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 ANSWER OF DELTA AIR LINES, INC.

Communications with respect to this document should be addressed to:

Glen Hauenstein

Executive Vice President – Network Planning

 & Revenue Management

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

October 17, 2014
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 ANSWER OF DELTA AIR LINES, INC.

American Airlines’ attempt to take Seattle’s only direct flight to Haneda Airport (HND) in 

Tokyo, Japan and move it to Los Angeles (LAX) is wholly without merit. Hawaiian’s pile-on 

motion adds nothing to the record but hyperbole. Both should be firmly rejected by the 

Department for the following, independent reasons: 

• Delta is operating its slots in full compliance with the Department’s conditions and has 

firm, scheduled plans to operate daily Seattle (SEA)-Haneda service at the start of the 

summer 2015 IATA season; 

• The Department’s 2013 public interest findings in awarding the SEA-HND frequency to 

Delta are even more compelling today and there is no cause to revisit those findings; 

• Stripping the slots from Delta and reassigning them to American (or Hawaiian) would be 

contrary to DOT precedent on dormancy and would violate the fundamental fairness and 

due process requirements of the Administrative Procedure Act and applicable federal 

case law. 

Moreover, the Department should question why American is now attempting to obtain 

more Haneda access by denying it to Seattle. Just a few months ago, American voluntarily 

relinquished its own HND slots at New York JFK and did not even attempt to reapply to use 
Delta Answer

Page 2

those slots at LAX. Even after choosing to give up its JFK slots – and perhaps as part of its 

rationale for doing so – American retains access to Haneda. In 2010, American convinced the 

Department to grant antitrust immunity (ATI) to create a revenue-sharing joint venture with 

Japan Airlines (JAL) on the premise that American and JAL would operate as one airline across 

the Pacific. Thus, ATI effectively provided American access to JAL’s two Haneda slots, which 

the joint venture uses to fly from San Francisco and Honolulu. American is now claiming that 

despite sharing revenue and scheduling control of two Haneda slots, and having given up 

another slot pair, the Department should remove service from Washington and shift it to 

California where there is already existing Delta and ANA service to Haneda from LAX, and to 

supplement recently awarded United service to Haneda from SFO in addition to JAL. This 

feeble claim is inconsistent with DOT’s public interest mandate.

The Department should also note American’s temerity in arguing here that DOT should 

strip Delta of its SEA-HND slot for having reduced its 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-1. No action was 

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

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

Regarding Hawaiian’s aspirations, the Department has three times rejected its bid to add 

a fourth daily Hawaii-Haneda flight on top of the existing three flights operated by Hawaiian

itself, JAL, and ANA (together with their respective immunized alliance partners). Just this year 

the Department declined Hawaiian’s Kona-Haneda proposal in favor of west coast hub service

to “enhance inter-gateway competition in the West Coast-Tokyo market by giving consumers an 

additional choice for connecting service to Haneda” and found “that the benefits to the traveling 

public of [competitive west coast hub service] outweigh the potential benefits associated with 

Hawaiian’s proposal.” Order 2014-2-23 at 4. Seattle, in contrast, is the only Haneda gateway in 
Delta Answer

Page 3

the Pacific Northwest, providing the geographic and commercial diversity the Department has 

prioritized in distributing Haneda slots. 

1. Delta is Operating its Seattle-Haneda Slots in Full Compliance with DOT’s 

Ordering Conditions. 

There is no question that Delta is operating its slots in full compliance with the DOT’s 90-

day dormancy condition. Consequently, Delta’s Seattle-Haneda slots are not dormant by 

definition and are therefore not subject to arbitrary withdrawal and reallocation as urged by 

American and Hawaiian. The dormancy condition associated with Delta’s Seattle-Haneda slots 

could not be more clear: 

The slot pair allocation will remain in effect indefinitely, provided that the holder 

continues to hold the necessary underlying authority to serve the markets 

authorized; and provided further that the slot pair will become dormant and will 

revert automatically to the Department if it is not used for a period of 90 days

(once inaugurated)

Order 2013-2-4, Condition 3, Page 6 

Delta is using its SEA-HND slots at least every 90 days in full compliance with the

condition, and neither American nor Hawaiian claim otherwise. See AA Motion/Answer at 3; 

Hawaiian Motion/Answer at 3. Due to low forecast demand this winter and the rapidlyexpanding but not-yet-mature Seattle hub, it was commercially necessary to make seasonal 

reductions this winter. The Department’s Order allows appropriate flexibility for Delta to do so. 

