BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Motions and Application of 

AMERICAN AIRLINES, INC.

HAWAIIAN AIRLINES, INC. 

In the matter of 2010 U.S.-Haneda Combination 

Services Allocation Proceeding

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Docket DOT-OST-2010-0018 

CONSOLIDATED REPLY

OF DELTA AIR LINES, INC.

Communications with respect to this document should be addressed to:

Glen Hauenstein

Executive Vice President 

 & Chief Revenue Officer

Robert J. Cortelyou

Senior Vice President – Network Planning

DELTA AIR LINES, INC.

1030 Delta Boulevard

Atlanta, Georgia 30320

Alexander Van der Bellen

Managing Director and Associate General 

Counsel – Regulatory and International Affairs

DELTA AIR LINES, INC. 

1212 New York Avenue, N.W. 

Washington, D.C. 20005

(202) 842-4184

sascha.vanderbellen@delta.com

January 20, 2015
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Motion and Application of 

AMERICAN AIRLINES, INC.

HAWAIIAN AIRLINES, INC. 

In the matter of 2010 U.S.-Haneda Combination 

Services Allocation Proceeding

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Docket DOT-OST-2010-0018 

CONSOLIDATED REPLY

OF DELTA AIR LINES, INC.

Delta Air Lines Inc. (“Delta”) hereby Replies to the Answers of American Airlines Inc. 

(“American”) and Hawaiian Airlines, Inc. (“Hawaiian”). The legal and public interest issues in 

the case are simple and straight forward. At bottom, the Department will need to decide four 

things:

• First, should Seattle and the Pacific Northwest maintain the only service in the 

entire region, enabling international commerce, business investment and 

convenience for the traveling public?

• Second, should the Department provide Los Angeles a third daily Haneda 

service by stripping Seattle of its only flight, when LAX is already strained under 

current operating conditions and one of the multiple LAX-HND flights might then 

fail?

• Third, should U.S. flag Haneda opportunities be used to benefit U.S. consumers 

and U.S. export business – or should they be used to benefit Japanese tourists? 

Given that plentiful capacity exists at Narita airport for less time sensitive leisure 

passengers, the answer seems obvious.
Delta Consolidated Reply

Page 2

• Fourth, will the Department observe its own rules and procedures, allowing a 

duly designated and operating carrier the flexibility expressly provided for in the 

Department’s ordering conditions, or will the Department arbitrarily and 

capriciously strip authority from Seattle inviting legal challenge, disruption, and 

further uncertainty in the U.S.-Haneda marketplace?

Delta respectfully submits that the answers to these questions are self-evident. There is 

no legitimate legal, policy, or public interest basis for removing Haneda service from Seattle. 

The service has shown marked improvement fueled in large part by Delta’s commitment to 

growing the Seattle hub. While Alaska is an important codeshare partner, we have seen U.S.-

Asia traffic improve by a factor of two-fold in various markets where Delta has added own metal 

service. 

Moreover, we note that Delta is currently operating Seattle-Haneda service in full 

compliance with the terms and conditions specified in Order 2013-2-4 (“Allocation Order”), 

including the dormancy condition. Seasonal variations are common in many international 

markets and while Delta is operating at a temporarily-reduced level, Delta has firm plans, has 

allocated aircraft, is actively marketing, and will operate daily service at the start of the IATA 

Summer Season, effective March 29, 2015 and beyond. 1

1 Delta reiterates that it does not concede the lawfulness of the Department’s decision to 

reexamine the allocation of the Seattle-Haneda frequencies or of any final decision to reallocate 

the same slots to another carrier. Delta expressly incorporates by reference its Petition for 

Reconsideration of December 22, 2014, and, for the reasons set forth in that document, urges 

that further proceedings be stayed pending reconsideration of Order 2014-12-9. Order 2014-12-

9 is arbitrary and capricious and contrary to law, and any final decision by the Department to 

reallocate the slots would be unlawful for the same reasons.

