BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________

)

Motion of )

 ) 

DELTA AIR LINES, INC. ) Docket DOT-OST-2010-0018

 )

in the matter of 2010 U.S.-Haneda )

Combination Services Allocation Proceeding )

__________________________________________)

ANSWER OF THE DELTA MASTER EXECUTIVE COUNCIL

OF THE AIR LINE PILOTS ASSOCIATION, INTERNATIONAL

IN SUPPORT OF DELTA AIR LINES, INC.

Communications with respect to this document should be addressed to:

Timothy S. O’Malley

Chairman

Delta Master Executive Council

Air Line Pilots Association, International

100 Hartsfield Centre Parkway, Suite 800

Atlanta, Georgia 30354

Tim.OMalley@alpa.org

September 6, 2012
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________

)

Motion of )

 ) 

DELTA AIR LINES, INC. ) Docket DOT-OST-2010-0018

 )

in the matter of 2010 U.S.-Haneda )

Combination Services Allocation Proceeding )

__________________________________________)

ANSWER OF THE DELTA MASTER EXECUTIVE COUNCIL

OF THE AIR LINE PILOTS ASSOCIATION, INTERNATIONAL

IN SUPPORT OF DELTA AIR LINES, INC.

Delta Air Lines, Inc. (“Delta”) has requested authority from the Department of 

Transportation to operate over the Seattle-Haneda route. The Delta Master Executive 

Council, the Delta chapter of the Air Line Pilots Association, International (the “Delta 

MEC”), strongly supports Delta’s request. 

Allowing Delta to serve the Seattle-Haneda route will maximize public benefits 

by permitting Delta to implement the only nonstop service between Haneda and Seattle, 

the largest U.S.-Tokyo O&D market that lacks nonstop Haneda service. In addition, 42 

U.S. cities will receive convenient one-stop connecting service to Haneda via Delta’s 

Seattle gateway in the Pacific Northwest.

Approval of Delta’s Seattle-Haneda request will serve an important public interest 

need. It will also benefit the 12,000 members of the Delta chapter of the Air Line Pilots 

Association, along with the other 70,000 dedicated employees who operate Delta’s 

worldwide network. Tokyo is extremely important to Delta’s Asia-Pacific network, and 

it is essential that Delta be allowed to compete at Tokyo’s close-in Haneda airport, which 

is a protected stronghold of the U.S.-Japan immunized alliances. Unlike United and
Answer of the Delta Master Executive Council

Page 2

American, Delta does not have a Japanese partner to help it compete in the U.S.-Haneda 

marketplace. In contrast to the multiple transpacific flights and large scale hubs operated 

by the Star and oneworld carriers at Haneda, Delta competes with two daily U.S.-Haneda 

flights operated by Delta pilots and crews. It is essential that Delta be allowed to make 

the most of its limited Haneda slots by operating at the preferred Seattle gateway. 

The benefits of this new route to our employee groups are in addition to furthering 

the Department’s long-standing objective of promoting inter-alliance competition in the 

U.S.-Haneda, U.S.-Japan and U.S.-Asia markets by enhancing Delta’s ability to provide 

consumers with a meaningful competitive alternative to the immunized Star 

(United/ANA) and oneworld (American/JAL) alliances. Both of these alliances have a 

much larger presence at Haneda and the Japanese partner airlines are free to change their 

U.S. Haneda gateways without regulatory approval. 

With over 114,000 Tokyo passengers annually, Seattle is the largest U.S.-Tokyo 

O&D market without Haneda service today. Both the Los Angeles-Haneda and San 

Francisco-Haneda markets, which American and United propose to serve, already enjoy 

non-stop service. An award to American or United would be duplicative of service 

already in these markets. 

Hawaiian proposes to reestablish service in the Tokyo-Kona market, which was 

previously served by JAL from Narita. Hawaiian does not need a further award of 

Haneda slots to serve the Tokyo-Kona market, since open skies opportunities exist at 

Narita. Hawaii already has three daily Haneda flights, which are used almost exclusively 

by Japanese tourists. The Delta MEC believes that Delta’s Seattle proposal will create
Answer of the Delta Master Executive Council

Page 3

greater benefits for U.S. consumers seeking convenient and competitive service to 

Haneda. 

Delta’s Seattle gateway competes for U.S.-Tokyo passengers with the West Coast 

gateways of Los Angeles and San Francisco, but is at a disadvantage because Delta is 

currently unable to offer nonstop service between Seattle and Haneda. By granting 

Delta’s request the Department will maximize public benefits by enabling Delta to meet 

the substantial consumer demand for well-timed nonstop service between Seattle and 

Haneda and at the same time promote inter-gateway competition among the alliances by 

opening a third West Coast gateway. 

JAL and ANA, which have “metal-neutral” immunized joint ventures with their 

U.S. partners, have discretion to use their Haneda slots to serve any U.S. point of their 

liking. 1 Delta, which does not have a Japanese alliance partner, is at a strategic 

disadvantage vis-à-vis the immunized Star and oneworld alliances because it cannot 

move its Haneda slot pairs without the permission of the Department. 

 

1

The DOT accepted the elimination of competition between United and ANA and 

between American and JAL based on the carriers’ assurances that immunizing the 

alliances from antitrust laws would result in integrated, metal-neutral joint venture 

benefits. Now United and American are acting as if metal neutrality does not result in the 

benefits both carriers claimed as justification for the grant of antitrust immunity.
Answer of the Delta Master Executive Council

Page 4

For the foregoing reasons, the Delta MEC strongly supports Delta’s request to 

move one of its Haneda slot pairs to the Seattle-Haneda route and urges the Department 

to allow Delta to do so. 

 Respectfully submitted,

Timothy S. O’Malley

Chairman

Delta Master Executive Council

Air Line Pilots Association, International
CERTIFICATE OF SERVICE

A copy of the foregoing document has been served this 6

th day of September, 2012, upon 

the following persons via email:

sascha.vanderbellen@delta.com

francis.heil@aa.com

Robert.Wirick@aa.com

dan.weiss@united.com

thomas.bolling@united.com

hershel.kamen@united.com

steve.morrissey@united.com

jonathan.linde@united.com

lhalloway@crowell.com

gmurphy@crowell.com

jhill@dowlohnes.com

perkmann@dowlohnes.com

bolson@dowlohnes.com

todd.homan@dot.gov

paul.gretch@dot.gov

keith.glatz@dot.gov

esta.rosenberg@dot.gov

brett.kruger@dot.gov

urskr@state.gov

eugene_alford@ita.doc.gov

ishiwata.k@portseattle.org

safora.i@portseattle.org

kyle.levine@alaskaair.com

megan.lawence@alaskaair.com

info@airlineinfo.com