Delta’s utilization of its SEA-HND slots not only meets the Department’s dormancy 

condition but also complies with the Department’s well-established precedent that when a 

carrier holding unused frequencies has “firm plans” to use them, those frequencies will remain 

with the holder and not be reallocated.1

 See Order 2005-4-13, April 12, 2005, p.3 n5 (declining 

to confiscate and re-allocate to American five U.S.-Brazil frequencies held by United which had 

1 While the “firm plans” line of decisions is fully supportive of Delta’s position, the DOT need not 

reach this question in disposing of American’s motion because Delta has fully complied with the 

dormancy provision in Order 2013-2-4 as quoted above.

 
Delta Answer

Page 4

been dormant since “at least 2003” where United announced on April 4, 2005 that it had firm 

plans to use them effective October 31, 2005); Order 95-3-52, March 27, 1995, p.4 (declining to 

confiscate and re-allocate to American on a permanent basis four U.S.-Brazil frequencies held 

by United where United announced firm plans to use them effective August 1, 1995). 

The Department has never stripped limited entry frequencies from a bona fide holder 

due to a temporary reduction over a single traffic season. It would be unfair, unprecedented, 

unlawful and bad policy to do so here. The 2008 Brazil Combination Case (Order 2008-10-20)

cited by American is inapposite. There, United’s Brazil frequencies were not subject to any 

express dormancy condition. United had allowed its frequencies to go dormant for more than 

three and a half years and had no stated plans to use them. That is in stark contrast to the 

present case, where Delta’s slots will be unused for less than 90 days, over a single off-peak 

season, and where Delta has published a full daily schedule at the start of the Summer 2015 

season. In addition, unlike the United/Brazil proceeding, here the Department’s Ordering 

Conditions state very clearly what the dormancy requirements are, and Delta is complying with 

them. 

2. The Department’s 2013 Decision to Award Delta Seattle-Haneda Slots Remains 

Correct.

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

public interest findings. Nothing has changed that would warrant removing slots that are used 

to operate Seattle’s only Haneda service to fund a third daily flight at Los Angeles or Hawaii. 

Specifically, the Department found that:

• “Delta’s proposal would best serve the public interest by providing the first nonstop 

Haneda service on a significant mainland U.S.-Tokyo route that currently lacks any such 

service, thereby establishing a new U.S. gateway to Haneda.”

• “Delta’s proposed service would further serve the public interest by providing a number 

of western cities with a first one-stop connecting opportunity to Haneda.”

• “Other cities that now enjoy one-stop connections over more southerly gateways would 

gain the option of service over a less circuitous northwest gateway.”
Delta Answer

Page 5

• “[Delta’s proposal] brings first-time Haneda service and first U.S.-flag Haneda service to 

the sixth- largest O&D market, while also promoting the geographic diversity of the U.S.-

Haneda gateways ... consistent with our established approach for the award of limited 

Haneda slot opportunities and would best serve the public interest.”

• “Los Angeles already has two daily nonstop flights to Haneda. Delta serves Los 

Angeles-Haneda with its own flights, and United offers Los Angeles- Haneda service 

through its code share with ANA. Given the very limited opportunities for U.S. carrier 

service to Haneda, we tentatively do not find American’s arguments persuasive for 

adding more Haneda service at Los Angeles while other significant U.S.-Tokyo 

gateways have no access to Haneda.” (emphasis added)

• “the State of Hawaii now enjoys three of eight total U.S.-Haneda route-opportunities

available to U.S. and Japanese carriers. Consistent with our goal of using our limited 

Haneda rights to address a variety of public interest objectives, including the objective of 

geographically diverse gateways, we tentatively find that the public interest would be 

better served by opening Haneda nonstop access to a new region of the country, the 

Pacific Northwest, than by allocating a fourth Haneda route to Hawaii.” (emphasis 

added).

Show Cause Order 2012-11-12 at pp. 5-6; confirmed by Final Order 2013-2-4. 

