OST-00-7194 / US-Vietnam Third-Country Codesharing / Answer of Northwest Airlines / April 14, 2000

CONSOLIDATED ANSWER OF NORTHWEST AIRLINES, INC.

Northwest Airlines, Inc. (Northwest"), pursuant to the Department's Notice entitled "U.S.-Vietnam Third-Country Code-Share Opportunity" served on April 5, 2000, hereby submits this Consolidated Answer to the applications of Delta Air Lines, Inc. ("Delta"), United Air Lines, Inc. ("United") and American Airlines, Inc. ("American").

On March 3, 2000, the Governments of the United States and Vietnam signed a Memorandum of Discussions ("MOD"). The MOD provides that up to three U.S. carriers may offer service between the United States and Vietnam, via intermediate points through codeshare arrangements with carriers of third countries. The MOD allows for a total allocation among the U.S. carriers of 21 weekly roundtrip frequencies. Delta and United have requested two of the available designations and all 21 of the available frequencies. Four U.S. carriers have applied for the third-country codeshare opportunity.

Northwest proposes to codeshare on six weekly flights operated by Malaysia Airlines ("MAS") between Malaysia and Vietnam connecting with Northwest and MAS service from the United States. Specifically, Northwest plans to codeshare on four MAS flights between Ho Chi

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Minh City and Kuala Lumpur and two MAS flights between Hanoi and Kuala Lumpur, connecting with Northwest flights between Kuala Lumpur and Detroit and MAS flights (on which Northwest will also codeshare) between Kuala Lumpur and Los Angeles.

United proposes to codeshare on 14 weekly flights operated by Thai Airways via Bangkok. Specifically, United proposes seven weekly roundtrips between Bangkok and Ho Chi Minh City, four weekly roundtrips between Bangkok and Hanoi and three weekly roundtrips between Bangkok and Da Nang. United operates two daily one-stops between the U.S. and Bangkok, one from Seattle via Tokyo, and the other from Los Angeles, via Hong Kong.

Delta proposes to codeshare on seven weekly flights operated by Air France. Specifically, Delta proposes four weekly roundtrips between Paris and Ho Chi Minh City, via Singapore, and three weekly roundtrip flights between Paris and Hanoi, via Bangkok. Delta and Air France provide service to Paris from various U.S. gateways.

American proposes to codeshare on three weekly flights operated by Swissair between Zurich and Ho Cho Minh City, via Singapore. American provides service to Zurich from Dallas/Fort Worth and Swissair provides service to Zurich from various U.S. Gateways.

Together, the Delta and United applications account for all 21 of the frequencies made available under the U.S.-Vietnam MOD. The Department should take full advantage of the bargained for bilateral rights and designate three U.S. carriers for third-country service to Vietnam, allocating the 21 frequencies among the three carriers. Utilizing all three designations will enable three U.S. carriers to offer the traveling and shipping public the broadest range of competitive service options between the U.S. and Vietnam.

The Department should award one of the three available designations to Northwest. At the very least, Northwest's proposal is superior to American's. Northwest proposes to serve

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twice as many points in Vietnam, with twice as many weekly frequencies as American, and will provide a more efficient and convenient service. Northwest will offer six roundtrip flights a week, whereas American proposes only three. Northwest proposes to serve both Hanoi and Ho Chi Minh City, whereas American proposes to serve only Ho Chi Minh City. With specific reference to Ho Chi Minh City, Northwest will provide one more weekly roundtrip flight than American (four weekly flights as opposed to three).

In sum, the Department should utilize all three U.S. carrier designations it successfully bargained for under the U.S.-Vietnam MOD, in order to permit the maximum number of U.S. carriers to enter and gain presence in the developmental U.S.-Vietnam market and provide passengers and shippers with the widest variety of competitive service options. Northwest should be one of the three U.S. carriers selected.

WHEREFORE, the Department should award Northwest one of the three third-country codeshare opportunities and an allocation of six of the 21 available frequencies.

Respectfully submitted,

Megan Rae Rosia

Managing Director, Government Affairs &

Associate General Counsel

NORTHWEST AIRLINES, INC.

901 15th Street, N.W.

Suite 310

Washington, D.C. 20005

(202) 842-3193