 7x

LAX/ORD/PHL7x

EWR 7x

IAD 7x

IAH 7x

ORD 7x

??? 7x

ATL 14x

JFK 14x

DTW 7x

Docket DOT-OST-2013-0072

Exhibit DL-R-105

Note: 2 DL Unrestricted Frequencies Support Atlanta-Rio de Janeiro
American Airlines and US Airways are Merging Docket DOT-OST-2013-0072

Exhibit DL-R-106

“The combination is expected to 

be completed in the third 

quarter of 2013”

 - newamericanarriving.com/faq

American and US Airways 

expect to merge before any of 

the U.S.-Brazil frequencies at 

issue become effective.
Brazil Frequencies at Issue Are Not Covered 

by American Airlines/US Airways Route Transfer Application Docket DOT-OST-2013-0072

Exhibit DL-R-107

• Would require a de novo carrier selection case

American/US Airways Route Transfer 

Application Exhibit A, p 4

American/US Airways Route Transfer 

Application Exhibit B, pp 2-3
American Airlines and US Airways are Merging

• American and US Airways tout the strength of their combined Latin American network

Docket DOT-OST-2013-0072

Exhibit DL-R-108

Source: American/US Airways Route Transfer Application at 17.
American was Awarded 17 Brazil Frequencies Just Last Year 

– 7 of Which It Used to Fund New Service on the Restricted 

JFK-Sao Paulo Route

Docket DOT-OST-2013-0072

Exhibit DL-R-109

Appl i ca t i on of 

BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON , D. C. 

AMERICAN AIRLI NES , I NC . 

for allocation of 17 weekly combination 

f r equ enc ies f o r addi t i onal U. S .-Br azil 

service i n 2012 

DOT - OST- 2012 -

APPLICATION OF AMERICAN AIRLINES , INC. FOR 

ALLOCATION OF 17 WEEKLY COMBINATION FREQUENCIES 

FOR ADDITIONAL U. S . - BRAZIL SERVICE IN 2012 

America n Ai r l i nes, I n c . her eby a ppl ies f o r a l l o cat i on o f 

17 U. S . - Brazil weekl y combination frequencies in order t o 

operate t h e following additional U. S. - Brazil service on a yearround bas is. 

MIAMI-RIO DE JANEIRO {GIG) "BACKFILL" (7) 

We presentl y oper a t e daily n o n s top servi ce bet ween Miami 

and Ri o de J aneiro {AA 905/904) . Th e frequencies now assign ed 

to these GIG flights are useable to serve any point in Brazil, 

including Sao Paulo (GRU) . Effective October 1 , 2012 , American 

wi l l beg i n a second da i l y n o nst op flig ht from New Yo r k (JFK) t o 

Sao Paulo by transferr i ng t he GRU- eligible f requenci es f rom the 

MIA- GIG rou te to the JFK- GRU route . 

DELTA 
American was Able to Increase New York-Sao Paulo Service 

by Using DOT’s Award of New Frequencies to “Backfill” 

Miami-Rio de Janeiro

Docket DOT-OST-2013-0072

Exhibit DL-R-110

26

7 7 7

MIA-GRU MIA-GIG JFK-GRU DFW-GRU

AA Unrestricted 

Frequencies May 

2012

DOT

26

14 14

7

MIA-GRU MIA-GIG JFK-GRU DFW-GRU

Select AA 

Frequencies 

Following “Backfill”

• American was allowed to move frequencies that became eligible for Sao Paulo flying from 

their Miami-Rio de Janeiro flight to New York (JFK)-Sao Paulo

– DOT then immediately granted American new Rio de Janeiro frequencies to backfill 

those transferred to JFK-GRU, and additional MIA-Brazil frequencies as well

New Restricted Frequencies

Note: 11 Frequencies currently used for non-Sao Paulo service are eligible for future 

use at Sao Paulo once infrastructure constraints are addressed. 
An Award of 21 Frequencies to Delta is Required to Improve 