The case for Seattle-Haneda is even stronger today. Delta is moving aggressively to 

develop Seattle as a hub with new Delta and Delta Connection-operated service, both domestic 

and international. While it has been challenging to establish Haneda service, as we continue to 

implement our Seattle strategy we have seen passenger traffic and profitability surge. In fact, 

Delta’s Summer Season SEA-HND 2014 performance improved by an astounding 54% percent

year-over-year. Buoyed by this unexpectedly strong summer 2014 performance, Delta has 

offered a full pattern of daily Seattle-Haneda service in summer 2015 and anticipates a more 

regular schedule next winter.2

 

Delta’s seasonal reduction this winter – operated in full compliance with DOT’s 

dormancy condition – is a temporary measure that is reasonable and appropriate in the current 

circumstances. Seattle is Delta’s largest West Coast hub and each new “spoke” added to the 

2 In its Motion and Answer (at p. 4) Hawaiian Airlines offers a deliberately selective and 

misleading description of Delta’s filed schedule. In fact, on March 29 and forward through the 

summer season, Delta will operate daily service from SEA to HND.

 
Delta Answer

Page 6

hub makes every other flight stronger. Delta has made major investments in facilities, aircraft, 

marketing and route development at the Seattle hub. As illustrated by the following table, since 

2012, when Delta was first awarded Seattle-Haneda authority, Delta-operated services have 

grown significantly: 

Domestic 

Connections 2012 2013 2014 2015

DL/DL 25 31 65 100

DL*/AS 137 151 107 107

Thus, by the start of the next winter season there will be 100 Delta and Delta connection 

flights supporting Seattle-Haneda service, along with 107 Delta codeshare flights operated by 

Alaska Airlines. The additional 35 flights that will be providing feed for Delta’s SEA hub by 

winter 2015 are a major network improvement over the current winter schedule. Moreover, 

Delta’s own-metal connections – which account for the entire increase - provide stronger and 

more effective feed. Delta’s temporary seasonal reductions reflect responsible commercial 

decision-making in the face of the large losses forecast this winter. Delta is working hard to 

make Seattle-Haneda service a permanent, year-round success, and for all the reasons stated 

herein, it is in the public interest to allow Delta to do so in a manner fully consistent with the 

award conditions.

3. Stripping the Slots from Delta and Reassigning Them to American or Hawaiian 

Would Violate the Administrative Procedure Act. 

As explained above, the actions urged by American and Hawaiian would contravene the 

express terms of Order 2013-2-4 and DOT precedent. Consequently, granting American’s 

Motion and Application would also violate the fundamental fairness and due process 

requirements of the Administrative Procedure Act. Given that Delta is both complying with its 

dormancy condition and meets the well-established “firm plans” line of precedent, the summary 
Delta Answer

Page 7

confiscation and reallocation urged by American and Hawaiian would be arbitrary and 

capricious. “An agency acts arbitrarily and capriciously if it ‘reverses its position in the face of a 

precedent it has not persuasively distinguished,’” New York Cross Harbor RR v. Surface 

Transportation Bd., 374 F.3d 1177, 1181 (D.C. Cir. 2004). 

Having granted Delta Seattle-Haneda slots only last year after a full route proceeding, 

and with not even American alleging that Delta isn’t complying with the Department’s Order, it 

would be both illegal and a policy mistake for DOT summarily revoke and reallocate the slots. 

Airlines need to have certainty to plan and develop service, and need to rely on presumptive 

finality if they comply with the Department’s ordering conditions. It has long been established 

that certificated carriers should enjoy “security of route” and that their operating authorizations 

are protected from summary revocation. See CAB v. Delta Air Lines, 367 U.S. 316, 321-25 

(1961). Any reexamination of Delta’s SEA-HND slot allocation would require, at a minimum, 

notice by the Department that it intended to change the dormancy condition applicable to 

Haneda slots and reasonable opportunity for cure. See DOT Order 2007-12-21 (“the issue is 

whether American was on notice that a change in its proposed plans could lead to a 

reexamination of the frequency allotment. The record demonstrates that it was given such 

notice.”). While the Department could amend the dormancy conditions applicable to U.S.-

Haneda slot holders, it has not and should not propose such a change, and in any event cannot 

impose it retroactively on Delta.

4. American has a Long History of Seasonal Suspensions Due to Seasonal Demand.

Going back at least as far as 2002, American has allowed its limited entry Brazil 

frequencies for months at a time, frequently for periods of 90 days or more. Exhibit DL-1. 

