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BEFORE THE
U.S. DEPARTMENT OF TRANSPORTATION
WASHINGTON, D.C.
_____________________________________________
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)
2022 U.S.-SOUTH AFRICA COMBINATION )
FREQUENCY ALLOCATION PROCEEDING ) Docket DOT-OST-2022-0050
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)
_____________________________________________
ANSWER OF
THE METROPOLITAN WASHINGTON AIRPORTS AUTHORITY
The Metropolitan Washington Airports Authority (“Airports Authority”) respectfully submits this
answer to address certain assertions about Washington Dulles International Airport (“Dulles
Airport”) made in the Answer of Delta Air Lines, Inc. (“Delta’s Answer”) submitted by Delta Air
Lines, Inc. (“Delta”) in the 2022 U.S.-South Africa Combination Frequency Allocation
Proceeding, Order 2022-5-1, DOT-OST-2022-0050.
I. Dulles Airport offers the traveling public same concourse connectivity. Delta suggests
that connecting passenger experience at Dulles Airport is inefficient and requires that passengers
use a “mixture of automated trains and decades-old people movers”. Delta Answer, p. 16. This
statement, however, is not accurate. As depicted on MWAA Exhibit I-A, included herewith,
United Airlines’ international passengers connecting via Dulles Airport have access to a separate
mid-field customs facility and, upon Customs clearance, have access to their connecting gates in
the same concourse or via a single stop on the airport’s automated train system. In contrast, Delta’s
international passengers at Atlanta-Hartsfield International Airport (“ATL”) do not have access to
a dedicated customs facility, nor are the majority of their connecting gates in the same concourse
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at that facility. Instead, most of ATL’s connecting gates require multiple stops on ATL’s train
system, followed by long walks down concourses. See MWAA Exhibit I-B.
II. Dulles Airport is ideally situated to serve the largest demand market without non-
stop service. Delta asserts that “Dulles [Airport] is actually the worst situated of all the
Washington, D.C. airports to serve the local South African population and general demand for
travel to South Africa.” Delta’s Answer, p. 13. In fact, however, the Washington, D.C., Region
has the highest level of demand for travel to Cape Town (“CPT”) outside of areas that already have
non-stop service. See MWAA Exhibit II. While Delta notes that Dulles Airport is located
(partially) in Loudoun County, Virginia, Delta’s submission does not acknowledge that Dulles is
located in a key population center of the Metropolitan Washington region, and is in convenient
proximity to Washington, D.C. and Prince George’s County, Maryland – the two locations
identified by Delta as having the highest concentration of South African-Americans in the region.
Delta’s Answer, p. 13.
Furthermore, by suggesting, without substantiation, that passengers would prefer a connecting
flight from Ronald Reagan Washington National Airport (“DCA”) to CPT through ATL rather
than a direct flight to CPT from Dulles Airport because of DCA’s close proximity to Washington,
D.C. and Prince George’s County, Delta ignores the added travel time and inconvenience of
unnecessarily connecting flights in ATL. It is well known that airline passengers prefer nonstop
flights over connecting itineraries when available, which is why commonly accepted airline
forecasting methodologies account for it.
https://dspace.mit.edu/bitstream/handle/1721.1/121459/ICAT-2019-3_Florian.pdf (finding that
passengers are willing to pay more for nonstop flights).
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Not only are passengers more likely to travel on a nonstop flight, but they are also willing to pay
more for the convenience. Id. Delta’s comments seem to disregard this basic factor in air-travel
demand.
III. Dulles Airport will offer greater connectivity for the Metropolitan Washington region
through the Silver Line Metrorail extension. Construction of the Silver Line Metrorail public
transit extension has reached substantial completion and is on track to open in 2022. MWAA
Exhibit III. With the proposed CPT services slated to start in late November 2022, we expect that
the Silver Line will be in operation when the selected services start. While the Airports Authority
agrees with Delta that DCA customers have easy access to public transportation, this will soon
also be true for Dulles Airport customers. The Silver Line’s Dulles Airport stop is located at the
front of airport’s main terminal and provides customers with direct access to the airport, compared
to Atlanta’s MARTA service, which requires taking a bus from the transit stop to ATL’s terminal.
https://www.itsmarta.com/getting-to-airport.aspx
IV. Dulles Airport is an ideal complement to United’s existing service and the greatest
benefit to the traveling public. United’s proposed service would benefit from the Metropolitan
Washington region’s existing strong demand and offer connecting passengers greater options for
travel to and from CPT. Delta claims that United’s Dulles Airport hub is largely duplicative of its
hub at Newark Liberty International Airport. Delta’s Answer, p. 5. The two United hubs, however,
serve separate and growing major metropolitan areas and have a drive time between them ranging
from four to five hours on some of most congested and delay-prone interstate highways in the
country.
Furthermore, according to data from the U.S. Census Bureau, 12.5% of the entire U.S. population
lives in or between the Washington, D.C., and the New York City metropolitan statistical areas.
