**BEFORE THE DEPARTMENT OF TRANSPORTATION**  **WASHINGTON, D. C.**

--------------------------------------------- 2010 U.S.-HANEDA COMBINATION SERVICES : DOT-OST-2010- ALLOCATION PROCEEDING : 0018

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**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 17 th 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 17 th 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

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**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 nonstopflights 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 **one** world alliance. JAL has been part of **one** world 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 **one** world 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’s18.5% (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 Asiafrom 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 withaccess 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 byincreasing 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 ChinaEastern 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 fostercompetitive balance among the three global alliances. In showcause Order 2010-2-8, February 13, 2010, in the **one** world 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 (“ **one** world 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

**one** world 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 ATIpartner 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 openskies 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 ofU.S.-China service by United and its partner . . . all demonstrate the extraordinarily anticompetitive effect of awarding even more frequencies to United”). Nevertheless, by Order2007-2-10, 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’sown 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 sixU.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 Koreaand 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 displaytheir codes on United’s U.S.-Japan flights and on Asiana’s U.SKorea flights (DOT-OST-2009-0277 and DOT-OST-2007-0059). USAirways 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 **one** world 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 onCommerce 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&Dtraffic (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’s16

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 schedulesshow 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

**one** world) 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 twodaily 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 marketssuch 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 alreadywell 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 **one** world 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 7 th And 8 th 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

# 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

# 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

# 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

# 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

# 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

# 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

# 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

# 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

Source: DOT Monthly Air Travel Consumer Reports, Table 2 (October 2009

- December 2009) http://airconsumer.ost.dot.gov/reports/atcr09.htmDOT

- OST

- 2010

- 0018 E xhibit 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 Ci ty 85.1 0 2 PHX Phoen ix 83.93 3 MDW Chicago Midway 83.54 4 LAS Las Ve gas 82.92 5 IAH Houston 82.75 6 LAX Los Angele s 82.68 7 BWI Baltimore 82.46 8 SEA Seattle 82.22 9 CVG Cincinnati 82.18 10 MEM Mem phis 82.05 11 STL St. L ouis 81.87 12 DTW Detroit 81.86 13 SAN San Diego 81.69 14 TPA Tampa 81.3 0 15 MCO Orl ando 80.89 16 IAD Washi ngton (Dulles) 80.8 0 17 DEN D enver 80.77 18 DCA Washington (Reagan) 80.34 19 CLT Charlott e 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 Sa n Francisco 73.53 28 JFK New York (Kennedy) 73.51 29 ATL Atlanta 72.6 0 30 LGA New York (LaGuardia) 68.7 0 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 2010DOT

- OST

- 2010

- 0018 E xhibit AA

- R

- 113 Page 1 of 1


## AMERICAN OFFER S SHORTER ELAPSED TIMES FOR THREE CITIES BEYOND JFK , INCLU D ING WASHINGTON AND BOSTON (THE 7 th 

## AND 8 th 

## 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

# Honolulu And Guam Enjoy Extensive Scheduled Service From Japan DOT

- OST

- 2010

- 0018 Exhibit AA

- R

- 114 Page 2 of 2

Source: OAG February 2010DOT-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)

- 8-767DOT-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 40000T-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 2009CERTIFICATE 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