During all this time Delta and other airlines were anxious to obtain more U.S.-Brazil frequencies 

to compete against American’s dominant position in the market.
Delta Answer

Page 8

For example, in July of 2013, American was allocated and operating 109 weekly 

frequencies. Then, in September, American slashed its schedule, suspending 28 frequencies 

(four daily flights), and did not return to its authorized level of 109 frequencies until three months 

later in December:

Travel Period Mktg Al Mon Tue Wed Thu Fri Sat Sun Ops/Week

Jul-13 AA 16 15 15 16 16 16 15 109

Aug-13 AA 15 15 14 16 15 16 14 105

Sep-13 AA 11 11 11 11 11 14 12 81

Oct-13 AA 12 11 12 12 13 14 13 87

Nov-13 AA 12 11 12 12 13 13 12 85

Dec-13 AA 15 16 15 16 16 16 15 109

And yet American was never threatened by the Department with summary revocation of its 

frequencies. Like American, Delta is employing a temporary seasonal adjustment, which in this 

case is intended to preserve and maintain Seattle as a viable U.S.-Haneda gateway. 

5. American Had the Benefit of Three Haneda Slots and Still Enjoys Two Through Its

Immunized Joint Venture with JAL.

Not only could American have reapplied for its own relinquished Haneda slot just a few 

short months ago, it also 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:

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 Answer

Page 9

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

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 

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. 

 
Delta Answer

Page 10

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 

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.

Finally, we note that American’s exhibits filed with its Application reveal that American

has assigned the same flight number to its proposed LAX-HND flight as its existing LAX-NRT 

flight. Exhibit DL-3. American apparently 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. If, as it appears, American intends to move its existing LAX-NRT flight to LAX-HND

there would be no public interest benefits at all to be gained from transferring Seattle’s slots to 

Los Angeles. By contrast, Delta plans to continue to serve NRT from Seattle, and Delta’s 

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

consumers. 

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]nhanced inter-alliance competition is beneficial for consumers across many markets....”)

 
Delta Answer

Page 11

6. Maintaining Delta’s SEA-HND Slots is Critical to U.S. Government Efforts to Open 

Haneda.

Delta strongly supports U.S. Government efforts to open Haneda sufficiently so that all

U.S. carriers, including American, can share in the benefits. Haneda is the largest and most 

important airport in Japan, and is unquestionably the most convenient airport serving downtown 

Tokyo. It is past time to bring Haneda under open skies. The technical talks held on a 

government-to-government basis last month in Tokyo confirmed that it is operationally feasible 

to do so; Haneda has plenty of capacity to allow all US carriers to operate their schedules there. 

It is simply a matter of Japan’s political will.

In order to strike a deal with Japan and open the skies over Haneda, the U.S. 

Government must secure a sufficient pool of slots to meet U.S. carrier needs. The two Haneda 

slots held by Delta represent a small but important step in the direction of what it will take to 

open Haneda. Taking slots from Delta and awarding them to American/oneworld only makes 

the goal of opening Haneda more difficult. As shown in the table above, oneworld holds a 

dominant slot position at Haneda, whereas Delta’s slot holdings are trivial. American would 

have the Department take from the poor to feed the rich. 

When the Department successfully opened London Heathrow to non-incumbents under

the landmark 2007 US-EU open skies agreement, it did not secure sufficient slots to meet all 

U.S. carrier needs. It was understood and expected that the U.S. non-incumbent carriers would

be able look to their immunized alliance partners to fund new, high value, U.S.-Heathrow flying 

from slots that were being used for lower value intra-European service. For example, Air 

France leased slots to Delta, and KLM leased slots to Northwest. In fact, slot leasing or 

transfers among the alliances has been actively discussed as one means of opening Haneda. 

JAL has a huge cache of slots that could be made available to American. In addition, the need 

for intra-Japan flying has been and will continue to be reduced as new bullet train service comes 

online from Tokyo to nearby cities flown from Haneda.
Delta Answer

Page 12

Unlike Heathrow, however, Haneda slots are highly concentrated and principally held by 

JAL and ANA. Delta is in a uniquely difficult position as the only major network carrier serving 

Japan without a Japanese alliance partner. In fact, the incumbent alliance carriers have every 

reason not to make slots available for Delta to compete. It is therefore imperative that the 

Department secure from the Government of Japan the slots that are necessary to move Delta’s 

hub and preserve Delta and SkyTeam as a third competitor in the U.S.-Tokyo marketplace. 

