BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Motion of 

DELTA AIR LINES, 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 – Network Planning

 & Revenue Management

Robert J. Cortelyou

Senior Vice President – Network Planning

Andreas Renner

Director – International Network Planning

DELTA AIR LINES, INC.

1030 Delta Boulevard

Atlanta, Georgia 30320

Andrea Fischer Newman

Senior Vice President – Government Affairs

DELTA AIR LINES, INC. 

1212 New York Avenue, N.W. 

Washington, D.C. 20005

Alexander Van der Bellen

Managing Director – Government Affairs

 & Associate General Counsel

DELTA AIR LINES, INC. 

1212 New York Avenue, N.W. 

Washington, D.C. 20005

(202) 842-4184

sascha.vanderbellen@delta.com

September 13, 2012
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Motion of 

DELTA AIR LINES, INC. 

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

Services Allocation Proceeding

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)

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Docket DOT-OST-2010-0018 

CONSOLIDATED REPLY OF DELTA AIR LINES, INC.

The Applications and Answers filed in this proceeding present the Department with 

some important choices. First, whether the slots at issue should be used to establish 

service at a large and important new U.S.-Haneda gateway, or whether they should be used 

to duplicate service in existing U.S.-Haneda markets. Second, whether the slots should be 

used to preserve and enhance 3-way alliance competition in the U.S.-Haneda and U.S.-

Tokyo marketplace, or to further strengthen the dominant U.S.-Japan immunized alliances

at the expense of the only unaligned U.S.-Japan network competitor. Third, whether U.S. 

citizens and U.S. businesses should enjoy the important convenience of new service to 

Tokyo’s preferred downtown airport, or whether Japanese tourists should have a fourth 

Haneda flight to the Hawaiian Islands. 

Delta believes the answers to these questions are clear and lead to the inevitable 

conclusion that Delta’s motion for flexibility to move its existing slots from Detroit to Seattle 

should be granted. 

This is no ordinary route case. It is also a critically important case regarding the 

Department’s continuing public interest oversight of its antitrust immunity authority. In this 

case, United has made bold claims as to its status as a “new entrant competitor” at Haneda

that are contrary to the “metal neutral” joint venture benefits it claimed to gain antitrust 
Delta Reply

Page 2

immunity with ANA. Delta believes that metal neutrality is a business model, not a concept

of regulatory expedience. Delta does not consider itself an independent competitor against 

any of its antitrust immunized partners. United’s “new entrant” competitor claim in the face 

of its immunized metal neutral joint venture with ANA bears close scrutiny and should be 

weighed carefully in this important decision which will have a major impact on U.S.-Haneda 

and U.S.-Japan alliance competition. 

I. Executive Summary

Seattle is the largest U.S.-Tokyo O&D gateway that does not have nonstop service 

to Haneda. It is the also the largest west coast business center without Haneda service, 

placing Seattle and the Pacific Northwest region at a disadvantage to the existing west coast 

gateways of San Francisco and Los Angeles. Delta’s proposal should be ranked first for the 

following reasons:

• Seattle will be established as a new gateway, providing 114,000 annual 

Tokyo passengers with new nonstop access to Haneda.1

 New intergateway 

competition will be created with San Francisco and Los Angeles which both 

have one or more Haneda flights.

• 32 cities will receive round-trip connections, and an additional 10 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 gain its first convenient access to Haneda 

because the existing west coast gateways are too far south and 

unreasonably circuitous. 

• The Delta/Alaska domestic marketing alliance will allow Alaska Airlines to 

bring its Seattle network into play, improving service and competition for U.S.-

Haneda passengers. Alaska and its employees will benefit from the 

additional traffic flowing across their system. 

• 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.

 1 See, DL-201 (MIDT data adjusted to account for direct sales). 
Delta Reply

Page 3

• Unlike United and American, Delta will create a new nonstop Haneda 

gateway at Seattle, rather than duplicating existing Haneda services at San 

Francisco and Los Angeles.

• 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. Hawaii already has three nonstop 

Haneda flights while Seattle and the Pacific Northwest region have none. 

Delta’s request to improve the utilization of its Haneda slots by moving them from 

Detroit to Seattle is clearly in the public interest. Delta’s request is also consistent with 

market-based principles that are fundamental to U.S. open skies policy. The Department’s 

current distribution of Haneda slots promotes rough parity between the alliances with Delta 

having two slot pairs, Star two slot pairs, and oneworld three slot pairs. However, while 

Delta is limited to the Haneda gateways selected in the 2010 route case, Star and oneworld 

have commercial discretion to select their own Haneda gateways and redeploy the Haneda 

slots operated by ANA and JAL under their metal neutral joint venture alliances. 

The Department can improve market-based competition at Haneda – and generate 

important new nonstop and network service benefits – by allowing Delta the flexibility to 

operate from its preferred U.S. mainland gateway at Seattle. It is both reasonable and 

commercially necessary for Delta to make network adjustments to improve under-performing 

flights. While Delta respects the regulatory requirement for this comparative selection 

proceeding, it would not be in the public interest for the Department to deprive Delta of the 

Haneda slots it needs to compete with the U.S.-Japan immunized alliances. 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 transpacific 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. 
Delta Reply

Page 4

II. Delta’s Seattle-Haneda Service Proposal Will Maximize Public Benefits. 

A. Delta’s Seattle-Haneda Proposal Will Create Important Service Benefits for 

the Traveling Public

Seattle is the largest U.S.-Tokyo O&D gateway without Haneda service. DL-R-101. 

In addition, the Seattle gateway competes with San Francisco and Los Angeles for U.S.-

Tokyo traffic and is disadvantaged in not being able to offer service to Haneda. DL-R-212, 

214, 410, 411.

Delta, together with its partner, Alaska Airlines, will be able to offer convenient 

nonstop-to-nonstop Haneda service at Seattle to 42 connecting cities – extending the 

benefits of Haneda service to the Pacific Northwest region and throughout the United 

States. DL-R-102, 103, 213, 410. Delta has built a successful international gateway at 

Seattle and will succeed in the Haneda market as it has in other international markets. 

Seattle’s demographic and business metrics support the establishment of Haneda service at 

the Seattle gateway. Seattle ranks near the top of 50 U.S. metropolitan areas in categories 

such as exports, growth, and household income. And, in 2011, two-way trade between the 

State of Washington and Japan surpassed $24 billion. (Answer of Seattle, p. 2). Yet, unlike 

the other major west coast business centers of San Francisco and Los Angeles, Seattle 

does not have any service to Tokyo’s preferred downtown airport. 

