BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

In the matter of 2010 U.S.-Haneda Combination 

Services Allocation Proceeding

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Docket DOT-OST-2010-0018 

PETITION FOR RECONSIDERATION

OF ORDER 2013-11-9

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

Andreas Renner

Director – International 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 – Regulatory and International 

Affairs & Associate General Counsel

Christopher Walker

Regional Director – Regulatory and International 

Affairs

DELTA AIR LINES, INC. 

1212 New York Avenue, N.W. 

Washington, D.C. 20005

(202) 842-4184

sascha.vanderbellen@delta.com

chris.walker@delta.com

November 19, 2012
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 

PETITION FOR RECONSIDERATION

OF ORDER 2013-11-9

By Order 2013-11-9, the Department instituted a proceeding to consider applications 

for the Tokyo Haneda Airport (“Haneda”) slot pair returned by American as a result of the 

cancellation of its New York (JFK) - Haneda service. Delta respectfully petitions the 

Department to expand the scope of this proceeding to consider and allow amending the 

terms and conditions of previously-allocated Haneda slots to allow them to be used at any 

U.S. gateway, consistent with Open Skies principles. 

The U.S.-Japan aviation marketplace is rapidly evolving, and it is important for 

carriers to have flexibility to respond to changes in the marketplace as they occur, without 

the need for successive route case proceedings. 

Delta operates a hub at Tokyo Narita, and provides nonstop U.S.-Haneda service 

from Los Angeles and Seattle. Delta is continuing to grow its domestic and international 

service from Los Angles and Seattle, and has no immediate plans to change its current 

pattern of Haneda service. However, gateway flexibility is critically important to allow 

carriers to adapt to the changing competitive environment that will continue to present 

unique challenges to U.S. flag carriers at Haneda until that airport is completely open for 

service to the United States.
Delta Petition

Page 2

Since the Department last conducted a Haneda route case in 2012, significant new

changes have occurred that will impact existing Haneda operations. American has elected 

to cease Haneda service from JFK, and those slots will be re-allocated. Additionally, Japan 

and Canada have entered into new agreement providing for Haneda flights beginning in 

April, 2014,1 making daytime service from Air Canada’s Vancouver hub a distinct possibility. 

The impact of these marketplace developments on other west coast Haneda 

gateways is not yet known. It is vital that U.S. flag Haneda competitors have the ability to 

make network changes quickly, as in other open skies markets, without the uncertainty and 

delay of a route case. Indeed, current gateway restrictions place U.S. carriers at a

disadvantage to their Japanese competitors, who are free to make changes to their Haneda 

services as market conditions warrant.

Delta’s request is consistent with DOT precedent. In the large and important U.S.-

Brazil market, DOT acted to eliminate city-pair limitations from all prior route case awards

and allowed carriers commercial discretion in the use of their frequencies: “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). 

In evaluating the distribution of Haneda slots among U.S. carriers, the Department

has discretion to consider a wide range of public interest factors. For the foregoing 

reasons, Delta asks that this request for gateway flexibility be considered together with the 

proposals of United and Hawaiian for the returned American Haneda slots.

 1 http://www.tc.gc.ca/eng/mediaroom/releases-2013-h127e-7368.html
Delta Petition

Page 3

Respectfully submitted,

_________________________________

Alexander Van der Bellen

Managing Director, Regulatory and 

International Affairs

 & Associate General Counsel

DELTA AIR LINES, INC.
CERTIFICATE OF SERVICE

A copy of the foregoing Petition has been served this 19th day of November, 2013, upon 

the following persons via email:

dan.weiss@united.com

thomas.bolling@united.com

lhalloway@crowell.com

gmurphy@crowell.com

jhill@dowlohnes.com

francis.heil@aa.com

robert.wirick@aa.com

howard.kass@usairways.com

benjamin.slocum@usairways.com

marshall.sinick@squiresanders.com

paul.gretch@dot.gov

brian.hedberg@dot.gov

esta.rosenberg@dot.gov

brett.kruger@dot.gov

todd.homan@dot.gov

urskr@state.gov

cristinasa@state.gov

eugene_alford@ita.doc.gov

info@airlineinfo.com