Moving slots from Delta to American is the worst possible public interest outcome, further 

entrenching oneworld at Delta’s expense and moving the goalpost further away in terms of the 

number of actual new slots that will be required to obtain in negotiations with the Government of 

Japan.

American observes that “[t]he Department worked long and hard to restore U.S. carrier 

access to Haneda after more than three decades of absence.” AA Motion/Answer at 3. This 

statement is most ironic considering that Tokyo Haneda was a Delta hub (legacy Northwest) 

until we were forced move to Narita three decades ago. We agree that U.S. carrier access 

should be restored at Haneda, specifically including Delta’s hub operation. 

7. Conclusion.

Delta is operating its Seattle-Haneda slots in full compliance with the Department’s 

dormancy conditions, its public interest findings and its precedent. The Department should 

swiftly deny American’s and Hawaiian’s attempts to confiscate Seattle’s Haneda flight as 

unsupported, unwarranted and unwise. 
Delta Answer

Page 13

Respectfully submitted,

_________________________________

Alexander Van der Bellen

Managing Director, Regulatory and 

International Affairs

 & Associate General Counsel

DELTA AIR LINES, INC.
American has a chronic history of allowing 

limited entry frequencies to remain dormant for 

periods of 90 days or more

Travel Period Mktg Al Mon Tue Wed Thu Fri Sat Sun Ops/Week

Jan-02 AA 7 8 8 8 8 8 7 54

Feb-02 AA 7 8 8 8 8 8 7 54

Mar-02 AA 7 7 7 8 8 8 7 52

Apr-02 AA 7 7 7 8 8 8 7 52

May-02 AA 7 7 7 8 8 8 7 52

Jun-02 AA 8 9 8 9 8 8 9 59

Jul-02 AA 8 9 8 9 8 8 9 59

Aug-02 AA 8 9 8 9 8 8 9 59

Sep-02 AA 8 8 9 9 9 9 9 61

Oct-02 AA 6 5 6 6 5 6 6 40

Nov-02 AA 6 5 6 6 5 6 6 40

Dec-02 AA 6 5 6 6 5 6 6 40

Jan-03 AA 7 6 6 7 6 7 6 45

Feb-03 AA 7 6 6 7 6 7 6 45

Mar-03 AA 7 6 6 7 6 7 6 45

Apr-03 AA 7 6 6 6 6 6 6 43

May-03 AA 5 6 6 6 5 6 6 40

Jun-03 AA 5 6 6 6 5 6 6 40

Jul-03 AA 6 6 6 6 6 6 6 42

Aug-03 AA 6 6 6 6 6 6 6 42

Sep-03 AA 6 6 6 6 6 6 6 42

Oct-03 AA 6 6 6 6 6 6 6 42

Nov-03 AA 6 6 6 6 6 6 6 42

Dec-03 AA 6 6 6 6 6 6 6 42

Jan-04 AA 7 7 7 7 8 8 7 51

Feb-04 AA 7 7 7 7 8 8 7 51

Mar-04 AA 7 7 7 7 8 8 7 51

Apr-04 AA 7 6 6 6 7 7 7 46

May-04 AA 7 6 6 7 7 7 7 47

Jun-04 AA 7 8 8 8 8 8 7 54

Jul-04 AA 7 8 8 8 8 8 7 54

Aug-04 AA 7 8 8 8 8 8 7 54

Sep-04 AA 7 6 7 6 8 7 8 49

Oct-04 AA 7 6 7 6 8 7 8 49

Nov-04 AA 7 6 7 6 8 7 8 49

Dec-04 AA 7 8 8 8 8 8 7 54

DL Exhibit 1

Page 1

= periods of frequency underutilization

(AA U.S.-Brazil frequencies 2002-2014)
American has a chronic history of allowing 

