# BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Application of

DELTA AIR LINES, INC.

2010 U.S.-Haneda Combination Services

Allocation Proceeding )

)

)

)

)

)

) Docket DOT-OST-2010-0018

ANSWER 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

Jeff Morgan

Regional Director – Government Affairs

DELTA AIR LINES, INC.

1212 New York Avenue, N.W.

Washington, D.C. 20005

(202) 842-4184

sascha.vanderbellen@delta.com

March 1, 2010

# BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Application of

DELTA AIR LINES, INC.

2010 U.S.-Haneda Combination Services

Allocation Proceeding )

)

)

)

)

)

) Docket DOT-OST-2010-0018

ANSWER OF DELTA AIR LINES, INC.

I. Introduction

Delta has submitted U.S.-Haneda service proposals from Seattle, Detroit, Los

Angeles and Honolulu that will maximize consumer benefits and competition for the traveling

public. Each of these gateways will provide significant service benefits and promote

effective 3-way alliance competition between Delta and the Star (United/Continental/ANA)

and oneworld (American/JAL) alliance carriers. Delta’s proposals will create a third

competitor in hundreds of U.S.-Haneda city-pai r markets and are backed by a strong service

commitment with 403-seat B747-400 and 298-seat A330-300 aircraft – delivering the

greatest capacity and greatest benefits of any applicant at the critical but tightly constrained

Haneda airport. We believe that the selection of Delta for service at Seattle, Detroit, Los

Angeles and Honolulu will maximize consumer benefits by promoting broad-based alliance

competition to the Star and oneworld carriers which already have a major presence at

Haneda by virtue of the large hubs and extensive slot holdings maintained by JAL and ANA.

The reopening of Tokyo’s downtown Haneda airport to international service is one of

the most important aspects of implementing the new open skies agreement with Japan.

# Answer of Delta

Page 2

Although bilateral limitations on U.S.-Japan service would be lifted, restrictions on airport

slots, particularly at Haneda, will limit carriers’ ability to implement new competitive service

at this critical airport.

The proposed antitrust immunized alliances between American/JAL and

United/Continental/ANA have a significant bearing on the disposition of this case. Japan

has indicated that it will not sign the open skies agreement until a favorable outcome is

reached in the pending ATI cases. 1 

# It is Delta’s understanding that new Haneda

opportunities are also part of the open skies package. Under their immunized joint venture

arrangements, American and JAL, and United/Continental ANA propose to operate as

single, merged entities. According to the principles of “metal neutrality” and “indifference” to

operating carrier advanced by the joint venture applicants themselves, service by American,

United, or Continental -- or its Japanese partner -- is exactly the same from a service and

competition standpoint.

The public interest would be well served by an allocation that maximizes interalliance competition. Haneda service w ill be in very high demand because of its

convenience to Tokyo passengers relative to Narita. Haneda is located just 15 minutes from

downtown Tokyo, whereas Narita is over an hour by car, bus, or train and located 45 miles

outside the city. Service at Narita is unlikely to constrain prices at Haneda because of its

remote location. Just at the Department correctly concluded that Heathrow and Gatwick are

separate relevant markets at London, so are Haneda and Narita at Tokyo.

Given the significant access restrictions that will persist at Haneda, Delta believes

that consumers will benefit from maximizing the impact of independent competitors against

the incumbent alliance carriers operating at Haneda. Oneworld members American and

JAL, once granted ATI, will not be independent competitors; nor will Star members United,

1 

# See, December 11, 2009 letter from JCAB Deputy Director-General Keiji Takiguchi to

Deputy Assistant Secretary for Transportation Affairs, John Byerly.

# Answer of Delta

Page 3

Continental and ANA be independent competitors once they are granted ATI. Therefore,

any grant of slots to American or United/Conti nental takes away slots that could be used by

Delta to provide independent price and service competition on hundreds of additional U.S.-

Haneda O&D itineraries.

For this reason, we believe that service, competition, and the public interest would be

well served by Delta’s proposals, which represent the best and only effective competition to

the Star and oneworld alliances operating at Haneda. This is consistent with the approach

the Department has taken in the past, and most recently confirmed in the American/British

Airways show cause order, in refusing slot eligibility to affiliated carriers or joint venture

partners at the slot constrained Heathrow Airport.

Delta recognizes that a request for all four of the available slot pairs at Haneda may

appear extraordinary. However, in order to provide consumers the benefit of an effective

third competitor in the U.S.-Haneda market, taking into account the presence benefits both

Star and oneworld will enjoy as incumbent hub operators at Haneda, Delta would need to be

able to enter the Haneda market on the scale reflected in its service proposals to ensure

competitive balance among the three alliances. 2 

# But because Delta lacks a Japanese

alliance partner and because there will be no buy-sell mechanism to acquire additional slots,

an allocation from DOT in this proceeding is the only way for Delta to acquire the slots it will

need to compete at Haneda.

2 

# While Delta has submitted the strongest and most effective proposal for Honolulu-Haneda

service utilizing 403-seat B747 aircraft, Delta recognizes the Department’s policy in

promoting new entry and would not object to Hawaiian receiving an award for one set of slot

pairs for Honolulu-Haneda. As discussed below, this will enable Hawaiian to realize

substantially all of benefits of its entire service proposal. Should the Department decide to

grant Hawaiian a pair of slots, Delta requests backup authority at Honolulu, together with the

grant of its remaining proposals.

# Answer of Delta

Page 4

II. American, United and Continental Should Be Treated as Haneda

Incumbents In Light of the Slots That Will be Granted By Japan to Their

Japanese Joint Venture Partners

The Department has in analogous circumstances treated alliance partners as

incumbents, not new entrants, when awarding limited slot opportunities and managing

alliance-related slot divestitures. This reflects the Department’s fundamental public interest

policy of promoting competition and maximizing consumer benefits.

The Department considers “affiliated carriers” together with their partners for slot

allocation purposes at restricted airports: “an air carrier that operates under the same

designator code, or enters into a codeshare agreement, with another air carrier shall not

qualify [for new entrant slots] . . .” 49 U.S.C. 41714 (k). The Department recently affirmed

this policy and its application to global alliance partners operating at slot restricted airports:

“Airlines are not eligible [Heathrow slot] recipients if they are members of the oneworld

global alliance, affiliates of the applicants, or ai rlines in which the airlines have a substantial

financial interest.” Oneworld Show Cause Order at 26. This same policy and precedent

should disqualify from consideration in this proceeding U.S. carriers that have entered into

joint venture alliance with the Haneda incumbents. The alliance competitive considerations

are especially important in this case given the extensive presence already enjoyed by the

Haneda incumbents at this restricted airport, and that there is no market opportunity for

unaligned carriers, such as Delta, to acquire the slots. 3

3 

# Equitable considerations also favor an award to Delta. Prior to 1978, Delta’s legacy Tokyo

hub was based at Haneda. Delta was compelled to give up all of its slots, and relocated all

of its facilities at great cost and expense to Narita when Haneda was declared a domesticonly airport. Now Delta is faced with the prospect of competing for international passengers

at Haneda against carriers that have built large hubs in a protected operating environment –

and stand ready to extend their reach and penetration into the U.S. market from Haneda

with the assistance of immunized U.S. carrier partners. Even if Delta were to receive an

award of all four Haneda opportunities, it would still be at a competitive disadvantage to Star

and oneworld at Haneda.

# Answer of Delta

Page 5

Here, the U.S members of Star and oneworld should be treated as incumbents for

the same policy reasons. American/JAL and United/Continental/ANA have applied for

antitrust immunity in order to form metal-neutral joint ventures covering all of their U.S.-

Japan services. Although those applications have not yet been granted, Japan has

indicated that it will not sign the open skies agreement until it is satisfied with the outcome of

the antitrust immunity proceedings. 4 

# Delta understand that the Haneda opportunities at

issue here are part of the same open skies package. Following the grant of antitrust

immunity, the Star and oneworld alliances will each have the benefit of 2 U.S.-Haneda slot

pairs, together with the important presence benefits of incumbent hubs. In these

circumstances, the Star and oneworld carriers should not be granted additional slots in this

proceeding when doing so would restrict the intr oduction of competitive service by Delta.

The Star and oneworld applicants do not need an allocation of Haneda slots from the

Department to provide the service benefits clai med in their applications. American, United

and Continental will have to access Haneda through the “metal neutral” joint ventures with

their Japanese partners for which they are seeking antitrust immunity. While the

Department has sometimes discounted the effectiveness of arms-length codeshare

arrangements as a substitute for own-metal service, the same cannot be said of integrated

joint ventures – which the applicants and the Department consider as the competitive

equivalent of a merger. Indeed, to conclude otherwise would deny the very benefits that

4 

# Delta appreciates the Department’s desire to allocate the Haneda opportunities in advance

of the ATI decisions, so that the selected applicants can have as much time as possible to

plan and implement their services. Delta believes the most expeditious determination can

be made by considering the ATI applicants as sing le competitive entities, as they would be

under open skies. Alternatively, the Department could consolidate this proceeding and the

ATI alliance cases for contemporaneous consideration.

# Answer of Delta

Page 6

American, United and Continental have advanced in support of their antitrust immunity

applications.

