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. 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, 2012BEFORE 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 t he 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 andDelta 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 main land 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 woul d, 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 suchflights. 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 f lights. The Department has used a 120 dayDelta 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