DOT can best achieve the public interest objectives it seeks to attain in this 

proceeding by allowing Delta to offer Haneda service at the Seattle gateway. This will 

enable Delta to better compete on the west coast with the services of the immunized 

alliance carriers. 

B. Delta’s Proposal Will Preserve 3-Way Alliance Competition at Haneda and 

Enhance the Competitive Market Structure. 

When it first allocated the Haneda slots at issue, the Department did not weigh the 

impact that the pending United and American ATI applications would have on U.S.-Haneda 

and U.S.-Tokyo service and competition. (Order to Show Cause, 2010-5-7, page 8; Final 
Delta Reply

Page 5

Order 2010-7-2, page 6). However, now that United and American have been granted 

antitrust immunity with their Japanese partners, DOT has properly indicated that in 

considering Delta’s request to move its Haneda slots from Detroit to Seattle, DOT intends to 

consider the “overall competitive environment” and “market structure.” Order 2012-8-20, 

page 3. Permitting Delta to serve the Seattle gateway in competition with San Francisco 

and Los Angeles will satisfy the DOT’s competition and market structure objectives. 

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 American/JAL at San Francisco and United/ANA at Los 

Angeles. The DOT has consistently sought to promote inter-alliance competition.2

 By 

approving Delta’s request, the Department will achieve this objective. 

III. Delta’s Seattle-Haneda Proposal Merits Priority Over the Competing 

Applications.

A. Reply to United. 

Delta’s proposal to provide Seattle with its first nonstop Haneda flight should be 

ranked above United’s proposal to add a second San Francisco service for the following 

reasons: 

• United operates a metal neutral joint venture with ANA, the largest hub 

operator at Haneda. A further award to United/Star would undermine alliance 

competition with Star and oneworld each having three Haneda flights to 

Delta’s one.

• San Francisco already has nonstop Haneda service (on JAL), and United and 

ANA have discretion under their metal-neutral joint venture to add a second 

 2 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 Reply

Page 6

daily flight if that is the best use of the slot pair for the alliance. San 

Francisco should not receive a second Haneda flight at the expense of 

Seattle’s first nonstop service.

• United will rationalize San Francisco-Narita service, canceling out the 

benefits of its proposed Haneda flight. United admits that it intends to 

operate “at least one daily Tokyo Narita flight” – whereas United currently 

operates two daily Tokyo Narita flights for seven months of the year. (UA app 

at n.4) By contrast, Delta’s daily full year-round Seattle-Narita service will be 

maintained and the new Haneda flight will produce true incremental benefits.

In carrier selection cases, the Department has long emphasized the importance of 

“provid[ing] consumers with the special convenience of nonstop service in a market that 

does not receive it.” Order 98-12-33 at 7. Delta’s Seattle-Haneda proposal would create 

this important new convenience, while United’s proposal would merely duplicate existing 

nonstop service on the San Francisco-Haneda route. 

(1) Seattle is a strong and growing Delta international hub. 

United attempts to denigrate Seattle as a “non-hub” for Delta, and is dismissive of 

the extensive online network provided by the Delta/Alaska domestic codeshare alliance. 

United’s criticism is without merit and has been proven false by the marketplace. DL-R-202, 

203. Seattle is a strong and growing international hub for Delta which currently supports 

nonstop service to Beijing, Osaka, Narita, Paris and Amsterdam. DL-R-204. Seattle is a 

cornerstone of Delta’s West Coast international route network and can readily support 

additional nonstop destinations, including Haneda. Delta has made major investments in 

facilities, aircraft, marketing and route development at the Seattle hub.

Delta’s partnership with Alaska Airlines is a critical component of Delta’s Seattle hub, 

which supports the growth and expansion of Delta international service. As well put by 

Alaska in its Answer, the Delta/Alaska marketing alliance is a deep and longstanding 

partnership and is much more than a “vanilla codeshare agreement.” (page 3). Under the 

enhanced agreement signed in 2008, Alaska has committed to provide dedicated 
Delta Reply

Page 7

international feed to support Delta’s international flights. Already, more than 200,000 annual 

passengers connect from the DL*/Alaska codeshare network onto Delta international flights, 

and that number continues to increase year after year. The combined Delta/Alaska network 

from Seattle provides a robust combination of nonstop and online connecting feed that is 

equivalent to the network United (and its connection carriers) operate at San Francisco. DLR-202, 203.

United claims that its San Francisco hub is larger than Delta/Alaska at Seattle, but as 

proved by its own exhibits, the number of nonstop destinations is the same (70), and the 

number of weekly flights is comparable. DL-R-203. More importantly, Seattle is the better 

and more effective gateway for Haneda connecting passengers. Delta will provide more 

new cities with first one stop Haneda service than United (18 vs. 13). DL-R-201. Delta will 

better serve the Pacific Northwest region, which has no nonstop Haneda gateway today. 

DL-R-212. And, in almost all cases, service via Seattle is more direct and less circuitous 

than service over San Francisco. Id. 

(2) United and ANA are Immunized Joint Venture Partners. 

To read United’s Answer one would think that United is alone in the marketplace and 

foreclosed from competing at Haneda. United ignores its metal neutral joint venture with 

ANA (DL-R-205) -- which makes Star the single largest competitor in the U.S.-Japan 

marketplace and the largest hub operator at Haneda. DL-R-105, 106. United’s Answer

makes the incongruous claim that it is “the only applicant that can bring new competition to 

Tokyo Haneda.” (page 1) United complains that it is “the only U.S. carrier serving Japan 

not permitted to operate at Haneda . . .” (page 7). However, United ignores the important 

benefits it has reaped from its alliance with ANA in the U.S.-Japan and U.S.-Haneda 

marketplace. 
Delta Reply

Page 8

United emerged from the 2010 U.S.-Japan open skies talks as the most richly 

rewarded U.S. carrier. United and Continental were each granted antitrust immunity with 

ANA – the strongest and healthiest Japanese carrier with the largest transpacific network 

and the biggest Haneda hub. That same year, United and Continental were granted 

permission to merge with each other, surpassing Delta to become the world’s largest carrier, 

and, together with ANA, became the largest single competitor in the U.S.-Tokyo market. 

Today, Star enjoys a 41 percent market share compared to 27 percent for Delta. DL-R-106.