The Star carriers say that:

“The Pacific JV will foster ‘metal neutrality’ – a commercial

environment in which joint venture partners share common

economic incentives to promote the interests of their

alliance over their individual corporate interests. By

pooling resources to improve the overall service offering

and sharing the resulting gains and losses, the Joint

Applicants will harmonize their joint network and become

indifferent as to which partner collects the revenue and

operates the aircraft on a given itinerary .”

Joint Application of ANA, Continental and United at 12, December 23, 2009, OST-2009-

0350

The same integrative joint venture benefits are echoed by oneworld alliance partners,

American and JAL:

“The Joint Applicants seek approval for a highly-integrated,

revenue-sharing joint venture that will strengthen their

alliance by eliminating each carrier’s economic incentive to

maximize its own revenue. Only the closer cooperation

made possible through a joint venture based on metal

neutrality – or indifference as to which airline actually

carries a customer – will maximize the consumer benefits

that immunized alliances make possible. This is because

metal neutrality removes each carrier’s incentive to act

opportunistically in ways that inure to its own short-term

financial advantage, to the detriment of the efficiencies and

consumer benefits that could otherwise be delivered by the

alliance. Accordingly, the Joint Applicants are seeking

approval for a highly integrated joint venture with revenue

sharing that creates metal neutrality. By providing for the

broad sharing of revenue on a metal neutral foundation,

the JBA will ensure that American and JAL act for the

benefit of – and are compensated for their contribution to –

the alliance as a whole.”

Joint Application of American and JAL at 7, February 12, 2010, OST-2010-0034

# Answer of Delta

Page 7

Given the entry constraints that will continue to exist at Haneda, and the large

presence already enjoyed by JAL and ANA which operate hubs there, the grant of additional

slots to the U.S. members of oneworld and Star would be contrary to competition and the

public interest. Joint venture alliance can and do produce important consumer benefits –

particularly when there is both de jure and de facto open entry. Here, however, taking into

account the limitations that will continue to affect competitive access at Haneda and

considering that American, United and Continental have entered into proposed joint venture

agreements with Japanese partners, it would be contrary to the public interest to allow these

carriers to “double dip” at Haneda – to receive access through their joint venture alliances,

and to receive further individual slot allocations – at the expense of Delta which would bring

additional price and service competition to the Haneda market.

It is important to note that declining to award additional Haneda slots to American,

United and Continental on top of their alliance partner holdings does not foreclose any of the

potential benefits of their service proposals. Los Angeles, San Francisco and New York can

and likely will receive Haneda service from Star and/or oneworld regardless of the outcome

of this proceeding. As explained above in the applicants’ own words, a core principle of joint

venture alliances is to achieve metal neutrality and indifference as to the operating carrier

.

Thus, the gateways proposed by American, United, and Continental can still enjoy service

by the Star and oneworld joint venture alliances. In contrast, none of Delta’s gateway cities

(or the beyond-gateway cities that are connected to them) can receive any service by Delta

or SkyTeam absent an award in this proceeding, because Delta has no joint venture partner

with Haneda slots and no other means to obtain them.

The applications presented in this case tell only half the story with respect to Star

and oneworld plans for U.S.-Haneda service. Given the closely inter-related issues affecting

antitrust immunity and the effectiveness of open skies and these Haneda opportunities, it is

# Answer of Delta

Page 8

important to take into account likely use and impact of the U.S.-Haneda slots brought to the

table by the Japanese partners of Star and oneworld. The proposed gateway choices put

forward by American, United and Continental would be factored into the joint route planning

decision of the Star and oneworld alliances when they implement Haneda service--

• United, Continental and ANA state that: “Under the Pacific JV Agreement, the

Joint Applicants will jointly manage capacity, planning, scheduling, pricing,

revenue management, sales and marketing of the carriers’ U.S.-Asia

services.” Star ATI Application at 12 (OST-2009-0350).

• American and JAL state that: “Approval and immunization of the

American/JAL alliance agreement will enable close integration of the two

carriers’ activities . . . This coordination will include the following: [pricing,

yield management, and schedules.] The Joint Applicants will jointly plan their

respective schedules . . .” oneworld ATI Application at 10 (OST-2010-0034).

Star and oneworld already enjoy the benefit of strong and established Haneda hubs

which will grow in strength and influence on U.S.-Tokyo service with antitrust immunity

under open skies. Therefore, in allocating the limited Haneda slots available in this

proceeding, the Star and oneworld carriers should not receive further slot allocations at the

expense of Delta’s proposal which will provide important independent price and service

options to consumers.

III. Delta’s Haneda Service Proposal Will Maximize Haneda Service and

Competitive Benefits for the Traveling Public.

The reopening of Haneda airport will hav e a profound effect on service and

competition in the U.S.-Japan and U.S.-Tokyo market. Haneda is highly preferred by Tokyo

passengers, because it is only minutes from downtown. Narita, by comparison is an hour

and a half and located 45 miles outside the city . Existing U.S.-Tokyo service at the far-

# Answer of Delta

Page 9

distant Narita airport will not effectively di scipline pricing for U.S.-Haneda services operated

by the Star and oneworld carriers. There is therefore a danger that Haneda’s strong appeal

combined with the very limited slots available for U.S.-Haneda service will expose

passengers to higher prices in many O&D markets due to limited competition. Delta’s full

package of Haneda service proposals offers the best opportunity to introduce effective

competition for the incumbent Haneda carriers.

In allocating the scarce Haneda opportunities in this case, we believe that

competition and the public interest would be maximized by promoting independent pricing

and 3-way alliance competition in as many U.S.-Haneda O&D markets as possible. Delta’s

proposed gateways provide important nonstop service benefits in their own right – and

extend the benefits of competitive service to scores of additional online cities served by

Delta behind its gateways. By contrast, a grant of slots to American or United/Continental –

coming as they necessarily would at the expense of Delta’s service proposals -- would be

additive to the routes already available to them under the umbrella of immunized

cooperation with JAL and ANA, and would result in increased concentration and less

competition on hundreds of U.S.-Haneda O&D markets.

Delta proposes a balanced package of Haneda services, which are designed to

maximize service and competitive benefits for the traveling public. Seattle and Detroit work

in tandem to provide comprehensive network coverage of the Western and Eastern halves

of the United States, respectively. Delta woul d also provide important competitive discipline

at Los Angeles and Honolulu, which are large local markets that are likely to receive (or

already are receiving) Haneda service by Japanese carriers.

A. Delta’s Seattle Proposal Will Establish a Key Tokyo Haneda Gateway in

the Pacific Northwest with Important Network and Competition Benefits.

Seattle-Haneda service is a top priority for Delta. The growth and development of

international service at Seattle is a key element of Delta’s west coast strategy. Seattle-

# Answer of Delta

Page 10

Tokyo is a large local market with nearly 80,000 annual Tokyo O&D passengers. 5 

# Seattle is

also well situated to serve as a West Coast hub gateway. Delta’s partnership with Alaska

Airlines, together with Delta’s own-metal services, will enable Delta to provide nonstop-tononstop Haneda service for 55 U.S. cities. DL-ANS-204.

The grant of slots to Delta for Seattle-Haneda service will dramatically enhance

competitive service options for west coast pa ssengers to Tokyo, which would otherwise face

a Star and oneworld duopoly. The west coast is particularly attractive for Haneda service in

light of the continued restrictions on schedules and operations. Furthermore, in addition to

the U.S. and Japanese services that would be authorized under the 2009 MOU, Japan and

Canada have already reached agreement that provides for expanded Haneda opportunities

for Japanese and Canadian carriers at airports including Vancouver. Seattle and Vancouver

compete aggressively for traffic in the Pacific Northwest, and Delta would be able to

compete for western passengers by offering service to Tokyo’s preferred airport from Seattle.

Seattle is a proven and successful gateway to Asia. This summer, Delta will

commence new nonstop service from Seattle to Beijing and Osaka – building on Delta’s

existing long-haul international services to Amsterdam and Narita.

Delta will operate its new Haneda services using large capacity Airbus 330-300

aircraft outfitted with 298 passenger seats. The proposed schedule to and from Haneda

dovetails with Delta’s Seattle-Amsterdam flight, making for a particularly efficient aircraft

rotation despite the Haneda scheduling challenges. Delta’s Haneda service will depart

Seattle at 7:25pm, arriving Haneda at 10:00pm to coincide with the opening of the Haneda

nighttime operating window. Eastbound, Delta proposes to depart Haneda at midnight,

arriving Seattle at 5:10pm. DL-104.

5 

# MIDT YE November 2009.

# Answer of Delta

Page 11

B. Delta’s Detroit Proposal Will Establish the Largest and Most Effective

Eastern U.S. Gateway for Haneda Passengers.

Detroit is Delta’s primary Eastern U.S. gateway for service to Asia. Detroit, in

concert with Seattle, will provide the comprehensive network coverage of the United States

and help to protect the traveling public from the effects of the increased market power by the

Star and oneworld immunized alliances operating from Haneda. Delta’s Detroit hub is the

largest and most effective U.S. airline hub for service to Asia, and will provide nonstop-tononstop Haneda service for 106 U.S. points. DL-112. In addition, Detroit boasts a large

local market to Tokyo with 33,000 annual O&D passengers. 6



# While the scheduling limitations at Haneda pose challenges for Eastern U.S. service,

Delta’s service pattern for Detroit addresses those concerns with a westbound departure at

8:10pm, arriving at the start of the 10pm nighttime operating window. The aircraft will

overnight at Haneda, and depart eastbound at 7:00 am, arriving Detroit at 5:45am (summer)

or 5:00am (winter). DL-113. This schedule enables Delta to make full use of Detroit’s

expansive network, and maximizes connectivity for Eastern U.S. passengers.

