BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Motion of 

DELTA AIR LINES, INC. 

In the matter of 2010 U.S.-Haneda Combination 

Services Allocation Proceeding 

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Docket DOT-OST-2010-0018 

COMMENTS 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

November 26, 2012
 

BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Motion of 

DELTA AIR LINES, INC. 

In the matter of 2010 U.S.-Haneda Combination 

Services Allocation Proceeding 

) 

) 

) 

) 

) 

) 

) 

Docket DOT-OST-2010-0018 

COMMENTS OF DELTA AIR LINES, INC.

 Delta is very pleased the Department has tentatively decided to grant Delta’s motion 

to operate Haneda service from the Seattle gateway. Seattle is the largest U.S.-Tokyo O&D 

market that currently lacks Haneda service. Opening Seattle for nonstop service to Haneda 

will create an important new hub gateway for the entire Pacific Northwest region. Grant of 

Delta’s request will enable Delta to provide its consumers with a more attractive schedule 

and improved product offering. The Department’s sound and well reasoned decision will 

clearly benefit the public interest. 

 Haneda service will be an important addition to Delta’s growing international network 

at Seattle. During the pendency of this case, Delta announced new Seattle nonstop service 

to Shanghai, and upgraded its transcontinental U.S. domestic services from Seattle to 

include widebody aircraft with lie flat seats. The ability to serve Tokyo’s close-in downtown 

airport from the Seattle hub compliments Delta’s growth strategy and makes Seattle more 

competitive for business traffic vis-à-vis the existing west coast Haneda gateways at San 

Francisco and Los Angeles. 

 Delta is grateful for the strong public support from the Port of Seattle, Alaska Airlines, 

Washington Governor Christine Gregoire, Senators Patty Murray and Maria Cantwell, 

Congressmen Adam Smith and Rick Larsen, and numerous business, community and 
Delta Reply 

Page 2 

airport leaders throughout the Northwest region. More than 6,000 Delta employees wrote to 

Secretary LaHood, and the new flight also received the endorsement and support of the 

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

 The Show Cause Order found that: 

 “Delta’s proposal would best serve the public interest by providing the first 

nonstop Haneda service on a significant mainland U.S.-Tokyo route that currently 

lacks any such service.” 

 “Delta’s proposed service would further serve the public interest by providing a 

number of western cities with a first one-stop connecting opportunity to Haneda.” 

 “cities that now enjoy one-stop connections over more southerly gateways would 

gain the option of service over a less circuitous northwest gateway.” 

 “Allowing Delta to move from Detroit to Seattle would . . . address a diversity of 

public interest goals.” 

Order 2012-11-12 at 5-6. 

Delta fully agrees with the Department’s tentative findings, all of which are well supported in 

the record. 

Regarding the Department’s tentative proposal to require that service be 

implemented with 90 days of a final order, Delta confirms that it is prepared to meet any 

startup condition required by DOT. It would, however, assist Delta in the orderly and 

efficient introduction of new Haneda service if the Department were to require startup within 

120 days of a final order. Delta normally begins marketing of a long-haul international flight 

at least six months in advance of the service. 90 days is well into the booking curve of such 

flights. Delta’s new Seattle-Haneda flight will be competing with the established SeattleTokyo services of United and ANA, which have been open and available for sale many 

months in advance. Passengers who would have been attracted to Delta’s new Haneda 

service have already booked travel on other flights. The Department has used a 120 day 
Delta Reply 

Page 3 

startup condition in numerous prior cases, and, for the reasons noted, it would also be 

appropriate to do so here.1

 

In conclusion, Delta welcomes the Department’s Show Cause determination to 

authorize Haneda service from Seattle, and Delta looks forward offering new flights that will 

benefit the traveling public at the Seattle gateway and throughout the entire Pacific 

Northwest region. 

Respectfully submitted,

_________________________________ 

Alexander Van der Bellen 

Managing Director, Government Affairs 

 & Associate General Counsel 

DELTA AIR LINES, INC. 

 

1 See, e.g. U.S.-Chile Combination Service (Order 98-1-22); U.S.-Columbia Combination 

Service – (Order 2000-9-21); U.S.-Brazil Combination Service (Order 2000-10-6). 
CERTIFICATE OF SERVICE 

A copy of the foregoing Reply has been served this 26th day of November, 2012, upon 

the following persons via email: 

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 

Tim.OMalley@alpa.org 

Ishiwata.K@portseattle.org 

Safora.I@portseattle.org 

Kyle.Levine@alaskaair.com 

Megan.Lawrence@alaskaair.com