United codeshares on each and every one of ANA’s U.S.-Japan flights, including ANA’s 

U.S.-Haneda services. DL-R-207. And, under the revenue sharing joint venture which 

United and ANA have certified they have implemented, United has the opportunity to share 

in the benefits of Haneda through its metal neutral alliance. DL-R-205.

For Delta’s part, the 2010 open skies agreement produced two formidable 

consolidated competitors: Star and oneworld immunized alliances -- each with inherent 

advantages in terms of network scope and Haneda incumbency. The only new competitive 

tools Delta was given to combat these challenges were its two limited Haneda slot pairs. 

United’s suggestion that these slots should be taken from Delta and given to United to 

“provide competitive parity among U.S. carriers at Haneda” (page 4) is incredulous. 

Delta would trade both of its Haneda slots for the advantage of antitrust immunity 

with a Japanese partner. Delta tried very hard to secure a Japanese partner, but was 

unsuccessful. While Delta accepts the challenge of being the lone independent network 

competitor in the U.S.-Japan market, the Department should avoid further injury to Delta’s 

competitive position that would result from enriching the dominant Star ATI alliance at 

Delta’s expense. DL-R-208.

United and ANA have the largest alliance and are the single biggest competitor in the 

U.S.-Japan marketplace. Without that immunity, United and ANA would be each other’s
Delta Reply

Page 9

largest competitors. As shown in the following table, United and ANA overlap on seven

U.S.-Tokyo nonstop routes:

United ANA 

Los Angeles-Narita Los Angeles-Narita 

New York City-Narita New York City-Narita 

Honolulu-Narita Honolulu-Narita 

San Francisco-Narita San Francisco-Narita 

Seattle-Narita Seattle-Narita 

Chicago-Narita Chicago-Narita 

Washington D.C.-Narita Washington D.C.-Narita 

Houston-Narita 

(DL-R-206).

United claims that it would be a “new competitor” at Haneda, but “new competition” could

also be created on each of the United/ANA nonstop overlap routes by removing the antitrust 

immunity that exists today. There is no reason competition at Haneda should be viewed

differently from any other U.S.-Japan route served by the antitrust immunized United/ANA

joint venture. United argued vigorously and the Department accepted that greater public 

benefits would be achieved through an immunized joint venture and “a truly metal neutral 

network” --

In the current environment, the two sets of parties are unable to cooperate on fares, 

route coordination, and other business plans on a network-wide basis because of the 

risk of a legal challenge. As such, the carriers are currently unable to implement 

many of the provisions that would deliver the most significant consumer benefits: 

joint pricing, joint scheduling, and network coordination. . . . Absent the ability to 

share revenues and establish a truly metal-neutral network, the alliances would also 

lack the commercial incentive to fully integrate their networks."

Japan ATI Show Cause Order 2010-10-4 at 15 (emphasis added). 

As correctly stated by the Department when it approved the United/ANA immunized 

alliance: "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. 
Delta Reply

Page 10

United cannot be a “new competitor” at Haneda because it has already been effectively 

merged with ANA for purposes of U.S.-Japan service and competition. 

United cannot have it both ways. Either United and ANA are competitively merged 

and commercially integrated members of the Star ATI alliance or United and ANA have 

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

the benefit of antitrust immunity.3 The Department should carefully examine the 

contradictory positions taken by United in the Star ATI and Haneda route case proceedings. 

(3) Star has multiple options to fund San Francisco-Haneda service and increase 

direct participation by United in the U.S.-Japan market.

United protests that Star cannot move its Los Angeles-Haneda flight to San 

Francisco because it produces important consumer benefits in its own right. However, 

United ignores the fact that Star holds a second pair of Haneda slots which ANA uses to 

provide B767 service between Haneda and Honolulu. DL-R-210. Like Hawaiian’s HanedaKona service to which United objects in this case, Haneda-Honolulu serves almost 

exclusively Japanese tourists.

The United/ANA joint venture made the commercial decision that Honolulu-Haneda 

is more important than San Francisco-Haneda. This is understandable because Honolulu is 

a highly lucrative market for carriers, and less expensive to operate than long-haul service to 

the United States. Having made that judgment, however, Star should not receive a third slot 

pair for San Francisco leaving Delta with just one pair. DL-R-208. In the face of scarce 

Haneda resources, each alliance must make rational business choices on which routes to 

 3 Delta is not questioning United’s claim to metal neutrality merely because United is an 

applicant in this proceeding. (UA Ans. At n.2) United has made metal neutrality an issue 

because it claims to be a distinct U.S. flag competitor apart from its immunized alliance. 

American makes no such claim. American was awarded Haneda slots at a different point in 

time before immunity had been granted to Star and oneworld. In the current competitive 

environment, taking Haneda slots from Delta (with no Japan partner) and awarding them to 

United (with the largest immunized alliance) can hardly be seen as “equal treatment.” 
Delta Reply

Page 11

serve. While United and ANA are free to make those decisions at their own discretion, 

Delta must seek permission from the Department to change gateways. United has provided 

insufficient basis to disturb the current equitable distribution of slots with Star and Delta 

holding two pairs each. 

While it is understandable that United and its pilots would like to increase U.S. carrier 

flying to Japan, it is not necessary for United to receive Haneda slots in order to do so. 

Under its metal neutral joint venture with Air France and KLM, Delta routinely switches 

operating carriers to balance commercial benefits and flying opportunities with its partner. 

For example, Delta recently assumed flying for Air France on the Chicago-Paris, SeattleParis and Philadelphia-Paris routes. To the extent United does not think it is getting a fair 

share of U.S.-Japan flying, that is a commercial discussion to be had with ANA that does not 

require the Department’s involvement or the award of additional Haneda slots. United does 

not need to fly its own aircraft to Haneda to enjoy the benefits of Haneda access though its 

revenue sharing joint venture. DL-R-205

B. Reply to Hawaiian 

Delta’s proposal to provide the first Haneda service to Seattle and the Pacific 

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

flight at Kona. DL-R-301. 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 operated to the Hawaiian Islands. The overwhelming majority of 

passengers on existing Tokyo-Hawaii flights (95%) are Japanese tourists (DL-R-305), and 

the Tokyo-Kona market is even more heavily Japanese originating (97%). DL-R-306. It is 

not in the public interest to have so many limited entry opportunities concentrated in Hawaii 
Delta Reply

Page 12

to the exclusion of service to U.S. citizens and U.S. businesses seeking access to Tokyo’s 

preferred close-in airport.

