### BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_________________________________________ )

In the matter of )

) Docket DOT

- OST

- 2010

- 0018

2010 US

- Haneda Combination Services )

Alloca tion Proceeding )
_________________________________________)

ANSWER OF THE

DELTA MASTER EXECUTIVE COUNCIL
OF THE AIR LINE PILOTS ASSOCIATION, INTERNATIONAL

IN SUPPORT OF THE MOTION OF DELTA AIR LINES

Communications with respect to this documen t 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

August 8, 2012

### BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

________________________________________ )

In the matter of )

) Docket DOT

- OST

- 2010

- 0018

2010 US

- Haneda Combination Services )
Allocation Proceeding )
________________________________________)

ANSWER OF THE

DELTA MASTER EXECUTIVE COUN CIL

OF THE AIR LINE PILOTS ASSOCIATION , INTERNATIONAL

IN SUPPORT OF THE MOTION OF DELTA AIR LINES

The Delta Master Executive Council, th e Delta chapter of the Air L ine P ilots Association,

Int ernational (the “MEC”), strongly supports the Motion of Delta Air Lines, Inc. (“Delta”) to

permit the carrier to move its daily Detroit

- Haneda slot pair to the Seattle gateway. T he Detroit

Han eda market has not performed as exp ected, and for this reason Delta has proposed that it be

permitted to move the gateway to Seattle. Delta’s Motion makes the case for providing Delta

the flexibility to move one of its two Haneda gateways. The MEC fully supports this Delta

request.

Unlik e other U.S. passenger carriers serving Tokyo, Delta is the only carrier without a

major Japanese partner, much less one that operates under an exemption from the antitrust laws.

As such Delta is at a structural disadvantage vis

- à

- vis its U.S. carrier com petitors in the U.S.

-

Japan market. Implicitly the award of two Haneda slot pairs to Delta in 2010 addressed this

competitive imbalance in the U.S.

- Tokyo market because unlike American and United, Delta

would have to compete harder for its share of Tokyo t raffic. The DOT should continue toAnswer of Delta Master Executive Council

August 8, 2012
Page 2 of 3

emphasize the need to foster competition between the immunized carriers and Delta by

permitting Delta to move one of its Haneda gateways.

Delta originally had identified the Seattle

- Haneda market as its number one prio rity based

on careful market planning considerations. The DOT authorized Delta to serve two of the other

gateways for which Delta had also requested Haneda slot pairs. Allowing Delta to move one of

its two Haneda gateways to a better performing gateway

— o ne with greater structural

advantages

-- thereby strengthening the Delta system is in the best interest of the traveling and

shipping public and the 80,000 worldwide employees of Delta, including the 12,000+ members

of the Delta chapter of the Air Line P ilot s Association, Int ernational. At the same time, the

traveling public will gain by the initiation of new nonstop Seattle

- Haneda service, as Seattle is

currently the largest U.S.

- Tokyo market without nonstop Haneda service. This benefit will be

felt not on ly in the local Seattle

- Tokyo market but also in the entire northwest region catchment

area served by Delta and its domestic code share partners, Alaska and Horizon. In making its

initial awards of Haneda slot pairs, the DOT emphasized as selection criter ia both local market

size and supporting traffic from the gateway catchment area. These factors strongly support the

request of Delta to move a Haneda slot pair to the Seattle gateway.Answer of Delta Master Executive Council

August 8, 2012
Page 3 of 3

For the reasons set forth above, the MEC strongly supports the Delta request to allow the

carrier to move one of its two Haneda gateways to Seattle and urges the DOT to expeditiously

grant Delta’s Motion.

Respectfully submitted

,

Timothy S. O’Malley

Chairman

Delta Master Executive Council

Air Line Pilots Association, In t ernationa l

### CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Answer in Support of the Motion of
Delta Air Lines, Inc. has this day been served by electronic mail on the following

individuals:

sascha.vanderbelle@delta.com

carl.nelson@ aa.com

Francis.Heil@aa.com

Robert.Wirick@aa.com

dan.weiss@united.com

thomas.bolling@united.com

howard.kass@usairways.com

benjamin.slocum@usairways.com

jhill@dowlohnes.com

paul.gretch@dot.gov

keith.glatz@dot.gov

esta.rosenberg@dot.gov

todd.homan@dot.gov

ur skr@state.gov

eugene_alford@ita.doc.gov

info@airlineinfo.com

August 8, 2012