BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

 WASHINGTON, D. C. 

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

2010 U.S.-HANEDA COMBINATION SERVICES : DOT-OST-2010- 

ALLOCATION PROCEEDING : 0018 

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

 

ANSWER OF AMERICAN AIRLINES, INC. 

 

Communications with respect to this document should be sent to: 

VIRASB VAHIDI WILLIAM K. RIS, JR. 

Senior Vice President - Senior Vice President - 

 Planning Government Affairs 

American Airlines, Inc. American Airlines, Inc. 

P.O. Box 619616, MD 5634 1101 17th Street, N.W. 

DFW Airport, Texas 75161 Washington, D.C. 20036 

 

KENJI C. HASHIMOTO CARL B. NELSON, JR. 

Vice President – Strategic Associate General Counsel 

 Alliances American Airlines, Inc. 

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

P.O. Box 619616, MD 5635 Washington, D.C. 20036 

DFW Airport, Texas 75261 (202) 496-5647 

 carl.nelson@aa.com 

ROBERT A. WIRICK 

Director, Regulatory 

American Airlines, Inc. 

P.O. Box 619616, MD 5635 

DFW Airport, Texas 75261 

(817) 963-0394 

robert.wirick@aa.com 

March 1, 2010 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

 WASHINGTON, D. C. 

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

2010 U.S.-HANEDA COMBINATION SERVICES : DOT-OST-2010- 

ALLOCATION PROCEEDING : 0018 

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

 

ANSWER OF AMERICAN AIRLINES, INC. 

 American Airlines, Inc., under the Department’s 

amended Notice of February 12, 2010, hereby answers the 

competing U.S.-Haneda applications submitted on February 16, 

2010 by Delta Air Lines, Inc., United Air Lines, Inc., 

Continental Airlines, Inc., Hawaiian Airlines, Inc., and 

Continental Micronesia, Inc. 

 American is an applicant for two of the four daily 

U.S.-Haneda slot pairs at issue. American proposes 247-seat 

B777 service from New York (JFK) and Los Angeles, the two 

largest U.S. Mainland-Tokyo markets. American’s first priority 

is New York. Via New York and Los Angeles, American will serve 

all of the top 10 U.S. Mainland-Tokyo markets, with nonstop 

flights from the two gateways, and roundtrip on-line connections from San Francisco, Chicago, Las Vegas, Seattle, 

Washington, Boston, Orlando, and Portland (Exhibit AA-105). 

 
2 

 American has a strong identity and presence in the 

U.S.-Japan market, and is well positioned to establish a new 

station at Haneda to supplement its Narita schedules. American 

has served Japan since l988, and has extensive point-of-sale 

relationships in both countries. 

 On February 9, 2010, Japan Airlines announced that it 

will continue its membership in the oneworld alliance. JAL has 

been part of oneworld since 2007, and has engaged in reciprocal 

codesharing with American since 1999. On February 12, 2010, 

American and JAL submitted a joint application for antitrust 

immunity for an alliance agreement and a metal-neutral joint 

business agreement (DOT-OST-2010-0034). With immunity, both 

carriers will cooperate more closely and generate new revenue 

while providing better travel choices for consumers. JAL has 

an established presence at Haneda, and links that airport to 

more than two dozen cities in Japan as well as Shanghai, 

Beijing, Hong Kong, and Seoul (Exhibit AA-117). American’s 

alliance with JAL will provide important long-term support for 

our proposed Haneda service, with significant benefits for the 

public. 

 Six applicants are seeking a total of 11 daily Haneda 

slot-pairs. Under the U.S.-Japan MOU initialed on December 10, 

2009, four opportunities are available. 
3 

 American 2 (JFK, LAX) 

 Delta 4 (SEA, DTW, LAX, HNL) 

 United 1 (SFO) 

Continental 1 (EWR) 

Hawaiian 2 (HNL) 

 Continental 1 (GUM) 

 Micronesia 

 

 American’s application for two daily slot pairs to 

operate to Haneda from JFK and LAX should be granted ahead of 

the other requests. If American receives only one slot pair, 

our priority is JFK. Continental’s competing proposal for 

Newark-Haneda should be ranked behind American’s for the 

reasons set forth below. As for Los Angeles, the largest 

Mainland-Tokyo market, the only competing proposal is from 

Delta. However, LAX is Delta’s third choice, and there is 

plainly no basis for making multiple awards to Delta at the 

expense of other applicants. 

 l. DELTA AIR LINES

 Delta points to the pending applications for antitrust immunity by American and JAL (DOT-OST-2010-0034) and by 

United/Continental and ANA (DOT-OST-2009-0350), and pronounces 

that “under no circumstances should any U.S. carrier member of 

Star or oneworld receive a single slot at the expense of 

Delta’s full proposal” (p. 7). 
4 

 Delta’s extraordinary bid to gain a monopoly U.S. flag 

position at Haneda by citing American’s prospective immunity 

with JAL does not withstand scrutiny. ATI between American and 

JAL will merely even the playing field that has long been the 

province of Delta/Northwest. 

 In five negotiating sessions in Washington and Tokyo 

in the months leading up to the open skies accord between the 

U.S. and Japan initialed in December, Delta did all it could to 

derail the conclusion of an agreement. At the end Delta 

engaged in a fierce lobbying campaign by enlisting political 

allies in its hub states to defeat open skies. As a protected 

incumbent at Narita, Delta sought to preserve its favored 

position (and the value of the Japan franchise it acquired from 

Northwest), contrary to the public interest of consumers and 

communities in securing open aviation competition between the 

U.S. and Japan after more than 50 years of restrictions. 

 Having lost its battle against open skies, Delta is 

now seeking to stifle competition by making a play for all four 

of the Haneda opportunities, hoping to foreclose operations 

there by any other U.S. carrier. 
5 

 Delta became the largest U.S.-Japan carriers when ist 

acquired the Narita hub operations of Northwest Airlines in 

2008. Since 1947, Northwest had been one of only two U.S. 

carriers authorized to operate unlimited service between the 

U.S. and Japan, and to base a fleet of aircraft in Tokyo and 

engage in Fifth Freedom services to points throughout Asia. 

