BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________ )

Motion s and Application of )
)

AMERICAN AIRLINES , INC. )

HAWAIIAN AIRLINES, INC. ) Docket DOT

- OST

- 2010

- 0018
)

i n the matter of 2010 U.S.

- Haneda )
Combination Services Allocation Proceeding )
__________________________________________)

CONSOLIDATED ANSWER OF

THE DELTA MASTER EXECUTIVE COUNCIL OF THE

AIR LINE PILOTS ASSOCIATION, INTERNATIONAL

Communications with respect to this document should be addressed to:

Michael G. Donatelli

Chairman

Delta Master Executive Council

Air Line Pilots Association, International
100 Hartsfield Centre Parkway, Suite 800
Atlanta, Georgia 30354
Mike.Donatelli@a lpa.org

January 12, 2015BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________ )

Motion s and Application of )
)

AMERICAN AIRLINES , INC. )

HAW AIIAN AIRLINES, INC. ) Docket DOT

- OST

- 2010

- 0018
)

i n the matter of 2010 U.S.

- Haneda )
Combination Services Allocation Proceeding )
__________________________________________)

CONSOLIDATED ANSWER OF

THE DELTA MASTER EXECUTIVE COUNCIL OF THE

AIR LINE PILOTS ASSOCIATION, INTERNATIONAL

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

Int ernational (the “ Delta MEC”) hereby answers in strong support of Delta’s response to the

DOT’s information request set forth in Order 2014

- 12

- 9 to maintain Seattle

- Haneda service. As

stated in Delta’s application, Delta has committed aircraft resources, Seattle based flight crews

and ground support employees to insure the success of the Seattle

- Haneda r oute. S trip p ing

D elta of the two slots used for Seattle

- Haneda

-- the only gateway in the Pacific Northwest

-- and

awarding them to another carrier for service in the well

- served regions of California or Hawaii

would be contrary to the public interest. Moreover, it would undermine the ability of Delta and

its employees to offer a viable competitive alternative to Amer ican/JAL and United/ANA which

operate massive hubs at Haneda, where Japanese carriers control 9 5 % of the Haneda slots.

The Delta MEC represents the interests of over 12,000 pilots working in concert with the

80,000 dedicated employees of Delta . In 2012

, the Delta MEC strongly supported Delta’s efforts

to establish Seattle

- Haneda service. Seattle is an important

– and growing

– international hub

gateway for D elta, providing quality U.S. jobs for Delta pilots, ground staff, and in

- flightpersonnel. Proof positive is the growing Delta and Delta

- Connection operated network that

Delta is building to support these international flights. We note that Delta has p ersistently and

determinedly added new flights (and new jobs) at Seattle every year since 2012, and continues to

plan for grow th in the future. Delta operated hub services increased to 51 daily departures in

August 2014, will grow to 85 in 2015, and will continue to grow in 2016 and beyond.

T he Department correctly found that the public interest was best served by making an

award to Delta for Seattle

- Haneda service

. 1 The same public interest considerations relied upon

by the Department to make the awar d for Seattle service over America n ’s LAX proposal and

Hawaiian’s Kona proposal in 2012 support ed the MEC’s call for the grant of Delta’s application

at that time and now provide the grounds for dismissal of the current American and Hawaiian

requests.

It is indeed ironic that American would criticize Delta for a temporary seasonal reduction

at Haneda

– when American has done the same at Haneda and in other international markets

–

and abandoned its JFK

- Haneda flight altogether in 2013. In fact, American c eded the entire

JFK

- Tokyo market (including Narita) to its Japanese partner, compromising U.S. jobs and flying

opportunities. While Hawaiian has been able to operate a more regular pattern of service than

other carriers, there i s less benefit to U.S. tra velers and shippers operating a flight that caters to

95 percent Japanese leisure passengers.

Delta and its employees have worked hard to pioneer service from the mainland United

States to Japan under difficult conditions at Haneda (which are improving , for the reason s noted

in the January 5, 2015 RESPONSE OF DELTA AIR LINES, INC. TO EVIDENCE REQUEST ).

We note that s easonal flight schedule reductions (especially in the off

- peak winter season) are

1 Show Cause Order 2012

- 11

- 12; Fin al Order 2013

- 2

- 4.common in many international markets. It should be note d that American has taken extensive

scheduling liberties with its own limited entry frequencies in Brazil, allowing them to be

dormant for periods of 90 days or more over the last decade. Given the challenges that all

carriers providing mainland U.S.

- Hane da service have experienced, including American Airlines

on its abandoned JFK to Haneda route, Delta’s temporary reduction in the 2014/2015 winter

season is appropriate and consistent with this long standing airline practice.

If service were taken away from Seattle, it would be the largest U.S.

- Tokyo market

without nonstop service. Moreover , it would be patently unfair to award three U.S.

- Haneda

opportunities to Los Angeles or four U.S.

- Haneda opportunities to Hawaii, and leave Seattle and

the Pacific Northwest with none . The flight has shown marked improvement and is vitally

important to business, international trade, and employment in the Northwest region and

specifically Seattle.

A n award of Haneda slots to American would also compromise effecti ve 3

- way alliance

competition. Delta h as no partner in Japan whereas American and JAL engage in reciprocal

antitrust immunized codesharing, bolstered by the benefits oneworld enjoys at Haneda by virtue

of JAL’s huge slot holdings and large hub operation at this slot constrained airport. It is also not

in the interest of the traveling public to put a cloud over Delta’s Seattle

- Haneda slots while Delta

is in the process of build ing its Seattle hub to provide , among other be nefits, maximum

connecting opport unities and additional traffic.For all of the foregoing reasons, we urge that Delta be allowed to continue Seattle

Haneda service and that the competing application of American and Hawaiian be denied.

Respectfully submitted,

Michael G. Donate lli

Chairman

Delta Master Executive Council

Air Line Pilots Association, International
100 Hartsfield Centre Parkway, Suite 800
Atlanta, Georgia 30354
Mike.Donatelli@alpa.orgCERTIFICATE OF SERVICE

A copy of the foregoing doc ument has been served this 12 th day of January, 201 5 , upon the following

persons via email:

howard.kass@aa.com

abigail.donovan@aa.com

robert.wirick@aa.com

charles.hunnicut@thompsonhine.com

patricia.snyder@thom p sonhine.com

jhill@cooley.com

perkmann@cooley. com

bberlin@cooley.com

dan.weiss@united.com

thomas.bolling@united.com

steve.morrissey@united.com

gmurphy@crowell.com

Mike.Donatelli@alpa.org

dino.atsalis@alpa.org

Doug.Ralph@alpa.org

Ishiwata.K@portseattle.org

Safora.I@portseattle.org

sascha.vanderbellen@d elta.com

chris.walker@delta.com

paul.gretch@dot.gov

brian.hedberg@dot.gov

brett.kruger@dot.gov

todd.homan@dot.gov

peter.irvine@dot.gov

englets@state.gov

cristinasa@state.gov

eugene_alford@ita.doc.gov

info@airlineinfo.com