Delta Already Has Access to 79 Percent of U.S.-Rome Traffic with Its JFK Service

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1 Already Has Access to 79 Percent of U.S.-Rome Traffic with Its Service Philadelphia R-103 (Rebuttal to -103) Seattle Portland Salt Lake City Denver Chicago Detroit Cleveland Columbus Dayton Pittsburgh Cincinnati Boston Hartford New York - Philadelphia Baltimore Washington-DCA Rome San Francisco Los Angeles Phoenix Dallas/Fort Worth Atlanta Houston Tampa Orlando West Palm Beach Ft. Lauderdale Miami deserves its first-ever Milan service before receives a second Milan service

2 While Travelers from Atlanta and Smaller Communities Behind Atlanta Already Have Access to Both on via s Gateway, Passengers Have Access to Milan via Any Point in the System Philadelphia R-104 (Rebuttal to -103,111) s Passengers Have Access to Both Rome and Milan Passengers Have Access to Milan New York Milan Rome NO Milan Lexington Pittsburgh Philadelphia Memphis Nashville Tri-Cities Knoxville Chattanooga Greensboro Asheville Raleigh/Durham Charlotte Greenville/Spartanburg Columbia Birmingham Montgomery Augusta Charleston Jackson Columbus Savannah Mobile Fort Walton Beach New Orleans Tallahassee Pensacola Panama City Gainesville Daytona Beach Charlotte Sarasota Melbourne Fort Myers deserves its first-ever Milan service before receives a second Milan service

3 Both Chicago and Atlanta Enjoy More On-Line One-Stop Connecting Service to Rome Than Philadelphia -- Atlanta 50 Percent More Such Service and Chicago More than Double Such Service Philadelphia R-106 (Rebuttal to -108,109) Number of Services Carrier KL SN AF LH UA BA IB LH AZ SR CO TW US Gateway Amsterdam Brussels Paris Frankfurt Frankfurt London Madrid Munich Milan Zurich Newark PHL Carrier KL AF LH SR CO US Gateway Amsterdam Brussels Paris Paris Frankfurt Zurich Newark Philadelphia Carrier Gateway Amsterdam London Philadelphia Newark Chicago-Rome Atlanta-Rome Philadelphia-Rome NW BA US CO TW Total Chicago-Rome Services = 14 Total Atlanta-Rome Services = 9 Total Philadelphia-Rome Services = 6 deserves its first-ever Milan service before receives a second Milan service Source: OAG te: Philadelphia-Rome nonstop service included

4 Both Chicago and Atlanta Enjoy More On-Line One-Stop Connecting Service to Milan Than Philadelphia -- Atlanta 50 Percent More Such Service and Chicago Nearly Double Such Service Philadelphia R-107 (Rebuttal to -108,109) Number of Services Carrier KL AF UA BA LH AZ SR CO TW AA Gateway Amsterdam Paris Washington London Munich Milan Zurich Newark Chicago Carrier KL AF LH SR CO UA Gateway Amsterdam Brussels Paris Paris Frankfurt Zurich Newark Washington Carrier NW BA UA CO TW Gateway Amsterdam London Washington Newark Chicago-Milan Atlanta-Milan Philadelphia-Milan Total Chicago-Milan Services = 11 Total Atlanta-Milan Services = 9 Total Philadelphia-Milan Services = 6 deserves its first-ever Milan service before receives a second Milan service Source: OAG te: Chicago-Milan nonstop service included

5 While American and Each Can Offer Only a Single Daily Flight to Italy, American Can Hardly Be Considered a Have t When It Comes to Europe Service Philadelphia R-108 (Rebuttal to ORD-104) Transatlantic Gateways Transatlantic Routes Transatlantic Destinations Stockholm American Glasgow Manchester Birmingham Amsterdam London-Gatwick London-Heathrow Brussels Frankfurt Paris Zurich Milan Chicago New York- Boston Newark-EWR Madrid Raleigh/Durham Los Angeles Dallas/Ft.Worth American s Transatlantic Network Miami Chicago (ORD) - Europe All Other AA European Gateways deserves its first-ever Milan service before receives a second Milan service