 Delta conducts daily nonstop operations with its own 

metal to Narita from nine gateways on the U.S. Mainland – 

Atlanta, Detroit, New York (JFK), Los Angeles, Minneapolis/St. 

Paul, Portland, Seattle, San Francisco, and Salt Lake City 

(seasonal service five days a week) – as well as multiple daily 

flights between Narita and Honolulu, Guam, and Saipan (Exhibit 

DL-136; Exhibit AA-R-101). All told, Delta operates 16 daily 

departures from Narita to points in the United States. Delta 

leads the way among all U.S. carriers with a 52% U.S.-Japan 

bookings share, far out-pacing Continental’s 21.8% and United’s 

18.5% (an aggregate Star alliance share of 40.3%), and American’s 7.6% (Exhibit AA-R-102). 

 Moreover, Delta’s application does not mention the 

large number of flights it operates to beyond points in Asia 

from its Narita hub, where Delta has based a fleet of approximately 20 aircraft and more than 1,300 employees devoted to 

intra-Asia service. 

 
6 

 As a privileged incumbent, Delta serves 10 Fifth 

Freedom destinations from Narita, including Beijing, Shanghai, 

Hong Kong, Seoul, Busan, Bangkok, Ho Chi Minh City, Singapore, 

Taipei, and Manila (Exhibit AA-R-103). Delta also serves 

through traffic and stopover traffic to Osaka and Nagoya, the 

third and fourth largest cities in Japan after Tokyo and 

Yokohama, via its Narita hub. Narita thus provides Delta with 

access to China, Hong Kong, Korea, Thailand, Vietnam, Singapore, Taiwan, and the Philippines, as well as other cities in 

Japan. 

 American, by contrast, is a non-incumbent airline under 

the 1952 agreement, with five daily frequencies from the U.S. 

to Narita (compared to Delta’s 16) via four U.S. gateways 

(compared to Delta’s 12). American has a 7.6% U.S.-Japan 

bookings share, one-seventh of Delta’s 52% (Exhibit AA-R-102). 

 As a non-incumbent, American has never held authority to 

engage in Fifth Freedom operations at Narita, and thus serves 

no beyond cities (compared to Delta’s 10). 

 But Delta’s Narita hub is only part of the story of 

Delta’s entrenched position in the U.S.-Asia market. In 2002, 

the Department granted antitrust immunity to Delta and Korean 

Air by Order 2002-6-18, June 27, 2002 (DOT-OST-2002-11842), 

which allowed Delta to gain a second hub in Asia. 
7 

 As the Department stated in the 2002 order, “Delta’s 

global network provides consumers with service to 230 U.S. 

cities in 48 states, and 182 foreign cities in 71 countries, 

and KAL’s global network serves 77 cities in 29 countries. 

Thus, the proposed arrangement will benefit consumers by 

increasing international service options and enhancing competition between airlines, particularly for traffic to or from 

cities beyond and behind major gateways” (p. 6). 

 Korean Air operates 79 weekly nonstop frequencies from 

nine U.S. gateways to Seoul. Beyond Seoul, Delta engages in 

immunized codesharing on flights operated by Korean Air to 

Busan in Korea; to 12 cities in Japan; and to 10 cities in 

other Asian countries. See Exhibit AA-R-104. Delta also 

engages in non-immunized codesharing in U.S.-Asia markets with 

China Southern Airlines (DOT-OST-1997-2653) and China Airlines 

(DOT-OST-2002-11459). 

 Together, the Delta/Korean Air immunized partnership 

commands the largest share of the U.S.-Korea market, with 54.4% 

of traffic between the two countries (Exhibit AA-R-106). Japan 

and Korea are the first and third largest U.S. to Asia O&D 

markets (Exhibit AA-R-105). 
8 

 American does not have an ATI partner in Asia. Apart 

from JAL, American engages in limited non-immunized codesharing 

with China Eastern, Cathay Pacific, and Eva. However, without 

open skies to China or Hong Kong, antitrust immunity with China 

Eastern and Cathay Pacific is not possible. By seeking immuneity with JAL, American aims to position itself as a stronger 

competitor against Japan incumbents Delta and United and their 

immunized allies. 

 With JAL’s reorganization and restructuring, it is 

likely that JAL will emerge as a smaller carrier, operating 

fewer departures and serving fewer destinations. Accordingly, 

claims by Delta that are based on JAL’s historic operations 

(e.g., Exhibit DL-101) should be considered in that context. 

 Awarding Haneda authority to American will foster 

competitive balance among the three global alliances. In showcause Order 2010-2-8, February 13, 2010, in the oneworld ATI 

docket, the Department recognized that a third strong global 

alliance is an important public benefit. See p. 14 (“the 

proposed alliance will provide a third global network that can 

better discipline the fares and services offered by the Star 

and SkyTeam alliances. The enhanced inter-alliance competition 

is beneficial for consumers across many markets, in particular 

the hundreds of transatlantic markets in which the applicants 

become more competitive as a direct result of the alliance. 
9 

Travelers in those markets instantly gain new competitive 

options”) and p. 28 (“oneworld will become more competitive in 

a number of markets, exerting increased competitive discipline 

on fares and services in those markets. Consumers getting a 

third viable option will enjoy more destinations, better 

connections, improved schedules, and better frequent flyer 

benefits”). Not allowing American access to Haneda while 

making awards to Delta and United or Continental would weaken 

oneworld to the detriment of the public. 

