# BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Application of

DELTA AIR LINES, INC.

2010 U.S.-Haneda Combination Services

Allocation Proceeding )

)

)

)

)

)

) Docket DOT-OST-2010-0018

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

Jeff Morgan

Regional Director – Government Affairs

DELTA AIR LINES, INC.

1212 New York Avenue, N.W.

Washington, D.C. 20005

(202) 842-4184

sascha.vanderbellen@delta.com

March 8, 2010

# BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Application of

DELTA AIR LINES, INC.

2010 U.S.-Haneda Combination Services

Allocation Proceeding )

)

)

)

)

)

) Docket DOT-OST-2010-0018

REPLY OF DELTA AIR LINES, INC.

I. Introduction

Delta’s U.S.-Haneda service proposals will create the greatest service and

competitive benefits for the traveling public. The pending antirust immunity applications of

American and JAL, and United and Continental and ANA, create a strong public interest

need to promote and maintain effective competition in a significantly more concentrated

U.S.-Japan aviation marketplace. Nowhere are those concerns more important than at

Haneda -- because Haneda will not be fully open to competitive service, and because the

Star and oneworld alliances enjoy the advantages of presence and incumbency by virtue of

the large hubs maintained at Haneda by JAL and ANA. The grant of Delta’s proposals

would enhance the competitive market struct ure and would provide important consumer

benefits:

• Seattle is the northernmost major city on the west coast and is ideally situated on

the great circle route to Tokyo. Seattle has the largest catchment area of any

U.S. hub, and will provide the most effective west coast - Haneda competition to

the Star and oneworld alliance carriers. Last year, Delta and Alaska Airlines

announced a major domestic marketing alliance, which provides a strong and

growing network of west coast services fueling Delta’s international expansion at

Seattle and Los Angeles. Haneda service fr om Seattle will provide Western U.S.

passengers with a critically needed third competitive option.

# Reply of Delta

Page 2

• Detroit is the largest airline hub in the Northern tier of the Eastern United States.

Detroit is also well situated to provide optimal great circle routings and is the

most convenient Haneda gateway for the greatest numbers of Eastern U.S.

passengers. Detroit’s award-winning terminal, vast airside capacity, and state-ofthe-art federal inspection facilities guarantee efficient, on-time connections for 1

million potential Haneda passengers in over 100 Eastern U.S. cities.

• Los Angeles is the largest U.S. mainland gateway to Tokyo. Delta’s 403-seat

B747 proposal will maximize service and competitive benefits at Los Angeles,

providing over 100,000 more annual seats to Haneda (63 percent more) than

American. Most importantly, only the selection of Delta assures meaningful

competitive choice for Los Angeles-Haneda passengers and prevents the

Star/oneworld monopoly or duopoly that would otherwise result from the grant of

antitrust immunity.

• Delta’s Honolulu proposal would also maximize public benefits by operating large

B747 aircraft. While Delta recognizes the Department’s desire to promote new

entry by carriers such as Hawaiian, those considerations should be weighed

carefully given the limited nature of the Haneda slots and the lesser benefits that

would be offered by Hawaiian’s much smaller B767 proposal. Hawaiian has a

poor track record of implementing prior Tokyo service awards, ultimately

surrendering the Honolulu-Tokyo authority it received in 1998. Haneda’s

convenience will be particularly valued by time sensitive business travelers

originating on the U.S. mainland, and Hawaiian provides few if any benefits for

such passengers. In these circumstances, at most, Hawaiian should receive no

more than a single pair of slots.

In light of the restrictions affecting Haneda access, and the competitive impact the

pending antitrust immunity applications will have on U.S.-Japan competition, it is especially

important that Delta be selected for slots in this proceeding to provide an effective third

alliance competitor at Haneda.

II. An Award of Haneda Slots to the Star or Oneworld Applicants Would be

Inconsistent With Approval of Their Pending Antitrust Immunity

Applications.

A. Even with Open Skies, Haneda Will Be Closed to New Entry.

Here the Department seeks to allocate the limited entry slots available for U.S.-

Haneda service in a way that will maximize competition and public interest benefits. At the

same time, the Department is being asked by the Star and oneworld carriers for a grant of

antitrust immunity that would cover all of their U.S.-Japan services and merge their

# Reply of Delta

Page 3

competing operations into integrated joint venture alliances. In 28 antitrust immunity cases

spanning seventeen years of open skies policy, the Department has consistently relied on

the open entry provisions of the open skies agreements to ensure that competition and the

public interest is not harmed by the eliminati on of competition between the ATI partners.

