BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

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

Applications of :

:

HAWAIIAN AIRLINES, INC. :

 and : Docket DOT-OST-2010-0018

UNITED AIRLINES, INC. :

:

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

Combination Service Allocation Proceeding :

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

ANSWER OF 

UNITED AIRLINES, INC.

Communications with respect to this document should be sent to:

Hershel I. Kamen

Senior Vice President–Alliances,

 Regulatory and Policy

Daniel A. Weiss

Managing Director–International

 Affairs and Regulatory

UNITED AIRLINES, INC.

233 South Wacker Drive

10th Floor – HDQIZ

Chicago, IL 60606

(872) 825-6828

hershel.kamen@united.com

dan.weiss@united.com

Steve Morrissey

Managing Director–Regulatory Affairs 

 and Policy

Karine R. Faden

Managing Counsel–Regulatory, Antitrust &

 Competition

UNITED AIRLINES, INC.

1225 New York Avenue, NW

Suite 1100 – DCAIZ/DCALD

Washington, DC 20005

(202) 521-4373

(202) 521-4363

steve.morrissey@united.com

karine.faden@united.com

Thomas Newton Bolling

Vice President and Deputy General Counsel

UNITED AIRLINES, INC.

233 South Wacker Drive

11th Floor – HDQLD

Chicago, IL 60606

(872) 825-8068

thomas.bolling@united.com

Douglas P. Kelley

Senior Counsel–Regulatory, Antitrust &

 Competition

UNITED AIRLINES, INC.

1600 Smith Street

HQSLG-15

Houston, TX 77002

(713) 324-5156

doug.kelley@united.com

Lorraine B. Halloway

Gerald F. Murphy

CROWELL & MORING LLP

1001 Pennsylvania Avenue, NW

Washington, DC 20004

(202) 624-2500

lhalloway@crowell.com

gmurphy@crowell.com

Counsel for

United Airlines, Inc.

December 9, 2013
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

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

Applications of :

:

HAWAIIAN AIRLINES, INC. :

 and : Docket DOT-OST-2010-0018

UNITED AIRLINES, INC. :

:

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

Combination Service Allocation Proceeding :

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

ANSWER OF 

UNITED AIRLINES, INC.

I. INTRODUCTION

United1proposes to provide first ever U.S. carrier Tokyo Haneda service at its San 

Francisco hub gateway – serving one of the largest U.S.-Tokyo gateways without nonstop U.S. 

carrier access to Haneda. Meanwhile, Hawaiian proposes to serve a small gateway that would 

offer comparatively far less benefits to U.S. consumers and virtually no connecting opportunities

for communities served behind Kona. United is the only applicant in this proceeding that has not 

been given the opportunity to serve Tokyo Haneda to the benefit of its customers, co-workers 

and communities and is thus the only applicant that can bring new competition to Tokyo Haneda. 

Selecting United over Tokyo Haneda incumbent Hawaiian will both maximize public benefits 

and create new U.S. carrier competition between the Western U.S. and Tokyo Haneda. 

To maximize the public benefits to the traveling and shipping public available through 

the use of these valuable Tokyo Haneda slots while at the same time enhancing the overall 

competitive environment between the U.S. and Japan, the Department should select United’s 

proposal to operate daily San Francisco-Tokyo Haneda flights because:

 

1 Common names are used for airlines.
Answer of United

Page 2

• United’s proposal will provide first time nonstop U.S. carrier competition 

between the West Coast and Tokyo Haneda.

• In addition to providing enhanced convenience for nonstop passengers in one of 

the largest U.S.-Tokyo markets, United will provide convenient connecting 

service with a catchment area covering key markets across the entire U.S. 

mainland.

• Only United’s proposal will introduce new and/or competitive U.S. carrier service 

and a large hub network for Tokyo Haneda passengers throughout the Western 

U.S., including smaller communities.

• United is the only U.S. carrier serving Japan that has not been given the 

opportunity to serve Tokyo Haneda to the benefit of its customers, co-workers 

and communities, and awarding the available slots to United will correct this 

imbalance; whereas Hawaiian already serves Tokyo Haneda.

• United continues to grow its Asia/Pacific operations at San Francisco and its San 

Francisco hub is the largest airline operation on the West Coast, thus making San 

Francisco an ideal gateway; whereas other U.S. gateways have been tried and 

failed in serving Tokyo Haneda.

Hawaiian already has access to Tokyo Haneda – and its Kona-Haneda proposal should

not be selected over United’s proposal to offer San Francisco-Haneda service. Hawaiian’s 

proposal to serve the much smaller Kona-Tokyo market is inferior to United’s proposal for San 

Francisco-Tokyo because it would: offer comparatively far fewer benefits to U.S. consumers; not 

increase competition between U.S. carriers at Tokyo Haneda; and not offer meaningful beyond 

gateway competition to multiple U.S.-Tokyo markets or smaller communities.

United answers the application of Hawaiian as follows and urges the Department to grant 

its application to provide San Francisco-Tokyo Haneda service.