 For these reasons, granting every available Haneda 

slot to Delta, and none to its competitors, would be contrary 

to the public interest. Delta, as a Japan incumbent and ATI 

partner of Korean Air, already has a commanding lead over American in U.S.-Japan and U.S.-Asia markets. ATI for American and 

JAL will remediate the current competitive imbalance. AA/JAL 

immunity provides no basis for the Department to turn Haneda 

into a U.S. carrier monopoly for Delta. The U.S.-Japan open 

skies agreement is intended to expand competition, not to perpetuate Delta’s privileged position. 
10 

 Delta’s declaration that no U.S. ATI partner of a 

Japanese carrier (i.e. American, United, and Continental) 

should get “a single slot” is not only against public policy, 

but is without support in Department precedent. The U.S.-Japan 

open skies agreement is unique in requiring carrier-selection 

for a limited-entry route. No case has arisen previously where 

an ATI applicant is also vying for restricted authority between 

the U.S. and its foreign partner’s homeland, since ATI requires 

open skies, and open skies has no limits on entry. 

 However, there are cases where an applicant had a 

codeshare relationship with a foreign homeland carrier, and the 

Department considered whether existing codeshare operations 

should be a disqualifying factor. In several of those cases, 

some involving Delta itself, the Department granted limited 

entry route authority to applicants even though they already 

had access to restricted-entry routes by codesharing on foreign 

partners. See, e.g., 2007/2008 U.S.-Colombia Combina-tion 

Frequency Allocation Proceeding, Order 2008-5-27, May 21, 2008 

(selecting Delta for New York-Bogota authority despite the fact 

that Delta already displayed the DL* code on Avianca on the 

same route); U.S.-France Combination Services Proceeding, Order 

1999-8-24, August 27, 1999, p. 5 (rejecting American’s argument 

that Delta should be excluded from any awards because Delta 

engaged in codesharing on Air France). 
11 

 See also Los Angeles-Puerto Vallarta Combination 

Service Proceeding, DOT-OST-2005-23497, Reply of Delta Air 

Lines, January 27, 2006, p. 4 (“United’s assertion that Delta 

should be precluded from an award because it has a codeshare 

relationship with Aeromexico is without merit. Codeshare 

service is not a substitute for an applicant’s direct service 

with its own aircraft”); the Department agreed and chose Delta 

over United, even though DL* was already being displayed on 

Aeromexico’s LAX-PVR flights (Order 2006-6-25, June 22, 2006). 

 And see 2007 U.S.-China Combination and All-Cargo 

Frequency Allocation Proceeding, DOT-OST-2006-25275, Objections 

of Continental Airlines, January 23, 2007, p. 3 (“United’s 

dominance of U.S.-flag U.S.-China nonstop frequencies, its 

codeshare alliance relationship with China’s largest airline, 

Air China, its developing relationship with Shanghai Airlines, 

a second major Chinese airline, its proposed China codeshare 

relationship with US Airways and the current domination of 

U.S.-China service by United and its partner . . . all demonstrate the extraordinarily anticompetitive effect of awarding 

even more frequencies to United”). Nevertheless, by Order 

2007-2-10, February 8, 2007, the Department rejected Continental’s arguments and awarded the opportunity to United (p. 19). 
12 

 Finally, with respect to LAX, Delta’s third choice for 

an award, we note that Delta claims “nonstop-to-nonstop Haneda 

service for 18 U.S. points” via LAX (Exhibit DL-121), but 

avoids using the word “roundtrip.” In fact, only seven of the 

18 behind cities shown on Delta’s map (JFK, DTW, MEM, ATL, SAN, 

RNO, and LAS) would have roundtrip service according to Delta’s 

own connecting schedules (Exhibits DL-126, DL-127). By contrast, American proposes roundtrip connections to and from 

Haneda via LAX for 13 beyond cities, including American’s hubs 

at ORD, DFW, and MIA, as well as SFO, SEA, PDX, LAS, SAN, SBA, 

FSN, JFK, IAD, and SJU (Exhibits AA-111, AA-112). 

 2. UNITED AIR LINES

 United is seeking one slot pair to operate between 

San Francisco and Haneda. United’s SFO proposal should not be 

selected at the expense of American’s application to serve 

Haneda from New York and Los Angeles. 

 New York and Los Angeles are the two largest O&D 

markets to Tokyo from the Mainland. Each exceeds San Francisco 

by a substantial margin (Exhibit AA-105): 

 Annual % Larger 

 Rank Gateway Bookings Than SFO

 1 LAX 434,085 + 83.1% 

 2 NYC 388,868 + 64.0% 

 3 SFO 237,077 - 
13 

 As a U.S.-Japan incumbent carrier, United, like Delta, 

has enjoyed unlimited authority to serve between the two 

countries, as well as a hub at Narita with full Fifth Freedom 

rights to beyond points in Asia, since acquiring Pan Am’s 

Pacific Division in 1985. United presently operates six daily 

U.S.-Japan frequencies (compared to American’s five) from 

Chicago, Honolulu, Los Angeles, San Francisco, Seattle, and 

Washington (IAD), a total of six U.S. gateways (compared to 

Ameri-can’s four). See Exhibit UA-14. 

 Beyond Narita, United serves five points in Asia with 

its own metal, Beijing, Seoul, Bangkok, Singapore, and Taipei 

(Exhibit AA-R-107). Like Delta, United has a base at Narita 

with aircraft and employees dedicated to intra-Asia operations. 

 In addition, United, like Delta, has antitrust immunity 

with a Korean carrier, in United’s case Asiana, thus giving 

United hubs at Narita and Seoul. See Order 2003-5-18, May 14, 

2003. Asiana operates 44 weekly nonstop frequencies from six 

U.S. gateways to Seoul, and United engages in immunized codesharing on each of these routes (except Chicago). Beyond 

Seoul, United codeshares on Asiana’s flights to Busan in Korea 

and to five cities in other Asian countries. See Exhibit AA-R108. 
14 

 In addition to ANA and Asiana, United engages in extensive non-immunized codesharing in U.S.-Asia markets on Star 

partners Air China (DOT-OST-2003-16213), Shanghai Airlines 

(DOT-OST-2006-24167), and Thai International (DOT-OST-1996-

1410). 