Delta is proposing its largest aircraft – the Boeing 747-400 for Detroit. The 403 seat

capacity of the 747 will help to maximize the value of the scarce Haneda slots that are

available to U.S. carriers.

Another factor favoring the selection of Detroit is its state-of-the art and consumer

friendly 120-gate terminal facility, which is backed by significant airside capacity. The

terminal was specifically designed to make international connections easy and efficient.

There is a Federal Inspection Services (FIS) station located in the center of the mile-long

terminal building, which is able to process 3,200 passengers an hour. The Express Tram

monorail station is positioned immediately adjacent to the FIS facility, allowing passengers

6 

# MIDT YE November 2009

# Answer of Delta

Page 12

to reach either end of the terminal building in less than two minutes. The Detroit terminal

has received numerous accolades for its des ign, aesthetics, and efficiency, including

recognition by J.D. Power & Associates, Airports Council International, and Airport Revenue

News, as being among the most consumer friendly and innovative airports in the United

States.

C. Delta’s Los Angeles-Haneda Proposal Will Serve the Largest U.S. Mainland

Market to Tokyo and Provide Significant Network Benefits.

Los Angeles is the largest U.S.-Tokyo O& D market. It is very likely to receive

Haneda service by the Star and oneworld alliances (as decided by their respective alliance

steering committees). Delta is the only non-aligned U.S. carrier that can provide effective

independent price competition to Star and oneworld on this important route -- but requires

an allocation of Haneda slots in order to do so. Delta will use large capacity 747-400

aircraft for maximizing service, competitive, and public interest benefits. Delta’s Los

Angeles schedules are provided at Exhibit DL-122.

With over 400,000 local O&D passengers, Los Angeles generates more than twice

as many passengers as United’s proposed San Francisco gateway. DL-ANS-506. And,

although Honolulu generates large numbers of local passenger by virtue of its appeal to

Japanese leisure passengers, Los Angeles would benefit more than twice as many U.S.

origin passengers which are particularly relevant to the Department’s public interest

determination. DL-ANS-505. The are numerous U.S. Fortune 500 companies and

Japanese multinational corporations located in the greater Los Angeles area – all of which

stand to benefit from the new nonstop access to Tokyo’s preferred downtown airport.

Delta will also provide significant network benefits to U.S. cities behind the Los

Angeles gateway. Delta and its domestic al liance partner, Alaska, provide connecting

opportunities to 18 interior U.S. cities via Los Angeles. DL-ANS-501.

# Answer of Delta

Page 13

D. Delta’s Honolulu-Haneda Proposal Will Maintain U.S. Flag Competitiveness

for Tokyo Beach Markets.

Competition for Tokyo leisure passengers is intense. Japanese carriers are already

using Haneda charter opportunities to their advantage, and would enjoy the additional

opportunity for scheduled service to U.S. beach markets if the 2009 MOU is formalized.

Delta seeks an allocation of seven Haneda sl ots for daily Haneda-Honolulu service (but

would accept a backup award if Hawaiian is selected as primary on this route). Once again,

Delta will use large capacity 747-400 aircraft, thereby maximizing service and competitive

benefits.

IV. Delta’s Proposals Are Superior on the Service Merits.

As stated, the proposals of American, United, and Continental can be fully

accommodated by services of their joint vent ure partners. The Star and oneworld alliances

are, by their own acknowledgment “indifferent” as to the operating carrier – and will fully

realize the benefits no matter which Star or oneworld member flies the aircraft. However,

only through an award in this case is Delta able to offer competitive service at its proposed

gateways. Even putting aside the ATI alliance competitive issues, Delta believes its

proposals are superior on the merits.

A. Delta Will Provide the Largest Capacity Aircraft Maximizing U.S.-

Haneda benefits

The Department has on numerous occasions stated that the size of the aircraft and

amount of capacity delivered by the applicant is an important selection criteria for

maximizing public benefits in carrier selection cases.

# Answer of Delta

Page 14

Here, by a substantial margin, Delta would deliver more capacity than any other

applicant:

As the Department explained in Order 2007-2-10 (2006 China Case), “shortfall of

available nonstop service options emphasizes the importance of injecting as much nonstop

capacity into the. . .market as possible when awarding these frequencies .” (Page 5

emphasis added). The Department went on to select United because it would “provid[e] the

most capacity in this proceeding with B-747 aircraft . . .” Id.

The extent of Delta’s capacity advantage varies by market, but in each and every

case is substantial:

• At Los Angeles, Delta proposes to fly 403 seat B747-400 aircraft in contrast

to the 247 seat B777 offered by American. This equates to 63 percent more

capacity for Delta’s proposal; which, on an annualized basis amounts to over

100,000 more nonstop seats. DL-ANS-502-504.

# Answer of Delta

Page 15

• At Detroit compared to New York/Newark in the Eastern U.S., Delta provides

63 percent more capacity than American at JFK, and 46 percent more

capacity than Continental at Newark – or approximately 100,000 incremental

annual seats. DL-ANS-402-404.

• In the Pacific Northwest, Delta’s 298 seat A330 is larger than United’s 269

seat B777 at San Francisco, delivering 11 percent more capacity with over

20,000 additional annual seats. DL-ANS-302-304.

• In the Pacific Islands, Delta’s B-747-400 proposal for Honolulu-Haneda

delivers 57 percent more seats (107,000 annually) than Continental’s 767

proposal for Guam, and 56 percent more seats (106,000 annually) than

Hawaiian’s 767 proposal for Honolulu. DL-ANS-602-604; 611-613.

The Department has previously found such ca pacity differences to be decisionally

significant. In rejecting Continental’s Newark-Shanghai proposal in favor of United, the

Department selected United because it would offer “22 percent more capacity than

Continental.” Order 2007-1-4 at 17. The importance of maximizing capacity is the same

regardless of whether the service limitation is imposed by bilateral constraints (as in China),

or by airport slot constraints and perimeter rules -- such as those that effect service at

Haneda and Washington National Airport. See, Order 2002-11-10 (selecting Delta for

DCA-Salt Lake City beyond-perimeter service for reasons including that “Delta would use

183-seat B-757, a relatively large aircraft.”).

B. Delta’s Seattle Proposal Will Maximize Competition In the Pacific

Northwest

For the reasons explained above, even absent an award to United in this case, San

Francisco is still likely to receive nonstop Haneda service from ANA -- which is equivalent to

service by United under their metal neutral joint venture. Thus, all of the benefits of United’s

# Answer of Delta

Page 16

proposal can and will be attained without compromising a vital competitive opportunity at

Haneda.

Like San Francisco, Delta’s Seattle gateway would provide comprehensive network

benefits to West Coast passengers. But, unlike a Star award for San Francisco, an award to

Delta will inject a third alliance that will offer independent price competition West CoastHaneda passengers. Seattle and the Pacific Northwest face a Star/oneworld Haneda

duopoly that is projected both from U.S. gateways as well as from nearby Vancouver,

Canada which is eligible for Haneda serv ice under the Japan-Canada agreement by

United’s current and future immunized Star partners, Air Canada and ANA (or JAL). By

authorizing a pair of slots for Delta service at Seattle, the Department will promote healthy 3-

way alliance competition to combat the inherent advantages already enjoyed by the

Japanese incumbents at Haneda.

Seattle is home to major international corporations with important interests in Tokyo

including Microsoft, Boeing, and Starbucks. In order to better serve its customers – and to

maintain the competitiveness of its Seattle gateway for passengers up and down the west

coast, Delta requires access to Haneda, the highly preferred downtown airport. Delta will

rely on network feed provided by Alaska Airlines, Seattle’s hometown hub carrier. Thus, not

only will an award benefit Delta, it will also further the interests of one of the country’s

smaller and highly efficient low cost carriers.

C. Delta’s Detroit Hub Gateway Maximizes Competition for

Eastern U.S. Customers.

Delta requires an allocation of Haneda slots in order to offer competitive service for

the Eastern United Sates from Detroit. Neither American nor Continental require an

allocation of slots to participate in the New York/Newark-Haneda market, because their

Japanese partners have slots available to provide New York service.

# Answer of Delta

Page 17

Under their immunized joint ventures Amer ican and Continental are “indifferent” as to

which carrier operates the aircraft. An award to American or Continental at the expense of

Delta’s Detroit proposal would reduce Eastern U.S.-Haneda competition from three carriers

to two – creating a competitive monopoly (or at best a duopoly) affecting over 900,000

passengers in more than 100 U.S. cities t hat would enjoy convenient and competitive

service by a third independent pricer from Detroit. DL-ANS-406, 414, 415.

American can muster well timed connections for only a handful of Eastern U.S. cities.

DL-ANS-408, 409. Continental’s Newark hub fares slightly better than American -- but is

completely eclipsed by Delta’s Detroit hub, which would offer service to more 60 additional

cities, benefitting 2.5 times more potential Eastern U.S.-Tokyo passenger than Continental.

DL-ANS-414, 415.