 
Delta Consolidated Reply

Page 3

1. Seattle needs and deserves nonstop service.

If service were taken away from Seattle it would be the largest U.S.-Tokyo O&D gateway 

without nonstop service to Haneda. Seattle would also be the largest west coast business 

center without Haneda service, placing Seattle and the Pacific Northwest region at a

disadvantage to the well-served cities of San Francisco and Los Angeles (to say nothing of 

Hawaii which currently enjoys 3 of 8 Haneda opportunities). Seattle-Haneda is in the public 

interest for the following reasons:

• Seattle will continue as an important and unique mainland gateway, providing 

122,000 annual Tokyo passengers with nonstop access to Haneda.2

 

Intergateway competition will be preserved with San Francisco and Los Angeles 

which both have two existing Haneda flights.

• 47 cities will receive round-trip connections, and an additional 38 cities will 

receive one-way connecting service to Haneda via Seattle. Seattle’s geographic 

location provides the largest catchment area and best network coverage of the 

United States. 

• The Pacific Northwest region will maintain its only convenient access to Haneda 

because the existing west coast gateways are too far south and unreasonably 

circuitous. 

• Delta’s growing Seattle network, served with Delta and Delta Connection aircraft,

is bringing more traffic and true online connections to the marketplace, improving 

service and competition for U.S.-Haneda passengers. 

• Delta’s proposal will preserve and enhance vigorous 3-way competition among 

the major alliances serving Japan. Delta is the only effective competitor to the 

United/ANA and American/JAL immunized alliances, both of which have major 

hub operations at Haneda.

• Unlike American, Delta’s service maintains a unique new Haneda gateway at 

Seattle, rather than duplicating existing Haneda services at Los Angeles. It 

would be patently unfair for Los Angeles to enjoy three Haneda slot pairs while 

Seattle would be relegated to none. 

• Unlike Hawaiian, Delta will use this limited Haneda opportunity to serve U.S. 

citizens and businesses, rather than transport Japanese tourists in the well 

served Haneda-Hawaii marketplace. Similar to American’s proposal, Hawaii 

already has three nonstop Haneda flights while an award to Hawaiian would 

deprive the Pacific Northwest of its only nonstop flight. 

2 (MIDT data adjusted to account for direct sales). 

 
Delta Consolidated Reply

Page 4

When the Department granted Delta Seattle-Haneda slots it made a number of important 

public interest findings confirming the benefits of Seattle-Haneda service. See, Show Cause 

Order 2012-11-12 at pp. 5-6; confirmed by Final Order 2013-2-4. Particularly given that Delta 

has committed to a full pattern of daily service beginning on March 29, there is no justifiable 

basis for removing the slots from Seattle.

2. The Public Interest Requires Maintaining Competition with the JAL and ANA Joint 

Ventures. 

Delta is manifestly committed to challenging the huge American/JAL and United/ANA 

alliance operations hubbed at Haneda. It is clear that Haneda will be the premier international 

gateway serving Tokyo in the next 10 years, and while developing service under the current 

constraints is difficult, it can and must be done. 

American claims that LAX is under-served to Tokyo relative to Seattle, but in reality 

seats per passenger today are comparable, and, if Haneda slots are shifted from SEA to LAX, 

Seattle would be under-served relative to LAX DL-R-106. Likewise, American’s claim that it 

would offer a superior network is false, considering that Delta’s rapidly expanding own-metal 

service, combined with supplemental Alaska codeshare service provides a broader and less 

circuitous network for U.S. mainland customers. DL-A-203. 

In addition, it is clear that Hawaiian has had a relatively easy time, sitting atop a large 

local market, operating shorter stage lengths, and by virtue of geography and timing, allowed to 

operate in a better time channel. This does not mean that mainland service should be 

abandoned in favor of operating half of all U.S. Haneda slots allocation from Hawaii. DL-R-202.

If we are to remain competitive in the global marketplace for U.S.-Asia service, the U.S. 

cannot give up on mainland service between the United States and Haneda. Delta has 

demonstrated persistence and commitment to the U.S.-Haneda market – making necessary and 

appropriate changes to its schedule and aircraft to meet these challenges. It would be ironic 

and unfair to allow American/JAL to further the duopoly at Haneda at Delta’s expense, 
Delta Consolidated Reply

Page 5

considering their outright abandonment of JFK-HND. More Haneda slots need to be freed up 

from Star and oneworld to provide meaningful competition at the airport. The actions urged by 

Delta’s opponents in this proceeding would have the opposite effect. 