 United also has two U.S. partners in the Star alliance, 

Continental and US Airways. Star is unique in having multiple 

U.S. carrier members. Both Continental and US Airways display 

their codes on United’s U.S.-Japan flights and on Asiana’s U.SKorea flights (DOT-OST-2009-0277 and DOT-OST-2007-0059). US 

Airways displays its code on ANA’s U.S.-Japan flights (DOT-OST2009-0181) as well as on Singapore Airlines flights (DOT-OST2007-28084). United and Continental are jointly seeking antitrust immunity with ANA. The Department should not further 

augment Star’s steel web of multi-carrier access to the U.S.-

Japan and U.S.-Asia markets by awarding San Francisco-Haneda 

authority to United to the exclusion of American and oneworld 

at JFK and LAX. 

 3. CONTINENTAL AIRLINES

 Continental proposes daily service between Newark and 

Haneda. American’s New York (JFK)-Haneda application should be 

ranked first, particularly in light of JFK’s preferred position 

as an international gateway, and JFK’s superiority over Newark 

in on-time performance. 
15 

 For most business travelers in Manhattan, JFK is more 

convenient than Newark. As we showed in the 2005/2006 U.S.-

China Air Services Case and Designations (DOT-OST-2004-19077), 

JFK is the preferred airport by a wide margin for international 

service to and from the New York metropolitan area. Based on 

Commerce Department data, Newark attracts just 6.4% of international passenger traffic for New York. Even with nonstop 

flights by Continental, Newark secured only 16.1% of total O&D 

traffic (including foreign flag) between the New York metropolitan area and Hong Kong. See Brief of American Airlines, 

November 22, 2004, p. 21 and exhibits cited therein. 

 Just as JFK is more convenient than Newark, Haneda as 

the closest airport to downtown Tokyo is far more convenient 

than Narita, which is located some 40 miles from Tokyo and 

requires time consuming ground transportation to reach the 

city. The public interest would be best served by linking the 

two most convenient airports, JFK and Haneda, with nonstop 

service. 

 Another factor for the Department to consider is that 

JFK has better overall on-time performance than Newark, and 

American at JFK has better on-time performance than Continental 

at Newark. Based on Table 7 of the Department’s monthly air 

travel consumer reports (4Q09), JFK’s overall on-time arrivals 

averaged 80.3%, more than nine points higher than Newark’s 
16 

71.0%. Table 2 for the same period shows that 84.4% of 

American’s flights at JFK arrived on time, nine points higher 

than Continental’s 75.5% at Newark. Among the 31 reportable 

airports, Newark ranked last in on-time performance in 2009. 

See Exhibits AA-R-109, AA-R-110, AA-R-111. 

 American’s superior on-time performance at JFK is significant not only because customers benefit from more reliable 

service (including fewer missed connections), but also because 

of the 2200 – 0700 operating window at Haneda for flights to 

and from the U.S. In these circumstances, the applicant and 

the airport with the better on-time record should be favored. 

 We recognize that Continental’s connecting schedules 

show on-line service to more cities behind Newark (Exhibits CO122 and CO-123) than American would serve behind JFK (Exhibits 

AA-108, AA-109). But Continental’s larger array of connections 

should not be a decisive factor. As shown in Exhibit AA-R-112, 

21 of Continental’s connecting cities had fewer than five Tokyo 

passenger bookings per day in each direction in CY 2009. In 

addition, three of the behind cities with roundtrip on-line 

connections on American via JFK, including Washington and 

Boston (the seventh and eighth largest Mainland-Tokyo O&D 

markets), would benefit from shorter elapsed times compared to 

Continental via Newark, as shown in Exhibit AA-R-113. 
17 

 Continental is not a large player in the U.S.-Japan 

market, operating to Tokyo from two U.S. gateways, Newark and 

Houston, with one daily flight at each city. Continental once 

served Tokyo from Seattle, but sold that route to American in 

the American/Continental Route Transfer, Order 91-1-16, January 

10, 1991. Since the 1998 MOU, Continental has had ample 

opportunity to expand its U.S.-Japan frequencies and gateways, 

but has not done so, with the exception of adding the CO* code 

to transpacific flights operated by United. 

 Another factor that the Department should consider is 

Continental’s position as a member of the Star alliance and 

co-applicant with United for antitrust immunity with ANA. It 

would be unfair for United and Continental (and Star) to 

receive two of the four Haneda slots but for American (and 

oneworld) to be left out. If United is selected for San Francisco, Continental should not be selected at the expense of 

American’s application. 
18 

 4. HAWAIIAN AIRLINES and CONTINENTAL MICRONESIA

 Two applicants are seeking authority to serve Haneda 

from non-Mainland points. Hawaiian proposes to operate two 

daily flights from Haneda to Honolulu, and Continental Micronesia proposes daily service from Haneda to Guam. None of the 

four Haneda opportunities should be assigned to leisure markets 

such as Honolulu and Guam, which are almost entirely Japanoriginating and would provide no benefit to U.S. passengers. 

 Haneda is the closest airport to downtown Tokyo, and 

should be used for the convenience of business travelers from 

the Mainland, particularly in the two largest markets, New York 

and Los Angeles. Leisure passengers will continue to be well 

served from Narita, which today offers 62 weekly nonstop 

scheduled flights to Honolulu from seven U.S. and Japanese 

airlines, and 58 weekly nonstop scheduled flights to Guam from 

four U.S. and Japanese airlines. See Exhibit AA-R-114. 

Honolulu and Guam also enjoy scheduled nonstop service from 

many other cities in Japan apart from Tokyo, including Osaka, 

Nagoya, Sapporo, Fukuoka, Hiroshima, Nigata, Okayama, and 

Sendai, operated by a number of U.S. and Japanese carrier 

(id.). 
19 

 Furthermore, U.S. and Japanese carriers operate extensive charter programs to both Honolulu and Guam from Haneda and 

Narita, as well as from Nagoya, Sapporo, Fukuoka, Sendai, and 

other cities in Japan, as shown by charter filings on file at 

the Department (Exhibit AA-R-115). 

