BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________ ) Motion of ) ) DELTA AIR LINES, INC. ) Docket DOT

- OST

- 2010

- 0018 ) i n 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 re spect 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

Sep tember 6 , 2012BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________ ) Motion of ) ) DELTA AIR LINES, INC. ) Docket DOT

- OST

- 2010

- 0018 ) i n the mat ter 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, th e Delta chapter of the Air Line P ilots Association, Int ernational (the “Delta
MEC”), st rongly 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 Han eda 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 essenti al 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 andAnswer 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
marketp lace. 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 competitio n 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 re establish 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 da ily Haneda flights, which are used almost exclusively
by Japanese tourists. The Delta MEC believes that Delta’s Seattle proposal will createAnswer of the Delta Master Executive Council

Page 3
greater benefits for U.S. consumers seeking convenient and competitive service to

Haneda.
Delta’s Seattle gatewa y 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 gatew ay.
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

d isadvantage 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 eliminatio n 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 r esult in the benefits both carriers claimed as justification for the grant of antitrust immunity.Answer of the Delta Master Executive Council

Pa ge 4
For the foregoing reasons, the Delta MEC strongly supports Delta’s request to

move one of its Haneda s lot 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, In ternationa lCERTIFICATE OF SERVICE

A copy of the foregoing document has been served this 6 th day of September , 201 2 , upon the following persons via email:

sascha.vanderbelle n @delta.com
francis.heil@aa.com
Robert.Wirick@aa.com
dan.weiss@ united .com thomas.bolling@united.com
hershel.kamen@unit ed.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.kr uger@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