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

TO OBJECTIONS TO ORDER 2012-11-12

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

December 3, 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 )

__________________________________________)

REPLY OF THE DELTA MASTER EXECUTIVE COUNCIL

OF THE AIR LINE PILOTS ASSOCIATION, INTERNATIONAL

IN SUPPORT OF DELTA AIR LINES, INC.

The Delta Master Executive Council, the Delta chapter of the Air Line Pilots Association, 

International (the “Delta MEC”) hereby answers the objections to Order to Show Cause 2012-

11-12, submitted by the Continental and United Master Executive Counsels of the Air Line 

Pilots Association, International (the “United MEC”), United Air Lines and San Francisco 

International Airport (“SFO”). Not surprisingly, these three parties object to the DOT’s Show 

Cause Order to the extent the DOT granted Delta’s request to move its Haneda gateway from 

Detroit to Seattle. The DOT’s determination to approve Delta request is a sound decision and 

warrants being made final by the Department. 

The public interest criteria employed in the DOT’s decision can hardly come as a surprise 

to United and its allies. The DOT chose to put a premium on Haneda service from a new 

gateway and to geographically diversify the limited number of gateways available to U.S. 

carriers. Hence, Delta’s Seattle proposal was found to be superior based on the objective 

evidence in the record. 
All of the objectors to the Show Cause Order gloss over a fundamental point and that is 

that an award to United would merely duplicate existing San Francisco-Haneda service offered 

by JAL and American through their joint immunized alliance. Put another way, the DOT took 

cognizance of the fact that Seattle, with 114,000 annual Tokyo passengers, is the largest U.S.-

Tokyo O&D market without service to Haneda. Exhibit DL-201. Claims by the United MEC 

that an award to United would maximize public benefits discounts entirely that fact that the San 

Francisco-Haneda market already enjoys nonstop service. It is hard, if not impossible, to make 

the case for awarding duplicative Haneda authority in lieu of new nonstop service at Seattle and 

to do so by claiming service from San Francisco would somehow produce greater public 

benefits. Obviously the public is better served by the dispersal of Haneda authority at gateway 

cities currently lacking such service and the DOT’s elevation of these factors is both appropriate 

and consistent with past DOT carrier/city selection cases. 

Another factor considered by the DOT, but disparaged by the objectors, is the weight the 

DOT correctly placed on the greater benefits new nonstop Haneda service from Seattle will 

produce compared to those were United to be awarded the San Francisco gateway. For 

example, compared to United, Delta will offer twice the number of Pacific Northwest round trip 

connecting flights. Exhibit DL-R-213. In all, Delta and its partner Alaska Airlines will provide 

nonstop service to Seattle to 62 points in the U.S. Exhibit DL-R-102. And many of these 

connecting flights over Seattle involve less circuity than would be the case if traffic had to flow 

over the California gateways. Exhibit DL-R-103. Delta will also provide more communities in 

the western United States with first time one-stop Haneda service than would United. Exhibit 

DL-R-201. The DOT correctly noted the market structure advantages flowing from Delta’s 
service proposal, compared to United’s proposal, and found, consistent with prior carrier/city 

selection determinations, that Delta’s service over Seattle will generate the types of public 

benefits the DOT set as priorities in this proceeding. Nothing United, the United MEC and SFO 

have stated in their objections presents any compelling reason to disturb the DOT’s tentative 

decision. 

Unlike the 2010 Haneda proceeding, in this case the DOT knows which U.S. gateway 

cities the Japan flag carriers are serving from Haneda. ANA, United’s immunized partner serves 

Honolulu and Los Angeles and JAL, American’s immunized partner serves Honolulu and San 

Francisco. Although United makes an argument that it should be permitted to operate to Haneda 

with its own aircraft and crews, United cannot overcome the fact that, as found by the DOT in its 

tentative decision, American offers non-stop San Francisco service though its code share partner, 

thereby implicitly recognizing that metal neutral alliances cannot be ignored when making 

carrier/city selection decisions. By selecting Delta to serve Seattle, inter-gateway competition is 

advanced rather than further concentrating Haneda gateway service in the two large California 

gateway cities. While it is understandable that United, the United MEC and SFO would object 

to the DOT’s Show Cause Order, their criticisms of the DOT’s logic is not compelling and 

overlooks the fundamental weakness of United’s proposal, as found by the DOT, and that is 

that its service would be duplicative and not additive in relation to the number and geographic 

diversity of U.S.-Haneda gateway cities. 

Respectfully submitted,
Timothy S. O’Malley

Chairman

Delta Master Executive Council

Air Line Pilots Association, International
CERTIFICATE OF SERVICE

A copy of the foregoing Reply has been served this 3rd day of December, 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

lhalloway@crowell.com

gmurphy@crowell.com

howard.kass@usairways.com

benjamin.slocum@usairways.com

jhill@dowlohnes.com

paul.gretch@dot.gov

keith.glatz@dot.gov

esta.rosenberg@dot.gov

brett.kruger@dot.gov

todd.homan@dot.gov

urskr@state.gov

eugene_alford@ita.doc.gov

info@airlineinfo.com

Ishiwata.K@portseattle.org

Safora.I@portseattle.org

Megan.Lawrence@alaskaair.com

Kyle.Levine@alaskaair.com