BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

------------------------------------------------------------------------

Applications of :

:

HAWAIIAN AIRLINES, INC. :

and : Docket DOT-OST-2010-0018

UNITED AIRLINES, INC. : 

:

in the matter of 2010 U.S.-Haneda :

Combination Service Allocation Proceeding :

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MOTION OF UNITED AIRLINES, INC.

FOR A 35-DAY START-UP EXTENSION

Communications with respect to this document should be sent to:

Hershel I. Kamen

Senior Vice President-Alliances,

 Regulatory and Policy

Daniel A. Weiss

Managing Director-International

 Affairs and Regulatory

UNITED AIRLINES, INC.

233 South Wacker Drive

10th Floor – HDQIZ

Chicago, IL 60606

(872) 825-6828

hershel.kamen@united.com

dan.weiss@united.com

Steve Morrissey

Managing Director-Regulatory Affairs 

 and Policy

Karine R. Faden

Managing Counsel-Regulatory, Antitrust &

 Competition

UNITED AIRLINES, INC.

1225 New York Avenue, NW

Suite 1100 – DCAIZ/DCALD

Washington, DC 20005

(202) 521-4373

(202) 521-4363

steve.morrissey@united.com

karine.faden@united.com

April 11, 2014

Thomas Newton Bolling

Vice President and Deputy General Counsel

Abby L. Bried

Associate General Counsel-Regulatory, 

 Alliances & International

UNITED AIRLINES, INC.

233 South Wacker Drive

11th Floor – HDQLD

Chicago, IL 60606

(872) 825-8068

(872) 825-7415

thomas.bolling@united.com

abby.bried@united.com

Gerald F. Murphy

Steven J. Seiden

CROWELL & MORING LLP

1001 Pennsylvania Avenue, NW

Washington, DC 20004

(202) 624-2500

gmurphy@crowell.com

sseiden@crowell.com

Counsel for

United Airlines, Inc.
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

------------------------------------------------------------------------

Applications of :

:

HAWAIIAN AIRLINES, INC. :

and : Docket DOT-OST-2010-0018

UNITED AIRLINES, INC. : 

:

in the matter of 2010 U.S.-Haneda :

Combination Service Allocation Proceeding :

------------------------------------------------------------------------

MOTION OF UNITED AIRLINES, INC.

FOR A 35-DAY START-UP EXTENSION

United1requests a 35-day start-up extension, from September 26, 2014 until October 31, 

2014, to inaugurate its daily nonstop service between San Francisco and Tokyo Haneda. 

Recognizing the important public benefits that United’s San Francisco-Tokyo Haneda 

service will provide, the Department awarded United the one daily slot pair that was available in 

this proceeding by Order 2014-4-6. That award is subject to a start-up condition that United 

commence service “within 180 days of March 30, 2014,” or by September 26, 2014. Order 

2014-4-6 at 3. As the IATA Winter Season begins just a few short weeks thereafter on October 

26, 2014 and United will only be able to secure the slot times at Tokyo Haneda best suited to its

San Francisco service as of that date,2 United requests a 35-day extension of the Department’s 

start-up condition.3 The modest extension United seeks will allow it to more efficiently plan, 

 

1 Common names are used for airlines.

2

The slot times that United was able to secure for the interim 30-day period 

between September 26, 2014 and the beginning of the IATA Winter Season would potentially

create marketability, network connectivity and aircraft flow issues. Granting United’s short 

extension request will address this issue completely.

3 United intends to commence its San Francisco-Tokyo Haneda service on October 

26, 2014, but in no event later than on October 31, 2014.