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In addition, 15.7% of the U.S. population lives within a 212-mile radius of Washington Dulles
International Airport. In contrast, only 4.7% of the U.S. population lives within a 212-mile radius
of Hartsfield-Jackson Atlanta International Airport. The larger population density surrounding
Dulles Airport makes it a more viable option for service to CPT than ATL. Furthermore, Delta
already serves CPT from ATL with a round-robin routing via Johannesburg. If Delta were to
operate three more weekly ATL-CPT flights, those flights would be highly duplicative of existing
service, because both services operate from the same airport (as opposed to the service offered to
CPT from EWR and Dulles Airport --- 212 miles apart).
Delta claims that it would offer D.C. passengers a new competitive option for travel to CPT.
However, with Delta’s announced plans to serve CPT via an ATL-JNB-CPT-ATL routing, that
will soon exist. See MWAA Exhibit IV. Granting Delta three additional frequencies would only
strengthen an existing route and would offer little in the way of new competition. The greatest
benefit to the traveling public, therefore, would be service to a new gateway airport such as Dulles
Airport.
V. Washington Dulles International Airport offers a level of operational flexibility
beyond other U.S. gateway airports. Delta states that “the connecting passenger experience at
Dulles [Airport] is suboptimal, with its mixture of automated trains and decades-old people
movers, compared to the simple efficiency of Delta’s hub in Atlanta.” Delta’s Answer, p. 15. With
respect to Delta’s first statement about the passenger experience, the Airports Authority disagrees
that the connecting passenger experience is suboptimal. In fact, Dulles Airport tops ATL in
customer satisfaction. J.D. Power’s 2021 North America Airport Satisfaction Study awards Dulles
Airport 802 customer satisfaction points out of a possible 1,000. This compares with ATL’s 798
customer satisfaction points. https://www.businessinsider.com/jd-power-reveals-top-mega-airport-in-
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terms-customer-satisfaction-2021-9; https://www.businessinsider.com/best-large-airport-us-new-orleans-
2021-11.
As for Dulles Airport’s “decades-old people movers”, Dulles Airport operates a unique fleet of
passenger conveyance vehicles known as mobile lounges. The mobile lounges allow Dulles
Airport to be more flexible than other major airports and airlines that operate at Dulles, including
Delta and its partner airlines, have benefited from this flexibility, especially during diversions,
weather emergencies and other unplanned events.
VI. Conclusion. The Airports Authority appreciates the opportunity to address statements about
Dulles Airport contained in Delta’s Answer. Additionally, for the reasons noted by United Airlines
in their filings, and contained herein, to Delta’s Answer, the Airports Authority supports United’s
application for an allocation of available U.S.-South Africa frequencies. If approved, these
additional frequencies would leverage the strength of existing demand and strong connections to
maximize the benefits to the traveling public.
Respectfully submitted,
/s/ Johnna S. Spera
Johnna S. Spera
Senior Vice President & General Counsel
METROPOLITAN WASHINGTON
AIRPORTS AUTHORITY
1 Aviation Cir.
Washington, D.C. 20001
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CERTIFICATE OF SERVICE
I hereby certify that on June 1, 2022, the foregoing document was served on the following persons
via the email addresses listed below in accordance with the Department’s Rules of Practice:
Department of Commerce: eugene.alford@trade.gov
Respectfully submitted,
/s/ Johnna S. Spera
Johnna S. Spera
Senior Vice President & General Counsel
METROPOLITAN WASHINGTON
AIRPORTS AUTHORITY
1 Aviation Cir.
Washington, D.C. 20001
MWAA Exhibit I-A.
Washington Dulles International Airport offers the traveling public same concourse connectivity
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United Airlines/
United Express
Gates
Midfield
Customs
Facility
MWAA Exhibit I-B.
Hartsfield–Jackson Atlanta International Airport Terminal Layout for Comparison
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Delta Air Lines /
Delta Connection Gates
Customs
Facility
54,025
18,742
16,558
11,605
11,510
11,172
10,192
8,224
6,498
6,107
4,621
4,008
3,727
3,627
3,195
2,072
2,002
1,828
1,725
1,698
0
10,000
20,000
30,000
40,000
50,000
60,000
CPT O&D Passengers
Washington, D.C. was the Largest Pre-COVID
U.S. – Cape Town O&D Passenger Market
without Nonstop Service
Nonstop CPT Service
No Nonstop CPT Service
Washington*
*Washington (WAS) = IAD, DCA & BWI
Source: O&D Passenger Data via Diio FMdi Market Intelligence (Year Ended December 31, 2019)
3x/Week Service
Began
December-2019
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MWAA Exhibit II.
Washington Dulles International Airport is ideally situated to serve the largest demand market without
non-stop service
MWAA Exhibit III
Washington Dulles International Airport will offer even more connectivity into the Greater Washington
with the Silver Line extension
• “Construction of the Silver Line Metrorail public transit extension has
reached substantial completion and is on track to be open later in 2022.”
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