3. Delta’s growing hub network is having a positive effect on Seattle-Haneda service. 

American’s answer erroneously discounts the positive effect Delta’s new own-metal 

services have had on the Seattle hub and the performance of the Seattle-Haneda flight. 

Indeed, Delta has observed traffic increases of 50 percent or more in west coast-Asia markets 

here it has added new flights. In particular, we note that Delta’s Summer Season SEA-HND 

2014 performance improved by 54% percent year-over-year. And, encouraged by this strong 

summer 2014 performance, Delta has allocated aircraft, published schedules and is actively 

selling a full pattern of daily Seattle-Haneda service in summer 2015 and beyond.

 A major contributor to the improved success of the Seattle-Haneda flight is the 

increased Delta-operated connecting service into Seattle, which grew to 51 daily departures in 

August 2014, will grow again to 85 in 2015, and is anticipated to continue growing in 2016. This 

growth represents an increase of 240 percent in Seattle flights, which will provide the necessary 

feed needed to make the Seattle-Haneda service a continued success:

25 29

51

85

2012 2013 2014 2015

Daily Delta to Delta Connections for SEA-HND 
Delta Consolidated Reply

Page 6

4. Delta's Temporary Response to Commercial Conditions Was Both Compliant and 

Responsible. 

American provides dozens of pages of exhibits on Delta’s service and capacity 

adjustments to establish a viable service pattern at Haneda. But, American conveniently 

ignores its own failed bid and “broken promises” to operate nonstop service from New York 

(JFK). American made major reductions in its JFK-HND service – reducing its service pattern 

similar to Delta – (DL-A-301) before abandoning the route entirely. American did not so much 

as bother to seek authority for a new gateway (such as Los Angeles). By contrast Delta has 

worked diligently and persistently to find a workable Haneda solution until that airport can finally 

be brought under open skies. 

We note the irony of American’s exaggerated claim that DOT should strip Delta of its 

SEA-HND slot for “appalling underuse” in the off-peak winter schedule, while American has 

regularly made its own seasonal adjustments rendering limited international frequencies unused 

for 90 days or more over a period spanning more than a decade. Exhibit DL-A-303. No action 

was taken by the Department to recall American’s unused frequencies. The Department should 

squarely reject American’s call for a different and unprecedented result here.

All carriers make adjustments to their schedules and aircraft size -- which is a normal, 

expected commercial response to observed market conditions. It is no secret that developing 

service from the mainland U.S. has been challenging; in fact, on several occasions Delta met 

with the Department staff and advised them that temporary seasonal reductions might be 

necessary. Delta never received any objections in the past to its seasonal reductions, and was 

given no notice that reduced winter operation this season could or would trigger a summary 

review of Seattle’s Haneda service. 
Delta Consolidated Reply

Page 7

5. American has abundant access to Haneda via its partnership with JAL.

American erroneously claims that it “is the only U.S. airline serving Japan without 

Haneda authority. (p.10). In fact, American enjoys important advantages with a large partner 

and major hub at Haneda. To that end, American conveniently overlooks that it is operating 

across the Pacific as one airline with JAL, one of the largest competitors in the U.S.-Japan 

marketplace with a huge incumbent position at Haneda:

American currently enjoys the benefit of two U.S.-Haneda slots Haneda under its joint 

venture with JAL, which American and JAL certify they have implemented. Exhibit DL-2. 

American’s stated objective in forming its immunized alliance was to create a metal-neutral joint 

venture in which each carrier was indifferent to the actual operator of the aircraft:

The Joint Applicants seek approval for a highly-integrated, revenue-sharing joint venture 

that will strengthen their alliance by eliminating each carrier’s economic incentive to 

maximize its own revenue. Only the closer cooperation made possible through a joint 

venture based on metal neutrality – or indifference as to which airline actually carries a 

customer – will maximize the consumer benefits that immunized alliances make 

possible. This is because metal neutrality removes each carrier’s incentive to act 

opportunistically in ways that inure to its own short-term financial advantage, to the 

detriment of the efficiencies and consumer benefits that could otherwise be delivered by 

the alliance. American/JAL Antitrust Immunity Application, Docket DOT-OST-2010-

0034, p.7.