American’s attempt to claim credit for beyond-Haneda connections by its immunized

alliance partner is not a relevant consideration because JAL can use the “established

Haneda presence” noted by American under the join t venture – delivering exactly the same

benefits as American – but without depriving an independent competitor the ability to offer

service. 7



# C. Delta’s Los Angeles Proposal Will Maximize Competition in the Largest

U.S.-Tokyo Market.

Delta and American have each proposed nonstop Los Angles-Haneda service.

However, the proposals are vastly different in terms of the service and competitive benefits

they will create. Los Angeles is the largest mainland U.S.-Japan O&D market, and it is

7 

# American goes on to speculate that its connecting schedules might improve “as the

Haneda window is expanded.” (Page 6). This is no reason to award American more slots.

The Haneda operating window was established through artful bilateral compromise. Should

the Haneda window be expanded through additional bilateral consultations, the Department

may need to examine what additional remedies and conditions would be necessary to

maintain fair and equal competitive conditions at the airport.

# Answer of Delta

Page 18

situated in the west coast region that is particularly attractive for Haneda service due to the

schedule and perimeter rule constraints imposed by JCAB. Given these attributes, Los

Angeles is likely to receive nonstop Haneda service from JAL or ANA, or both. The

immunized alliance steering committees will be able to make joint route planning decisions

based on the Haneda slots allocated to JAL an d ANA. Los Angeles-Haneda service by JAL

gives American fully effective commercial acce ss through its immunized joint venture – but

leaves unfulfilled the Department’s critical public interest objective of maximizing service and

competition for the traveling public.

By contrast, the selection of Delta for service at Los Angles would create a third

competitive option to the entrenched oneworld and Star alliance carriers that are firmly

ensconced at Haneda. In light of the strong existing presence by JAL and ANA at Haneda,

Delta submits that the public interest is better served by allocating Los Angeles-Haneda

slots to a third alliance carrier without a Japanese partner that can provide meaningful

competition -- rather than further exacer bating the Haneda advantages already enjoyed by

the Star and oneworld alliance carriers.

As noted above, Delta will operate much larger 747 aircraft, providing 63 percent

more capacity or more than 100,000 more annual seats than American. DL-ANS-502-504.

In addition, Delta’s substantial network at Los Angeles will extend Haneda service benefit to

interior U.S. points, further bolstering service with the Star and oneworld alliance carriers.

Delta, together with its domestic alliance partner Alaska Airlines, will provide nonstop-tononstop service via Los Angeles for 18 U.S. points. DL-ANS-501.

# Answer of Delta

Page 19

D. Delta’s Honolulu-Haneda Service Provides the Greatest Benefits for

the Pacific Islands.

1. Hawaiian at Honolulu.

Delta’s 403-seat B747 proposal would maximize service benefits on the HonoluluHaneda route, delivering 56 percent more seats (106,000 annually) than Hawaiian’s B767

proposal. DL-ANS-602-604. This will maximize U.S. flag competition with the Japanese

flag incumbents, who are already serving Honolulu on a charter basis from Haneda.

Nonetheless, Delta is mindful of the high priority the Department places on new entry.

Hawaiian Airlines, like Delta, lacks a Japanese alliance partner, and absent an award in this

case Hawaiian would be limited to offering charter service at Haneda. In these

circumstances, Delta would have no objection to Hawaiian receiving one slot pair for

Honolulu-Haneda scheduled service, with Delta receiving backup authority on the route.

All of the benefits of Hawaiian’s service proposal can and will be realized with a

single slot pair. There is no utility to a second “wingtip” flight using smallest aircraft at issue

in this case. Hawaiian acknowledges it has larger capacity A330 aircraft on order and that it

could upgauge to if the response to its service is positive. Providing Hawaiian a single slot

pair will incentivize Hawaiian to use larger and more efficient aircraft – as well as preserving

scarce slots that are critically needed at key mainland gateways to combat the expanding

Haneda presence of the Star and oneworld alliance carriers. There are 600 Haneda charter

opportunities that can be used by Hawaiian to augment service on the route, without

expending a second pair of critically scarce sc heduled service slots that can be used to

provide new service at an additional U.S. gateway. DL-ANS-608.

With only four slot pairs available, Honolulu should not receive more than a single

slot pair – since any further allocation would come at the expense of Delta’s large and

important mainland gateway that will benefit U.S. passengers . While Honolulu-Tokyo is an

important route, passengers are 94% Japan-originating. DL-ANS-601. Service at Delta’s

# Answer of Delta

Page 20

mainland gateways of Seattle, Detroit, and Los Angeles will benefit a much larger

percentage of U.S. origin passengers which are more important than Japanese leisure traffic

in the Department’s public interest analysis.

While Hawaiian attempts to claim credit for a number of U.S. west coast gateways on

a connecting basis via Honolulu, in reality Hawaiian’s service via the South Pacific would be

highly circuitous, inconvenient, and ineffective for west cost passengers. DL-ANS-605, 606,

607. As illustrated by the following table, Delta’s Seattle and Los Angeles proposals

provide far more convenient and effective routings for West Coast Passengers:

Given the need for effective Haneda competition from the mainland U.S. to combat

the Star and oneworld alliances, at most a single pair should be allocated for Hawaiian

service at Honolulu. As acknowledged by Ha waiian, it has competed successfully for many

years as a charter carrier in the U.S.-Japan market (and could do so at Haneda). An

allocation of a single pair Haneda slots will enable Hawaiian to try its hand at scheduled

operations for competing in the Japanese leisure market, while preserving maximum

competitive opportunities for U.S. travelers and shippers at key mainland gateways.

# Answer of Delta

Page 21

2. Continental at Guam

Guam is another Japan-original leisure market that is currently eligible for Haneda

charters and is eligible to receive more such service under the new agreement. Delta and

Continental both serve Guam on a scheduled basis from Narita. There is no justification for

giving Continental a competitive advantage from the preferred airport at Delta’s expense –

especially when Continental will reap the benefits of a major Haneda presence from its

partner, ANA.

V. Conclusion.

For the foregoing reasons, Delta requests the allocation of slot pairs to provide new

daily Haneda service from Seattle, Detroit and Los Angeles, with either primary or backup

authority for Honolulu.

