BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, DC 

 

In the Matter of ) 

 ) 

2010 U.S.-Haneda Combination ) Docket DOT-OST-2010-0018 

Services Allocation Proceeding ) 

 ) 

CONSOLIDATED ANSWER 

OF 

UNITED AIR LINES, INC.

 Communications with respect to this document should be addressed to: 

JULIE OETTINGER 

Managing Director – International 

& Regulatory Affairs 

UNITED AIR LINES, INC. 

1025 Connecticut Avenue, NW 

Suite 1210 

Washington, DC 20036 

BRUCE H. RABINOVITZ 

DAVID HEFFERNAN 

NEIL J. KING 

WILMER CUTLER PICKERING 

 HALE AND DORR LLP 

1875 Pennsylvania Avenue, NW 

Washington, DC 20006 

(202) 663-6000 (Phone) 

(202) 663-6363 (Fax) 

bruce.rabinovitz@wilmerhale.com 

david.heffernan@wilmerhale.com 

neil.king@wilmerhale.com 

Counsel for 

UNITED AIR LINES, INC. 

DATED: March 1, 2010 
































Index of Exhibits for United 

Docket DOT-OST-2010-0018 

EXHIBITS OF UNITED AIR LINES, INC. 

NO. TITLE

UA-A-1 United Will Offer Roundtrip Online Connections To Haneda From 27 Airports 

Via San Francisco 

UA-A-2 The San Francisco – Tokyo Local Market Is More Than Twice As Large As 

Seattle – Tokyo 

UA-A-3 The San Francisco Local Market Is 28% Larger Than Honolulu And 123% 

Larger Than Guam 

UA-A-4 Los Angeles Has 75% More Scheduled Weekly Departures To Tokyo Than San 

Francisco 

UA-A-5 Delta’s Claim That Its SEA-HND Service Would Connect To 60 Airports Is 

Misleading 

UA-A-6 American’s Claim That Its LAX-HND Service Would Connect To 25 Airports Is 

Misleading 

UA-A-7 Delta’s Claim That Its LAX-HND Service Would Connect To 20 Airports Is 

Misleading 

UA-A-8 United’s SFO-HND Service Will Reach More Than 40% Of The Total U.S. To 

Tokyo Demand 

UA-A-9 United’s SFO-HND Service Will Offer More Non-Stop Plus SingleConnect Service To Haneda Than Any Other West Coast Gateway Proposal 

UA-A-10 ANA Operates A More Extensive Asia Network At Haneda Than American’s 

Alliance Partner, JAL 

UA-A-11 Korean Air Only Serves 1 Airport From Haneda 

UA-A-12 United's B777-200XQ Aircraft Will Provide Ample Cargo Capacity On The 

SFO-HND Route 

UA-A-13 Delta Has The Largest Share Of The U.S. – Tokyo Market, With Far More 

Departures Than Any Other Carrier 

UA-A-14 Delta Has The Largest Share Of The U.S. – Tokyo Market, With A 33% Share 

Of Weekly Services 
Index of Exhibits for United 

Docket DOT-OST-2010-0018 

UA-A-15 Delta Serves 11 Points In The U.S. With 120 Weekly Nonstop Departures From 

Narita 

UA-A-16 Delta And Its Alliance Partner Korean Air Serve 13 Points In Asia With 118 

Weekly Nonstop Departures From Narita 

UA-A-17 San Francisco and Detroit Would Serve A Comparable Number Of Local Plus 

Connecting Passengers 

UA-A-18 Los Angeles And New York Have More U.S. – Tokyo Nonstop Service Than 

San Francisco 

UA-A-19 American’s Claim That Its JFK-HND Service Would Connect To 41 Airports Is 

Misleading 

UA-A-20 United’s 4-Option Seating Configuration Is Superior To American’s 3-Option 

Configuration 

UA-A-21 Continental’s Claim That Its EWR-HND Service Would Connect To 74 Airports 

