BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C. Motions and Application of AMERICAN AIRLINES, INC. HAWAIIAN AIRLINES, INC. Docket DOT-OST-2010-0018 in the matter of 2010 U.S.-Haneda Combination Services Allocation Proceeding CONSOLIDATED ANSWER OF THE DELTA MASTER EXECUTIVE COUNCIL OF THE AIR LINE PILOTS ASSOCIATION, INTERNATIONAL The Delta Master Executive Council, the Delta chapter of the Air Line Pilots Association, International (the Delta MEC hereby answers in strong support of Delta s response to the DOT s information request set forth in Order 2014-12-9 to maintain Seattle-Haneda service. As stated in Delta s application, Delta has committed aircraft resources, Seattle based flight crews and ground support employees to insure the success of the Seattle-Haneda route. Stripping Delta of the two slots used for Seattle-Haneda -- the only gateway in the Pacific Northwest -- and awarding them to another carrier for service in the well-served regions of California or Hawaii would be contrary to the public interest. Moreover, it would undermine the ability of Delta and its employees to offer a viable competitive alternative to American/JAL and United/ANA which operate massive hubs at Haneda, where Japanese carriers control 95% of the Haneda slots. The Delta MEC represents the interests of over 12,000 pilots working in concert with the 80,000 dedicated employees of Delta. In 2012, the Delta MEC strongly supported Delta s efforts to establish Seattle-Haneda service. Seattle is an important and growing international hub gateway for Delta, providing quality U.S. jobs for Delta pilots, ground staff, and in-flight

personnel. Proof positive is the growing Delta and Delta-Connection operated network that Delta is building to support these international flights. We note that Delta has persistently and determinedly added new flights (and new jobs at Seattle every year since 2012, and continues to plan for growth in the future. Delta operated hub services increased to 51 daily departures in August 2014, will grow to 85 in 2015, and will continue to grow in 2016 and beyond. The Department correctly found that the public interest was best served by making an award to Delta for Seattle-Haneda service. 1 The same public interest considerations relied upon by the Department to make the award for Seattle service over American s LAX proposal and Hawaiian s Kona proposal in 2012 supported the MEC s call for the grant of Delta s application at that time and now provide the grounds for dismissal of the current American and Hawaiian requests. It is indeed ironic that American would criticize Delta for a temporary seasonal reduction at Haneda when American has done the same at Haneda and in other international markets and abandoned its JFK-Haneda flight altogether in 2013. In fact, American ceded the entire JFK-Tokyo market (including Narita to its Japanese partner, compromising U.S. jobs and flying opportunities. While Hawaiian has been able to operate a more regular pattern of service than other carriers, there is less benefit to U.S. travelers and shippers operating a flight that caters to 95 percent Japanese leisure passengers. Delta and its employees have worked hard to pioneer service from the mainland United States to Japan under difficult conditions at Haneda (which are improving, for the reasons noted in the January 5, 2015 RESPONSE OF DELTA AIR LINES, INC. TO EVIDENCE REQUEST. We note that seasonal flight schedule reductions (especially in the off-peak winter season are 1 Show Cause Order 2012-11-12; Final Order 2013-2-4.

common in many international markets. It should be noted that American has taken extensive scheduling liberties with its own limited entry frequencies in Brazil, allowing them to be dormant for periods of 90 days or more over the last decade. Given the challenges that all carriers providing mainland U.S.-Haneda service have experienced, including American Airlines on its abandoned JFK to Haneda route, Delta s temporary reduction in the 2014/2015 winter season is appropriate and consistent with this long standing airline practice. If service were taken away from Seattle, it would be the largest U.S.-Tokyo market without nonstop service. Moreover, it would be patently unfair to award three U.S.-Haneda opportunities to Los Angeles or four U.S.-Haneda opportunities to Hawaii, and leave Seattle and the Pacific Northwest with none. The flight has shown marked improvement and is vitally important to business, international trade, and employment in the Northwest region and specifically Seattle. An award of Haneda slots to American would also compromise effective 3-way alliance competition. Delta has no partner in Japan whereas American and JAL engage in reciprocal antitrust immunized codesharing, bolstered by the benefits oneworld enjoys at Haneda by virtue of JAL s huge slot holdings and large hub operation at this slot constrained airport. It is also not in the interest of the traveling public to put a cloud over Delta s Seattle-Haneda slots while Delta is in the process of building its Seattle hub to provide, among other benefits, maximum connecting opportunities and additional traffic.

For all of the foregoing reasons, we urge that Delta be allowed to continue Seattle- Haneda service and that the competing application of American and Hawaiian be denied. Respectfully submitted, Michael G. Donatelli Chairman Delta Master Executive Council Air Line Pilots Association, International 100 Hartsfield Centre Parkway, Suite 800 Atlanta, Georgia 30354 Mike.Donatelli@alpa.org

CERTIFICATE OF SERVICE A copy of the foregoing document has been served this 12 th day of January, 2015, upon the following persons via email: howard.kass@aa.com abigail.donovan@aa.com robert.wirick@aa.com charles.hunnicut@thompsonhine.com patricia.snyder@thompsonhine.com jhill@cooley.com perkmann@cooley.com bberlin@cooley.com dan.weiss@united.com thomas.bolling@united.com steve.morrissey@united.com gmurphy@crowell.com Mike.Donatelli@alpa.org dino.atsalis@alpa.org Doug.Ralph@alpa.org Ishiwata.K@portseattle.org Safora.I@portseattle.org sascha.vanderbellen@delta.com chris.walker@delta.com paul.gretch@dot.gov brian.hedberg@dot.gov brett.kruger@dot.gov todd.homan@dot.gov peter.irvine@dot.gov englets@state.gov cristinasa@state.gov eugene_alford@ita.doc.gov info@airlineinfo.com