 Hawaiian would be an especially poor choice for an 

award of scheduled Haneda authority. Hawaiian has never served 

Tokyo, even though it has had the opportunity to do so for 12 

years, when the 1998 U.S.-Japan MOU substantially expanded U.S. 

carrier frequencies. Hawaiian briefly served Japan in the 

early 1990s from Honolulu to Fukuoka with wet lease operations 

by Northwest Airlines, but sold the route outright to Northwest 

in 1991. See Northwest/Hawaiian Route Transfer, Order 91-4-3, 

March 29, 1991. 

 Following the 1998 MOU, Hawaiian applied for MauiNarita frequencies which it received by Order 99-4-4, April 2, 

1999, with a start-up deadline of March 31, 2000, almost a year 

later. On December 15, 1999, Hawaiian asked for a two-year 

dormancy waiver, which the Department granted by Notice of 

Action Taken, DOT-OST-1999-3419, January 14, 2000. But even 

with three years to start, Hawaiian never did so. Hawaiian did 

not seek a further dormancy waiver, and its Japan authority 

automatically lapsed in 2002. 
20 

 We also note that Hawaiian has not operated charter 

service between Hawaii and Japan in at least the last five 

years (2005 to 2009), which is as far back as we checked the 

Department’s notices of consistency. 

 Nor should any of the Haneda opportunities be assigned 

to Continental Micronesia and Guam. Not only is Guam already 

well served with scheduled and charter flights (Exhibits AA-R114 and AA-R-115), but Tokyo-Guam, with a stage length of 1,565 

miles, is a short-haul route compared to New York (6,733 miles) 

and Los Angeles (5,468 miles). To obtain the maximum operational benefit for U.S. carriers and maximum public benefit for 

U.S. passengers, none of the valuable Haneda slots should be 

awarded for additional scheduled service from Japan to Guam. 

CONCLUSION

 The Department should promptly conclude this proceeding by awarding two of the four slot pairs in issue to 

American to serve Haneda from New York and Los Angeles, the two 

largest Mainland-Tokyo markets, notwithstanding American’s 

prospective antitrust immunity with JAL. From these gateways, 

American will provide roundtrip on-line Haneda service in the 

10 largest Mainland-Tokyo markets. Selection of American will 

benefit U.S.-Japan passengers and allow American to achieve a 

stronger competitive position for itself and for oneworld 

versus incumbent airlines and their alliance partners. 
21 

Respectfully submitted, 

CA9!N~O:'f: p. Associate General Counsel 

American ines, Inc. 

March 1, 2010 
AMERICAN AIRLINES 

NEW YORK (JFK) – TOKYO (HANEDA) 

LOS ANGELES – TOKYO (HANEDA) 

 INDEX OF REBUTTAL EXHIBITS

AA-R-101 Delta Operates 16 Daily Departures 

 Between The United States And Tokyo 

AA-R-102 Delta Has The Largest U.S.-Japan Market 

 Share Among All U.S. Carriers 

AA-R-103 From Its Narita Hub, Delta Serves 10 

 Fifth Freedom Destinations In Asia 

AA-R-104 Delta Has A Second Hub In Asia Through Its 

 Immunized Partership With Korean Air 

AA-R-105 U.S.-Japan And U.S.-Korea Are The First 

 And Third Largest U.S.-Asia Passenger 

Markets 

AA-R-106 The Immunized Delta/Korean Air And 

United/Asiana Alliances Account For 91% 

 Of All Bookings in the U.S.-Korea Market 

AA-R-107 From Its Narita Hub, United Serves Five 

 Fifth Freedom Destinations In Asia 

AA-R-108 United Has A Second Hub In Asia Through 

 Its Immunized Partnership With Asiana 

AA-R-109 JFK’s Overall On-Time Performance Is 

 Better Than Newark’s (4Q09) 

AA-R-110 American’s On-Time Performance At JFK 

 Is Better Than Continental’s On-Time 

 Performance At Newark (4Q09) 

AA-R-111 Among The 31 Reportable Airports, Newark 

 Ranked Last In On-Time Performance In 2009 
- ii - 

AA-R-112 21 Of Continental’s On-Line Connecting 

 Cities Beyond Newark Account For Fewer 

Than 5 Bookings Per Day Each Way To Tokyo 

AA-R-113 American Offers Shorter Elapsed Times 

 For Three Cities Beyond JFK, Including 

Washington And Boston (The 7th And 8th

 Largest U.S. Mainland-Tokyo O&D Markets) 

AA-R-114 Honolulu And Guam Enjoy Extensive Scheduled 

Service From Japan 

 