Respectfully submitted,

_________________________________ Alexander Van der Bellen

Managing Director, Government Affairs

& Associate General Counsel

DELTA AIR LINES, INC.ANS-100 SeriesDelta’s Proposals Provide EffectiveCompetition to the Star and OneworldIncumbent Alliances at HanedaHaneda is the Preferred Airport Serving the Metro TokyoArea – Services at Narita are at a Serious CompetitiveDisadvantage•Haneda is the busiest airport in Japan and 4thbusiest in the world•Haneda is located in downtown Tokyo; Narita is 45+ miles away from central TokyoSource: Google Maps. Map copyright Google.•Narita to Tokyo (Marunouchi) :46 miles•Haneda to Tokyo (Marunouchi) :13 miles46 miles13 milesABBCDocket DOT-OST-2010-0018Exhibit DL-ANS-101Page 1 of 1Star46%Oneworld38%Other16%Star50%Oneworld40%Other10%Star and Oneworld Have a Significant Presence at HanedaSource: February 2010 schedules (APGdat)Haneda SeatsHaneda DeparturesDocket DOT-OST-2010-0018Exhibit DL-ANS-102Page 1 of 1An Allocation of Haneda Slots to Delta is Necessaryto Enable Inter-Alliance Competition2 20012Star (UA, CO, NH, US) Oneworld (AA, JL) SkyTeam (DL)U.S.-Japan Haneda Daily Slot PairsDocket DOT-OST-2010-0018Exhibit DL-ANS-103Page 1 of 1American, United, and Continental Will Have HanedaAccess Through Their Metal Neutral Joint Ventures WithJAL and ANA“The Pacific JV will foster ‘metal neutrality’ – a commercial environmentin which joint venture partnersshare common economic incentives topromote the interestsof their alliance over their individualcorporate interests. Bypooling resources to improve the overall service offering and sharing theresulting gains and losses, the Joint Applicants will harmonize their joint network and becomeindifferent as to which partner collects the revenue andoperates the aircraft on a given itinerary.”- Joint Application of ANA, Continental and United at 12,December 23, 2009, OST-2009-0350“The Joint Applicants seek approval for a highly-integrated, revenue-sharing joint venture that willstrengthen their alliance by eliminating eachcarrier’s economic incentive to maximize its ownrevenue. Only the closercooperation made possible through a joint venturebased on metal neutrality– or indifference as to which airline actually carries a customer – willmaximize the consumer benefitsthat immunized alliances make possible. This is because metal neutrality removes each carrier’sincentive to act opportunisticallyin ways that inure to its own short-term financial advantage, to thedetriment of the efficiencies and consumer benefitsthat could otherwise be delivered by the alliance.Accordingly, the Joint Applicants are seeking approval for a highly integrated joint venture withrevenue sharing that createsmetal neutrality. By providing for the broad sharingof revenue on ametal neutral foundation, the JBA will ensure thatAmerican and JAL act for the benefit of – and arecompensated for their contributionto – the alliance as a whole.”- Joint Application of American and JAL at 7, February 12, 2010, OST-2010-0034Delta Has No Japanese Carrier Partner -- and Therefore No Haneda AccessAbsent An Allocation of Haneda Slots By the DepartmentDocket DOT-OST-2010-0018Exhibit DL-ANS-104Page 1 of 1ANS-200 SeriesSelection of Delta’s Haneda ProposalsWill Maximize Public BenefitsDelta’s Proposals Will Bring the Greatest Capacityto the U.S.-Haneda Market294,190 294,190 294,190217,540201,480196,370188,340186,880180,310 180,310050,000100,000150,000200,000250,000300,000350,000Delta DTW747-400Delta LAX747-400Delta HNL747-400Delta SEAA330-300ContinentalEWR 777-200UnitedSFO 777-200HawaiianHNL 767-300ContinentalGUM 767-400AmericanLAX 777-200AmericanJFK 777-200Annual SeatsSources: Exhibits DL-115, DL-124, DL-133, DL-106,CO-114, UA-2, HA-App-3, CO-115, AA-104, and AA-102Docket DOT-OST-2010-0018Exhibit DL-ANS-201Page 1 of 1Seats PerFlight:403 403 403 298 276 269 258 256 247 247Delta’s Detroit and Seattle Gateways Will Serve the MostNonstop-to-Nonstop U.S. Points to Haneda905040191110940020406080100120Delta DTW Delta SEA ContinentalEWRUnited SFO AmericanLAXAmericanJFKDelta LAX HawaiianHNLContinentalGUMNonstop-to-Nonstop U.S. Points(Within 10% Circuity)Note: Includes U.S. points with no more than 10% circuity toHaneda via U.S. gateway and included in applicant’s connecting schedule exhibits.Sources: Exhibits DL-108-111, DL-117-120, DL-126-129, UA-3,UA-6, CO-122-123, CO-124-125, AA-107-110, AA 111-114, HA-App-2Docket DOT-OST-2010-0018Exhibit DL-ANS-202Page 1 of 1Delta’s Detroit and Seattle Connecting Traffic Bases toHaneda Are Larger Than Any Other Applicant’s1,434,020886,662602,505369,208267,001245,029169,325128,75200200,000400,000600,000800,0001,000,0001,200,0001,400,0001,600,000Delta SEA Delta DTW UnitedSFOContinentalEWRAmericanLAXDelta LAX AmericanJFKHonoluluHNLContinentalGUMBase Passengers in U.S. – Tokyo Connecting Markets(Within 10% Circuity)Note: Includes U.S. points with no more than 10% circuity toHaneda via U.S. gateway and included in applicant’s connecting schedule exhibits.Sources: Exhibits DL-108-111, DL-117-120, DL-126-129, UA-3, UA-6, CO-122-123, CO-124-125, AA-107-110, AA 111-114, HA-App-2; MIDT CY 2009Docket DOT-OST-2010-0018Exhibit DL-ANS-203Page 1 of 1Delta’s Seattle and Detroit Gateways Will Serve the LargestCombined Local and Connecting U.S. – Tokyo Traffic BaseAmong U.S. Mainland Gateways1,511,348918,938807,854721,033668,783646,811521,1500200,000400,000600,000800,0001,000,0001,200,0001,400,0001,600,000Delta SEA Delta DTW United SFO ContinentalEWRAmerican LAX Delta LAX American JFKLocal and Connecting Base Passengers in U.S. – Tokyo Markets(Within 10% Circuity)Note: Includes U.S. points with no more than 10% circuity toHaneda via U.S. gateway and included in applicant’s connecting schedule exhibits.Proposed U.S. gateway demand included (includes JFK, EWR, and LGA for CO EWR and AA JFK proposals).Sources: Exhibits DL-108-111, DL-117-120, DL-126-129, UA-3, UA-6, CO-122-123, CO-124-125, AA-107-110, AA 111-114, HA-App-2; MIDT CY 2009Docket DOT-OST-2010-0018Exhibit DL-ANS-204Page 1 of 1BURBURSBASBASTSOAKSFOSJCSJCONTONTONTLAXLAXSNASNAALWPUWPSCPSCPSCPSCYKMEATEATEATGEGFCAFCAFATFATFATPDXEUGTo ANC, FAI, JNU, SIT, KTNTo ANC, FAI, JNU, SIT, KTNTo ANC, FAI, JNU, SIT, KTNTo ANC, FAI, JNU, SIT, KTNTo ANC, FAI, JNU, SIT, KTNTo ANC, FAI, JNU, SIT, KTNATLATLATLBILBILBILBLIBLIBLIBOIBOIBOIBOSBZNBZNCVGDENDFWDTWGTFGTFGTFGTFGTFGTFGTFHLNJFKJFKLASLASLGBLGBLGBLWSLWSMCOMEMMFRMFRMFRMIAMIAMSOMSPMSPMSPMSPORDORDPHXPHXPSPPSPRDDRDDRDMRNORNORNOSANSANSLCSMFSMFSMFSeattle is an Ideal West Coast Gateway to HanedaDelta Will Provide Nonstop-to-Nonstop Haneda Service for 55 U.S. PointsHanedaNote: Includes service operated by Alaska/HorizonSource: Exhibits DL-108-111SEADocket DOT-OST-2010-0018Exhibit DL-ANS-205Page 1 of 1To SJUTo SJUTo SJUTo SJULGALGAJFKJFKHPNHPNEWRSWFSWFSWFSBNSBNFWAFWAMDWORDORDDAYDAYRICRICCHOAVPAVPSCESCEABEABEITHITHSYRSYRELMALBALBMHTMHTMHTBTVROCBUFBUFBUFBUFBUFBUFLANLANMBSMBSPLNPLNMQTMQTMQTGRBGRBCWAMKEMKEMSNMSNGRRGRRINDINDCAKCAKEVVEVVSDFSDFSDFDCADCAIADTPATPAMSYMSYMSYMSYIAHIAHSATSATSATAUSAUSDFWTULTULTULOKCOKCMCIMCIMCISTLSTLSTLCMICMICMIBMIBMIBMIPIAMLIMLIMLICIDCIDDSMOMAOMARSTRSTRSTMSPMSPDLHDLHRSWMIAMIAAPNAPNATLATLATLATWAVLAVLAVLAZOBDLBDLBDLBDLBDLBDLBDLBGMBGRBGRBHMBNABNABOSBOSBWIBWIBWICAECHSCHSCHSCHSCLECLECLTCLTCLTCMHCMHCRWCVGERIERIERIERIFLLFLLFLLFNTFNTFNTGSOGSPGSPHSVJAXJAXLEXLEXLSELSEMCOMDTMDTMDTMEMMYRMYRORFORFORFPBIPBIPBIPBIPHLPHLPHLPITPITPITPITPVDPVDPWMRDURDURDURDUROAROASAVTOLTOLTOLTOLTOLTOLTOLTRITRITRITRITVCTVCTYSTYSDelta’s