limited entry frequencies to remain dormant for 

periods of 90 days or more

Travel Period Mktg Al Mon Tue Wed Thu Fri Sat Sun Ops/Week

Jan-05 AA 7 8 8 8 8 8 7 54

Feb-05 AA 7 8 8 8 8 8 7 54

Mar-05 AA 7 8 8 8 8 8 7 54

Apr-05 AA 7 8 8 8 8 8 7 54

May-05 AA 7 6 6 7 7 7 7 47

Jun-05 AA 7 8 7 8 8 8 8 54

Jul-05 AA 7 8 7 8 8 8 8 54

Aug-05 AA 7 8 7 8 8 8 8 54

Sep-05 AA 7 6 6 7 8 8 7 49

Oct-05 AA 7 6 6 7 8 8 7 49

Nov-05 AA 7 8 7 8 8 8 8 54

Dec-05 AA 6 7 6 7 7 7 7 47

Jan-06 AA 8 8 8 9 8 9 9 59

Feb-06 AA 7 7 7 8 7 8 8 52

Mar-06 AA 6 7 6 7 7 7 7 47

Apr-06 AA 6 5 5 7 7 7 6 43

May-06 AA 6 5 5 7 7 7 6 43

Jun-06 AA 6 5 5 7 7 7 7 44

Jul-06 AA 6 7 6 7 7 7 7 47

Aug-06 AA 6 7 6 7 7 7 7 47

Sep-06 AA 6 5 5 5 6 6 6 39

Oct-06 AA 6 5 5 5 6 6 6 39

Nov-06 AA 6 5 5 7 6 7 7 43

Dec-06 AA 7 7 7 8 8 8 8 53

Jan-07 AA 7 8 7 8 8 8 8 54

Feb-07 AA 7 7 7 7 7 7 7 49

Mar-07 AA 6 7 7 7 7 7 6 47

Apr-07 AA 6 5 5 6 6 6 6 40

May-07 AA 6 5 5 6 6 6 6 40

Jun-07 AA 6 5 5 8 8 8 7 47

Jul-07 AA 6 8 7 8 8 8 7 52

Aug-07 AA 6 7 6 7 7 7 7 47

Sep-07 AA 6 5 5 5 6 6 6 39

Oct-07 AA 6 5 5 5 6 6 6 39

Nov-07 AA 7 7 7 7 7 6 6 47

Dec-07 AA 7 7 7 7 8 8 7 51

DL Exhibit 1

Page 2
American has a chronic history of allowing 

limited entry frequencies to remain dormant for 

periods of 90 days or more

Travel Period Mktg Al Mon Tue Wed Thu Fri Sat Sun Ops/Week

Jan-08 AA 8 8 8 7 8 8 7 54

Feb-08 AA 7 7 7 6 7 7 6 47

Mar-08 AA 7 7 7 6 7 7 5 46

Apr-08 AA 5 6 5 6 6 6 6 40

May-08 AA 5 6 5 6 6 6 6 40

Jun-08 AA 6 8 6 8 7 8 8 51

Jul-08 AA 7 8 7 8 7 8 8 53

Aug-08 AA 6 7 6 7 7 7 7 47

Sep-08 AA 6 7 6 7 6 7 6 45

Oct-08 AA 6 7 6 7 6 6 6 44

Nov-08 AA 8 9 8 8 8 9 7 57

Dec-08 AA 8 9 8 9 10 10 10 64

Jan-09 AA 9 11 10 9 10 10 10 69

Feb-09 AA 8 8 8 8 9 9 9 59

Mar-09 AA 8 8 7 8 8 9 8 56

Apr-09 AA 6 8 7 7 7 8 7 50

May-09 AA 6 8 7 7 7 8 7 50

Jun-09 AA 6 8 7 8 8 9 9 55

Jul-09 AA 7 9 6 10 7 10 9 58

Aug-09 AA 7 9 6 10 7 10 9 58

Sep-09 AA 6 6 6 6 6 8 7 45

Oct-09 AA 6 6 6 6 6 8 7 45

Nov-09 AA 6 7 6 8 8 9 9 53

Dec-09 AA 8 8 8 8 8 10 9 59

Jan-10 AA 8 9 8 8 8 10 9 60

Feb-10 AA 8 9 8 8 8 9 9 59

Mar-10 AA 8 8 8 8 8 9 9 58

Apr-10 AA 7 8 7 8 7 8 7 52

May-10 AA 7 8 7 8 7 8 7 52

Jun-10 AA 7 8 7 9 8 9 8 56

Jul-10 AA 8 10 8 9 9 9 9 62

Aug-10 AA 8 10 8 9 9 9 8 61

Sep-10 AA 7 9 7 9 7 9 7 55

Oct-10 AA 7 9 7 9 7 9 7 55

Nov-10 AA 7 9 7 9 7 9 7 55

Dec-10 AA 9 9 10 9 10 11 11 69

DL Exhibit 1

Page 3
American has a chronic history of allowing 

limited entry frequencies to remain dormant for 

periods of 90 days or more

Travel Period Mktg Al Mon Tue Wed Thu Fri Sat Sun Ops/Week

Jan-11 AA 10 11 11 11 11 12 11 77

Feb-11 AA 10 11 11 10 10 12 11 75

Mar-11 AA 9 10 10 10 10 12 11 72

