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

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 DELT A 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

– Reg ulatory 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@de lta.com chris.walker@delta.com

November 19 , 2012BEFORE 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 RECONS IDERATION 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 servic e. 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 p rinciples.

The U.S.

- Japan aviation marketplace is rapidly evolving, and it is important for

carriers to have flexibility to respond to changes i n 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 ser v i c e. 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

ser vi c e 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 develo pments on other west coast Haneda

gateways is not yet know n . I t 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, curre nt 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 allow ed carriers commercial discretion in the use of their frequencies : “We . . . grant the

. . . U.S. carriers designated for combination services in th e U.S.

- Brazil markets flexibility to

use their allocated frequencies in markets where the carriers hold requisite underlying

authority.” (Order 2 004

- 6

- 25).

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

has discre tion 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.htmlDelta Petition Page 3

Respec tfully submitted,

_________________________________ Alexander Van der Bellen Managing Director, Regulatory and International Affairs

& Associate General Counsel DELTA AIR LINES, INC.C ERTIFICATE OF SERVICE

A copy of the foregoing Petition has been ser ved this 1 9 th day of November, 2013 , upon the following persons via email:

dan.weiss@united.com thomas.bolling@united.com
lhalloway@crowell.com gmurphy@crowell.c om jhill@dowlohnes.com

f rancis. h eil@aa.com

robert.w irick@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.k ruger@dot.gov todd.homan@dot.g ov urskr@state.gov

c ristina sa @state.gov eugene_alford@ita.doc.gov

info@airlineinfo.com