Is Misleading 

UA-A-22 United’s SFO-HND Proposal Would Serve 30% More Local Plus Connecting 

Passengers Than Continental’s EWR-HND Proposal 
United Will Offer Roundtrip Online Connection

United Will Offer Roundtrip Online Connection

To Haneda From 27 Airports Via San Francisc

To Haneda From 27 Airports Via San Francisc

Sources: MIDT, CY2009. U.S. to Tokyo (HND/NRT).OAG, November 2010 (as adjusted to reflect planned retiming of 6 connections predicated on receipt of a Haneda slot award).Each of these round-trip connections meets the following criteria: year-round, connection window less than 4 hours, and connection flights operated by United/United Express. 

YEG

LAX

YVR

YYJ

SEA

PDX

EUG

BOI

YYC

SLC

RNO

ACV

RDD

CIC

SMF

SFO MOD

MRY

FAT

SBP LAS

SBA

BUR

SNA

SAN PHX

DEN

ORD

United Connections To SFO-HND Will Serve 175,566 (or 31% of) U.S.-Originating Tokyo 
The San Francisco The San Francisco – Tokyo Local Market Tokyo Local Market 

Is More Than Twice As Large As Seattle Is More Than Twice As Large As Seattle – Toky

Source: MIDT, CY2009. U.S. to Tokyo (HND/NRT).SFO=SFO,SJC,OAK.

51,700

23,477

0

10,00020,00030,00040,00050,00060,000

SFO SEA

Annual Passengers

Annual U.S. To Tokyo O&D Passengers (U.S. Point Of Origin)
The San Francisco Local Market Is 28% The San Francisco Local Market Is 28% 

Larger Than Honolulu And 123% Larger Than Gu

Larger Than Honolulu And 123% Larger Than G

Source: MIDT, CY2009. U.S. to Tokyo (HND/NRT).SFO=SFO,SJC,OAK.

51,700

40,457

23,133

0

10,00020,00030,00040,00050,00060,000

SFO HNL GUM

Annual Passengers

Annual U.S. To Tokyo O&D Passengers (U.S. Point Of Origin)
49

28

05

101520253035404550

LAX SFO

Los Angeles Has 75% More Scheduled Los Angeles Has 75% More Scheduled 

Weekly Departures To Tok Weekly Departures To Tokyo Than San Francis

yo Than San Francis

Weekly Departures

Source: OAG, February 2010.

Weekly Nonstop Departures To Tokyo
0

102030405060

Connecting

Airports Claimed

By Delta (U.S.

Plus Int'l)

Minus Non YearRound

Connection

Airports

Minus Airports

Delta Claims As

One-Way

Connections

Only

Minus Airports

With Connection

Window > 4

Hours In One Or

Both Directions

Minus Airports

Operated By

Delta's

Codeshare

Partners

Remaining

Connection

Airports

Operated By

Delta/Delta

Connection

Delta’s Claim That Its SEA s Claim That Its SEA-HND Service HND Service 

Would Connect To 60 Airports Is Misleading Would Connect To 60 Airports Is Misleading

Sources: Exhibits DL-108, DL-109, DL-110, DL-111.

5

60

20

15

20

0

BOSFATMCO

ORDSIT 

BZNCVGDFWDTWEATEUGFAIGTFHLNJFK

JNULGBLWSMEMMIAPSPPUWRDDSBASTS 

ATLBILBOIBURDENFCAMFRMSO

MSPONTRDMRNOYEGYLWYYC

ALWANCBLIGEGKTNLASLAXOAKPDXPHX

PSCSANSFOSJCSLCSMFSNAYKMYVRYYJ

Connecting Airports

Breakdown Of Delta’s Claimed 60 Connecting Airports (SEA-HND)
0

5

10152025

Connecting

Airports Claimed

By American

(U.S. Plus Int'l)

