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 ) ) ) ) ) ) ) ) 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 , 2015BEFORE 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 ) ) ) ) ) ) ) ) Docket DOT - OST - 2010 - 0018

CONSOLIDATED REPLY OF DELTA AIR LINES, INC
. Delta Air Lines I nc. (“Delta”) hereby Replies to the Answers of American Airlines Inc. (“American”) and Hawaiian Airlines , Inc. (“Hawaiian”)

. The legal and publi c interest issues in the case a re 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 inve stment 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 le ss 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 conditio ns, 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
- evide nt . There is no legitimate legal, policy, or public interest basis for removing Haneda service from Seattle. The service has shown marked improvement f ueled 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 o w n metal service. Moreover, we note that Delta is currently operating Seattle
- Haneda service in ful l 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 temporar il y - 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 Reconsid eration 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 t he 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
- serv ed 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 I ntergateway 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 St ates.

• 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 aircr aft, is bringin g 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 e xisting 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
- Han eda 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 Se attle

. 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 wil l 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 re ality 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, sittin g 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 sl ot s 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 ha s 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, e ncouraged by this stron g 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
- ope ra ted connecting service into Seattle, whi ch 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 fl ights , 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 - HNDDelta Consolidated Reply Page 6 4

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

. Americ an provides dozens of pages of e xhibits on Delta’s service and capacity adjustments to establish a viable service pattern at Haneda. But, American conveniently ignores it s 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 an d unprecedented result he re. 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 main land 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 g iven 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

. America n erroneously claim s 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 Pa cific 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 Appli cants 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 opportunisti cally 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. T oday, 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 '15Delta 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 benefi t 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 c ompetition on U.S

. - Haneda routes and is essential to preventing further deterioration of the c om petitive market
s tructure. 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 promot e 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 contrad ict 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 bu siness and leisure passengers.” ); Order 2010
- 2
- 8, pag e 28 (“[E]e n hanced 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 number s , 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 i t s LAX service from one airport to an o ther (particularly when LAX ha s two existing Haneda flights ) provides no public interest benefits compared with the substantial benefits generated by maintain ing 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 t ourists. 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 Han eda
- 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 beDelta 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 marke t is even more heavily Japanese
- originating (96 %). D L
- 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 opportunit ies 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. Ins tead 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 com petition 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
- to point Japanese originating leisure traffic and Hawaiian can point to no valid reason these pass engers cannot be accommodated by it at Narita. 8. Conclusion As the Department already found in its 2013 Order granting Delta's application, Seattle
Haneda 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 theDelta 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 US Tokyo 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 LAX HNL 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 Own Metal/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 LAX HNL 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 SaleC ERTIFICATE OF SERVICE A copy of the foregoing document has been ser ved this 20 th day of January, 2015 , upon the following persons via email: howard.kass@aa.com abigail.donovan@aa.com robert.wirick@aa.com charles.hunnicut t @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@crow ell.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