Today, American codeshares on each and every one of JAL’s U.S.-Japan flights, 

including JAL’s HND-San Francisco and highly lucrative HND-Honolulu flights. When the 

DL

24%

AA/JL

29%

UA/NH

38%

Other

9%

US-Japan ASMs by Immunized Alliance

OAG, Mar '15

Other

18%

SkyTeam 

2%

oneworld

33%

Star 

47%

HND Slots by Alliance

OAG, Mar '15
Delta Consolidated Reply

Page 8

Department approved the American/JAL immunized alliance it stated: "The intended 

commercial effects of the ATI Applicants’ respective joint business agreements are similar to 

those resulting from a merger." (Japan ATI Order 2010-10-4 at 5). If American and JAL are not 

working together to jointly realize the full benefit of JAL’s two Haneda flights, then they have 

failed to realize the claimed benefits of their ATI alliance and should no longer be entitled to 

antitrust immunity.3

Delta service at Seattle will continue progress toward three-way alliance competition on 

U.S.-Haneda routes and is essential to preventing further deterioration of the competitive market 

structure. The two immunized U.S.-Japanese alliances have inherent advantages over Delta, 

which does not have a Japan alliance partner. As a SkyTeam member and major U.S.-Japan 

competitor, Delta is the only carrier capable of offering a competitive alternative to the west 

coast Haneda services of oneworld (JL) and Star (UA) at San Francisco and Star (ANA) at Los 

Angeles. The DOT has consistently sought to promote inter-alliance competition.4

 Maintaining 

Delta’s SEA-HND service helps to promote the Department’s public interest objectives. 

Conversely, the loss of a slot pair would marginalize Delta in the U.S.-Haneda marketplace, 

leaving Delta with just a single daily flight to compete against the multiple daily trans-Pacific 

flights and large Haneda hubs operated by Star and oneworld. This would increase market 

3 Moreover, American and JAL could serve Los Angeles-Haneda today simply by moving JAL’s 

SFO-HND flight to LAX. Given the recently authorized United SFO-HND service, there is a 

strong possibility that the oneworld carriers might make this decision on their own initiative. It 

would make absolutely no sense (and contradict the Department’s stated public interest 

objectives for U.S.-Haneda flying) to strip Delta of its SEA-HND slots that are used to operate 

from the Pacific Northwest to allow American/JAL to pile on more flights on the already 

saturated LAX-HND route. 

4 See Order 2009-7-10, page 17 (“We also examined the changes in inter-alliance 

competition.... The ability of the ‘non-hub’ alliance members to compete at [a hub of another 

alliance] can benefit both business and leisure passengers.”); Order 2010-2-8, page 28 

(“[E]enhanced inter-alliance competition is beneficial for consumers across many markets....”)

 
Delta Consolidated Reply

Page 9

dominance by the U.S.-Japan ATI alliances and undermine Delta’s ability to compete in the 

U.S.-Tokyo and U.S.-Japan marketplace.

6. American will provide no new capacity benefits. 

American’s exhibits filed with its original Application showed that American assigned the 

same flight number to its proposed LAX-HND flight as its existing LAX-NRT flight. Although 

American has now attempted to cover this up by assigning new flight numbers, American avoids 

mentioning and makes no commitment to maintain LAX-NRT service despite being called out on 

it in the initial round of pleadings. Furthermore, American’s gimmick of proposing an unrealistic

60 day startup in a long haul widebody market is further indication that American intends to 

swap the Tokyo markets operated with its existing equipment. Thus, it would appear that 

American intends to drop its own LAX-NRT service just as it canceled its own JFK-NRT service 

when it launched JFK-HND and left its partner JAL to fly JFK-NRT. American is playing a zero 

sum game. Allowing American to switch its LAX service from one airport to another (particularly 

when LAX has two existing Haneda flights) provides no public interest benefits compared with 

the substantial benefits generated by maintaining Seattle as a unique gateway serving the 

Pacific Northwest. By contrast, Delta will continue to serve NRT from Seattle, and Delta’s 

Haneda flight represents true incremental capacity in the marketplace to the benefit of 

consumers. 

7. Pacific Northwest Travelers, Shippers and Businesses Shold have Public Interest 

Priority Over Japanese tourists. 

To be sure, Hawaii is a lovely state and enjoys a large visitor economy with Japan. 