Minus Non YearRound

Connection

Airports

Minus Airports

American Claims

As One-Way

Connections

Only

Minus Airports

With Connection

Window > 4

Hours In One Or

Both Directions

Minus Airports

Operated By

American's

Codeshare

Partners

Remaining

Connection

Airports

Operated By

American /

American Eagle

American American’s Claim That Its LAX s Claim That Its LAX-HND Service HND Service 

Would Connect To 25 Airports Is Misleading Would Connect To 25 Airports Is Misleading

Sources: Exhibits AA-111, AA-112, AA-113, AA-114.MIDT, CY2009. U.S. to Tokyo (HND/NRT).Passenger totals are derived from summing industry U.S. To Tokyo O&D passengers for each applicant’s relevant connecting U.S. airports.

Connecting Airports 25 10 1

ANCAUSDEN

BOSIADLHRMCOORD

SAFSALSJDSJUSTL 

3

SEA

American offers only 8 single-connect, on-line roundtrip services, accounting for only 15% of total U.S. – Tokyo O&D passengers annually (83,911 passengers)

3

JFKMIAPDX

DFWFATLASMRY

SANSBASFOSJC 

8

Breakdown Of American’s Claimed 25 Connecting Airports (LAX-HND)
0

2468

101214161820

Connecting Airports

Claimed By Delta

(U.S. Plus Int'l)

Minus Non YearRound Connection

Airports

Minus Airports Delta

Claims As One-Way

Connections Only

Minus Airports With

Connection

Window > 4 Hours

In One Or Both

Directions

Remaining

Connection Airports

Operated By

Delta/Delta

Connection

Delta’s Claim That Its LAX s Claim That Its LAX-HND Service HND Service 

Would Connect To 20 Airports Is Misleading Would Connect To 20 Airports Is Misleading

1

20

10

1

PRC

DCAFLLGDLINDMCO

MMHRDDSANSLCTPA 8

ATLCVGDTWGUA

JFKMEMMSPRNO 

LAS

Delta offers only 1 single-connect, on-line roundtrip service, accounting for 

less than 1% of total U.S. – Tokyo O&D passengers annually (4,532 passengers)

Connecting Airports

Breakdown Of Delta’s Claimed 20 Connecting Airports (LAX-HND)

Sources: Exhibits DL-126, DL-127, DL-128, DL-129.MIDT, CY2009. U.S. to Tokyo (HND/NRT).Passenger totals are derived from summing industry U.S. To Tokyo O&D passengers for each applicant’s relevant connecting U.S. airports.
United’s SFO-HND Service Will Reach More HND Service Will Reach More 

Than 40% Of The Total U.S. To Tokyo Deman

Than 40% Of The Total U.S. To Tokyo Deman

Sources: MIDT, CY2009. U.S. to Tokyo (HND/NRT).OAG, November 2010 (as adjusted to reflect planned retiming of 6 connections predicated on receipt of a Haneda slot award).*Each of these round-trip connections meets the following criteria: year-round, connection window less than 4 hours, and connection flights operated by United/United Express.SFO=SFO,SJC,OAK. 

0

50,000

100,000150,000200,000250,000

SFO Local Market U.S. Round Trip

Connections*

Total Coverage

Annual Passengers

Annual U.S. To Tokyo O&D Passengers (U.S. Point Of Origin)

51,700

9%

175,566

31%

227,266

40%
United’s SFO-HND Service Will Offer More Non HND Service Will Offer More Non-Stop Plus S

Stop Plus S

Connect Service To Haneda Than An Connect Service To Haneda Than Any Other West Coast Gateway 

y Other West Coast Gatewa

Sources: MIDT, CY2009. U.S. to Tokyo (HND/NRT).Passenger totals are derived from summing industry U.S. To Tokyo O&D passengers for each applicant’s relevant local and connecting U.S. airports.Each of these round-trip connections meets the following criteria: year-round, connection window less than 4 hours, and connection flights operated by United/United Express for United, American/American Eagle for American, and Delta/Delta Connection for Delta.SFO=SFO,SJC,OAK.

