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

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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.org
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

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

partners, have requested antitrust immunity so that Delta and Virgin Atlantic can form 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, the Delta Master Executive 

Council, the Delta chapter of the Air Line Pilots Association, International (the “Delta 

MEC”), strongly supports 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 Association 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 transatlantic joint 

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

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

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

opportunities for Delta 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/BA 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 welltimed 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 be 
Answer of the Delta MEC

Page 3

realized in the Boston-London Heathrow market, where Delta and Virgin each operate a 

single daily flight against the 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 American

network, which connects to the nonstop U.S.-UK joint venture flights at major hubs 

including JFK, Atlanta, 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. 

flight 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, International
CERTIFICATE 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