4 

Delta’s service proposal is superior to Hawaiian’s because:

• Seattle and the Pacific Northwest have no nonstop service to Haneda, 

whereas Hawaii has three daily Haneda flights. DL-R-301.

• Seattle nonstop service will benefit 114,000 nonstop Tokyo O&D passengers 

vs. 80,000 at Kona. DL-R-304.

• Seattle service will benefit U.S. travelers while Kona service will benefit 

Japanese tourists. DL-R-305, 306.

• Kona does not have functional CBP/FIS facilities, and there can be no 

certainty that these facilities will be available at Kona in the near future, if at 

all. DL-R-310.

• Delta’s proposal will preserve and enhance competition among the U.S.-

Japan network competitors at Haneda; Hawaiian’s proposal would consume 

Haneda limited entry authority for a niche market that can readily be served 

using open skies rights.

The Tokyo-Kona route proposed by Hawaiian was previously operated by JAL for 

fourteen years from June 1996 to October 2010. DL-R-307. Kona no longer has a functional 

CPB/FIS inspection facility, and Hawaiian concedes that the timeline and ability to resume 

international service at Kona is uncertain in light of these constraints. (HA App. at n.2). 

Hawaiian does not need an award of Haneda slots to reestablish Tokyo-Kona 

service. The United States secured an open skies agreement with Japan, with the limited 

exception of Haneda. The open skies agreement includes Tokyo Narita, which is far and 

away the largest Japanese gateway to Hawaii. Yet, Hawaiian fails to offer any competitive 

service from Tokyo Narita. Instead, Hawaiian seeks out protected niche markets (such as 

 4 In past carrier selection cases the DOT has held that reliance on foreign originating traffic 

is of secondary importance to a carrier/gateway proposal that provides greater benefits to 

the U.S. traveling public. See, U.S.-Japan Gateway Order, Docket 43575, page 60. In that 

proceeding the DOT selected Delta to serve Portland-Tokyo over a Hawaiian Airlines

proposal to serve Honolulu-Nagoya. This longstanding precedent favors the selection of 

Delta’s Seattle-Haneda proposal over Hawaiian’s Kona-Haneda proposal here.
Delta Reply

Page 13

Haneda), and secondary cities such as Sapporo, Fukuoka, and Osaka. DL-R-308. 

Hawaiian boasts that it has opened three new Japan gateways in the last two years. But all 

of Hawaiian’s new gateways combined generate fewer passengers than Narita, which 

Hawaiian conspicuously avoids. Id. 

If Hawaiian wishes to initiate Tokyo-Kona service, it is free to do so at Narita. 

Hawaiian does not need a further allocation of limited entry Haneda slots to provide this 

service. As detailed in Hawaiian’s application, it has implemented a broad expansion 

strategy in the Hawaiian-Japan and Hawaii-Asia markets. While the Department may have 

been justified in providing Hawaiian preferential new entrant treatment in 2010, by its own 

account Hawaiian is now an established and successful incumbent. Hawaiian should be 

expected to take advantage of the Tokyo Narita open skies opportunities available to it 

today. 

While Haneda-Hawaii service is an attractive commercial proposition for carriers,5 it 

is not necessarily in the public interest to have so many limited entry opportunities 

concentrated in a single state. Hawaii receives three Haneda flights today, and a grant of 

Hawaiian’s application would result in half of all bilaterally authorized slots being 

concentrated in Hawaii. DL-R-301. Haneda-Hawaii flights are used almost exclusively by 

Japanese leisure passengers and do not produce benefits for the U.S. traveling public. DLR-305, 306.

(1) Seattle-Haneda can readily support nonstop service. 

Contrary to Hawaiian’s suggestion, Seattle can readily support nonstop Haneda 

service. Seattle is the largest U.S. gateway without Haneda access, and is substantially 

larger than Hawaiian’s proposed Kona gateway (114,000 vs. 80,000 annual passengers). 

 5

 Delta would welcome the opportunity to provide Haneda-Honolulu service. Delta is the 

only Tokyo-Honolulu competitor that does not have the ability to provide service from 

Haneda, placing Delta at a competitive disadvantage to Hawaiian, Star, and oneworld. 

Delta requested, but did not receive Haneda-Honolulu slots in the 2010 proceeding. 
Delta Reply

Page 14

DL-R-304. In fact, despite being a larger local market to Tokyo than Chicago, Seattle has 

fewer flights and fewer seats. DL-R-302.

Delta’s Seattle-Haneda proposal represents much more than just an incremental 

Tokyo flight at Seattle. Haneda is a unique new product in a new time channel that will drive 

increased demand for this service. DL-R-303. Haneda is the preferred airport for business 

passengers based on its proximity to downtown Tokyo. Delta’s schedule is well timed to 

capture business demand, with an evening westbound departure from Seattle and a 

midnight eastbound return from Haneda. DL-101. These flights provide good connections 

to the Delta/Alaska connecting network in a distinct new time channel for the scores of 

online connecting cities that will gain improved access to Haneda. DL-R-303. 

C. Reply to American

American’s proposal to add a third Los Angeles-Haneda flight would create the 

fewest service benefits and is least desirable from an alliance competition standpoint. 

Delta’s Seattle proposal would open a new U.S. gateway to Haneda and provide 18 

communities with their first one-stop service to Haneda, versus only 5 for American. DL-R401. 

Oneworld already holds three U.S.-Haneda slots pairs – more than any other U.S.-

Japan competitor. Los Angeles has two daily nonstop Haneda flights, and American/JAL 

have the option to add a third Los Angeles service under their metal neutral joint venture. 

DL-R-403, 407. An award to American would undermine the competitive distribution of 

Haneda slots, with oneworld holding four opportunities, Star two, and Delta one. DL-R-405. 

American has already rationalized its JFK-Narita flight (with American flying JFKHaneda and JAL flying JFK-Narita). And, American is reducing Los Angeles-Narita from 

daily to 5 weekly in early 2013. Should American receive additional Haneda slots, the 
Delta Reply

Page 15

Department can expect American to fully rationalize its Los Angeles-Narita flight, as it did at 

JFK, thereby canceling out the limited benefits of its Haneda proposal. DL-R-408. 