Apr-11 AA 7 9 9 10 9 11 9 64

May-11 AA 7 9 9 10 9 11 9 64

Jun-11 AA 7 9 9 10 10 11 10 66

Jul-11 AA 10 11 10 10 10 11 10 72

Aug-11 AA 10 11 10 10 10 11 10 72

Sep-11 AA 7 9 9 10 9 11 9 64

Oct-11 AA 7 9 9 10 9 11 9 64

Nov-11 AA 7 9 9 10 10 11 10 66

Dec-11 AA 8 11 11 12 13 12 13 80

Jan-12 AA 12 13 13 12 13 12 13 88

Feb-12 AA 12 13 12 11 11 12 11 82

Mar-12 AA 10 12 11 11 11 12 11 78

Apr-12 AA 9 10 9 10 9 11 9 67

May-12 AA 9 10 9 10 9 11 9 67

Jun-12 AA 9 10 9 12 12 12 12 76

Jul-12 AA 12 13 12 12 12 12 12 85

Aug-12 AA 12 13 12 12 12 12 12 85

Sep-12 AA 10 11 10 11 10 12 10 74

Oct-12 AA 11 12 11 12 11 13 11 81

Nov-12 AA 11 13 12 13 14 14 13 90

Dec-12 AA 13 14 14 16 16 16 15 104

Jan-13 AA 16 15 16 16 16 16 15 110

Feb-13 AA 16 15 16 16 16 16 15 110

Mar-13 AA 15 14 14 15 15 15 14 102

Apr-13 AA 13 12 12 13 13 15 13 91

May-13 AA 13 12 12 13 13 15 13 91

Jun-13 AA 13 13 15 16 16 16 15 104

Jul-13 AA 16 15 15 16 16 16 15 109

Aug-13 AA 15 15 14 16 15 16 14 105

Sep-13 AA 11 11 11 11 11 14 12 81

Oct-13 AA 12 11 12 12 13 14 13 87

Nov-13 AA 12 11 12 12 13 13 12 85

Dec-13 AA 15 16 15 16 16 16 15 109

DL Exhibit 1

Page 4
American has a chronic history of allowing 

limited entry frequencies to remain dormant for 

periods of 90 days or more

Travel Period Mktg Al Mon Tue Wed Thu Fri Sat Sun Ops/Week

Jan-14 AA 16 17 17 17 18 17 17 119

Feb-14 AA 16 17 17 17 18 17 17 119

Mar-14 AA 14 13 13 14 14 15 14 97

Apr-14 AA 14 12 14 13 14 15 14 96

May-14 AA 16 17 16 17 17 17 16 116

Jun-14 AA 16 16 17 17 17 17 16 116

Jul-14 AA 17 16 17 17 17 17 15 116

Aug-14 AA 17 16 17 17 17 17 15 116

Sep-14 AA 13 12 13 13 13 14 13 91

Oct-14 AA 13 12 13 13 13 15 14 93

DL Exhibit 1

Page 5
DL Exhibit 2

American Airlines certified that it has 

implemented a metal neutral, antitrust immune 

joint venture with Japan Airlines
American apparently intends to replace its 

AA flight # 169/170 LAX-NRT flights 

with AA flight # 169/170 LAX-HND flights

This cancels out an marginal public benefit 

AA may claim for its HND proposal

Mktg Al Alliance Op Al Orig Dest Miles Flight Stops Equip Seats

AA oneworld AA LAX NRT 5,451 169 0 777 247

AA oneworld AA NRT LAX 5,451 170 0 777 247

Current AA LAX-NRT Schedules as published in OAG

AA LAX-HND schedules now proposed in OST-2010-0018 

DL Exhibit 3
CERTIFICATE OF SERVICE

A copy of the foregoing document has been served this 17th day of October, 2014, upon 

the following persons via email:

howard.kass@aa.com

abigail.donovan@aa.com

robert.wirick@aa.com

charles.hunnicut@thompsonhine.com

patricia.snyder@thomsponhine.com

jhill@cooley.com

perkmann@cooley.com

bberlin@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