BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________

)

Motions and Application of )

 ) 

AMERICAN AIRLINES, INC. )

HAWAIIAN AIRLINES, INC. ) Docket DOT-OST-2010-0018

 )

in 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@alpa.org

January 12, 2015
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________

)

Motions and Application of )

 ) 

AMERICAN AIRLINES, INC. )

HAWAIIAN AIRLINES, INC. ) Docket DOT-OST-2010-0018

 )

in 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, the Delta chapter of the Air Line Pilots Association, 

International (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 route. Stripping 

Delta 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 American/JAL and United/ANA which

operate massive hubs at Haneda, where Japanese carriers control 95% 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 Delta, providing quality U.S. jobs for Delta pilots, ground staff, and in-flight 
personnel. 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 persistently and 

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

plan for growth 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.

The 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 award for Seattle service over American’s LAX proposal and 

Hawaiian’s Kona proposal in 2012 supported 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 ceded 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 is less benefit to U.S. travelers 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 reasons noted 

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

We note that seasonal flight schedule reductions (especially in the off-peak winter season) are 

 1 Show Cause Order 2012-11-12; Final Order 2013-2-4.
common in many international markets. It should be noted 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.-Haneda 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. 

An award of Haneda slots to American would also compromise effective 3-way alliance 

competition. Delta has 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 building its Seattle hub to provide, among other benefits, maximum 

connecting opportunities and additional traffic. 
For all of the foregoing reasons, we urge that Delta be allowed to continue SeattleHaneda service and that the competing application of American and Hawaiian be denied. 

Respectfully submitted,

Michael G. Donatelli

Chairman

Delta Master Executive Council

Air Line Pilots Association, International

100 Hartsfield Centre Parkway, Suite 800

Atlanta, Georgia 30354 

Mike.Donatelli@alpa.org
CERTIFICATE OF SERVICE

A copy of the foregoing document has been served this 12th day of January, 2015, upon the following 

persons via email:

howard.kass@aa.com

abigail.donovan@aa.com

robert.wirick@aa.com

charles.hunnicut@thompsonhine.com

patricia.snyder@thompsonhine.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@delta.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