6 s Proposed Change-of-Gauge Service Offers Improvement on What is Available Today Between Orlando and Rome Philadelphia R-109 (Rebuttal to -101) s Proposed Change-of-Gauge Service Between Rome and Orlando s Current Connecting Service Between Rome from Orlando via Current Connecting Service Between Rome from Orlando via Philadelphia TWA s Current Connecting Service Between Rome and Orlando via Continental s Current Connecting Service Between Rome and Orlando via Newark Eastbound Depart Orlando Depart Orlando Depart Orlando Depart Orlando Depart Orlando Arrive Atlanta Passengers deplane with all carry-on baggage and walk to another airplane at a different gate Arrive Passengers deplane with all carry-on baggage and walk to another airplane at a different gate Arrive Philadelphia Passengers deplane with all carry-on baggage and walk to another airplane at a different gate Arrive Passengers deplane with all carry-on baggage and walk to another airplane at a different gate Arrive Newark Passengers deplane with all carry-on baggage and walk to another airplane at a different gate Baggage Transfers Baggage Transfers Baggage Transfers Baggage Transfers Baggage Transfers Depart Atlanta Depart Depart Philadelphia Depart Depart Newark Arrive Rome Arrive Rome Arrive Rome Arrive Rome Arrive Rome Westbound Depart Rome Depart Orlando Depart Rome Depart Rome Depart Rome Arrive Atlanta Arrive Arrive Philadelphia Arrive Arrive Newark Passengers Deplane, Clear Customs Passengers Deplane, Clear Customs Passengers Deplane, Clear Customs Passengers Deplane, Clear Customs Passengers Deplane, Clear Customs Recheck Baggage Recheck Baggage Recheck Baggage Recheck Baggage Recheck Baggage Depart Atlanta Depart Depart Philadelphia Depart Depart Newark Arrive Orlando Arrive Orlando Arrive Orlando Arrive Orlando Arrive Orlando deserves its first-ever Milan service before receives a second Milan service

7 The Majority of U.S.-Italy Passengers are Located in the rtheast and Midwest... t the Southeast Philadelphia R-111 (Rebuttal to -110) Share of U.S.-Italy Traffic Greater than 31% 13-14% 4-8% 2-3% % <1% N/A deserves its first-ever Milan service before receives a second Milan service Source: O&D Survey YE 1Q 1998

8 The Majority of U.S. Regions and Large U.S.-Rome O&D Markets (Including Most of Florida) are Located Outside Atlanta s Radius of Convenient Connecting Service Philadelphia R-112 (Rebuttal to -112,113) Mountain Central Great Lakes/ Ohio Valley rtheast West Philadelphia Southwest Southeast Atlanta Outside 15% Band Within 10-15% Band Within 5-1 Band Florida deserves its first-ever Milan service before receives a second Milan service

9 After Appropriate Foreign Flag Adjustments, s Estimate of Its Local Atlanta-Rome Traffic is t Credible Philadelphia R-125 (Rebuttal to -304) Population (000) Existing U.S.-Rome Gateways YE 6/98 O&D Traffic Reported Traffic per 1000 Population Foreign Flag Adjustment Adjusted Adjusted Traffic Adjusted Gravity Ratio NYC MIA/FLL PHL 19, , , ,070 19,340 33, NYC MIA/FLL PHL 65.5% 62.1% ,985 31,143 39, Rome Gateways/Proposed Gateways With Single U.S. Flag Services CHI ATL PHL 1/ 2/ 2/ 8, , , ,520 15,640 33, CHI ATL PHL ,036 26,067 39, , , , s Adjusted Local Atlanta-Rome Traffic ATL 3/ 3, , ATL , s Forecast of Its Local Atlanta-Rome Traffic is More Than Twice as Large as Chicago or Philadelphia, When Indexed to Population 1/ 2/ 3/ American s adjusted Chicago-Rome traffic per AA-311. Atlanta and Philadelphia traffic to Rome adjusted for foreign flag adjustments per GKMG estimate of foreign flag participation in each respective local market. market estimate of Atlanta-Rome traffic per deserves its first-ever Milan service before receives a second Milan service