Detroit Hub is the Largest and Most EffectiveGateway to Haneda for the Eastern United StatesDelta Will Provide Nonstop-to-Nonstop Haneda Service for 106 U.S. PointsHanedaSource: Exhibits DL-117-120DTWDocket DOT-OST-2010-0018Exhibit DL-ANS-206Page 1 of 1ATLATLCVGDTWFLLFLLFLLFLLINDJFKLASMCOMEMMSPPRCRNOSANSANSLCSLCSLCSLCTPADCARDDRDDRDDRDDMMHDelta Los Angeles-Haneda Service Would Provide StrongCompetition at Star Alliance’s LAX HubDelta Will Provide Nonstop-to-Nonstop Haneda Service for 18 U.S. PointsHanedaNote: Includes service operated by Alaska/HorizonSource: Exhibits DL-126-129LAXDocket DOT-OST-2010-0018Exhibit DL-ANS-207Page 1 of 1HNDHNDDelta’s Honolulu-Haneda Service Will Maintain U.S.Flag Competitiveness for Tokyo Leisure PassengersHNLDocket DOT-OST-2010-0018Exhibit DL-ANS-208Page 1 of 1Honolulu is Already Served by Japanese Charter Flights from HanedaANS-300 SeriesDelta’s Seattle Proposal WillMaximize Competition in thePacific NorthwestSEASEAALWPUWGEGGEGGEGPSCPSCPSCONTONTONTLAXLAXLAXSNASNASNAPSPPSPPSPBURBURBURSANSANSANSBASBASBASFOSFOSFOSTSSTSSTSATLATLATLBILBILBILBILBLIBLIBLIBLIBOIBOIBOIBOIBOSBOSBOSBZNBZNBZNCVGCVGCVGDENDENDENDFWDTWEATEATEATEUGEUGEUGFATFATFATFCAFCAFCAGTFGTFGTFHLNHLNHLNJFKJFKJFKLASLASLASLGBLGBLGBLWSLWSLWSMCOMCOMCOMEMMEMMFRMFRMFRMIAMIAMIAMSOMSOMSOMSPMSPMSPOAKOAKOAKORDORDORDPDXPDXPDXPHXPHXPHXRDDRDDRDDRDMRDMRNORNORNOSJCSJCSJCSLCSLCSLCSMFSMFSMFYKMYKMSeattle’s Pacific Northwest Location EnablesNon-Circuituous Connections to HanedaFrom Across the Entire Continental U.S.10% Circuity10% CircuityDL U.S. Behind Points Served 50Docket DOT-OST-2010-0018Exhibit DL-ANS-301Page 1 of 1Note: Includes service operated by Alaska/HorizonSource: Exhibits DL-108-111Delta’s Seattle Service Would Offer 29 More SeatsPer Flight Than United’s San Francisco Proposal298269250255260265270275280285290295300305United (SFO) Delta (SEA)Sources: Exhibits DL-106 and UA-2Seats Per Flight+11%0Docket DOT-OST-2010-0018Exhibit DL-ANS-302Page 1 of 1Delta’s Seattle Service Would Offer 29 More SeatsPer Flight Than United’s San Francisco ProposalDelta’s Airbus A330-300298 SeatsUnited’s 777-200269 SeatsDocket DOT-OST-2010-0018Exhibit DL-ANS-303Page 1 of 1Sources: Exhibits DL-106 and UA-2Delta’s Seattle Service Would Offer Over 20,000 MoreAnnual Nonstop Seats to/from Haneda Than United’sSan Francisco Proposal196,370217,540180,000190,000200,000210,000220,000United (SFO) Delta (SEA)Sources: Exhibits DL-106 and UA-2Annual Seats+11%0Docket DOT-OST-2010-0018Exhibit DL-ANS-304Page 1 of 1SFOSFOSFOSFOSNASNASNABURBURBURACVACVACVBOIBOIBOIBOICICCICCICCICDENDENDENFATFATFATLASLASLASLAXLAXLAXMODMODMODMRYMRYMRYPHXPHXPHXRDDRDDRDDRNORNORNOSANSANSANSBASBASBASBPSBPSBPSLCSLCSLCSMFSMFSMFUnited’s San Francisco Hub Serves Far Fewer Points in aSmaller Catchment Area Than Delta’s Seattle GatewaySFO 10% CircuitySEA10% CircuitySources: Exhibits DL-108-111, UA-3, and UA-610% CircuityUA U.S. Behind Points Served 19DL U.S. Behind Points Served 50% DL Greater 163%Docket DOT-OST-2010-0018Exhibit DL-ANS-305Page 1 of 1Seattle’s Primary Catchment Traffic Base to Tokyo is87% Larger Than San Francisco’s807,8541,511,3480200,000400,000600,000800,0001,000,0001,200,0001,400,0001,600,000UA SFO TokyoBaseDL SEA TokyoBaseLocal and Connecting U.S.– Tokyo Traffic Base(Within 10% circuity)Note: Includes U.S. points with no more than 10% circuity toHaneda via U.S. gateway and included in applicant’s connecting schedule exhibits. ProposedU.S. gateway demand included.Sources: MIDT CY 2009; Exhibits DL-108-111, UA-3, and UA-6 (for one-way connections)+87%Docket DOT-OST-2010-0018Exhibit DL-ANS-306Page 1 of 1Seattle’s Primary Catchment Connecting Traffic Baseto Tokyo is More Than Double San Francisco’s602,5051,434,0200200,000400,000600,000800,0001,000,0001,200,0001,400,0001,600,000UA SFO TokyoBaseDL SEA TokyoBaseU.S. – Tokyo Connecting Traffic Base(Within 10% circuity)Note: Includes U.S. points with no more than 10% circuity toHaneda via U.S. gateway and included in applicant’s connecting schedule exhibits.Sources: MIDT CY 2009; Exhibits DL-108-111, UA-3, and UA-6 (for one-way connections)+138%Docket DOT-OST-2010-0018Exhibit DL-ANS-307Page 1 of 1Delta’s Seattle Service Will Serve 90% MoreNonstop-to-Nonstop U.S. Points to Haneda asUnited’s San Francisco Proposal29550102030405060United (SFO) Delta (SEA)Nonstop-to-Nonstop U.S.Points to Haneda(No Circuity Limitation)Delta will serve 26 more total points than UnitedNote: Includes U.S. points included in applicant’s connecting schedule exhibits.Sources: Exhibits DL-108-111, UA-3, and UA-6 (for one-way connections)+90%Docket DOT-OST-2010-0018Exhibit DL-ANS-308Page 1 of 1Delta’s Seattle Service Will Offer 31 MoreNonstop-to-Nonstop U.S. Points to Haneda ThanUnited’s San Francisco Proposal Within 10% Circuity19500102030405060United (SFO) Delta (SEA)Nonstop-to-Nonstop U.S.Points to Haneda(Within 10% Circuity)Delta will serve 31 more points than UnitedNote: Includes U.S. points with no more than 10% circuity toHaneda via U.S. gateway and included in applicant’s connecting schedule exhibits.Sources: Exhibits DL-108-111, UA-3, and UA-6 (for one-way connections)+163%Docket DOT-OST-2010-0018Exhibit DL-ANS-309Page 1 of 1Delta’s Seattle Gateway isUnder Competitive Threat bythe Nearby Vancouver Gateway,Which is Eligible for HanedaService by Multiple Star ATIPartners (Air Canada and ANA),as Well as Oneworld (JAL)SEASEATokyoTokyoYVRYVRDocket DOT-OST-2010-0018Exhibit DL-ANS-310Page 1 of 1SFOSFOSFOSFOSEASEAPassengers Throughout the West Coast Can Conveniently Travelvia Seattle – But Pacific Northwest Passengers Would BeInconvenienced Under United’s San Francisco ProposalNote: Mileage is statute mileage.Source: Exhibits DL 110-111, UA-1, and UA-3DeltaUnitedSFOSEAVia SEAVia SFOTwo Segment Miles 5,468 5,824Circuity (%) 6% 22%Circuity (Miles Roundtrip) 644 2,068Docket DOT-OST-2010-0018Exhibit DL-ANS-311Page 1 of 1ANS-400 SeriesDelta’s Detroit Hub GatewayMaximizes Competition forEastern U.S. CustomersLGALGALGAEWREWREWRHPNHPNHPNSWFSWFSWFSWFSWFSWFJFKJFKJFKFNTFNTFNTDTWMBSMBSMBSCAKCAKCAKCLECLECLEMDWMSNMSNMSNORDORDORDGRRGRRGRRITHITHITHITHSYRSYRSYRELMELMSDFSDFSDFEVVEVVEVVPIAPIAPIAPIAATWGRBGRBGRBMDTMDTMDTSCESCESCEIADIADIADIADROCROCROCMIAMIAMIAABEABEABEALBALBALBAPNAPNAPNATLATLATLAVLAVLAVLAVPAVPAVPAZOAZOAZOBDLBDLBDLBGMBGMBGRBGRBGRBHMBHMBMIBMIBMIBNABNABNABOSBOSBOSBTVBTVBTVBUFBUFBUFBWIBWIBWICAECAECAECHOCHOCHOCHSCHSCHSCLTCLTCLTCMHCMHCMHCMICMICMICRWCVGCVGCVGDAYDAYDAYDCADCADCAERIERIERIERIFLLFLLFLLFWAFWAFWAGSOGSOGSOGSPGSPGSPHSVHSVHSVINDINDINDINDJAXJAXJAXLANLANLANLEXLEXLEXMCOMCOMCOMEMMEMMHTMHTMHTMKEMKEMKEMLIMLIMLIMSYMSYMSYMYRMYRMYRORFORFORFPBIPBIPBIPBIPHLPHLPHLPITPITPITPITPLNPLNPLNPVDPVDPVDPWMPWMPWMPWMRDURDURDURICRICRICRICROAROAROARSWSAVSAVSAVSBNSBNSBNSTLSTLSTLTOLTOLTOLTPATPATPATRITRITRITRITVCTVCTVCTYSTYSTYSDelta’s Primary Catchment Area From DetroitProvides Comprehensive and CompetitiveHaneda Service for the Entire Eastern U.S.10% Circuity10% CircuityDL U.S. Behind Points Served 90To SJUDocket DOT-OST-2010-0018Exhibit DL-ANS-401Page 1 of 1Source: Exhibits DL-117-120Delta’s Detroit Service Would Offer 156 More SeatsPer Flight Than American’s New York Proposal247403050100150200250300350400450American (JFK) Delta (DTW)Sources: Exhibits DL-115 and AA-102Docket OST-2007-28567Exhibit NW-ANS-402Page 1 of 1Seats Per Flight+63%Delta’s Detroit Service Would Offer 156 More SeatsPer Flight Than American’s New York ProposalDelta’s Boeing 747-400403 SeatsAmerican’s 777-200247 SeatsDocket DOT-OST-2010-0018Exhibit DL-ANS-403Page 1 of 1Sources: Exhibits DL-115 and AA-115Delta’s Detroit Service Would Offer More Than 100,000More Annual Nonstop Seats to/from Haneda ThanAmerican’s New York Proposal180,310294,190050,000100,000150,000200,000250,000300,000American (JFK) Delta (DTW)Sources: Exhibits DL-115 and AA-104Annual Seats+63%Docket DOT-OST-2010-0018Exhibit DL-ANS-404Page 1 of 1JFKJFKBOSBOSBOSBWIBWIBWIDCADCADCAMCOMCOMCOMIAMIAMIAPITPITPITPITRDURDURDUTPATPATPAAmerican’s JFK Gateway Serves Far Fewer Points in aSignificantly Smaller Catchment Area Than Delta’sDetroit HubJFK 10% CircuitySource: Exhibits AA-107-110 and DL-117-12010% CircuityAA U.S. Behind Points Served 10DL U.S. Behind Points Served 90% DL Greater 800%DTW10% CircuityTo STTand SJUDocket DOT-OST-2010-0018Exhibit DL-ANS-405Page 1 of 1Detroit’s Primary Catchment Traffic Base to Tokyo is76% Larger Than American’s at JFK521,150918,9380100,000200,000300,000400,000500,000600,000700,000800,000900,0001,000,000AA JFK-TokyoBaseDL DTWTokyo BaseLocal and Connecting U.S.