II. UNITED’S PROPOSAL OFFERS FAR MORE PUBLIC BENEFITS THAN DOES 

HAWAIIAN’S PROPOSAL

United’s proposal to provide nonstop San Francisco-Tokyo Haneda service offers far 

more public benefits than does Hawaiian’s proposal, and Department precedent compels the 

award of the available Tokyo Haneda slots to United. The Department should select the largest 

U.S.-Tokyo market available in this proceeding to maximize the number of passengers who will 
Answer of United

Page 3

benefit from the introduction of nonstop Tokyo Haneda service at the gateway supporting the 

largest traffic volume to meet its “principal objective” in allocating slots to “maximize public 

benefits...that will likely result in service that best meets the needs of the traveling and shipping 

public.” Order 2013-11-9 at 3; see also Orders 2012-8-20 at 3 and 2010-1-17 at 1-2. To make 

this determination, the Department must consider the relative merits of each proposal, especially 

the number of passengers who would benefit from the connecting networks of the applicants’ 

U.S. gateways, in addition to the relative volumes of local Tokyo traffic flowing to each 

gateway.

2

 The combination of a large gateway with plentiful online connections has enabled 

United to institute and sustain U.S.-Asia services. Exhibits UA-A-104 to A-106. Appropriate 

emphasis on these two factors will also ensure the success of the selected Tokyo Haneda service. 

United proposes to serve a large nonstop market that lacks U.S. carrier service, and properly 

timed Tokyo Haneda flights from United’s San Francisco hub would provide competitive new 

entrant service to approximately 1.8 million Americans – reaching a catchment area far larger 

than what would be offered by Hawaiian’ proposal. Exhibits UA-A-101 and UA-A-107. United 

at San Francisco will also provide far more roundtrip connections than Hawaiian can provide at 

Kona. Exhibit UA-A-101.

United’s San Francisco hub is the largest hub on the West Coast and the only hub at 

which Tokyo Haneda service is being proposed in this proceeding. Exhibit UA-A-106. San 

Francisco is also one of the largest U.S.-Tokyo gateways without nonstop U.S. carrier access to 

Haneda, and United is the only U.S. carrier serving Japan that has not been given the opportunity 

to operate at Tokyo Haneda to the benefit of its customers, co-workers and communities. 

Exhibit UA-A-109. Awarding the available Tokyo Haneda slots to United will correct this 

 

2

Indeed, the “ability to flow traffic over the primary route to and from points 

behind the U.S. gateway...figured significantly in carrier selection because it bears on both the 

economic viability of a carrier’s proposal and the benefits it might bring to passengers outside of 

the primary market.” 51 Fed. Reg. 43180, 43187 (Dec. 1, 1986) (establishing procedures and 

criteria for selecting carriers for limited entry markets). 
Answer of United

Page 4

imbalance and create first time nonstop U.S. carrier competition between the Western U.S. and 

Tokyo Haneda. In addition, United’s hub at San Francisco will offer convenient online 

connecting service for passengers traveling between points throughout North America and 

Tokyo Haneda – including the four largest U.S. cities. See Exhibit UA-A-102. Moreover, the 

Department has already recognized the “notable attributes” of United “offer[ing] the first U.S.-

carrier nonstop service using its own aircraft in the sizeable San Francisco-Haneda 

market...[and] an extensive number of online connections through its San Francisco hub to an 

appreciable catchment area.” See Order 2012-11-12 at 6. 

III. UNITED’S PROPOSAL SHOULD BE SELECTED OVER HAWAIIAN’S PROPOSAL

Hawaiian’s proposal would use these valuable Haneda slots to serve the small KonaTokyo market and offer comparatively far fewer benefits to U.S. consumers than would United’s 

San Francisco-Tokyo Haneda proposal. The San Francisco-Tokyo market is four times larger

than the Kona-Tokyo market and United’s proposed service would reach 29 times more

consumers than Hawaiian at Kona. Exhibits UA-A-100 and UA-A-101. Putting aside that 

Hawaiian is seeking a second pair of U.S.-Tokyo Haneda slots while United has still not been 

given the opportunity to operate at Tokyo Haneda (Exhibit UA-A-109), Hawaiian has yet to 

provide any Asia/Pacific service from its proposed Kona gateway. Exhibit UA-A-105. 

Hawaiian’s proposed service at Kona would also offer no connections to the U.S. mainland 

whatsoever, offering only its Neighbor Hawaiian Island connecting service. See, e.g., Hawaiian

Application at 3. This stands in stark contrast to the comprehensive network benefits offered by 

United at San Francisco – where United will offer first time U.S. carrier connecting service 

and/or competitive connecting service between Tokyo Haneda and 17 smaller communities in 

the Western U.S. Exhibit UA-A-104. 

Selecting United’s San Francisco-Tokyo Haneda proposal will provide additional 

capacity for the large business communities and shippers in San Francisco and Tokyo, the large