BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D. C.

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

In the matter of :

: DOT-OST-2010-

2010 U.S.-Haneda Combination Services : 0018

Allocation Proceeding :

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

ANSWER OF AMERICAN AIRLINES, INC. TO MOTION OF

DELTA AIR LINES, INC. FOR DORMANCY WAIVER

Communications with respect to this document should be sent to:

VIRASB VAHIDI WILLIAM K. RIS, JR.

Senior Vice President - Senior Vice President -

Marketing and Planning Government Affairs

and Chief Commercial Officer American Airlines, Inc.

American Airlines, Inc. 1101 17th Street, N.W.

P.O. Box 619616, MD 5634 Washington, D.C. 20036

DFW Airport, Texas 75161

CARL B. NELSON

KENJI C. HASHIMOTO Associate General Counsel 

Vice President – Strategic American Airlines, Inc.

Alliances 1101 17th Street, N.W. 

American Airlines, Inc. Washington, D.C. 20036

P.O. Box 619616, MD 5635 (202) 496-5647

DFW Airport, Texas 75261 carl.nelson@aa.com

ROBERT A. WIRICK

Director, Regulatory Affairs

American Airlines, Inc.

P.O. Box 619616, MD 5635

DFW Airport, Texas 75261

(817) 963-0394

robert.wirick@aa.com

June 14, 2011
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D. C.

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

In the matter of :

: DOT-OST-2010-

2010 U.S.-Haneda Combination Services : 0018

Allocation Proceeding :

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

ANSWER OF AMERICAN AIRLINES, INC. TO MOTION OF

DELTA AIR LINES, INC. FOR DORMANCY WAIVER

 American Airlines, Inc. hereby answers the motion filed 

by Delta Air Lines, Inc. on June 3, 2011 seeking a dormancy 

waiver for the seven weekly Detroit-Haneda slots (frequencies)

that Delta received in the captioned proceeding by Order 2010-7-

2, July 2, 2010. 

 In its motion, Delta cites “the lingering effects of the 

Japanese earthquake” (p. 1) and states that it requires the 

waiver in order to have “the flexibility to respond to difficult 

and unexpected market conditions” (p. 4). 

 American is also being challenged by very difficult

conditions in the U.S.-Tokyo market which are adversely

impacting our New York (JFK)-Haneda operations. American is 

committed to making this route succeed, and is devoting 

substantial marketing and other resources to that end.

 
- 2 -

 We do not oppose Delta’s motion and agree that Delta has 

provided compelling reasons for the Department to review the 

Haneda situation. However, American would like to offer a 

somewhat different perspective because we intend to continue our 

Haneda service without further interruption. 

 To be in the best position to do so, we are interested in 

extra-bilateral authorization to depart Haneda in the 2300 hour. 

Under Section 3 of the U.S.-Japan Memorandum of Understanding 

initialed on December 11, 2009 and signed on October 25, 2010, 

scheduled combination service “is permitted at Haneda between 

2200 and 0700 hours local time,” subject to the additional

condition that “departures from Haneda to a point in the 48 

contiguous U.S. states shall not be permitted prior to 

midnight.” 

 The operating environment would substantially improve, 

and American’s New York (JFK)-Haneda service would have far 

greater prospects for long-term viability, if we could leave

Haneda in the 2300 hour, which is before the midnight departure

requirement in the MOU. With this proposed change, and assuming 

that American is able to secure the slots to support it, we feel 

that JFK-Haneda will have a substantially better chance of 

succeeding.
- 3 –

 The modest relief American desires should be granted on 

an interim extra-bilateral basis pending amendment of the MOU. 

See Lan Airlines and Lan Cargo, DOT-OST-2005-23236, Notice of 

Action Taken, April 13, 2006 (granting authority as being in the 

public interest despite lack of an applicable bilateral 

provision); Continental/Alitalia Codeshare, Order 94-9-4, 

September 6, 1994 (granting extra-bilateral authority as being 

in the public interest and citing likely approval by the 

Government of Italy); Delta/Varig Codeshare, Order 94-3-33, 

March 18, 1994 (granting extra-bilateral authority as being in 

the public interest and citing likely approval by the Government 

of Brazil). 

 The MOU specifically states with respect to Haneda that

“the delegations affirmed that the provisions of Section 3 of 

the Annex of the 2009 MOU may be amended by agreement of the 

Parties . . . and the delegations expressed their willingness to 

consider amendments on an expedited basis if operational or 

commercial considerations so justify.” 
- 4 -

 The requested adjustment is amply supported by 

“operational or commercial considerations” related to the stage 

length of the New York (JFK)-Haneda route (6,733 miles) that do 

not apply to the shorter Honolulu (3,844 miles) and Los Angeles 

routes (5,468 miles). The action we are seeking will enhance 

the viability of our New York (JFK)-Haneda service, and should 

be granted as consistent with the public interest. 

 American has reason to believe that the Government of 

Japan would not object to interim extra-bilateral relief from 

the midnight departure condition while formal amendments to the 

Haneda operating window are being considered. Indeed, we 

believe that the Japanese Government is prepared to immediately 

eliminate the midnight provision altogether, resulting in a 

single operating window, from 10 pm to 7 am, for all departures 

to, or arrivals from, the United States. 

 As the Department considers Delta’s request for a 

dormancy waiver (which would permit Delta to suspend service),

the Department should at the same time consider American’s 

request to adjust the Haneda departure window in order to help 

American to maintain service. 
- 5 -

 With the ability to depart Haneda earlier than midnight, 

we can improve our New York (JFK)-Haneda schedules, and enhance 

the viability of our Haneda flights during a time of very 

challenging conditions in the U.S.-Tokyo market.

 Respectfully submitted,

 _____________________________ 

 CARL B. NELSON

 Associate General Counsel

 American Airlines, Inc.

June 14, 2011
CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing document by email 

on the following persons:

sascha.vanderbellen@delta.com jhill@dlalaw.com

scott.mcclain@delta.com bill@mietuslaw.com

sametta.c.barnett@delta.com mgoldman@sgbdc.com

kquinn@pillsburywinthrop.com rsilverberg@sgbdc.com

bkeiner@crowell.com dhainbach@ggh-airlaw.com

esahr@eckertseamons.com mcmillin@woa.com

bruce.rabinovitz@wilmerhale.com eskraft@jamhoff.com

jeffrey.manley@united.com dpdean@jamhoff.com

bob.kneisley@wnco.com dkirstein@yklaw.com

robert.land@jetblue.com jyoung@yklaw.com

msinick@ssd.com William.stallings@usdoj.gov

cdonley@ssd.com dwight.moore@ustranscom.mil

gbleopard@fedex.com john.allen@faa.gov

david.heffernan@wilmerhale.com urskr@state.gov

kevin.montgomery@polaraircargo.com recohn@hoganlovells.com

jrichardson@johnlrichardson.com cjsimpson@zsrlaw.com

lhalloway@crowell.com pmurphy@lopmurphy.com

efaberman@wileyrein.com lachter@starpower.net

mroller@rollerbauer.com anita.mosner@hklaw.com

howard.kass@usairways.com jennifer.nowak@hklaw.com

benjamin.slocum@usairways.com gmurphy@crowell.com

dan.weiss@coair.com russell.bailey@alpa.org

rpommer@atlasair.com Thomas.bolling@coair.com

annalei.avancena@united.com Paul.Gretch@dot.gov

keith.glatz@dot.gov esta.rosenberg@dot.gov

todd.homan@dot.gov Eugene_alford@ita.doc.gov

info@airlineinfo.com

________________________________

CARL B. NELSON

June 14, 2011