– Tokyo Traffic Base(Within 10% circuity)Note: Includes U.S. points with no more than 10% circuity toHaneda via U.S. gateway and included in applicant’s connecting schedule exhibits. ProposedU.S. gateway demand included (EWR, LGA, and JFK for AA).Sources: MIDT CY 2009; Exhibits AA-107-110 and DL-117-120+76%Docket DOT-OST-2010-0018Exhibit DL-ANS-406Page 1 of 1Detroit’s Primary Catchment Connecting Traffic Baseto Tokyo is Five Times the Size of American’s at JFK169,325886,6620100,000200,000300,000400,000500,000600,000700,000800,000900,0001,000,000AA JFK TokyoBaseDL DTW TokyoBaseU.S. – Tokyo Connecting Traffic Base(Within 10% circuity)Note: Includes U.S. points with no more than 10% circuity toHaneda via U.S. gateway and included in applicant’s connecting schedule exhibits.Sources: MIDT CY 2009; Exhibits AA-107-110 and DL-117-120+424%Docket DOT-OST-2010-0018Exhibit DL-ANS-407Page 1 of 1Delta’s Detroit Service Will Serve 91 MoreNonstop-to-Nonstop U.S. Points to HanedaThan American’s JFK Proposal15106020406080100120American (JFK) Delta (DTW)Nonstop-to-Nonstop U.S.Points to Haneda(No Circuity Limitation)Delta will serve 91 more total points than AmericanNote: Includes U.S. points included in applicant’s connecting schedule exhibits.Sources: Exhibits AA-107-110 and DL-117-120+607%Docket DOT-OST-2010-0018Exhibit DL-ANS-408Page 1 of 1Delta’s Detroit Service Will Serve 80 MoreNonstop-to-Nonstop U.S. Points to Haneda ThanAmerican’s JFK Proposal Within 10% Circuity10900102030405060708090100American (JFK) Delta (DTW)Nonstop-to-Nonstop U.S.Points to Haneda(Within 10% Circuity)Delta will serve 80 morepoints than AmericanNote: Includes U.S. points with no more than 10% circuity toHaneda via U.S. gateway and included in applicant’s connecting schedule exhibits.Sources: Exhibits AA-107-110 and DL-117-120+800%Docket DOT-OST-2010-0018Exhibit DL-ANS-409Page 1 of 1Delta’s Detroit Service Would Offer 127 More SeatsPer Flight Than Continental’s Newark Proposal276403050100150200250300350400450Continental(EWR)Delta (DTW)Sources: Exhibits DL-115 and CO-114 (CO capacity reflects removal of 9 seats from B777 as explained in note on CO-114)Seats Per Flight+46%Docket DOT-OST-2010-0018Exhibit DL-ANS-410Page 1 of 1Delta’s Detroit Service Would Offer 127 More SeatsPer Flight Than Continental’s Newark ProposalDelta’s Boeing 747-400403 SeatsContinental’s 777-200276 SeatsDocket DOT-OST-2010-0018Exhibit DL-ANS-411Page 1 of 1Sources: Exhibits DL-115 and CO-118Delta’s Detroit Service Would Offer Nearly 100,000 MoreAnnual Nonstop Seats to/from Haneda Than Continental’sNewark Proposal201,480294,190050,000100,000150,000200,000250,000300,000Continental(EWR)Delta (DTW)Sources: Exhibits DL-115 and CO-114 (CO capacity reflects removal of 9 seats from B777 as explained in note on CO-114)Annual Seats+46%Docket DOT-OST-2010-0018Exhibit DL-ANS-412Page 1 of 1DCADCADCAIADIADIADIADGSOGSOGSOMIAMIAMIAEWREWRALBALBALBATLATLATLAVLAVLAVLAVPAVPAVPBDLBDLBDLBOSBOSBOSBTVBTVBTVBUFBUFBUFBWIBWIBWICHSCHSCHSCLECLECLECLTCLTCLTCMHCMHCMHFLLFLLFLLITHITHITHITHJAXJAXJAXMCOMCOMCOMDTMDTMDTMHTMHTMHTMYRMYRMYRORFORFORFPBIPBIPBIPBIPHLPHLPHLPITPITPITPITPVDPVDPVDPWMPWMPWMPWMRDURDURDURICRICRICRICROCROCROCRSWSAVSAVSAVSYRSYRSYRTPATPATPATYSTYSTYSContinental’s Newark Hub Serves Far Fewer Points in aSignificantly Smaller Catchment Area Than Delta’sDetroit HubEWR 10% CircuityDTW10% CircuitySources: Exhibits DL-117-120 and CO-122-12310% CircuityCO U.S. Behind Points Served 40DL U.S. Behind Points Served 90% DL Greater 125%To SJUDocket DOT-OST-2010-0018Exhibit DL-ANS-413Page 1 of 1Detroit’s Primary Catchment Connecting Traffic Baseto Tokyo is Nearly 2.5 Times As Large As Newark’s369,208886,6620100,000200,000300,000400,000500,000600,000700,000800,000900,0001,000,000CO EWRTokyo BaseDL DTW TokyoBaseU.S. – Tokyo Connecting Traffic Base(Within 10% circuity)Note: Includes U.S. points with no more than 10% circuity toHaneda via U.S. gateway and included in applicant’s connecting schedule exhibits.Sources: MIDT CY 2009; Exhibits DL-117-120 and CO-122-123+140%Docket DOT-OST-2010-0018Exhibit DL-ANS-414Page 1 of 1Delta’s Detroit Service Will Serve 130% MoreNonstop-to-Nonstop U.S. Points to Hanedaas Continental’s Newark Proposal46106020406080100120Continental(EWR)Delta (DTW)Nonstop-to-Nonstop U.S.Points to Haneda(No Circuity Limitation)Delta will serve 60 more total points thanContinentalNote: Includes U.S. points included in applicant’s connecting schedule exhibits.Sources: Exhibits DL-117-120 and CO-122-123+130%Docket DOT-OST-2010-0018Exhibit DL-ANS-415Page 1 of 1Delta’s Detroit Service Will Offer More Than Twice As ManyNonstop-to-Nonstop U.S. Points to Haneda AsContinental’s Newark Proposal Within 10% Circuity40900102030405060708090100Continental(EWR)Delta (DTW)Nonstop-to-Nonstop U.S.Points to Haneda(Within 10% Circuity)Delta will serve 50 more points than ContinentalNote: Includes U.S. points with no more than 10% circuity toHaneda via U.S. gateway and included in applicant’s connecting schedule exhibits.Sources: Exhibits DL-117-120 and CO-122-123+125%Docket DOT-OST-2010-0018Exhibit DL-ANS-416Page 1 of 1Delta’s Detroit Hub is a More Effective Transpacific GatewayThan Continental at Newark and American at JFKDetroit Has More Transpacific Seats Than All of the CompetingEastern U.S. GatewaysSource: July 2010 schedules (APGdat)19,79015,8483,45805,00010,00015,00020,00025,000Delta DTW Continental EWR American JFKTranspacific Weekly Seats(Both Directions)Docket DOT-OST-2010-0018Exhibit DL-ANS-417Page 1 of 1ANS-500 SeriesDelta’s Los Angeles ProposalWill Maximize Competition inthe Largest Mainland U.S.-Tokyo MarketATLATLCVGDTWFLLFLLFLLFLLINDJFKLASMCOMEMMSPPRCRNOSANSANSLCSLCSLCSLCTPADCARDDRDDRDDRDDMMHDelta Los Angeles-Haneda Service Would Provide StrongCompetition at Star Alliance’s LAX HubDelta Will Provide Nonstop-to-Nonstop Haneda Service for 18 U.S. PointsHanedaNote: Includes service operated by Alaska/HorizonSources: Exhibits DL-126-129; MIDT CY 2009.LAXDocket DOT-OST-2010-0018Exhibit DL-ANS-501Page 1 of 1The Los Angeles local market andDelta’s 18 connecting U.S. pointsvia LAX account for 1 millionTokyo passengers annually.Delta’s Los Angeles Service Would Offer 156 More SeatsPer Flight Than American’s Los Angeles Proposal247403050100150200250300350400450American (LAX) Delta (LAX)Sources: Exhibits DL-124 and AA-104Seats Per Flight+63%Docket DOT-OST-2010-0018Exhibit DL-ANS-502Page 1 of 1Delta’s Los Angeles Service Would Offer 156 More SeatsPer Flight Than American’s Los Angeles ProposalDelta’s Boeing 747-400403 SeatsAmerican’s 777-200247 SeatsDocket DOT-OST-2010-0018Exhibit DL-ANS-503Page 1 of 1Sources: Exhibits DL-124 and AA-115Delta’s Los Angeles Service Would Offer More Than 100,000More Annual Nonstop Seats to/from Haneda ThanAmerican’s Los Angeles Proposal180,310294,190050,000100,000150,000200,000250,000300,000American(LAX)Delta (LAX)Sources: Exhibits DL-124 and AA-104Annual Seats+63%Docket DOT-OST-2010-0018Exhibit DL-ANS-504Page 1 of 1The Los Angeles-Tokyo Local Market Has Twice As ManyU.S.