Docket OST-95-765 / Docket OST-97-2693 / US-Hong Kong/Northwest / July 15, 1997

Application of

NORTHWEST AIRLINES, INC.

for selection of a new gateway and designation of Northwest pursuant to the U.S.-Hong Kong bilateral air services agreement of 1995 (Minneapolis/St. Paul-Hong Kong)

The Wayne County parties strongly object to the opposing parties' suggestion that the gateway authority needed for the new service be taken from Detroit. Detroit strongly desires Hong Kong service, which would significantly strengthen its commercial and other ties to southern China and Southeast Asia, and Northwest intends to provide the service as soon as that is technically feasible. Removing Detroit's gateway designation would make that impossible.

The opposing parties suggest that Seattle's multiple designation status be preserved in case a second designation is needed at Seattle or a first designation at some other new gateway at some indefinite time in the future. None offers any concrete service proposal. In contrast, Northwest has, and has had, firm plans to offer nonstop Detroit-Hong Kong service as soon as technically feasible. It will be time enough to reconsider the Detroit designation if and when another airline offers a comparable proposal for Hong Kong service, there is no gateway authority readily available, and Northwest has not initiated Detroit Metro service.

The possibility that two or more designations will be needed at Seattle, as United suggests, is exceedingly remote. Major U.S. airlines have attempted non-stop Seattle-Hong Kong service on three separate occasions. None of the attempts was successful. That even one airline will try again in the next few years is unlikely. That two will want to operate simultaneously boggles the imagination.

It is also worth noting that United is in error in contending that "Seattle, unlike Detroit, is well situated as a nonstop gateway to Hong Kong." In fact, for most of the U.S. the opposite is true. A Boston passenger, for example, can save over 500 miles by traveling to Hong Kong via Detroit instead of Seattle. United itself has chosen to serve Hong Kong from Chicago, relatively near Detroit, rather than from Seattle.

From the perspective of other possible future proposals for new U.S. gateways to Hong Kong, if Northwest for any reason has not yet commenced Detroit-Hong Kong service, it is utterly immaterial whether the unused designation to be transferred is at Detroit or at Seattle.

The opposing parties also imply that Northwest will somehow retain rights to Seattle's remaining designation. To the best of our knowledge, there is no basis for that implication. Northwest has given up at Seattle as far as Hong Kong is concerned, and intends to institute service from its major northern hubs, Detroit Metro and Minneapolis/St. Paul (MSP). Even if it were someday to change its mind and wish to re-institute Seattle-Hong Kong service, the Department would have to agree that Northwest service was the best possible use of the designation.

In sum, the only issue here is whether to obtain authority for MSP-Hong Kong service by withdrawing a designation for which there is a concrete proposal (Detroit), or one for which there is not only no concrete proposal but no likelihood of any in the foreseeable future (the second designation at Seattle). Clearly it makes much more sense to withdraw the Seattle authority.

WHEREFORE, the Wayne County parties respectfully urge that the Department dismiss the suggestion that existing Detroit-Hong Kong authority be withdrawn and approve the Northwest application in its entirety.

Respectfully submitted,

Samuel C. Keiter

Kurth & Company, Inc

Robert C. Braun

Director of Airports

Detroit Metropolitan Wayne County Airport .

July 15, 1997