10 Admittedly, Has an Impressive Record of Stimulating New International Markets from Atlanta Philadelphia R-126 Page 1 of 2 (Rebuttal to -304) Market Calendar Year O&D PAX Calendar Year O&D PAX % Change Estimated rmal Growth Rate Indicated Stimulation Atlanta-Amsterdam , , % 1 13 Atlanta-Madrid , , % 1 102% Atlanta-Manchester , , % Atlanta-Munich , , % 1 176% Atlanta- Shannon , % 1 728% Atlanta-Vienna , , % 1 265% Average 3,267 11, % 1 195% BUT... Source: Exhibit -306 deserves its first-ever Milan service before receives a second Milan service

11 Its Atlanta-Rome Stimulation Rate is Totally Unrealistic Philadelphia R-126 Page 2 of 2 Atlanta-Rome (YE 6/98) (per IR2arom) Average size of Atlanta markets used as basis for stimulation (per -306) Average size of Atlanta markets as a percent of Rome Average small market stimulation rate realized in Atlanta-Europe services (per -306) Reduction in the stimulation rate to reflect size of local Atlanta-Rome market as compared to s experience in smaller markets Restated Atlanta-Rome stimulation rate which realistically sizes the local market 15,640 3, % 195% 79.1% 40.7% The Proper Stimulation Rate for the Atlanta-Rome Market is not 175%, as Suggests, but 41%. When a Stimulation Rate of 41% is Used, the Size of the Atlanta-Rome Market is in Line with Other U.S.-Rome Markets. deserves its first-ever Milan service before receives a second Milan service

12 s Adjustment to the Atlanta-Rome Market is t Credible Philadelphia R-127 (Rebuttal to -302) 20 Passengers per Thousand of Population New York Miami Atlanta Philadelphia Chicago s Reported Adjusted Atlanta-Rome Adjustment deserves its first-ever Milan service before receives a second Milan service

13 When Its Traffic Forecast is Properly Adjusted, Will Carry Almost 70,000 Fewer Passengers Than It Claims... and This Significant Reduction Assumes Diversion from its Multiple -Rome Services Philadelphia R-128 Page 1 of 3 (Rebuttal to -302) City YE June 98 Rome Passenger Traffic Growth Rate Rome Passenger Traffic Market Stimulation Rome Passenger Traffic After Stimulation s Share Passengers Between Rome and: Atlanta 15,640 18,508 41% 26,048 75% 19,536 Between Rome and: Albuquerque Asheville Augusta Albany Birmingham Bristol Brunswick Charleston, SC Charleston, WV Charlotte Chattanooga Cincinnati Columbia Columbus, GA Columbus, MS Dallas-Ft. Worth Daytona Beach Dothan Evansville Fayetteville, NC Florence, SC Fort Lauderdale 2, , , , , , ,180 2, , , , ,402 1, , ,763 2, , , , ,402 1, , ,763 31% 74% 73% 78% 58% 69% 9 44% % 47% 5 81% 78% 25% 56% 87% 47% 6 83% 38% , , , , ,430 deserves its first-ever Milan service before receives a second Milan service

14 When Its Traffic Forecast is Properly Adjusted, Will Carry Almost 70,000 Fewer Passengers Than It Claims... and This Significant Reduction Assumes Diversion from its Multiple -Rome Services Philadelphia R-128 Page 2 of 3 (Rebuttal to -302) City Between Rome and: Fort Myers Fort Walton Greensboro Greenville/Spartanburg Gulfport Houston Huntsville Jackson Jacksonville, NC Kansas City Knoxville Lexington Los Angeles Louisville Melbourne Memphis Meridian Miami Mobile Montgomery Myrtle Beach Nashville New Orleans Orlando Panama City YE June 98 Rome Passenger Traffic , , ,630 1, ,724 1, , , ,980 8,560 15, Growth Rate Rome Passenger Traffic 1, , , ,479 1, ,379 2, , , ,527 10,130 17, Market Stimulation Rome Passenger Traffic After Stimulation 1, , , ,479 1, ,379 2, , , ,527 10,130 17, s Share 43% 87% 28% 44% 73% 3 73% 85% 77% 3 67% 6 6% 43% 84% 41% 76% 7% 87% 82% 65% 45% 45% 4 8 Passengers , , , , ,587 4,558 7, deserves its first-ever Milan service before receives a second Milan service