Competitive Balance

American

34%

US Airways

4% Tam, future 

oneworld

26%

Delta

14%

United

19%

Other

3%

U.S.-Sao Paulo 

Capacity Share by Airline

Docket DOT-OST-2013-0072

Exhibit DL-R-111

Source: August 2013 OAG

oneworld

64%

Star

19%

Skyteam

17%

U.S.-Sao Paulo 

Capacity Share by Alliance

American and US Airways offer 277% 

more Sao Paulo capacity than Delta

oneworld will control 64% of U.S.-Sao 

Paulo capacity
Gol Enhances Delta’s Brazil Network

• Delta codeshares on Gol to 19 Points beyond Sao Paulo

Docket DOT-OST-2013-0072

Exhibit DL-R-112

Source: August 2013 OAG
Section II: US Airways – Charlotte
Delta Needs Additional Frequencies at Atlanta to Better 

Compete with the 5 Daily Flights of AA/US from Their Eastern 

Network Hubs

• A single daily Atlanta flight puts Delta’s network at a competitive disadvantage to the five 

daily flights offered by AA/US from Miami and Charlotte.

Source: August 2013 OAG

Docket DOT-OST-2013-0072

Exhibit DL-R-201

5

1

AA/US DL

Daily Flights to GRU from Southeastern U.S. 

Gateways 

US Hub

DL Hub

AA Hub

500%
Additional Atlanta Frequencies Will Help to Alleviate the Loss 

of One-Stop Connecting Competition from AA/US Merger

48 Cities Will Lose A Competitive Alternative

Source: August 2013 schedules, Diio Mi

Docket DOT-OST-2013-0072

Exhibit DL-R-202

Note: Cities served from ATL by DL, and US/AA from MIA and CLT

DELTA 

Airport AA/US One-Stop Overlap Airport AA/US One-Stop Overlap Airport AAIU S One-Stop Overlap Airport AAIUS One-Stop Overlap Airport AA/US One-Stop Overlap 

ABE DAY JAX X PBI SRQ 

AGS DCA X JFK X POX STL X 

ALB DEN X LAS X PGV STT X 

ATL X DFW X LAX X PHF STX 

AUS DSM LEX PHL X SYR 

AVL DTW X LGA X PHX X TLH X 

AVP EWN LIT PIT X TPA X 

BDL X EWR X LYH PNS X TRI 

BHM X EYW MCI PVD TUL 

BNA X FAY MCO X PWM TYS 

BOS X FLL MDT RDU X VPS 

BTR FLO MEM X RIC X XNA 

BUF GNV X MGM ROA 

BWI X GPT MHT ROC 

CAE GSO X MIA X RSW 

CAK GSP MKE SAN X 

CHA HHH MLB SAT 

CHO HPN MOB SAV 

CHS X HSV MSP X SBY 

CLE X HTS MSY X SDF X 

CLT X lAD X MYR SEA X 

CMH X IAH X OAJ SFO X 

CRW ILM OMA SJU X 

CVG X IND X ORO X SLC 

DAB JAN ORF X SMF 
Delta’s Proposed Atlanta Gateway Offers Broadest Access 

for U.S. Cities Docket DOT-OST-2013-0072

Exhibit DL-R-203

150

108

85

ATL CLT PHL

Non-stop Destinations from Proposed Hubs

Source: August 2013 OAG

US Proposal

DL Proposal
Delta’s Proposed Sao Paulo Gateways Offer Greater Access 

for More U.S. Customers Docket DOT-OST-2013-0072

Exhibit DL-R-204

5,457

2,296

0

2,000

4,000

6,000

ATL CLT

Population from Proposed Hub’s 

Metropolitan Areas (Thousands)

Source: 2012 Census Estimate

18,897

5,965

0

5,000

10,000

15,000

20,000

JFK PHL

Population from Proposed Hub’s 

Metropolitan Areas (Thousands)

US Proposal

DL Proposal
Atlanta Offers More Potential U.S. City Connections Than 

Charlotte and Miami Combined

• Atlanta offers 38 more unique U.S. destinations than Charlotte and Miami Combined