Finally, contrary to American’s claim, Seattle is the largest U.S.-Tokyo gateway 

without Haneda service. DL-R-404. This was the case when Delta filed its initial exhibits, 

and current MIDT data places Seattle even further ahead of the next-largest gateway 

(Chicago), and Las Vegas (which is not a Tokyo gateway). Id. 

IV. Conclusion 

Delta’s request to establish Haneda service at the Seattle gateway will improve 

Delta’s utilization of its Haneda slots, enhance consumer benefits, and promote competition 

on U.S.-Haneda routes. The competing applications of United, American and Hawaiian 

would produce fewer benefits and undermine competition and market structure objectives 

the Department seeks to achieve. For these reasons, we respectfully urge that Delta’s 

motion for flexibility to use its Haneda slots at the Seattle gateway be granted.

Respectfully submitted,

_________________________________

Alexander Van der Bellen

Managing Director, Government Affairs

 & Associate General Counsel

DELTA AIR LINES, INC.
CERTIFICATE OF SERVICE

A copy of the foregoing Reply has been served this 13th day of September, 2012, upon 

the following persons via email:

Francis.Heil@aa.com

Robert.Wirick@aa.com

dan.weiss@united.com

thomas.bolling@united.com

lhalloway@crowell.com

gmurphy@crowell.com

howard.kass@usairways.com

benjamin.slocum@usairways.com

jhill@dowlohnes.com

paul.gretch@dot.gov

keith.glatz@dot.gov

esta.rosenberg@dot.gov

brett.kruger@dot.gov

todd.homan@dot.gov

urskr@state.gov

eugene_alford@ita.doc.gov

info@airlineinfo.com

Tim.OMalley@alpa.org

Ishiwata.K@portseattle.org

Safora.I@portseattle.org

Kyle.Levine@alaskaair.com

Megan.Lawrence@alaskaair.com
Delta Reply Exhibits

Section I: Delta’s Seattle-Haneda Service Proposal Will Maximize Service and 

Competitive Benefits

Section II: Reply to United Airlines

Section III: Reply to Hawaiian Airlines

Section IV: Reply to American Airlines
Section I: Delta’s Seattle-Haneda Service Proposal Will Maximize 

Service and Competitive Benefits
Seattle is the Largest US Mainland-Tokyo Gateway Without 

Haneda Service

• With HND service now established at LAX (x2) and SFO, SEA is the largest West Coast-Tokyo 

gateway without Haneda service

481,791

293,257 246,782

84,359 37,707

LAX JFK SFO SEA DTW

US48-Tokyo Annual Passengers

YE July 2012

HND Service

No HND Service

Docket DOT-OST-2010-0018

Exhibit DL-R-101

Page 1 of 1

Source: MIDT

Note: Delta estimates SEA-TYO true market size to be approximately 35% higher (114,000) due to sales not captured via MIDT (direct 

bookings, data from non-participating GDS’s).
Seattle is an Ideal West Coast Gateway to Haneda 

Delta and Alaska Provide Nonstop Service to 62 U.S. Points 

Note: Includes service operated by Alaska/Horizon

Source: August 2012 schedules, Diio Mi

Docket DOT-OST-2010-0018

Exhibit DL-R-102

Page 1 of 1

To ANC, FAI, JNU, SIT, KTN

Haneda
Seattle is Geographically Positioned to Optimally

Connect U.S. Traffic to Haneda

• Seattle connections are less circuitous versus other West Coast gateways for points across the US—

including the Pacific Northwest, the Southeast and the East Coast

SEA is a more direct route to HND for the most US cities

SEA

SFO

Docket DOT-OST-2010-0018

Exhibit DL-R-103

Page 1 of 1
Two Delta US-Haneda Routes are Required to Maintain 

Competitive Balance

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

benefits

• Today US-HND capacity is balanced between the three major alliance groupings

3

2 2

oneworld

AA/JL

Skyteam

DL

Star

NH/UA

US-Haneda Slot Pairs by Alliance Group

Docket DOT-OST-2010-0018

Exhibit DL-R-104

Page 1 of 1

HNL 777

JFK 777

SFO 777

HNL 767

LAX 777

LAX 332

SEA 767
All Nippon Airways, 

43%

Japan Airlines, 35%

Other Japanese 

Airlines, 17%

All Non-Japanese 

Airlines, 5%

Japanese Carriers Control 95% of Haneda Slots

Source: Counts based on August 2012 scheduled passenger operations. Does not include non-scheduled or cargo operations.

524 daily 

operations

58 daily 

operations

Docket DOT-OST-2010-0018

Exhibit DL-R-105

Page 1 of 1

422 daily 

operations

214 daily 

operations
Delta Provides the Only Broad-based US-Tokyo Alliance 

Competition to Star and oneworld

Source: August 2012 OAG schedules

Delta

27%

United/ANA

41%

American/JAL

24% Foreign Flags

8%

U.S. Mainland-Tokyo Transpacific Seat Share

Delta Does Not Have a Japanese Carrier Partner

Docket DOT-OST-2010-0018

Exhibit DL-R-106

Page 1 of 1
Section II: Reply to United Airlines
Delta Will Provide More Western Communities With First 

One-Stop Haneda Service Than United Docket DOT-OST-2010-0018

Exhibit DL-R-201

Page 1 of 1

Carrier

First-Time HND Service 

to Western 

Communities

United 13*

Delta/Alaska 18

ANC

JNU

KTN

* United erroneously counts Sacramento as one of 14 new West Coast service points; Delta currently serves Sacramento-Haneda via Los Angeles.

