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.

Communications with respect to this document should be addressed to:
Joe Cambron Director, Air Service Development Thomas Naughton Chief Ex ecutive Officer Emily Neuberger Senior Vice President
WAYNE COUNTY AIRPORT AUTHORITY L.C. Smith Terminal Detroit , M ichigan 48242 ( 734 ) 9 42

- 3550

May 14 , 201 3BEFORE 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 do es not even attempt to argue that Detroit is not deserving of Sao Paulo service, nor do es it make any case against Detr oit’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 ca se 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 main taining 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 p roposal s 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 ri de 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 acc ording 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 Ma rch 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 valu e 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 belie ve 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 justificationReply 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 a s 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 a utomotive 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 AUTHORITYCERTIFICATE OF SERVICE A copy of the foregoing A nswer has been served this 14th day of May , 201 3 , 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 s teve.Luben@atlanta

- airport.com sascha.vanderbellen@delta.com info@airlineinfo.com