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

TO OBJECTIONS TO ORDER 2012

- 11

- 12
Communications with resp ect 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

Decem ber 3 , 2012BEFORE 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 ) __________________________________________)

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

IN SUPPORT OF DELTA AIR LINES , INC.

The Delt a Master Executive Council, th e Delta chapter of the Air Line P ilots Association,

Int ernational (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

P ilots Association, Int ernational (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 i ts 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 join t 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 Unit ed 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 ser vice from Seattle will
produce compared to those were United to be awarded the San Francisco gateway

. For
example, c ompared 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 tha n would United. Exhibit

DL

- R

- 201. The DOT correctly noted the market structure advantages flowing from Delta’sservice 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 Uni ted, 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 serv ing 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 airc raft 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. B y 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 duplic ative 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, In ternationa lCERTIFICATE OF SERVI CE

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@crowel l.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@airl ineinfo.com Ishiwata.K@portseattle.org Safora.I@portseattle.org Megan.Lawrence@alaskaair.com Kyle.Levine@alaskaair.com