150

112 108

50

ATL Combined CLT & MIA CLT MIA

U.S. City Connections from Southeastern Hubs

AA/US Hub

DL Hub

Source: August 2013 OAG

Docket DOT-OST-2013-0072

Exhibit DL-R-205
Atlanta is an Ideal East Coast Gateway to Sao Paulo 

Delta Provides Nonstop Service to 150 U.S. Points 

Source: August 2013 schedules, Diio Mi To GRU

To HNL

Docket DOT-OST-2013-0072

Exhibit DL-R-206

To ANC
Atlanta is Delta’s Largest Hub 

and a Major Long-Haul International Gateway

• Atlanta is a major South American gateway

• Delta has a leading international presence in Atlanta and currently serves nine non-stop

destinations in South America, two in Africa, one in Asia, and sixteen in Europe

Docket DOT-OST-2013-0072

Exhibit DL-R-207
Atlanta Needs a Second Frequency to Offer Competitive Time 

Channel Coverage to Miami

Source: August 2013 OAG

Docket DOT-OST-2013-0072

Exhibit DL-R-208

ATL 

1030 

1100 

1130 

1200 

1830 

1900 

1930 

2000 

2030 

2100 

2130 

2200 

2230 

2300 

2330 

2400 

Southbound Departures 

Summer 2013 

Proposed DL - 767 

DL - 767 

CLT/MIA 

1030 

1100 

1130 

1200 

1830 

1900 

1930 

2000 

2030 

2100 

2130 

Southbound Departures 

Summer 2013 

AA - 777 

AA -777 

2200 AA - 777 & US - 767 

2230 

2300 

2330 

2400 

AA -777 

ATL 

0800 

0830 

0900 

1030 

1100 

1130 

1200 

2100 

2130 

2200 

2230 

2300 

2330 

2400 

Northbound Departures 

Summer 2013 

DL - 767 

Proposed DL - 767 

DELTA 

CLT/MIA 

0800 

0830 

0900 

1030 

1100 

1130 

1200 

2100 

2130 

2200 

2230 

2300 

2330 

2400 

Northbound Departures 

Summer2013 

us - 767 

AA -777 

AA - 777 

AA - 777 

AA- 777 
Atlanta Offers Unsurpassed Convenience for U.S.-Brazil 

Connection Passengers Docket DOT-OST-2013-0072

Exhibit DL-R-209

• In May 2012, Delta and Atlanta opened the state-of-the-art Maynard H. Jackson 

Jr. International Terminal, a new $1.4 billion terminal project.
Atlanta Offers Unsurpassed Convenience for U.S.-Brazil 

Connection Passengers Docket DOT-OST-2013-0072

Exhibit DL-R-210

• DL offers exceptional convenience for connecting passengers at HartsfieldJackson Atlanta International Airport. International arrivals and departures are 

gated in Concourses E and F and are easily accessed via airport tram.
EWR EWR

LAX LAX

ORD ORD

MIA MIA

MCO MCO

ATL ATL

CLT CLT

IAHIAH

DFW

JFK JFK

IADIAD

Delta’s Detroit-Sao Paulo Service Gives the Underserved 

Midwest Region A Second U.S. Gateway to Brazil

DTW

Existing Brazil Gateway

Docket DOT-OST-2013-0072

Exhibit DL-R-211
Docket DOT-OST-2013-0072

Exhibit DL-R-212

20,347

6,271

DTW CLT

Local GRU Bookings

DL Proposal

Detroit is a Important Gateway At Risk of Losing Service

Source: MIDT YE Mar 2013

US Proposal

• Detroit is more than three times larger than Charlotte, which US Airways claims 

is at risk of loss of service as a result of the merger.
Docket DOT-OST-2013-0072

Exhibit DL-R-213

Michigan Industry Relies on DTW International Service 

Major Michigan Companies:

General Motors Stryker

Ford Motor Autoliv

Chrysler Group Visteon

Dow Chemical Masco 

Whirlpool Borg Warner

TRW Automotive Holdings CMS Energy

Lear Auto-Owners Insurance

Ally Financial Kelly Services

Kellogg Con-way

Penske Automotive Group Meritor

DTE Energy
DTW is Delta’s Primary Midwestern Hub

Delta Provides Nonstop Service to 114 U.S. Points 

Source: August 2013 schedules, Diio Mi

Docket DOT-OST-2013-0072

Exhibit DL-R-214

To GRU

DELTA 
The DOT-Approved DCA/LGA Slot Swap Produced 

Enormous Consumer Benefits Docket DOT-OST-2013-0072

Exhibit DL-R-215

8%

13%

Seat Chg Pax Chg

LGA Capacity vs. Demand

Slot transaction created immediate value to traveling public

• DL/US seats in LGA increased 8% and passenger demand increased 

almost twice that amount at 13%

• LGA industry traffic increased by more than 2,000 daily passengers YoY 

which is over 750,000 annually

Source: Seat Change – OAG guide for peak week August 2012 v August 2011 to USA 

DOT 3Q 2012 v. 3Q 2011 for passenger change (U.S. only)
Section III: US Airways – Philadelphia
New York is the Largest and Most Important U.S. Market to 

Sao Paulo Docket DOT-OST-2013-0072

Exhibit DL-R-301

338,196

97,309

51,281

7,288 6,271

NYC LAX ORD PHL CLT

0

100000

200000

300000

400000

U.S.-GRU Local Bookings

DL Proposal

Source: MIDT YE Mar 2013

• New York dwarfs the competing gateway proposals in terms of local market size

AA Proposal

US Proposal
American and Its oneworld Partner, TAM, Out-schedule Delta 

3 Flight to 1 in the Critical New York-Sao Paulo Market

• An additional JFK frequency will help to achieve parity with American, but Delta will still 

trail the combined American/TAM (JJ) oneworld offering.

Source: August 2013 OAG

Docket DOT-OST-2013-0072

Exhibit DL-R-302

3

1

AA & JJ DL

Daily JFK-Sao Paulo Flights

AA

JJ

1,838

492

AA & JJ DL

Daily JFK-Sao Paulo Seats

AA

JJ
Delta Needs a Second JFK Frequency

to Offer Competitive Time Channel Coverage

Source: August 2013 OAG

Docket DOT-OST-2013-0072

Exhibit DL-R-303

DL 

1030 

1100 

1130 

2030 

2100 

2130 

2200 

2230 

2300 

Southbound Departures 

Summer 2013 

Proposed DL - 767 

DL - 764 

AA &JJ 

1030 

1100 

1130 

2030 

2100 

2130 

2200 

2230 

2300 

Southbound Departures 

Summer 2013 

AA - 777 

JJ - 773 

AA - 77W 

DL 

0700 

0730 

0800 

2030 

2100 

2130 

2200 

2230 

2300 

2330 

Northbound Departures 

Summer 2013 

DL - 767 

Proposed DL - 767 

DELTA 

AA&JJ 

0700 

0730 

0800 

2030 

2100 

2130 

2200 

2230 

2300 

2330 

Northbound Departures 

Summer2013 

AA - 77W 

AA -777 

JJ - 773 
Delta’s Domestic JFK Routes Provide Key Access to 

International Destinations 

Delta Provides Nonstop Service to 48 U.S. Points 

Source: August 2013 schedules, Diio Mi

Docket DOT-OST-2013-0072

Exhibit DL-R-304

To GRU

DELTA 

• SEA ---------- ------------------------

PDX 

SFO 

SJU 
JFK is Delta’s Premier International Gateway 

Delta Provides Nonstop Service to 44 International Points 

Source: August 2013 schedules, Diio Mi

Docket DOT-OST-2013-0072

Exhibit DL-R-305

DELTA 
JFK’s New Terminal 4 Will Offer NYC-Brazil Passengers A 

Premier Airport Experience Docket DOT-OST-2013-0072

Exhibit DL-R-306

• In May 2013, Delta and New York will open the new Terminal 4, a $1.4 billion 

terminal project that will allow for easier transit with additional baggage claims, 

as well as customs and border-security facilities.
JFK’s New Terminal 4 Will Offer NYC-Brazil Passengers A 