15 When Its Traffic Forecast is Properly Adjusted, Will Carry Almost 70,000 Fewer Passengers Than It Claims... and This Significant Reduction Assumes Diversion from its Multiple -Rome Services Philadelphia R-128 Page 3 of 3 (Rebuttal to -302) City Between Rome and: Pensacola Phoenix Roanoke Salt Lake City San Francisco Savannah Shreveport St. Louis Tallahassee Tampa Valdosta West Palm Beach Wilmington YE June 98 Rome Passenger Traffic 1,080 7, ,030 29, , , , Growth Rate Rome Passenger Traffic 1,278 8, ,952 35,312 1, , , , Market Stimulation Rome Passenger Traffic After Stimulation 1,278 8, ,952 35,312 1, , , , s Share % 34% 6% 47% 69% 12% 68% 49% 81% 31% 45% Passengers 767 1, ,024 2, , , Interline Forecast per -302 Overestimate 356, , ,365 Growth rate reflects U.S. growth rate per US-307. Markets eliminated from behind Atlanta which fall outside the 15% circuity band or multiple stop itineraries per -201, 202. Traffic stimulation to markets behind Atlanta eliminated. Market stimulation to Atlanta market reduced to 41% to account for relatively high base traffic level as indicated in ADJUSTED TOTAL 72,419 3, ,335 (69,431) 95,634 deserves its first-ever Milan service before receives a second Milan service

16 The Georgia and Atlanta Parties Demographic Case Works Only Because Atlanta s Southeast Region Includes Twelve States While Philadelphia s Mideast Region Includes Only Six States Philadelphia R-129 (Rebuttal to ATL-802, 804, 805, 806, 808, and 809) Southeast (Atlanta) Plains (Chicago) Mideast (Philadelphia) New England Far West Great Lakes Rocky Mountain Southwest deserves its first-ever Milan service before receives a second Milan service

17 Chicago Tries to Claim That It Has an Italian-American Population Almost as Large as Philadelphia s by Inappropriately Manipulating the Data... But, Any Way You (Fairly) Slice It, Philadelphia Enjoys a Significantly Larger Italian-American Population Than Chicago Philadelphia R-138 (Rebuttal to ORD-114) Italian-American Population Comparison Based on CMSAs (Philadelphia s Method per PHL-203): Philadelphia CMSA Includes: Philadelphia/PA/NJ Suburbs PMSA Atlantic City, NJ PMSA Vineland-Millville-Bridgeland, NJ PMSA Wilmington, DE PMSA Chicago CMSA Includes: Chicago and Suburbs PMSA Gary PMSA Kankakee PMSA Kenosha PMSA Philadelphia CMSA Total Italian-American Population: 844,262 Chicago CMSA Total Italian-American Population: 626,541 Philadelphia PMSA Includes: Philadelphia; Pennsylvania, and New Jersey Suburbs Philadelphia CMSA Advantage: 217,721 Italian-American Population Comparison Based on PMSAs: Chicago CMSA Includes: Chicago and Its Suburbs Philadelphia PMSA Total Italian-American Population: 701,156 Chicago PMSA Total Italian-American Population: 492,158 Only Philadelphia portion of Philadelphia PMSA (excludes New Jersey suburbs) Philadelphia PMSA Advantage: 208,998 The Chicago Approach (ORD-114): Entire Chicago PMSA Philadelphia PMSA Partial Italian-American Population: 497,721 Chicago PMSA Total Italian-American Population: 492,158 vs vs vs Any Fair, and Honest, Comparison Results in Only One Possible Conclusion: Philadelphia Enjoys a Significantly Larger (200,000+++) Italian-American Population Than Chicago deserves its first-ever Milan service before receives a second Milan service

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