That said, Delta’s proposal to maintain the only Haneda service to Seattle and the Pacific 

Northwest region deserves priority over Hawaiian’s proposal to add a fourth Haneda-Hawaii 

flight at Kona. Hawaii already receives three nonstop Haneda services operated by Hawaiian 

Airlines, JAL and ANA. Combined, these services represent 37.5% of all available Haneda 

slots. If Hawaiian’s Kona proposal were granted, 50% of Haneda slots (four of eight) would be 
Delta Consolidated Reply

Page 10

operated to the Hawaiian Islands. The overwhelming majority of passengers on existing 

Tokyo-Hawaii flights (95%) are Japanese tourists (DL-R-203) and the Tokyo-Kona market is 

even more heavily Japanese-originating (96%). DL-R-204. It is not in the public interest to 

have so many limited entry opportunities concentrated in Hawaii to the exclusion of a Pacific 

Northwest gateway that provides service to U.S. citizens and U.S. businesses seeking access 

to Tokyo’s preferred close-in airport.

Hawaiian claims that “access to Kona is only available through Honolulu; as such the 

availability of nonstop service will be attractive to Japanese-originating tourists.” (Application 

p.6). Yet, Hawaiian ignores the open entry opportunities available to Kona from Tokyo Narita –

a major achievement under the open skies agreement the United States secured with Japan. 

Haneda is the preferred business airport serving downtown Tokyo. And, as Japan’s airport 

policies continue to evolve it is likely that more leisure and charter traffic will shift to Narita. U.S. 

customers and U.S. businesses should receive public interest priority over Japan’s tourists. 

Moreover, Hawaiian should not enjoy a U.S. flag monopoly on Haneda-Hawaii service. Instead 

of offering Narita-Kona service which it is free to do today, Hawaiian seeks only to operate from 

the constrained Haneda airport.

By contrast, in order to take on the American/JAL and United/ANA joint ventures and 

maintain effective 3-way alliance competition from key U.S. business markets, it is vital for Delta

to maintain service at Seattle and grow its U.S.-Haneda network. Tokyo-Kona traffic is point-topoint Japanese originating leisure traffic and Hawaiian can point to no valid reason these 

passengers cannot be accommodated by it at Narita. 

8. Conclusion

As the Department already found in its 2013 Order granting Delta's application, SeattleHaneda service is the highest and best use for the limited, available frequencies. We have 

seen remarkable increases in traffic and profitability and Delta is committed to operating the 
Delta Consolidated Reply

Page 11

route beginning this summer and beyond. Confirming this authority is consistent with the 

Department’s public interest vision to provide a broad base of geographically diverse gateways 

serving large O&D markets and providing effective network competition for U.S. consumers. 

Respectfully submitted,

_________________________________

Alexander Van der Bellen

Managing Director, Regulatory and 

International Affairs

 & Associate General Counsel

DELTA AIR LINES, INC.
Delta Answer Exhibits

Section I: American Already Enjoys Access to Haneda and Tokyo 

Section II: Scarce Haneda Slots Should Benefit U.S. Public, Not Just Japanese 

Tourists
Section I: American Already Enjoys Access to Haneda and Tokyo
American’s Proposal Undermines Inter-Alliance Competition 

at Haneda

• DOT maintained in the final HND order that “enhancing alliance competition in the USTokyo and US-Asia markets” is one of its public interest objectives

• The DOT’s instituting order in this proceeding also emphasizes competition and market 

structure benefits

• To that end, US-HND capacity is balanced between the three major alliance groupings

3 3

1

Star

NH/UA

oneworld

AA/JL

Skyteam

Delta

US-Haneda Slot Pairs by Alliance Group per 

American’s Proposal

Docket DOT-OST-2010-0018

Exhibit DL-R-101

Page 1 of 1

HNL

LAX

SFO

HNL LAX

LAX

SFO
American’s Proposal Would Concentrate 62.5% of Haneda

Slots in California, Depriving the Greater US Access

• This would result in the rest of the US shut out of Tokyo’s preferred, supposedly open 

skies, airport.