UA SFO Connections

DL SEA Connections

Source: Aug 2012 OAG
Delta’s Seattle Hub Balances Alaska Airlines Feed with a 

Strong Local Market and Significant Own-Metal Connectivity

26%

40%

64%

36%

42%

10%

38%

18%

27%

KIXSEA PEKSEA NRTSEA

Traffic Composition of Delta’s SEA-Asia Flights

MIDT, YE August 2012

SEA Local DL Connected AS Connected

Docket DOT-OST-2010-0018

Exhibit DL-R-202

Page 1 of 1
As United’s Own Exhibits Prove, Delta’s SEA Hub Serves The 

Same Number of Domestic Destinations With A Comparable 

Number of Flights vs. United’s San Francisco Hub

Docket DOT-OST-2010-0018

Exhibit DL-R-203

Page 1 of 1
Seattle is a Successful Delta Long-Haul International Gateway

• Seattle is a major Asia gateway and is the 5th largest Asia market in the US

• Delta has a leading international presence in Seattle and currently serves three non-stop

destinations in Asia and two in Europe

Delta Market Served Since

SEA-NRT Pre-1989

SEA-AMS 1998

SEA-KIX 2010

SEA-PEK 2010

SEA-CDG 2012*

SEA

AMS

CDG

KIX

PEK

NRT

Docket DOT-OST-2010-0018

Exhibit DL-R-204

Page 1 of 1

* DL replaced AF in April 2012; AFoperated since 2007
United and ANA Have Certified to the DOT That They Have 

Implemented a Metal Neutral Joint Venture Alliance Docket DOT-OST-2010-0018

Exhibit DL-R-205

Page 1 of 1
United and ANA Overlap on Seven US-Tokyo Nonstop 

Routes Where Competition Between the Carriers Has Been 

Eliminated by the Grant of ATI

Docket DOT-OST-2010-0018

Exhibit DL-R-206

Page 1 of 1

United/ANA USA-Narita Service

United Flight ANA Flight

Los Angeles-Narita Los Angeles-Narita

New York City-Narita New York City-Narita

Honolulu-Narita Honolulu-Narita

San Francisco-Narita San Francisco-Narita

Seattle-Narita Seattle-Narita

Chicago-Narita Chicago-Narita

Washington D.C.-Narita Washington D.C.-Narita

Houston-Narita
United Codeshares on All of ANA’s US-Japan Flights, 

Including US-Haneda Flights Docket DOT-OST-2010-0018

Exhibit DL-R-207

Page 1 of 1

ANA USA-Japan Service

ANA Flight United Codeshare?

Los Angeles-Narita YES

New York City-Narita YES

Honolulu-Narita YES

San Francisco-Narita YES

Seattle-Narita YES

Chicago-Narita YES

Washington D.C.-Narita YES

Los Angeles-Haneda YES

Honolulu-Haneda YES
An Award to United Results in a Less Competitive 

Distribution of Slots among the Alliances and Undermines 

the Competitive Market Structure at Haneda

Docket DOT-OST-2010-0018

Exhibit DL-R-208

Page 1 of 1

3 3

1

oneworld Star Delta

US-Haneda Slot Pairs by Alliance Group

HNL 777

JFK 777

SFO 777

SFO 777

HNL 767

LAX 777

LAX 332

SEA 767
United Ignores its ATI Partnership with ANA and the 

Metal-Neutral Benefits Claimed to Justify Immunity

“United’s proposed San Francisco-Haneda flights will enable it to provide U.S.-Tokyo Haneda service 

through its San Francisco hub with its own U.S. aircraft and crews”

—Application of United Airlines Inc, DOT-OST-2010-0018

“The Pacific JV will foster “metal neutrality” – a commercial environment in which joint venture partners 

share common economic incentives to promote the interests of their alliance over their individual 

corporate interests.”

“...the Joint Applicants will harmonize their joint network and become indifferent as to which partner 

collects the revenues and operates the aircraft on a given itinerary.”

—United/ANA ATI Application, DOT-OST-2009-0350

 

Docket DOT-OST-2010-0018

Exhibit DL-R-209

Page 1 of 1
United Ignores its ATI Partner ANA Which Could Operate 

SFOHND Today

• Any of ANA’s current Haneda frequencies can be used to serve San Francisco under the metal 

neutral ATI with United

Origin Destination Operating

Carrier Alliance Equipment Eligible for SFO move

HND LAX NH UA/NH 777 YES

HND HNL NH UA/NH 767 YES

Docket DOT-OST-2010-0018

Exhibit DL-R-210

Page 1 of 1
Delta’s Seattle-Haneda Proposal Will Add More Than Twice 

as Many Flights and Seats to the Marketplace than United

• United admits it intends to operate “at least one daily Tokyo Narita flight” – whereas United 

currently operates two daily Tokyo Narita flights for seven months of the year

• Delta’s daily year-round Seattle-Narita service will be maintained and the new Haneda flight will 

produce true incremental benefits

163,520

81,238 730

302

Delta SEA United SFO

Annual Incremental Seats and Flights in 

West Coast-Tokyo Markets

Seats Flights Seats Flights

Docket DOT-OST-2010-0018

Exhibit DL-R-211

Page 1 of 1
Passengers Throughout the West Coast Can Conveniently 

Travel via Seattle – But Pacific Northwest Passengers are 

Inconvenienced by Travel via SFO

SEA

SFO

Docket DOT-OST-2010-0018

Exhibit DL-R-212

Page 1 of 1

SFO-HND SEA-HND

Nonstop Mileage 5,160 4,803

SFO-SEA-HND SEA-SFO-HND

Combined Connecting 

Segment Mileage 5,482 5,839

Circuity (%) 6% 22%

Circuity (Miles 

Roundtrip) 644 2,072

The Pacific Northwest and Alaska 

are more direct to HND via SEA
Delta and United Provide a Similar Number of Round-Trip 

Connections, but Delta will Better Serve the Pacific 

Northwest Region

UA SFO Connections

DL SEA Connections

To ANC, JNU, KTN

Carrier Total N. Am. RT 

Connections

East Coast RT 

Connections

West Coast RT 

Connections

Pacific NW RT 

Connections

United 36 8 28 9

Delta/Alaska 32 3 29 18

*Pacific Northwest defined as Washington, Oregon, Montana, Idaho, Alaska and Western Canada; West Coast defined as West of Texas.

