BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

2013/2014 U.S.-Brazil Combination Frequency

Allocation Proceeding

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Docket DOT-OST-2013-0072

REPLY OF WAYNE COUNTY AIRPORT AUTHORITY 

IN SUPPORT OF DELTA AIR LINES, INC. 

Communications with respect to this document should be addressed to:

Joe Cambron

Director, Air Service Development

Thomas Naughton

Chief Executive Officer

Emily Neuberger

Senior Vice President

WAYNE COUNTY AIRPORT AUTHORITY

L.C. Smith Terminal

Detroit, Michigan 48242

(734) 942-3550

May 14, 2013
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

2013/2014 U.S.-Brazil Combination Frequency

Allocation Proceeding

)

)

)

)

)

)

)

Docket DOT-OST-2013-0072

REPLY OF WAYNE COUNTY AIRPORT AUTHORITY 

IN SUPPORT OF DELTA AIR LINES, INC. 

After reviewing the answers and supporting documents filed by other parties last 

week, Detroit wishes to supplement its comments to add the following additional 

observations.

American’s Answer does not even attempt to argue that Detroit is not deserving 

of Sao Paulo service, nor does it make any case against Detroit’s flight being 

economically the proper choice. Instead, American chooses to focus on fringe 

arguments rooted in past events that have nothing to do with the merits of the service 

proposals in this case. We believe this belies the weakness of their case against 

Detroit-Sao Paulo, a market that would lose all service to Brazil if our request is not 

granted, versus their requests to simply add additional service in markets that already 

have non-stop operations to Sao Paulo. We strongly believe that maintaining the only 

Detroit-Brazil service is of far greater importance than allowing a second carrier to 

operate on either of American’s requested routes, to say nothing of the fact that 

American has more than ample frequencies to operate either its proposals by moving 

just one of the quadruple daily Miami flights or double daily JFK flights it operates today.
Reply of WCAA

Page 2

In Philadelphia’s Answer, it is stated that Philadelphia “is the largest urban region 

served by a single airport”, but later states that that 52% of their “primary catchment 

traffic” is lost to other airports which seems to contradict the claim that their region is 

served by only a single airport. Three other airports with scheduled service are 34 to 53 

driving miles from the city center according to Yahoo Maps; Atlantic City (ACY), Trenton 

(TTN), and Wilmington (ILG). More importantly, Newark (EWR) is only 84 miles from 

Philadelphia by road and is probably primarily responsible for the airport’s leakage since 

84 miles is not a particularly long ride to enjoy non-stop service to Brazil. Conversely, if 

Detroit were to lose service, the next best option is Chicago (ORD) and its previously 

mentioned existing non-stop service. The drive to Chicago is 298 miles by car and 

requires 4.5 hours of driving according to Yahoo. Philadelphia also states that it is the 

“most populous MSA still lacking non-stop service to Brazil”, but Detroit’s O&D traffic to 

Sao Paulo is three-times-larger at 25,518 vs. 8,206 according to Sabre MIDT data for 

the 12 months ended March 2013. That means that even allowing for Philadelphia’s 

proposed leakage to nearby airports like Newark, Detroit’s O&D is still 49% larger. The 

revenue data is even more compelling. Because of Detroit’s industrial and business ties 

to Sao Paulo, the increased mix of business passengers on the route results in O&D 

revenue of $42 million per year according to Sabre, while Philadelphia’s only totals $9.7 

million; 77% smaller than Detroit. This serves to make the route far more viable and 

belies the value that businesses place on this service. While initiating Philadelphia-Sao 

Paulo service may be a priority for the DOT, it is clearly a lower economic priority for the 

DOT than allowing continuance of Detroit-Sao Paulo service.

In closing, we firmly believe that maintaining service is not only important to 

Detroit, Wayne/Oakland Counties, and the State of Michigan, but is also of great 

importance to the U.S. economy in general. While tourism seems to be the justification 
Reply of WCAA

Page 3

behind many of the applications we’ve read, Detroit’s application is different. Our 

application is about the value of ties to a major market for American-made products, 

allowing our automotive engineers access to stay in touch with that market as it evolves, 

retaining Detroit’s position as a world leader in automotive R&D by connecting us to 

other primary locations in the world where that R&D is also performed, and collectively 

helping afford Americans the types of well-paying jobs that come from maintaining 

America’s position as a world automotive leader. We respectfully ask the DOT to 

support this goal by awarding the requested authority for Detroit-Sao Paulo service.

Respectfully submitted,

_________________________________

Joe Cambron

Director, Air Service Development, 

WAYNE COUNTY AIRPORT AUTHORITY
CERTIFICATE OF SERVICE

A copy of the foregoing Answer has been served this 14th day of May, 2013, upon 

the following persons via email:

Francis.Heil@aa.com 

Robert.Wirick@aa.com

howard.kass@usairways.com

benjamin.slocum@usairways.com

dan.weiss@united.com

thomas.bolling@united.com

paul.gretch@dot.gov

esta.rosenberg@dot.gov

brian.hedberg@dot.gov

brett.kruger@dot.gov

urskr@state.gov

brubinst@panynj.gov

louis.miller@atlanta-airport.com

steve.Luben@atlanta-airport.com

sascha.vanderbellen@delta.com

info@airlineinfo.com