AA-R-115 Honolulu And Guam Enjoy Extensive Charter 

Service From Japan 

 
Delta Operates 16 Daily Departures 

Between The United States and Tokyo

DOT-OST-2010-0018

Exhibit AA-R-101

Page 1 of 1

Source: OAG February 2010

U.S.Cities - Tokyo Daily Departures

Atlanta 1

Detroit 1

Guam 3

Honolulu 2

Los Angeles 1

Minneapolis/St. Paul 1

New York (JFK) 1

Portland 1

Saipan 3

Salt Lake City 5/7 1/

San Francisco 1

Seattle 1

TOTAL 16

1/ May - October 2010
55.1%

44.9%

Delta Has The Largest U.S. – Japan 

Market Share Among All U.S. Carriers

DOT-OST-2010-0018

Exhibit AA-R-102

Page 1 of 1

Source: MIDT Bookings Y2009

DL

52% CO

21.8%

UA

18.6%

AA

7.6%

U.S. Carriers Foreign Carriers
From Its Narita Hub, Delta Serves 10 

Fifth Freedom Destinations In Asia

DOT-OST-2010-0018

Exhibit AA-R-103

Page 1 of 1

Source: OAG February 2010

Bangkok 

Beijing

Busan 

Ho Chi Minh City 

Hong Kong

Manila 

Seoul

Shanghai 

Singapore

Taipei
Delta Has A Second Hub In Asia Through Its 

Immunized Partnership With Korean Air

DOT-OST-2010-0018

Exhibit AA-R-104

Page 1 of 2

Source: OAG February 2010

Seoul - Japan

Weekly 

Operations

Operating 

Carrier

Marketing 

Carrier

Tokyo(Narita) 7 KE DL*

Akita 3 KE DL*

Aomori 4 KE DL*

Fukuoka 7 KE DL*

Hakodate 3 KE DL*

Kagoshima 3 KE DL*

Komatsu 4 KE DL*

Nagasaki 2 KE DL*

Niigata 7 KE DL*

Oita 2 KE DL*

Okayama 7 KE DL*

Sapporo 7 KE DL*

49

U.S. - Seoul

Weekly 

Operations

Operating 

Carrier

Marketing 

Carrier

Atlanta 7 KE DL*

Chicago 8 KE DL*

Dallas/Ft. Worth 3 KE DL*

Honolulu 7 KE DL*

Los Angeles 23 KE DL*

New York (JFK) 14 KE DL*

San Francisco 5 KE DL*

Seattle 5 KE DL*

Washington (IAD) 7 KE DL*

79
Delta Has A Second Hub In Asia Through Its 

Immunized Partnership With Korean Air

DOT-OST-2010-0018

Exhibit AA-R-104

Page 2 of 2

Source: OAG February 2010

Seoul - Other Asia

Weekly 

Operations

Operating 

Carrier

Marketing 

Carrier

Phnom Penh 7 KE DL*

Siem Reap 6 KE DL*

Hong Kong 14 KE DL*

Busan 7 KE DL*

Kota Kinabalu 3 KE DL*

Kuala Lumpur 7 KE DL*

Bangkok 7 KE DL*

Chiang Mai 3 KE DL*

Phuket 6 KE DL*

Hanoi 7 KE DL*

Ho Chi Minh City 7 KE DL*

73
U.S. – Japan And U.S. – Korea Are The First And 

Third Largest U.S. – Asia Passenger Markets

DOT-OST-2010-0018

Exhibit AA-R-105

Page 1 of 1

Source: MIDT YE Aug 2009

0 500 1,000 1,500 2,000 2,500 3,000 3,500 4,000 4,500 5,000

Indonesia

Singapore

Thailand

Vietnam

Taiwan

Hong Kong

Phillipines

Korea

China

Japan

177

366

482

676

928

1,055

1,410

1,985

2,329

4,687

U.S. - Asia Bookings (000s)
9.3%

54.4% 36.3%

THE IMMUNIZED DELTA/KOREAN AIR AND UNITED/ASIANA ALLIANCES 

ACCOUNT FOR 91% OF ALL BOOKINGS IN THE U.S. – KOREA MARKET

DOT-OST-2010-0018

Exhibit AA-R-106

Page 1 of 1

Source: MIDT Bookings Y2009

DL /KE UA /OZ

OTHER
From Its Narita Hub, United Serves 

Five Fifth Freedom Destinations In Asia

DOT-OST-2010-0018

Exhibit AA-R-107

Page 1 of 1

Source: OAG February 2010

Other 

Star Alliance

Operating Carrier

Star Alliance

Marketing Carrier

Bangkok UA NH UA*/NH, CO*/UA, NH*/UA

Beijing UA NH

Seoul UA NH, OZ OZ*/NH,UA, CO*/OZ,UA, NH*/OZ,UA

Singapore UA NH CO*/UA, UA*/NH, NH*/UA

Taipei UA NH UA*/NH, CO*/UA, NH*/UA
United Has a Second Hub In Asia Through 

Its Immunized Partnership With Asiana

DOT-OST-2010-0018

Exhibit AA-R-108

Page 1 of 1

Source: OAG February 2010

Seoul - Asia

Operating

Carrier

Star Alliance

Marketing 

Carrier

Weekly 

Operations

Tokyo(Narita) OZ CO* 28

Nagoya OZ CO* 14

Busan OZ UA* 14

Hong Kong OZ UA* 14

Kota Kinabalu OZ UA* 4

Phuket OZ UA* 5

Hanoi OZ UA* 7

Ho Chi Minh City OZ UA* 7

93

U.S. - Seoul

Operating

Carrier

Star Alliance

Marketing 

Carrier

Weekly 

Operations

New York (JFK) OZ UA*, US* 7

Los Angeles OZ CO*, UA*, US* 14

Chicago OZ US* 4

Seattle OZ UA*, US* 5

San Francisco OZ CO*, UA*, US* 4

Saipan OZ UA* 11

44
JFK’s Overall On-Time Performance Is 

Better Than Newark’s (4Q09)

DOT-OST-2010-0018

Exhibit AA-R-109

Page 1 of 1

Source: DOT Monthly Air Travel Consumer Reports,

Table 7 (October 2009 - December 2009)

http://airconsumer.ost.dot.gov/reports/atcr09.htm

80.3%

71.0%

66.0%

68.0%

70.0%

72.0%

74.0%

76.0%

78.0%

80.0%

82.0%

JFK EWR
American’s On-Time Performance at JFK Is Better Than 

Continental’s On-Time Performance At Newark (4Q09)

DOT-OST-2010-0018

Exhibit AA-R-110

Page 1 of 1

Carrier / Airport

Percent On-Time

(Arrivals)

AA at JFK 84.4%

CO at EWR 75.5%

Source: DOT Monthly Air Travel Consumer Reports,

Table 2 (October 2009 - December 2009)

http://airconsumer.ost.dot.gov/reports/atcr09.htm
DOT-OST-2010-0018

Exhibit AA-R-111

Page 1 of 1

OF THE 31 REPORTABLE AIRPORTS,

NEWARK RANKED LAST IN ON-TIME

 PERFORMANCE IN 2009

 On-Time Arrivals

 (Percent)

