BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Joint Application of

Virgin Atlantic Airways, Ltd. Delta Air Lines, Inc. Société Air France Koninklijke Luchtvaart Maatschappij N.V. Alitalia Compagnia Aerea Italiana S.p.A

Under 49 U.S.C. §§ 41308 and 41309 for Approval of and Antitrust Immunity for Alliance Agreements ) ) ) ) ) ) ) ) ) ) ) ) Docket DOT

- OST

- 2013

- 0068

ANSWER OF THE DELTA MASTER EXECUTIVE COUNCIL OF THE AIR LINE PILOTS ASSOCIATION, INTERNATIONAL IN SUPPORT OF DELTA AND VIRGIN ATLANTIC

Communications with respect to this document should be addressed to:

June 4 , 2013 Kingsley S. Roberts Chairman Delta Master Executive Council Air Line Pilots Association, International 100 Hartsfield Centre Parkway, Suite 800 Atlanta, Georgia 30354 Kingsley.Roberts@alpa.orgBEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Joint Application of

Virgin Atlantic Airways, Ltd. Delta Air Lines, Inc. Société Air France Koninklijke Luchtvaart Maatschappij N.V. Alitalia Compagnia Aerea Italiana S.p.A

Under 49 U.S.C. §§ 41308 and 41309 for Approval of and Antitrust Immunity for Alliance Agreements ) ) ) ) ) ) ) ) ) ) ) ) Docket DOT

- OST

- 2013

- 0068

ANSWER OF THE DELTA MASTER EXECUTIVE COUNCIL OF THE AIR LINE PILOTS ASSOCIATION, INTERNATIONAL IN SUPPORT OF DELTA AND VIRGIN ATLANTIC

Delta and Virgin Atlantic, together with Delta’s existing European alliance

partners, have requested antitrust immunity so that Delta and Virgin Atlantic can for m a

North America

- U. K. joint venture. The joint venture will improve service and

competition on U.S.

- U.K. routes, particularly at London Heathrow Airport (LHR), where

service today is dominated by the AA/BA alliance. The joint venture will increase

Delta ’ s competitive presence at LHR. It will also produce new flying opportunities for

Delta and its employees
, including plans for Delta to operate new nonstop Seattle

- LHR

service as part of the joint venture. For these reasons, t he Delta Master Executive

Cou ncil, th e Delta chapter of the Air Line P ilots Association, Int ernational (the “Delta

MEC”), strongly support s the request of Delta and Virgin Atlantic for antitrust immunity.Answer of the Delta MEC

Page 2 The grant of antitrust immunity for the Delta/Virgin Atlantic joint venture will

benefit the 12,000 members of the Delta chapter of the Air Line Pilots Ass ociation as

well as the other 68 ,000 dedicated employees of Delta. Over the years Delta has entered

into a number of joint venture relationships, including the current transatl antic joint

venture with Air France, KLM and Alitalia. The Delta MEC has been pleased with the

positive results of the se joint ventures which have produced value for the company, new

service and competitive opportunities for the traveling public, and new flying

opportunities for D elta pilots and flight crews. New flights have been equitably

apportioned between Delta and its EU partners, and we note that in this instance one of

the first new JV routes to be flown would be Delta

- operated Seattle

- LHR service

. The Delta/Virgin Atlantic joint venture will benefit the traveling public because it

will dramatically improve service and competition on U.S.

- U.K. routes, where AA /BA

are the dominant players. Today, AA/BA operate 59% of U.S.

- LHR capacity; Virgin

Atlantic has a 16% share, and Delta is a marginal player with only an 8% share. In terms

of U.S.

- LHR frequencies, AA/B A have 54 nonstop U.S.

- LHR flights, 13 for Virgin

Atlantic , and 9 for Delta. (Based on June 2013 peak day schedules).

By joining forces, Delta and Virgin Atlantic will be a more effective competitor

for U.S.

- U.K. traffic

-- particularly for time sensitive business travelers who demand

schedule flexibility and a choice of travel options. Nowhere is this more apparent than

in the New York

- LHR market, where Delta is able to operate just 3 daily flights against

the 15 flights of the AA/BA alliance. Together Delta and Virgin will provide 9 well

timed flights, with Delta and Virgin each maintaining all of their current frequencies and

optimizing schedules to achieve better time of day coverage . Similar benefits will beAnswer of the Delta MEC

Page 3

realized in the Boston

- London Heathrow market, where Delta and Virgin each operate a

single daily flight against th e four offered by the AA/BA alliance. Delta and Virgin plan

to maintain their current services, but to spread out “wingtip” flights to better serve their

customers.
The Delta/Virgin Joint Venture will be fed by Delta’s large North America n

network
, which connects to the nonstop U.S.

- UK joint venture flights at major hubs

including JFK, Atlan ta, Detroit and Los Angeles. The Joint Venture, in turn, will supply

additional traffic and revenue to Delta’s domestic flights, staffed by Delta pilots and U.S.

flig ht crews.

Given the benefits of the Delta/Virgin Atlantic joint venture to the traveling

public, as well as the benefits to U.S. aviation interests including the Delta pilots , we
respectfully urge the Department to grant antitrust immunity to the proposed

arrangement.

Respectfully submitted
,

Kingsley S. Roberts Chairman Delta Master Executive Council Air Line Pilots Association, In ternationa lCERTIFICATE OF SERVICE

A copy of the foregoing document has been served this 4th day of June 2013 , upon the following persons via email:

francis.heil@aa.com robert.wirick@aa.com sascha.vanderbellen@delta.com howard.kass @usairways.com benjamin.slocum@usairways.com thomas.bolling@united.com dan.weiss@united.com todd.homan@dot.gov peter.irvine@dot.gov reese.davidson@dot.gov bob.goldner@dot.gov paul.gretch@dot.gov esta.rosenberg@dot.gov Jill.Ptacek@usdoj.gov urskr@state.gov Ishiwata.K@portseattle.org joe.cambron@wcaa.us brubinst@panynj.gov louis.miller@atlanta

- airport.com info@airlineinfo.com YSurehan@massport.com Dino.Atsalis@alpa.org