October 14, 2010 

The Honorable Raymond H. LaHood 

Secretary 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, D.C. 20590 

Re: Application of Delta Air Lines, Inc., in Docket DOT-OST-2008-0252 

Dear Mr. Secretary: 

For the reasons set forth below, this is to express the support of the Air 

Line Pilots Association for the application of Delta Air Lines – as it is the 

only U.S. airline that has applied - for three of the slot pairs involving 

Heathrow airport that American Airlines and its oneworld partners have 

been required to divest as a condition of the Department’s approval of 

their request for antitrust immunity in this proceeding. An award of the 

slots to a U.S. air carrier such as Delta would ensure that the economic 

and employment benefits represented by the slots will be maximized and 

will flow to a U.S. airline and its employees. 

In the Final Order (Order 2010-7-8), DOT determined that a slot transfer 

remedy was necessary to preserve some of the competition that will be 

lost by virtue of the alliance proposed by the oneworld applicants. This 

remedy requires the transfer of two slot pairs for the Boston-Heathrow 

route and two for any other U.S. – Heathrow service. 

It would be appropriate for the Department to award as many of these 

slots as possible to a U.S. air carrier. Delta has requested the allocation 

of the two slot pairs for Boston-Heathrow and one of the others, which it 

plans to use on the Miami-Heathrow route. No other U.S. airline has 

applied for these slots and the proposed operations represent more than 

80 quality pilot jobs as well as several hundred more jobs for other Delta 

and U.S. airport workers. Under the aviation statutes the DOT is to 

attempt to strengthen the competitive position of U.S. air carriers to 

ensure at least equality with foreign air carriers, including the attainment 

of the opportunity to maintain and increase their profitability in foreign air 

transportation. The Department is also required to attempt to encourage 

fair wages and working conditions. 49 U.S.C. sections 40101 (a)(5) and 

(15). Certainly, an award to Delta would advance these statutory 
 

 

The Honorable Raymond H. LaHood 

Secretary 

U.S. Department of Transportation 

October 14, 2010 

Page 2 

 

objectives. Moreover, as Delta shows in its application, the carrier is in a 

good position to maximize the value of these slots. Delta currently uses all 

the slots it currently has at Heathrow and has presented a sound business 

proposal for using the requested slots as well. 

Accordingly, ALPA strongly urges the Department to grant Delta’s 

request. It is essential that U.S. carriers and their employees receive the 

most benefit possible from the decision to grant the oneworld partners’ 

application for antitrust immunity. It is all the more important that the 

Department take this action at a time when the economic health of U.S. air 

carrier industry remains fragile and employment at the major U.S. airlines 

continues to drift downward. 

We appreciate your consideration of our views on this matter. 

Sincerely, 

 John H. Prater 

President 

cc: Docket OST-2008-0252