1 SLC Salt Lake City 85.10

2 PHX Phoenix 83.93

3 MDW Chicago Midway 83.54

4 LAS Las Vegas 82.92

5 IAH Houston 82.75

6 LAX Los Angeles 82.68

7 BWI Baltimore 82.46

8 SEA Seattle 82.22

9 CVG Cincinnati 82.18

10 MEM Memphis 82.05

11 STL St. Louis 81.87

12 DTW Detroit 81.86

13 SAN San Diego 81.69

14 TPA Tampa 81.30

15 MCO Orlando 80.89

16 IAD Washington (Dulles) 80.80

17 DEN Denver 80.77

18 DCA Washington (Reagan) 80.34

19 CLT Charlotte 80.05

20 ORD Chicago 79.42

21 DFW Dallas/Ft. Worth 79.00

22 MSP Minneapolis/St. Paul 78.94

23 FLL Fort Lauderdale 78.01

24 BOS Boston 76.45

25 MIA Miami 75.76

26 PHL Philadelphia 74.62

27 SFO San Francisco 73.53

28 JFK New York (Kennedy) 73.51

29 ATL Atlanta 72.60

30 LGA New York (LaGuardia) 68.70

31 EWR Newark 65.76

SOURCE: DOT Monthly Air Travel Consumer Reports,

 Table 7 (January 2009 - December 2009)

http://airconsumer.ost.dot.gov/reports/atcr09.htm
21 Of Continental’s On-Line Connecting Cities Beyond Newark 

Account For Fewer Than 5 Bookings Per Day Each Way To Tokyo

DOT-OST-2010-0018

Exhibit AA-R-112

Page 1 of 1

Source: Exhibits CO-122 and CO-123

OAG February 2010

 Tokyo Bookings Per Day Each Way

Hartford 4.8

Ft. Lauderdale 4.7

Albany 3.6

Rochester 3.6

Knoxville 3.4

Richmond 2.9

Providence 2.8

Syracuse 2.5

Greensboro 2.4

Charleston 2.3

West Palm Beach 2.3

San Juan 2.3

Burlington 2.0

Savannah 1.7

Harrisburg 1.6

Manchester 1.5

Portland 1.5

Fort Myers 1.4

Asheville 0.5

Ithaca 0.5

Myrtle Beach 0.4
DOT-OST-2010-0018

Exhibit AA-R-113

Page 1 of 1

AMERICAN OFFERS SHORTER ELAPSED TIMES

FOR THREE CITIES BEYOND JFK, INCLUDING 

WASHINGTON AND BOSTON (THE 7th AND 8th

LARGEST U.S.MAINLAND-TOKYO O&D MARKETS)

 American Continental

 Via JFK Via Newark

Washington (DCA) 

 Westbound 17:40 20:54

 Eastbound 17:00 17:35

 Roundtrip 34:40 38:41

 

Boston

 Westbound 16:51 19:20

 Eastbound 16:25 15:49

 Roundtrip 33:16 35:09

Miami

 Westbound 20:20 21:15

 Eastbound 17:55 20:11

 Roundtrip 38:15 41:26

SOURCE: Exhibits AA-109 and AA-110; Exhibits CO-122 

and CO-123 (winter schedules; CO did not provide 

summer schedules); Exhibit AA-105 (top 10 

U.S. Mainland traffic generating cities to 

Tokyo)
DOT-OST-2010-0018

Exhibit AA-R-114

Page 1 of 2

Source: OAG February 2010

Honolulu And Guam Enjoy Extensive Scheduled Service 

From Japan

Operating

 Carrier

Weekly 

Operations

Tokyo(Narita) Continental Micronesia 5

Tokyo(Narita) Delta Air Lines 15

Osaka Delta Air Lines 7

Osaka Japan Airlines 7

Nagoya Japan Airlines 7

Tokyo(Narita) Japan Airlines 27

Tokyo(Narita) JALways 1

Tokyo(Narita) All Nippon Airways 6

Tokyo(Narita) Air Japan 1

Tokyo(Narita) United Air Lines 7

83
Honolulu And Guam Enjoy Extensive Scheduled Service 

From Japan

DOT-OST-2010-0018

Exhibit AA-R-114

Page 2 of 2

Source: OAG February 2010

Operating

 Carrier

Weekly 

Operations

Tokyo(Narita) Continental Micronesia 21

Sapporo Continental Micronesia 3

Fukuoka Continental Micronesia 7

Hiroshima Continental Micronesia 2

Niigata Continental Micronesia 2

Nagoya Continental Micronesia 14

Okayama Continental Micronesia 2

Sendai Continental Micronesia 3

Osaka Continental Micronesia 6

Tokyo(Narita) Delta Air Lines 23

Nagoya Delta Air Lines 7

Osaka Delta Air Lines 9

Tokyo(Narita) Japan Airlines 14

Osaka Japan Airlines 7

Osaka Korean Air 7

128
DOT-OST-2010-0018 

Exhibit AA-R-115 

Page 1 of 3 

HONOLULU AND GUAM ENJOY EXTENSIVE 

CHARTER SERVICE FROM JAPAN 

(OPERATIONS IN 2009) 