0

50,000

100,000150,000200,000250,000

SFO-HND LAX-HND LAX-HND SEA-HND

CoLoc

Annual Passengers

Annual U.S. To Tokyo O&D Passengers (U.S. Point Of Origin)

227,266

167,208

87,829

23,47
ANA Operates A More Extensive Asia ANA Operates A More Extensive Asia 

Network At Haneda Than American Network At Haneda Than American’s Alliance Partn

s Alliance Partn

1,556

1,295

1,0001,1001,2001,3001,4001,5001,600

Weekly Departures

Weekly Departures From Haneda

Serving

42*

Airports

From

Haneda Serving 36

Airports

From

Haneda

Source: OAG, February 2010.* In addition, ANA is scheduled to begin nonstop HND-TSA service in October 2010.
Source: OAG, February 2010.

Tokyo(HND)

Korean Air Only Serves 1 Airport From Haned

Korean Air Only Serves 1 Airport From Haned

Seoul (GMP)
United's B777 United's B777-200XQ Aircraft Will Provide 200XQ Aircraft Will Provide 

Ample Cargo Capacity On The SFO Ample Cargo Capacity On The SFO-HND Rout

HND Rou

Aircraft

Route Type Seats Summer Winter

SFO-HND 777-200 269 58,800 58,800HND-SFO 777-200 269 58,800 58,800

Aircraft

Route Type Seats Summer Winter

SFO-HND 777-200 269 41,500 41,500HND-SFO 777-200 269 41,500 41,500

70% Passenger Load Fact

100% Passenger Load Fac

Cargo Payload Capabilityin pounds per flight

Source: United Cargo.
Airline Route Aircraft 70% LF 100% LF 70% LF 100% LF 

SFO-HND B777-200 58,800 41,500 58,800 41,500HND-SFO B777-200 58,800 41,500 58,800 41,500

EWR-HND1/ B777-200 49,408 27,094 49,408 27,094

HND-EWR1/ B777-200 56,837 37,140 56,837 37,140

GUM-HND1/ B767-400 56,151 38,333 56,151 38,333HND-GUM1/ B767-400 52,094 34,276 52,094 34,276

JFK-HND2/ B777-200ER 39,139 21,429 41,037 23,517

HND-JFK2/ B777-200ER 37,326 19,616 32,942 15,423

LAX-HND2/ B777-200ER 60,440 42,730 60,869 43,349HND-LAX2/ B777-200ER 60,477 42,767 60,922 43,402

SEA-HND A330-300 26,406 5,726 28,119 7,439HND-SEA A330-300 41,960 21,857 41,069 20,389

DTW-HND B747-400 39,160 15,006 39,160 22,852HND-DTW B747-400 39,160 27,425 34,068 5,163

LAX-HND B747-400 39,160 27,510 39,160 27,510HND-LAX B747-400 39,160 27,510 39,160 27,510

HNL-HND B747-400 39,160 27,510 39,160 27,510HND-HNL B747-400 39,160 27,510 39,160 27,510

HNL-HND3/ B767-300ER 29,800 29,800 29,800 29,800

HND-HNL3/ B767-300ER 29,800 29,800 29,800 29,800HNL-HND3/ A330 21,160 21,160 21,160 21,160

HND-HNL3/ A330 21,160 21,160 21,160 21,160

Winter Summer

United’s B777-200XQ Aircraft Offers More Carg

200XQ Aircraft Offers More Carg

Capacity Than Any Of The Other Applicants Capacity Than Any Of The Other Applicants’ First-Priority 

Priority 

Sources: Exhibits CO-116, CO-117, AA-118, DL-107, DL-116, DL-125, DL-134, and HA-App-3. 

1/ Continental did not provide discrete summer and winter cargo estimates.2/ American provided monthly cargo estimates. Seasonal estimates above based on average November – March (Winter) and April – October (Summer).3/ Hawaiian did not provide cargo estimates at 70% and 100% load factors. Assumed cargo estimate provided applies to both.
Delta Has The Largest Share Of The U.S. Delta Has The Largest Share Of The U.S. 