Hawaii, 4

California, 5

US-Haneda Slot Pairs by State Served 

per American’s Proposal

Docket DOT-OST-2010-0018

Exhibit DL-R-102

Page 1 of 1

LAX 3x

SFO 2x

HNL 2x

KOA
• Delta’s buildup of it Seattle hub with own-metal flights offers customers the best access to the 

Haneda flight.

• Alaska’s codeshare offerings compliment and enhance access options by greatly increasing the 

number of points that connect to Delta’s SEA-HND flight.

• American, meanwhile, bemoans it’s small status at Tokyo (Exhibit AA-R-113) while conveniently 

ignoring their antitrust immune partner, JAL, serves an additional 6 points in the U.S. from Tokyo.

American Misunderstands the Difference Between OwnMetal/Metal-Neutral Connections Versus Codeshare 

Connections

Docket DOT-OST-2010-0018

Exhibit DL-R-103

Page 1 of 1
American Misrepresents the Competitive 

Tokyo Environment, Again Docket DOT-OST-2010-0018

Exhibit DL-R-104

Page 1 of 1

• AA makes the laughable claim that it, along antitrust immune partner and Japanese flag carrier 

JAL, are somehow at a disadvantage to Delta (Exhibits AA-R-114 & 115).

• American and JAL could, at any time, add flights from Tokyo-Narita to remedy their 

“disadvantaged” situation flying from Tokyo.

• But American is not interested in adding Narita flying, in fact, based on their pleadings so far in this 

route case, it seems that American will likely cancel their LAX-NRT flight if they are granted the 

rights to fly LAX-HND, mitigating any benefits claimed in AA’s proposal.

• American further doesn’t seem to think that antitrust immune alliances are relevant to this 

proceeding, and go to great lengths to distinguish themselves from their Japanese partner, JAL.

• Yet, AA clearly benefits from JAL’s Haneda Flights, which are currently in parity with Delta’s.

Source: OAG

2 2

oneworld

AA/JL

Skyteam

Delta

US-Haneda Slot Pairs by Alliance Group
• When additional services are included in the TYO-LAX market, the ratio of seats to MIDT O&D 

passengers in the Seattle-Tokyo and Los Angeles Tokyo markets are nearly equal:

• American could increase the number of seats available in the LAX-TYO market by upgauging their 

LAX-NRT service to a 777-300ER rather than stripping the Pacific Northwest of its only Haneda

gateway.

American Now Fully Lists Tokyo-Los Angeles Service, but 

Continues to Misrepresents the Competitive Environment Docket DOT-OST-2010-0018

Exhibit DL-R-105

Page 1 of 1

LAX-TYO Passengers 423,525

LAX-TYO Seats 1,648,857

93,892 SEA-TYO Passengers

461,611 SEA-TYO Seats

3.8

4.9

LAX SEA

Seats per passenger

Source: OAG & MIDT
• Under AA’s proposal to deprive Seattle of its only Haneda flight, the ratio would skew heavily 

towards Los Angeles, resulting in under- service for Seattle:

• Seattle would be served by even fewer seats per passenger than LAX is currently, which American 

portrays as a severely underserved market.

• American’s proposal would also inconvenience the traveling public as it would remove the most 

convenient US-HND gateway, depriving most of the nation of non-circuitous connections at Seattle.

American Now Fully Lists Tokyo-Los Angeles Service, but 

Continues to Misrepresents the Competitive Environment Docket DOT-OST-2010-0018

Exhibit DL-R-106

Page 1 of 1

4.6

3.2

LAX SEA

Seats per passenger

LAX-TYO Passengers 423,525

LAX-TYO Seats 2,003,549

93,892 SEA-TYO Passengers

303,602 SEA-TYO Seats

Source: OAG & MIDT
• Delta’s SEA-Tokyo flights compliment each other. SEA-HND allows passengers to access the 

preferred downtown airport for Tokyo O&D traffic while SEA-NRT connects passengers to Delta’s 

intra-Asia destinations.

• Similarly, LAX-HND and SEA-HND flights compliment each in allowing passengers from different 

catchment areas access to Haneda. Taking away the SEA-HND flight would deprive Seattle and the 

Pacific Northwest of convenient options to Haneda.

• American has left unanswered whether they plan to continue flying LAX-NRT if they are awarded 

the Haneda frequencies at issue.

• In their initial application, American’s proposed LAX-HND service used the same flight 

numbers as LAX-NRT.