At Haneda, the Department now confronts, for the first time, a truly closed airport

within an open skies country. Even at the slot-constrained London Heathrow Airport there is

an effective buy-sell-trade mechanism and the ability of competing alliance partners to

transfer slots to enhance competition on routes affected by the immunity. 1 

# There is no buysell-trade mechanism at Haneda, and the grant of limited-entry Haneda slots to Star and

oneworld here would create an irreconcilable conflict with the request for antitrust immunity

with the Japanese-flag Haneda incumbents.

The 2009 U.S.-Japan MOU contains certain unique features which require special

consideration. As aptly stated by American:

“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 partners’ homeland,

since ATI requires open skies, and open skies has no limits on entry .” (AA Answer at

10).

The issue here is how to allocate the limited entry opportunities in a way that maximizes

competition and thus achieves the greatest public interest benefit. Awarding any of the four

pairs of Haneda slots to airlines that already enjoy Haneda access through the pending

immunized joint ventures would exacerbate the consequences of those restrictions and

would not maximize public benefits. 2

1 

# Order 2010-2-8 at 24.

2 

# The suggestion by some carriers that they should be favored for an award here because

they were quick to support compromise on critical airport access issues is without merit and

irrelevant to the Department’s public interest analysis. Delta’s position throughout the Japan

negotiations was that Delta favored open skies, free from the “unique” provisions identified

by American. While Delta would have preferred a more conventional open skies regime, we

understand the compromises that were made in order to reach agreement with Japan.

# Reply of Delta

Page 4

B. Although the Star and oneworld Applicants Want the Department to

Ignore Their Pending Antitrust Immunity Applications In This

Proceeding, The Fact Is American, Continental, and United Will Serve

Haneda Through Joint Ventures With Their Japanese Partners.

American will have access to the U.S.-Haneda market through its partnership with

JAL, as will United and Continental through ANA. This is an efficient result that will

maximize the benefits of the limited entry opportunities and promote competition among the

three major alliances at Haneda. Delta does not have a Japanese partner and enjoys none

of the benefits of hub presence and incumbency at Haneda that are the exclusive

providence of Star and oneworld. ANA operates 226 daily scheduled departures at Haneda

and JAL operates 189 daily scheduled departures. 3 

# The extensive hub operations of Star

and oneworld create significant advantages in marketing U.S.-Tokyo and U.S.-Haneda

service. To help offset these advantages and provide effective 3-way alliance competition

for time-sensitive travelers and corporate accounts, grant of Delta’s proposals would

produce the best public interest result.

Under their immunized joint ventures, the Star and oneworld carriers say that they

will engage in integrated route planning, joint pricing, revenue sharing, and joint marketing

and sales. The object of “metal neutrality” is to erase any distinction or preference between

the operating and marketing carriers. In granting antitrust immunity, the Department places

a heavy emphasis on joint venture “integrative efficiencies” and has concluded that carve

outs are an inappropriate and ineffective remedy.

It is not realistic to think that the Star and oneworld carriers could merge their U.S.-

Japan networks, their marketing and corporate sales efforts, and coordinate fully at Narita

while remaining competitors at the limited-entry Haneda airport. For this reason, a Haneda

carve out would not work. It would both impair the function of the alliances and lessen the

3 

# Average Daily Departures, OAG February, 2010.

# Reply of Delta

Page 5

benefits attainable from the limited entry slots. On the other hand, if the U.S. and Japanese

alliance partners are granted the broad immunity they are requesting, they would be able to

share in the commercial results of those services at Haneda.

Given the limited-entry conditions that affect access to Haneda, the lack of a

workable carve-out remedy, and the material reduction in competition at Haneda that would

result from antitrust immunity if U.S. and Japanese slot holders in the same alliance were

granted immunity, Delta resolved that it would not apply for Haneda slots if Delta was

selected as JAL’s immunized partner. The Star and oneworld carriers have chosen a more

aggressive and competitively problematic approach. Delta urges the Department to apply

the same policy and precedent from the recent oneworld Show Cause Order, namely that:

“Airlines are not eligible [Haneda slot] recipients if they are members of the oneworld [or

Star] global alliance, affiliates of the applicants, or airlines in which the airlines have a

substantial financial interest.” (Page 26).