–

Tokyo Market, With Far More De Tokyo Market, With Far More Departures Than Any Oth

partures Than Any Oth

120

72

42 42

35 34

7

7

0

20406080

100120

Weekly Departures

Weekly Departures From U.S. To Tokyo

Source: OAG, February 2010.*JAL departures include its subsidiary, JALways (JO).

*
33%

20%

12% 12%

9% 9%

2% 2% 

0%5%

10%15%20%25%30%35%

% Of Weekly Departures

Percentage Of Weekly Departures From U.S. To Tokyo

Source: OAG, February 2010.*JAL departures include its subsidiary, JALways (JO).

Delta Has The Largest Share Of The U.S. Delta Has The Largest Share Of The U.S. –

Tokyo Market, With A 33% Share Of Weekly Serv

Tokyo Market, With A 33% Share Of Weekly Serv

*
Source: OAG, February 2010.

HNL

Tokyo(NRT)

Delta Serves 11 Points In The U.S. With Delta Serves 11 Points In The U.S. With 

120 Weekly Nonstop Departures From Narita 120 Weekly Nonstop Departures From Narita

LAX

SFOSEA

PDX MS

GUM

SPN
Delta And Its Alliance Partner Korean Air Serve Delta And Its Alliance Partner Korean Air Serve 

13 Points In Asia With 118 Weekl 13 Points In Asia With 118 Weekly Nonstop Departures F

y Nonstop Departures F

Source: OAG, February 2010.

76

42

0

1020304050607080

Weekly Departures

Weekly Departures From Narita

BKK

HKG

ICN

KIX

MNL

NGO

PEKPUS

PVG

SGN

SIN

TPE

CJU

ICN

PUS
Source: OAG, February 2010.

PEK

ICN PUS

KIX

NGO Tokyo

CJU (NRT)

PVG

TPE

HKG

BKK

SGN

SIN

MNL

Delta And Its Alliance Partner Korean Air Serve Delta And Its Alliance Partner Korean Air Serve 

13 Points In Asia With 118 Weekl 13 Points In Asia With 118 Weekly Nonstop Departures F

y Nonstop Departures F
San Francisco and Detroit Would Serve A San Francisco and Detroit Would Serve A 

Comparable Number Of Local Plus Connecting Pass

Comparable Number Of Local Plus Connecting Pass

Sources: MIDT, CY2009. U.S. to Tokyo (HND/NRT).Passenger totals are derived from summing industry U.S. To Tokyo O&D passengers for each applicant’s relevant local and connecting U.S. airports.Each of these round-trip connections meets the following criteria: year-round, connection window less than 4 hours, and connection flights operated by United/United Express for United, and Delta/Delta Connection for Delta. SFO=SFO,SJC,OAK.

0

50,000

100,000150,000200,000250,000

SFO DTW

ConnLoca

Annual Passengers

Annual U.S. To Tokyo O&D Passengers (U.S. Point Of Origin)

227,266 229,071

175,566

217,121

51,700

11,950
Los Angeles And New York Have More Los Angeles And New York Have More 

U.S. 

– Tokyo Nonstop Service Than San Francis

Tokyo Nonstop Service Than San Franci

Source: OAG, February 2010.