Docket DOT-OST-2010-0018

Exhibit DL-R-213

Page 1 of 1
San Francisco Already Has Nonstop Haneda Service While 

Seattle Has None

2

1

0

LAXHND SFOHND SEAHND

US West Coast – Haneda Flights by Gateway

Docket DOT-OST-2010-0018

Exhibit DL-R-214

Page 1 of 1
Section III: Reply to Hawaiian Airlines
Current Distribution of HND Slots Is Concentrated In 

Hawaii, While The Pacific Northwest Has No Service Today Docket DOT-OST-2010-0018

Exhibit DL-R-301

Page 1 of 1

3

2

1 1

0

HNL LAX SFO JFK SEA

Daily HND Frequencies December 2012
Seattle-Tokyo Can Readily Support New Haneda Service

• Seattle demand for TYO traffic is greater than Chicago demand

• Chicago currently has more weekly frequencies and seats

• ORD currently has 45% more weekly seats to TYO than SEA

• SEAHND will be a unique product in a new time channel (DL-R-303)

Sources: Demand data is from MIDT, YE Aug 2012; Weekly frequencies are from OAG, reflecting August 2012 schedule

ORD SEA

Demand (market size in 

annual MIDT bookings) 83,347 91,165

Tokyo round-trip weekly 

frequencies 28 21

Weekly seats 7,770 5,369

Demand and Seat Capacity Comparison: ORD and SEA

Docket DOT-OST-2010-0018

Exhibit DL-R-302

Page 1 of 1
SEAHND is a Unique Product in a New Time Channel Driving 

New Market Demand

• SEAHND will offer a second Tokyo time 

channel for both local Seattle and 

connecting passengers 

• Time channel uniqueness, coupled with 

airport preference, will allow Delta to 

stimulate true incremental demand to 

support SEAHND

Inbound SEA Time Outbound

05:00

06:00

07:00

08:00

09:00

Eastbound NRT-SEA-USA 

Westbound USA-SEA-NRT Connections

Connections

10:00

11:00

12:00

13:00

14:00

15:00

Westbound USA-SEA-HND

Connections

16:00

17:00

Eastbound HND-SEA-USA 

Connections

18:00

19:00

20:00

21:00

22:00

23:00

SEA-HND

HND-SEA

NRT-SEA

SEA-NRT

Docket DOT-OST-2010-0018

Exhibit DL-R-303

Page 1 of 1
Seattle-Tokyo Is 43% Larger Than Kona-Tokyo Docket DOT-OST-2010-0018

Exhibit DL-R-304

Page 1 of 1

84,359

58,944

29,526

20,630

SEATYO KOATYO

Adjusted MIDT Passengers

YE July 2012

Note: Delta estimates true market size to be approximately 35% higher due to sales not captured via MIDT (direct bookings, data from nonparticipating GDS’s).

~114,000

~80,000

MIDT

True-Up
In the Tokyo-Hawaii Market, 95% of Traffic Originates in Japan Docket DOT-OST-2010-0018

Exhibit DL-R-305

Page 1 of 1

Source: MIDT, YE Aug 2012

Japan, 95%

US, 5%
In the Tokyo-Kona Market, 97% of Traffic Originates in Japan Docket DOT-OST-2010-0018

Exhibit DL-R-306

Page 1 of 1

Source: MIDT, YE Aug 2012

Japan, 97%

US, 3%
JAL Served Tokyo-Kona For More Than 14 Years From 

Narita; Open Skies Opportunities Are Available to Hawaiian 

to Resume Service On The Route

93

217

366 360 357 351 359

293

364 364 359 363 357 359

301

1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

JL/JO Annual NRT-KOA Departures

Source: DOT, T-100

Docket DOT-OST-2010-0018

Exhibit DL-R-307

Page 1 of 1
Hawaiian Can Fly Additional Hawaii-Tokyo Service Today 

But Chooses Not To Do So Docket DOT-OST-2010-0018

Exhibit DL-R-308

Page 1 of 1

• Hawaiian avoids service at Tokyo Narita – the largest Japanese gateway to Hawaii

• Hawaiian selects markets where there is less competition – including HND and secondary Japan 

cities outside of Tokyo

0

7 7 7

3 0

58

14 14

7

0 0

NRTHNL HNDHNL KIXHNL FUKHNL CTSHNL NRTKOA

Hawaiian and Competitor Weekly Japan Frequencies

(Dec 2012 schedule)

Hawaiian

Competitors
Narita-Honolulu Is 46 Times Larger than Haneda-Kona

Docket DOT-OST-2010-0018

Exhibit DL-R-309

Page 1 of 1

878,180

346,115

39,639 19,305

NRTHNL HNDHNL NRTKOA HNDKOA

TYO-Hawaii MIDT Passengers for YE July 2012

Source: MIDT

• Hawaiian avoids Open Skies competition at Narita and seeks a protected limited entry advantage 

at Haneda
Hawaiian’s Application Depends on the Uncertain Ability to 

Add FIS Capabilities in Kona Docket DOT-OST-2010-0018

Exhibit DL-R-310

Page 1 of 1

“The initiation of Hawaiian’s service from Haneda to Kona may require updates to CBP/FIS facilities at 

Kona International Airport. Hawaiian already has reached out to the appropriate state and local 

officials to address this potential issue so that the facility satisfies current Department of Homeland 

Security standards in time for Hawaiian’s proposed start date for Kona-Haneda.”

-- DOT-OST-2010-0018

2012 Application of Hawaiian Airlines, Inc. p.4 footnote 2
Seattle-Haneda Will Benefit US Travelers Whereas KonaHaneda Will Benefit Japanese Tourists

33,132

1,484

SEA KOA

US Point-of-Sale Passengers Between the US and Tokyo

Year Ended July 2012

Source: MIDT

Docket DOT-OST-2010-0018

Exhibit DL-R-311

Page 1 of 1
Hawaiian’s Kona Proposal Would Benefit A Small Segment 

Of The US Population, While Delta’s Seattle Proposal Will 

Benefit Almost The Entire US

Docket DOT-OST-2010-0018

Exhibit DL-R-312

Page 1 of 1

• Kona service would benefit only Hawaii, which enjoys plentiful existing Haneda service

• Seattle service would benefit 49 of 50 US states by way of the connections Delta and Alaska 

Airlines provide via Seattle

307,385,237

1,360,301 185,079

US49 State of Hawaii Island of Hawaii

US Census Population Data for 2010
Docket DOT-OST-2010-0018

Exhibit DL-R-313

Page 1 of 1

Pacific Northwest Passengers Are More Inconvenienced By 

Lack Of Non-Stop Seattle-Haneda Service Than Kona-Haneda 

Passengers Are By Lack Of Kona-Haneda Service

• KOA-HND via HNL is only 0.1% more circuitous than KOA-HND nonstop service

• SEA-HND via LAX is 34% more circuitous than SEA-HND nonstop service

• SEA-HND via SFO is 22% more circuitous than SEA-HND nonstop service

SEA-HND KOA-HND

Nonstop Mileage 4,803 4,013

SEA-LAX-HND SEA-SFO-HND KOA-HNL-HND

Combined Connecting 

Segment Mileage 6,441 5,839 4,017

Circuity (%) 34% 22% 0.1%

Circuity (Miles 

Roundtrip) 3,276 2,072 8
Section IV: Reply to American Airlines
Delta Will Provide More Western Communities With First 