Premier Airport Experience Docket DOT-OST-2013-0072

Exhibit DL-R-307

• International arrivals will be concentrated in the new Terminal 4.
Section IV: American – Los Angeles
American is Able to Fly LAX-GRU Today Docket DOT-OST-2013-0072

Exhibit DL-R-401

26

14

7

0

MIA JFK DFW LAX

AA Frequencies by Gateway

• Despite holding 47 unrestricted frequencies, with no U.S. gateway limitations, AA spurns 

LAX-GRU in favor of quadruple daily service at MIA and double daily service at JFK

?
Los Angeles Has Not Sustained Direct 

Daily Sao Paulo Service

• Only Korean Air Lines operates this route currently

– 3x weekly

– Historical Load Factor < 70%

• Delta and United have both operated the route before, each attempt lasted less 

than 8 months

– DL August 2009-February 2010

– UA October 1992-April 1993

Docket DOT-OST-2013-0072

Exhibit DL-R-402

1990 2000 2010

DL

UA

AA

LAX-GRU Scheduled Service History by U.S. Flag Carriers
American’s Los Angeles Customers Can Conveniently 

Connect Via DFW & MIA Docket DOT-OST-2013-0072

Exhibit DL-R-403

LAX-GRU via DFW via MIA

Distance 6,346 6,414

Circuity 3.1% 4.2%
LAX-GRU Would Only Benefit a few West Coast Connections Docket DOT-OST-2013-0072

Exhibit DL-R-404

More convenient 

via LAX

More convenient via DFW or MIA
American’s Los Angeles Customers Can Conveniently 

Connect Via DFW & MIA Docket DOT-OST-2013-0072

Exhibit DL-R-405

• Of the 43 cities AA serves from LAX, only 6 are not already connected to DFW

Source: August 2013 OAG
American’s Los Angeles Customers Can Conveniently 

Connect Via DFW & MIA Docket DOT-OST-2013-0072

Exhibit DL-R-406

• Of the 43 cities AA serves from LAX, only 6 are not already connected to DFW

Source: August 2013 OAG

37

6

Already 

Connected

New Conneciton 

via LAX

AA LAX Cities Already 

Connected to GRU via DFW
Section V: American – Chicago
EWR EWR

LAX LAX

ORD ORD

MIA MIA

MCO MCO

ATL ATL

CLT CLT

IAHIAH

DFW

JFK JFK

IADIAD

Delta’s Detroit-Sao Paulo Service Gives the Underserved 

Midwest Region A Second U.S. Gateway to Brazil

DTW

Existing Brazil Gateway

Docket DOT-OST-2013-0072

Exhibit DL-R-501
DTW is Delta’s Primary Midwestern Hub

Delta Provides Nonstop Service to 114 U.S. Points 

Source: August 2013 schedules, Diio Mi

Docket DOT-OST-2013-0072

Exhibit DL-R-502

To GRU

DELTA 
DTW is Delta’s Midwest International Gateway 

Delta Provides Nonstop Service to 16 International Points 

Source: August 2013 schedules, Diio Mi

Docket DOT-OST-2013-0072

Exhibit DL-R-503

DELTA 

GRU 
Detroit Offers More Potential U.S. City Connections Than 

AA at O’Hare

• Detroit offers 13 more unique U.S. destinations than O’Hare

114

101

DTW ORD

U.S. City Connections from 

Midwestern Hubs

AA Hub

DL Hub

Source: August 2013 OAG

Docket DOT-OST-2013-0072

Exhibit DL-R-504
Passengers Throughout the U.S. 

Can Conveniently Travel via Detroit Docket DOT-OST-2013-0072

Exhibit DL-R-505

• The McNamara Terminal was designed with simplicity and ease of passenger 

transfer in mind.
Passengers Throughout the U.S. 

Can Conveniently Travel via Detroit Docket DOT-OST-2013-0072

Exhibit DL-R-506

• DL offers exceptional convenience for connecting passengers with the 

McNamara Terminal at Detroit Metropolitan Wayne County Airport.