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

MOTION OF DELTA AIR LINES, INC.
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 – Government Affairs & Associate General Counsel DELTA AIR LINES, INC. 1212 New York Avenue, N.W. Washington, D.C. 20005 (202) 842-4184 sascha.vanderbellen@delta.com

July 30, 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

MOTION OF DELTA AIR LINES, INC.
Delta requests permission to move its Detroit-Haneda slots to the Seattle-Haneda

route. These slots were awarded by Order 2010-7-2, and are currently limited to service at
Detroit. Delta moves the Department to amend the Order to allow Delta flexibility to operate
from the Seattle gateway.
The marketplace has indicated that Delta’s Detroit-Haneda slots would be better
utilized at Seattle. Based on its actual operating experience, Delta has found that Eastern
U.S.-Haneda service is underperforming relative to the West Coast-Haneda service. Seattle
is the largest U.S.-Tokyo market without nonstop Haneda service. Seattle’s West Coast
location also allows for a more attractive and consumer friendly schedule that is a better fit
with the Haneda operating window. Delta’s network at Seattle, together with its codeshare
partner, Alaska Airlines, provides convenient and non-circuitous connections to scores of
U.S. cities. By establishing Haneda service at the Seattle gateway —

 Delta will be able to respond to demand in the marketplace and better serve

its customers.

 Delta will be a more effective challenger to the immunized Star and oneworld

alliances at Haneda and in Japan.Motion Page 2

 Delta will be able to operate a more profitable and economically viable

service.
In other open skies markets, carriers have the flexibility to chose their gateways and
make adjustments based on market reaction to new service offerings. However, Delta
recognizes that the open skies agreement with Japan and the bilateral compromise that was
reached on Haneda service is unique. Accordingly, Delta requests the Department to
conduct any necessary administrative proceedings as quickly as possible, so that Delta can
have flexibility to change gateways and improve it s service offering in the U.S. - Haneda
marketplace.

Respectfully submitted,

_________________________________ Alexander Van der Bellen Managing Director, Government Affairs & Associate General Counsel DELTA AIR LINES, INC.CERTIFICATE OF SERVICE
A copy of the foregoing document has been served this 30th day of July, 2012, upon the following persons via email:

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 urskr@state.gov eugene_alford@ita.doc.gov info@airlineinfo.com