2008-412 - JALways 

Sapporo-Honolulu - (December 29, 2008-January 2, 2009) - B-744 

Fukuoka-Honolulu (December 30, 2008-January 3, 2009) - B-744 

Nagoya-Guam (December 29, 2008-Jzanuary 2, 2009) - 8-767 

2008-443 - JALways 

Fukuoka-Honolulu (4) - (January 2-11, 2009) - B-744 

Sapporo-Honolulu (4) (January 3-13, 2009) - B-744 

2009-012 - JALways 

Sapporo-Honolulu - (February 12-16, 2009) - B-747 

Hiroshima-Honolulu (February 26-20, 2009) - B-744 

Kumamoto-Honolulu - (February 20-24, 2009) - B-744 

Fukuoka-Honolulu - (February 24-28, 2009) - B-744 

2009-054 - JALways 

Ube-Honolulu - (March 4-8, 2009) - 8-744 

Nagasaki-Honolulu - (March 8-13, 2009) - B-744 

Hiroshima-Honolulu - (March 16-20, 2009) B-744 

Fukuoka-Honolulu (2) - (March 19-31, 2009) - B-744 

Sapporo-Honolulu (March 23-27, 2009) - B-744 

2009-076 - JAL 

Nigata-Honolulu (March 12-16, 2009) B-744 

2 09-116 -- JAL 

Fukuoka-Honolulu (3) - (April 25-May 6, 2009) - 8-744 

Sapporo-Honolulu (2) (April 27-May 5, 2009) - B-744 

Sendai-Honolulu (April 29-May 3, 2009) - B-744 

Nagoya-Guam (2) - (April 29-May 6, 2009) - 8-767 
DOT-OST-2010 0018 

Exhibit AA-R-115 

Page 2 of 3 

HONOLULU AND GUAM ENJOY EXTENSIVE 

CHARTER SERVICE FROM JAPAN 

(OPERATIONS IN 2009) 

2009-172 - ANA 

Osaka-Honolulu - (June 4-9, 2009) B-767-300 

20 42 - ANA 

Tokyo (HND)-Guam (33) - (July 17-September 24, 2009) - B-747-400 

2009-266 - JALways 

Sapporo-Honolulu (2) (August 2-19, 2009) B-744 

Fukuoka-Honolulu (2) - (August 5-24, 2009) - B-744 

Sendai-Honolulu - (August 6-10, 2009) B-744 

Tokyo (NRT)-Honolulu (2) - (August 14 18, 2009) B-744 

2009-304 - JALways 

Nagoya-Guam (September 19-23, 2009) - B-767 

2009-436 - JALways 

Oita-Honolulu (1) - (December 5-10, 2009) B-744 

Tokyo (HND)-Honolulu (4) (December 9-17, 2009) - B-744 

Fukuoka-Honolulu (4) - (December 22, 2009-January 3, 2010) B-744 

Sapporo-Honolulu (3) (December 29, 2009-January 10, 2010) - B-744 

Hiroshima-Honolulu (1) (December 29, 2009-January 2, 2010) B-744 

Nagoya-Guam (1) (December 29, 2009-January 2, 2010) - B-767 

200 42 - ANA 

Tokyo (NRT)-Hono1ulu (December 16-20, 2009) B-747-400 

Yonago-Honolulu - (December 19-22, 2009) - B-767-300ER 

Sendai-Honolulu - (December 29, 2009-January 2, 2010) B-747 400 

Nagoya-Honolulu - (December 29, 2009-January 2, 2010) B-747-400 

Tokyo (HND)-Guam (December 29, 2009-January 2, 2010) - B-747-400 

Tokyo (HND)-Guam (December 30, 2009 January 3, 2010) - B-747-400 

Okayama-Honolulu - (December 30, 2009-January 2, 2010) - B-747 400 
00T-08T-2010-0018 

Exhibit AA-R-115 

Page 3 of 3 

HONOLULU AND GUAM ENJOY EXTENSIVE 

CHARTER SERVICE FROM JAPAN 

(OPERATIONS IN 2009) 

Continental Micronesia - Notice of Consistency 

Tokyo-Guam (2) - (July 24-September 23, 2009) - B-737 

Guam-Tokyo (2) - (July 24-September 23, 2009) - B-737 

Continental Micronesia - Notice of Consistency 

Tokyo-Guam (3) - (August 4-16, 2009) - B-737 

Guam-Tokyo (3) - (August 4-16, 2009) - B-737 

Continental Micronesia - Notice of Consistency 

Tokyo-Guam (1) - (September 19-November 23, 2009) - B-737 

Guam-Tokyo (1) (September 19-November 23, 2009) B-737 

North American - Notice of Consistency 

Tokyo (HNO)-Honolulu (2) - (September 18-23, 2009) - B-767 

Honolulu-Tokyo (HNO) (2) - (September 22-26, 2009) - B-767 

Omni - Notice of Consistency 

Tokyo (NRT)-Honolulu (2) (September 17-23, 2009) 

Honolulu-Tokyo (NRT) (2) - (September 17-23, 2009) 

SOURCE: DOT Office of International Aviation, U.S.-Japan Charter 

Filings for 2009 
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 

scott.mcclain@delta.com 

sametta.c.barnett@delta.com 

kquinn@pillsburywinthrop.com 

bkeiner@crowell.com 

mrosia@crowell.com 

bruce.rabinovitz@wilmerhale.com 

jeffrey.manley@united.com 

bob.kneisley@wnco.com 

robert.land@jetblue.com 

msinick@ssd.com 

cdonley@ssd.com 

anbird@fedex.com 

dvaughan@kelleydrye.com 

kevin.montgomery@polaraircargo.com 

jrichardson@johnlrichardson.com 

lhalloway@crowell.com 

efaberman@wileyrein.com 

mroller@rollerbauer.com 

howard.kass@usairways.com 

benjamin.slocum@usairways.com 

sophy.chen@hklaw.com 

david.heffernan@wilmerhale.com 

March 1, 2010 

jhill@dlalaw.com 

bill@mietuslaw.com 

mgoldman@sgbdc.com 

rsilverberg@sgbdc.com 

dhainbach@ggh-airlaw.com 

mcmillin@woa.com 

eskraft@jamhoff.com 

dpdean@jamhoff.com 

dkirstein@yklaw.com 

jyoung@yklaw.com 

donna.kooperstein@usdoj.gov 

dwight.moore@ustranscom.mil 

jim.ballough@faa.gov 

byerlyjr@state.gov 

recohn@hhlaw.com 

cjsimpson@zsrlaw.com 

pmurphy@lopmurphy.com 

lachter@starpower.net 

anita.mosner@hklaw.com 

rpommer@atlasair.com 

gmurphy@crowell.com 

russell.bailey@alpa.org