OST-98-3419 / 1998 US-Japan Combination / Answer of Hawaii to Delta / March 26, 1998

 

1998 U.S. - JAPAN COMBINATION SERVICE PROCEEDING / Docket OST 98-3419

 

ANSWER OF THE STATE OF HAWAII

TO AMENDMENT NO. 3 TO THE

APPLICATION OF DELTA AIR LINES, INC.

 

On March 25, 1998, Delta Air Lines, Inc. ("Delta") filed an Amendment (No. 3) to its Application in the 1998 US. - Japan Combination Service Proceeding, seeking certificate authority and the allocation of six weekly frequencies to operate nonstop service between Honolulu and Tokyo, beginning December 15, 1998. The State of Hawaii (the "State" or "Hawaii") strongly supports Delta's Application for the same reasons it supports the Application of Continental Micronesia, Inc. ("Continental Micronesia) /1 See Answer of the State of Hawaii to Supplement Number Two to the Application of Continental Micronesia, filed March 26, 1998.

Delta's Application for Honolulu-Tokyo authority here reflects the immediate need for new service in the market in light of recent service reductions by Northwest Airlines and United Airlines, is consistent with the Department's determination in Order 98-3-15 to promote the

1/ Continental Micronesia requested the immediate allocation of five round trip frequencies between the U.S. and Japan in order to allow Continental Micronesia to begin Honolulu-Tokyo service on December 15, 1998.

 

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rapid utilization of new U.S.-Japan service opportunities, and fall within the frequency limitations available for MOU carriers to provide new services.

As the State noted in its Answer to the Continental Micronesia Application, the Department has determined that "there is a significant need for rapid, maximum implementation of the new and valuable U.S.-Japan route rights" that became available in the January 30, 1998 U.S.-Japan Memorandum of Consultations (Order 98-3-15 at 7). That decision, coupled with the unquestioned importance of the Hawaii-Japan market; the significant benefits that would immediately accrue to the traveling public; and the availability of frequencies under the MOC to meet all l998 route requests virtually mandates the grant of Delta's request to commence Honolulu-Tokyo service on December 15, 1998.

Delta's Application offers the additional benefit of adding a new competitor to the Honolulu-Tokyo market. This additional service by a new competitor would produce tremendous public benefits.

Also, as the State indicated in its Answer to the Continental Micronesia Application, there is no downside to grant of Delta's Application because, consistent with its standard practice, the Department proposed that frequencies allocated in this proceeding will be subject to a 90-day dormancy condition. Under the dormancy condition, which we assume also would apply to Delta Amended Application, if frequencies allocated are not used they expire automatically and revert back to the Department for reallocation.

 

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For these reasons, the State of Hawaii urges the Department to grant the Amended Application of Delta Air Lines to enable the carrier to commence Honolulu-Tokyo service on December 15, 1998.

 

Respectfully submitted,

Stephen H. Lachter

LAW OFFICES OF STEPHEN H. LACHTER

Counsel for THE STATE OF HAWAII

March 26, 1998