• American’s proposed 60-day startup time is unreasonable for a new, widebody international 

route unless they plans to transfer bookings from LAX-NRT to LAX-HND.

• If American decides it would rather not “compete with itself”, and cancels LAX-NRT, any seat 

access benefits to consumers is Los Angeles would disappear and Seattle and the Pacific 

Northwest would lose their only gateway to Haneda.

American is Unlikely to Continue to Serve LAX-NRT if Awarded 

LAX-HND, Mitigating Any Potential Consumer Benefits Docket DOT-OST-2010-0018

Exhibit DL-R-107

Page 1 of 1
Section II: Scarce Haneda Slots Should Benefit U.S. Consumers, Not 

Just Japanese Tourists
Hawaiian’s Proposal Would Concentrate Half of Haneda Slots 

in Hawaii, of Minimal Benefit to the Average US Traveler

• DOT maintained in the final HND order that gateway diversity is one of its public interest 

objectives

• The DOT’s instituting order in this proceeding also emphasizes competition and market 

structure benefits

• Hawaiian’s proposal would result in half of all Haneda flights being concentrated in Hawaii

3

2 2

1

Star

NH/UA

oneworld

AA/JL

Hawaiian Skyteam

Delta

US-Haneda Slot Pairs by Alliance Group per 

Hawaiian’s Proposal

Docket DOT-OST-2010-0018

Exhibit DL-R-201

Page 1 of 1

HNL

LAX

SFO

HNL LAX

SFO

HNL

KOA
Hawaiian’s Proposal Would Concentrate Half of Haneda Slots 

in Hawaii, of Minimal Benefit to the Average US Traveler

• This would result in half of Haneda slots being flown from Hawaii and half from California, 

leaving the rest of the US shut out of Tokyo’s preferred, supposedly open skies, airport.

• If Kona is a such an underserved market as Hawaii claims, it could easily be served with 

flights to Narita, allowing scarce Haneda slots to be deployed with more geographically 

diversity. 

Hawaii, 4

California, 4

US-Haneda Slot Pairs by State Served 

per Hawaiian’s Proposal

Docket DOT-OST-2010-0018

Exhibit DL-R-202

Page 1 of 1

LAX 2x

SFO 2x

HNL 3x

KOA
• Hawaiian’s proposal would overwhelmingly benefit Japanese tourists to Hawaii, while 

depriving most of the U.S. from the most convenient Haneda connecting gateway at Seattle.

Hawaiian Concedes that Almost All Benefits to KOA-HND will 

be for Japanese Tourists

Source: MIDT 2014

Docket DOT-OST-2010-0018

Exhibit DL-R-203

Page 1 of 1

Japan 95%

U.S. 4%

Other 1%

Hawaii-Tokyo O&D Passengers by Point of Sale
• The imbalance of public benefits is even greater for Kona-Tokyo traffic:

Hawaiian Concedes that Almost All Benefits to KOA-HND will 

be for Japanese Tourists

Source: MIDT 2014

Docket DOT-OST-2010-0018

Exhibit DL-R-204

Page 1 of 1

Japan 96%

U.S. 3%

Other 0%

Kona-Tokyo O&D Passengers by Point of Sale
CERTIFICATE OF SERVICE

A copy of the foregoing document has been served this 20th day of January, 2015, upon 

the following persons via email:

howard.kass@aa.com

abigail.donovan@aa.com

robert.wirick@aa.com

charles.hunnicutt@thompsonhine.com

patricia.snyder@thomsponhine.com

jhill@cooley.com

perkmann@cooley.com

dan.weiss@united.com

thomas.bolling@united.com

steve.morrissey@united.com

lhalloway@crowell.com

gmurphy@crowell.com

Mike.Donatelli@alpa.org

dino.atsalis@alpa.org

Doug.Ralph@alpa.org

Ishiwata.K@portseattle.org

Safora.I@portseattle.org

sascha.vanderbellen@delta.com

chris.walker@delta.com

paul.gretch@dot.gov

brian.hedberg@dot.gov

brett.kruger@dot.gov

todd.homan@dot.gov

peter.irvine@dot.gov

englets@state.gov

cristinasa@state.gov

eugene_alford@ita.doc.gov

info@airlineinfo.com