49

37

28

101520253035404550

LAX JFK/EWR SFO

Weekly Departures

Nonstop Weekly Departures To Tokyo
0

5

1015202530354045

Connecting Airports

Claimed By

American (U.S. Plus

Int'l)

Minus Non YearRound Connection

Airports

Minus Airports

American Claims As

One-Way

Connections Only

Minus Airports With

Connection

Window > 4 Hours

In One Or Both

Directions

Remaining

Connection Airports

Operated By

American /

American Eagle

American American’s Claim That Its JFK s Claim That Its JFK-HND Service HND Service 

Would Connect To 41 Airports Is Misleading Would Connect To 41 Airports Is Misleading

41 22

AUABCNBGIBRUBWICDG

CLEDFWFCOMBJMCOMXP 

3

American offers only 8 single-connect, on-line roundtrip services, accounting for less than 4% of total U.S. – Tokyo O&D passengers annually (20,965 passengers)

8

CUNLHRYHZ

BOSDCAMIAPLS

RDUSTISTTYYZ 

8

CCSCMHMADMAN

SJOSTLUVFYUL

ORDPAPPITPUJSDQSJU

SKBSXMTPAYYZ 

Sources: Exhibits AA-107, AA-108, AA-109, AA-110. MIDT, CY2009. U.S. to Tokyo (HND/NRT).Passenger totals are derived from summing industry U.S. To Tokyo O&D passengers for each applicant’s relevant connecting U.S. airports.

Connecting Airports

Breakdown Of American’s Claimed 41 Connecting Airports (JFK-HND)
United’s 4-Option Seating Configuration Is Option Seating Configuration Is 

Superior To American Superior To American’s 3-Option Configuratio

Option Configuratio

Sources: Exhibit UA-2, Page 1. Exhibit AA-115, Page 1. 

114107

40

8

194

37

16

0

255075

100125150175200225250275

Economy Economy Plus Busine

Boeing 777 Seats

Boeing 777 Seat Configuration Comparison

Total Seats: 269 247
0

5

1015202530354045505560657075

Connecting Airports

Claimed By Continental

(U.S. Plus Int'l)

Minus Airports

Continental Claims As

One-Way Connections

Only

Minus Airports With

Connection Window > 4

Hours In One Or Both

Directions

Remaining Co

Airports Ope

Continental / C

Expre

Continental Continental’s Claim That Its EWR s Claim That Its EWR-HND Servic

HND Servic

Would Connect To 74 Airports Is Misleading Would Connect To 74 Airports Is Misleading

74

27

9

Continental offers 38 single-connect, on-line roundtrip services, accounting for 

19% of total U.S. – Tokyo O&D passengers annually (106,746 passengers)

38

Sources: Exhibits CO-122, CO-123. MIDT, CY2009. U.S. to Tokyo (HND/NRT).Passenger totals are derived from summing industry U.S. To Tokyo O&D passengers for each applicant’s relevant connecting U.S. airports.

Connecting Airports

Breakdown Of Continental’s Claimed 74 Connecting Airports (EWR-HND)

ACAANUAVPBOGBUFBZECUN

DAYGCMGUAJAXLIRMBJPOP

PUJPVRSALSAPSATSDQSJD

STTSXMTYSYMTYOWYUL

ALBATLAUSBDLBOSBWICLTCMHCVGDCA

DFWFLLGSOIADIAHITHMCOMEXMHTNAS

ORPBPHPITPTPVPWRDRICRO

AUAAVLBTV

CHSCLE

MDTMIA

MYRTPA
United’s SFO-HND Proposal Would Serve 30% More Lo

HND Proposal Would Serve 30% More Lo

Plus Connecting Passengers Than Continental Plus Connecting Passengers Than Continental’s EWR-HND 

HND 

Sources: MIDT, CY2009. U.S. to Tokyo (HND/NRT).Passenger totals are derived from summing industry U.S. To Tokyo O&D passengers for each applicant’s relevant local and connecting U.S. airports.Each of these round-trip connections meets the following criteria: year-round, connection window less than 4 hours, and connection flights operated by United/United Express for United, and Continental/Continental Express for Continental. SFO=SFO,SJC,OAK. NYC=EWR,JFK,LGA.

0

50,000

100,000150,000200,000250,000

SFO NYC

ConnLoca

Annual Passengers

Annual U.S. To Tokyo O&D Passengers (U.S. Point Of Origin)

227,266

174,623

175,566

106,746

51,700 67,877