One-Stop Haneda Service Than American Docket DOT-OST-2010-0018

Exhibit DL-R-401

Page 1 of 1

Carrier

First-Time HND Service 

to Western 

Communities

American 5

Delta/Alaska 18

ANC

JNU

KTN

ANC

AA LAX Connections

DL SEA Connections

Source: Aug 2012 OAG
Delta’s Seattle Hub Balances Alaska Airlines Feed with a 

Strong Local Market and Significant Own-Metal Connectivity

26%

40%

64%

36%

42%

10%

38%

18%

27%

KIXSEA PEKSEA NRTSEA

Traffic Composition of Delta’s SEA-Asia Flights

MIDT, YE August 2012

SEA Local DL Connected AS Connected

Docket DOT-OST-2010-0018

Exhibit DL-R-402

Page 1 of 1
American and JAL Have Certified to the DOT That They Have 

Implemented a Metal Neutral Joint Venture Alliance Docket DOT-OST-2010-0018

Exhibit DL-R-403

Page 1 of 1
Contrary to American’s claims, Seattle is the Largest US 

Mainland-Tokyo Gateway Without Haneda Service

• SEA has been the largest existing US-Tokyo gateway without non-stop Haneda service, and more

recent MIDT data shows that it is larger than ever before

• LAS is not a US-TYO gateway; it is served exclusively as a behind gateway point

• Delta’s SEA market size figures are not erroneous as AA suggests in their answer (AA-R-104)

• Slight differences across carriers’ MIDT statistics can be attributed to different data vendors

Delta estimates SEA-TYO true market size to be approximately 35% higher (114,000) due to sales not captured via MIDT (direct bookings, 

data from non-participating GDS’s).

Rank City Pax NRT Service? HND Service?

1 LAX 488,583 YES YES

2 JFK 294,248 YES YES

3 SFO 252,834 YES YES

4 SEA 91,165 YES NO

5 LAS 90,575 NO NO

6 ORD 83,347 YES NO

7 BOS 66,243 YES NO

8 IAD 63,639 YES NO

9 EWR 51,689 YES NO

10 MCO 50,869 NO NO

US48-Tokyo Annual Passengers

MIDT, YE August 2012

Docket DOT-OST-2010-0018

Exhibit DL-R-404

Page 1 of 1
Docket DOT-OST-2010-0018

Exhibit DL-R-405

Page 1 of 1

An Award to American Results in a Less Competitive 

Distribution of Slots among the Alliances and Undermines 

the Competitive Market Structure at Haneda

LAX 777

HNL 777

JFK 777

SFO 777

HNL 767

LAX 777

LAX 332

SEA 767

4

2

1

oneworld Star Delta

US-Haneda Slot Pairs by Alliance Group
Docket DOT-OST-2010-0018

Exhibit DL-R-406

Page 1 of 1

“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.”

“By providing for the broad sharing of revenue on a metal neutral foundation, the JBA will ensure that 

American and JAL act for the benefit of – and are compensated for their contribution to – the alliance 

as a whole.” 

--- American/JAL ATI Application ,DOT-OST-2010-0034 

 (12Feb2010)

American Ignores its ATI Partnership with JAL and the 

Metal-Neutral Benefits Claimed to Justify Immunity

“Delta’s Detroit-Haneda authority should be reallocated to American Airlines to operate service 

between Los Angeles and Haneda.” 

“Global alliance competition between Los Angeles and Haneda is limited to Star and SkyTeam. There 

is no Los Angeles-Haneda nonstop service operated or marketed by oneworld.”

--- Application of American Airlines Inc. ,DOT-OST-2010-0018 

 (27Aug2012)
Docket DOT-OST-2010-0018

Exhibit DL-R-407

Page 1 of 1

• Any of JAL’s current Haneda frequencies can be reallocated to serve Los Angeles under the metal 

neutral ATI joint venture with American

Origin Destination Operating

Carrier Alliance Equipment Eligible for LAX move

HND SFO JL AA/JL 777 YES

HND HNL JL AA/JL 777 YES

HND JFK AA AA/JL 777 NO

American’s Proposal Ignores its ATI Partner JAL, Which 

Could Operate LAXHND Today
Delta’s Proposal Would Introduce Incremental West Coast 

Capacity While American’s Proposal Would Not Docket DOT-OST-2010-0018

Exhibit DL-R-408

Page 1 of 1

• Delta’s daily year-round Seattle-Narita service will be maintained and the new Haneda flight will 

produce true incremental benefits

• American will rationalize their LAXNRT frequency in favor of LAXHND

• American has completely canceled JFK-NRT and relinquished this market to JAL

• American is already reducing LAX-NRT this winter (7x to 5x weekly in January 2013)

163,520

0

730

0

Delta SEA American LAX

Annual Incremental Seats and Flights in 

West Coast-Tokyo Markets

Seats Flights Seats Flights
Docket DOT-OST-2010-0018

Exhibit DL-R-409

Page 1 of 1

Passengers Throughout the West Coast Can Conveniently 

Travel via Seattle – But Pacific Northwest Passengers Are 

Inconvenienced By Travel Via LAX

SEA

LAX

The Pacific Northwest and Alaska 

are more direct to HND via SEA

LAX-HND SEA-HND

Nonstop Mileage 5,487 4,803

LAX-SEA-HND SEA-LAX-HND

Combined Connecting 

Segment Mileage 5,757 6,441

Circuity (%) 5% 34%

Circuity (Miles 

Roundtrip) 540 3,276
Delta’s Seattle Proposal Provides More Unique Roundtrip 

Connections and Better Service to the Pacific Northwest 

than AA’s Los Angeles Proposal

Docket DOT-OST-2010-0018

Exhibit DL-R-410

Page 1 of 1

DL SEAHND AA LAXHND

R/T connection cities without direct TYO service 25 14

R/T connection cities with direct TYO service 7 10

Total 32 24

Unique US Roundtrip Connection Cities

Based on Summer 2012 IATA Schedules

AA LAX Connections

DL SEA Connections

To ANC, JNU, KTN

To ANC
Los Angeles Already Has Nonstop Haneda Service While 

Seattle Has None Docket DOT-OST-2010-0018

Exhibit DL-R-411

Page 1 of 1

2

1

0

LAXHND SFOHND SEAHND

US West Coast – Haneda Flights by Gateway