-Originating Passengers as the Honolulu-TokyoLocal Market60,961125,617020,00040,00060,00080,000100,000120,000140,000Honolulu Los AngelesSource: MIDY CY 2009U.S. Point-of-SaleU.S.-Tokyo O&D Passengers+106%Docket DOT-OST-2010-0018Exhibit DL-ANS-505Page 1 of 1Los Angeles is the Largest Mainland U.S.-Tokyo Marketand is Nearly Twice the Size of the San Francisco-TokyoLocal Market205,349401,782050,000100,000150,000200,000250,000300,000350,000400,000450,000San Francisco(United)Los Angeles(Delta)Source: MIDY CY 2009U.S.-Tokyo O&D Passengers+96%Docket DOT-OST-2010-0018Exhibit DL-ANS-506Page 1 of 1ANS-600 SeriesDelta’s Honolulu-Haneda ServiceProvides the Greatest Benefitsfor the Pacific Islands6.3%93.7%Honolulu-Tokyo Passengers Are Overwhelmingly Non-U.S.Point of SaleSource: MIDT CY 2009Honolulu-Tokyo PassengersU.S. Point of SaleNon-U.S. Point of SaleDocket DOT-OST-2010-0018Exhibit DL-ANS-601Page 1 of 1Delta’s Honolulu Service Would Offer 145 More SeatsPer Flight Than Hawaiian’s Honolulu Proposal258403050100150200250300350400450Hawaiian (HNL) Delta (HNL)Sources: Exhibits DL-133 and HA-App-3 (HA capacity reflects 6 seats blocked for crew as explained in note on HA-App-3)Seats Per Flight+56%Docket DOT-OST-2010-0018Exhibit DL-ANS-602Page 1 of 1Delta’s Honolulu Service Would Offer 145 More SeatsPer Flight Than Hawaiian’s Honolulu ProposalDelta’s Boeing 747-400403 SeatsHawaiian’s767-300258 SeatsDocket DOT-OST-2010-0018Exhibit DL-ANS-603Page 1 of 1Sources: Exhibits DL-133 and HA-App-3Delta’s Honolulu Service Would Offer 106,000 MoreAnnual Nonstop Seats to/from Haneda ThanHawaiian’s Honolulu Proposal188,340294,190050,000100,000150,000200,000250,000300,000Hawaiian (HNL) Delta (HNL)Sources: Exhibits DL-133 and HA-App-3 (HA capacity reflects 6 seats blocked for crew as explained in note on HA-App-3)Annual Seats+56%Docket DOT-OST-2010-0018Exhibit DL-ANS-604Page 1 of 1HNLHNLSEASEAHNDHNDHonolulu is an Ineffective Gateway to Haneda for theContinental U.S.Note: Mileage is statute mileage.Source: Exhibits DL-104 and HA-App-1-2Docket DOT-OST-2010-0018Exhibit DL-ANS-605Page 1 of 1Delta SEA-HNDMiles: 4,790Circuity: 0%Roundtrip Elapsed Time Summer: 19:45Roundtrip Elapsed Time Winter: 19:50Hawaiian SEA-HNL-HNDMiles: 6,521Circuity: 36%Roundtrip Elapsed Time Summer: 44:05Roundtrip Elapsed Time Winter: 35:00HNLHNLHNDHNDLAXLAXHonolulu is an Ineffective Gateway to Haneda for theContinental U.S.Note: Mileage is statute mileage.Source: Exhibits DL-122 and HA-App-1-2Docket DOT-OST-2010-0018Exhibit DL-ANS-606Page 1 of 1Delta LAX-HNDMiles: 5,474Circuity: 0%Roundtrip Elapsed Time Summer: 22:00Roundtrip Elapsed Time Winter: 22:35Hawaiian LAX-HNL-HNDMiles: 6,397Circuity: 17%Roundtrip Elapsed Time Summer: 42:15Roundtrip Elapsed Time Winter: 34:50Honolulu is an Ineffective Gateway to Haneda for theContinental U.S.*LAX elapsed times for DL based on DL’s nonstop LAX-HND proposal.Note: Best roundtrip elapsed time shown for each applicant based on applicant’s schedule exhibits.Source: Exhibits DL-104, DL-122, DL-108-111, DL-126-129 and HA-App-2Docket DOT-OST-2010-0018Exhibit DL-ANS-607Page 1 of 1Hawaiian’s Proposed Continental U.S. Connecting Points Are Much MoreConveniently Served by Delta’s Seattle and Los Angeles ProposalsU.S. Point DL via SEA HA via HNL DL via SEA HA via HNL DL via SEA HA via HNLLAS 2% 19% 28:05 35:05 27:57 34:50LAX* Nonstop 17% 22:00 42:15 22:35 34:50OAK 6% 21% 27:55 one-way only 30:34 34:10PDX 2% 33% 23:50 35:00 24:50 34:50PHX 2% 17% 29:47 37:49 29:54 37:59SAN 5% 16% 30:13 one-way only 29:02 33:40SEA Nonstop 36% 19:45 44:05 19:50 35:00SFO 6% 21% 29:04 one-way only 27:42 34:00SJC 6% 21% 29:00 one-way only 29:47 34:05SMF 5% 23% 27:45 one-way only 29:29 34:20SummerRoundtrip Elapsed TimeWinterRoundtrip Elapsed TimeCircuityHawaiian Competes Today in Japan via Charters andHas 600 Annual Haneda Opportunities Available- Hawaiian Haneda Application at 5Docket DOT-OST-2010-0018Exhibit DL-ANS-608Page 1 of 1- 2009 U.S.-Japan MOU,Annex, Section 3Hawaiian’s “Wingtip” Flights Fail to MaximizePublic Benefits188,340214,620150,000170,000190,000210,000230,000250,000Hawaiian 767-300 ProposalHawaiian A330ProposalSource: HA-App-3Annual Seats+14%Docket DOT-OST-2010-0018Exhibit DL-ANS-609Page 1 of 1•Hawaiian could increase HNL-HND capacity by 14% by using itslarger A330 aircraft•No new connecting benefits arerealized from two flights inexactly the same time channel00.9%99.1%Guam-Tokyo Passengers Are Overwhelmingly Non-U.S.Point of SaleSource: MIDT CY 2009Guam-Tokyo PassengersU.S. Point of SaleNon-U.S.Point of SaleDocket DOT-OST-2010-0018Exhibit DL-ANS-610Page 1 of 1Delta’s Honolulu Service Would Offer 147 More SeatsPer Flight Than Continental Micronesia’s Guam Proposal256403050100150200250300350400450ContinentalMicronesia(GUM)Delta (HNL)Sources: Exhibits DL-133 and CO-115Seats Per Flight+57%Docket DOT-OST-2010-0018Exhibit DL-ANS-611Page 1 of 1Delta’s Honolulu Service Would Offer 147 More SeatsPer Flight Than Continental Micronesia’s Guam ProposalDelta’s Boeing 747-400403 SeatsContinental Micronesia’s764-400256 SeatsDocket DOT-OST-2010-0018Exhibit DL-ANS-612Page 1 of 1Sources: Exhibits DL-133 and CO-119Delta’s Honolulu Service Would Offer 107,000 MoreAnnual Nonstop Seats to/from Haneda ThanContinental Micronesia’s Guam Proposal186,880294,190050,000100,000150,000200,000250,000300,000ContinentalMicronesia(GUM)Delta (HNL)Sources: Exhibits DL-133 and CO-115Annual Seats+57%Docket DOT-OST-2010-0018Exhibit DL-ANS-613Page 1 of 1Based on U.S. Point-of-Sale Bookings, the GuamLocal Market is Substantially Smaller Than the LocalMarkets of Delta’s Proposed Continental U.S. Gateways125,61739,03016,4347,882020,00040,00060,00080,000100,000120,000140,000Los Angeles Seattle Detroit GuamU.S. Point-of-SaleU.S.-Tokyo O&D PassengersSource: MIDT CY 2009 (U.S. point-of-sale only)Docket DOT-OST-2010-0018Exhibit DL-ANS-614Page 1 of 1GUMGUMNRTNRTContinental and Delta Each Serve Guam from NaritaDelta’s Narita-Guam Flights Would Be Placed at a SevereCompetitive Disadvantage if Only Continental Was Allowed toServe Guam From Tokyo’s Preferred AirportDocket DOT-OST-2010-0018Exhibit DL-ANS-615Page 1 of 1

# CERTIFICATE OF SERVICE

A copy of the foregoing document has been served this 1st day of March, 2010, upon

the following persons via email:

carl.nelson@aa.com

dan.weiss@coair.com

hershel.kamen@coair.com

rbkeiner@crowell.com

mrosia@crowell.com

gmurphy@crowell.com

jeffrey.manley@united.com

julie.oettinger@united.com

howard.kass@usairways.com

benjamin.slocum@usairways.com

jhill@dowlohnes.com

ldeavers@dowlohnes.com

perkmann@dowlohnes.com

dmendersbee@zsrlaw.com

todd.homan@dot.gov

paul.gretch@dot.gov

keith.glatz@dot.gov

esta.rosenberg@dot.gov

byerlyjr@state.gov

eugene_alford@ita.doc.gov

joe.cambron@wcaa.us

Ishiwata.K@portseattle.org

Safora.I@portseattle.org

mike.orr@airlineinfo.com