The Star and oneworld carriers should be treat ed, respectively, as single competitive

entities for purposes of this proceeding. In order for the open skies agreement (and the

related Haneda opportunities) to come into effect, antitrust immunity must first be granted to

the Japanese carriers and their U.S. partners:

" the Japanese delegation has expressed its view that signature on and entry into

force of that MOU would need to be preceded by a grant of antitrust immunity from

the United Sates for anticipated joint application(s) for such immunity by Japanese

airline(s) and the partner U.S. airline(s). . . . the Japanese delegation intends to sign

the draft MOU upon the grant by the competent U.S. authority of antitrust immunity

on the terms that are acceptable to the Japanese delegation . . . " 4



# Star and oneworld have requested antitrust immuni ty to jointly plan routes, set prices, and

share revenues, but ignore their immunity wh en it comes to seeking limited Haneda entry

4 

# December 11, 2009 letter from JCAB Deputy Director-General Keiji Takiguchi to Deputy

Assistant Secretary for Transportation Affairs, John Byerly.

# Reply of Delta

Page 6

awards, or when it is otherwise inconvenient or inexpedient. 5 

# Despite the extensive

benefits United and Continental claimed would be realized by the grant of their existing

global immunity , they trade Haneda route case jabs as if they were competitors. United and

Continental previously said that “the inclusi on of Continental as a fully immunized member

of the Star ATI alliance will enhance inter-alliance competition in the U.S.-Asia/Pacific

markets.” 6 

# And, in their current antitrust immunity application with ANA, they say that “the

Pacific JV will foster ‘metal neutrality’ – a commercial environment in which joint venture

partners share common economic incentives to pr omote the interests of their alliance over

their individual corporate interests.” 7 

# Either United/Continental do not plan to use the

immunity for the purpose granted, or they are being dishonest in attempting to falsely

portray themselves as competitors for purposes of this route case. Likewise, American’s

request for an award for it to keep pace with the “U.S. flag position at Haneda” (AA Answer

at 5) is incongruent with its antitrust immunity bid with JAL –where the two will become a

single competitive entity irrespective of the nationality of the operating carrier.

C. In the Absence of Open Entry at Haneda, a Grant of Additional Slots to

the Star and oneworld Applicants Would Be Inconsistent with

Department Policy and Precedent in Granting Antitrust Immunity.

In granting antitrust immunity, the D epartment places prime emphasis on the

existence of open entry conditions to discipline the immunized partnership. It is often the

case that immunized alliances produce high shares in key relevant markets. Joint ventures

also produce important efficiencies and benefits – but at the expense of the loss in

competition between the applicants. It is the existence of both de facto and de jure open

5 

# For example, United has attempted to disavow its existing global antitrust immunity with Air

Canada and Asiana which compete in the U.S.-Japan and U.S.-Asia marketplace. It is

difficult to understand how United will engage in simultaneous immunized transpacific

cooperation with Asiana and ANA, which overlap extensively across their route systems.

6 

# Consolidated Reply of the Star Joint Applicants at 11-12, OST-2008-0234 (December 15,

2008).

7 

# Joint Application of ANA, Continental and United at 12, December 23, 2009, OST-2009-

0350

# Reply of Delta

Page 7

entry under open skies which the Department has found enables the release of joint venture

benefits through immunity, while protecting the traveling public from competitive harm and

higher prices:

We recognize that the oneworld alliance (A merican, Lan Airlines and Lan Peru) will have

the largest share of the US-Peru Marke t, 69.1% based on historical data. By

comparison, the SkyTeam Alli ance (Delta and Continental) w ill have a smaller market

share of 29.6%. Nonetheless, our approval of the alliance relations hip between the Joint

Applicants should not substant ially reduce competition in the U.S.-Peru market.”

...[T]hese markets are governed by an open skies agreement that eliminates all barriers

to entry and provides the opportunity for other airlines to freely enter and meet the needs

of consumers. . . . The Joint Applicants alliance thus should not enable them to raise

fares above, or reduce service below, the le vels that would exist in a competitive

marketplace. American/LAN Airlines/LAN Peru, DOT Order 2005-10-8 at 10.

***

ANZ’s nonstop market share was 42 percen t. United had about a 28 percent market

share for a combined passenger market share of about 70 percent. . . . . As previously

determined, even if a transaction creates a partnership with a preponderant market

share, the transaction will not substantially reduce competit ion if the competitors have

free and open access to the marketplace . This is precisely t he type of market envisioned

and promoted by the U.S.-New Zealand open -skies accord. United/Air New Zealand

(DOT Order 2001-3-4) at 12.



# As discussed below, Haneda is an important, separate relevant market for U.S.-

Tokyo service. But, the critical open entry provisions which DOT precedent requires to

support the grant immunity do not exist at Haneda. There are not sufficient slots to meet

demand, and there is no market mechanism to obtain them. In these circumstances, the

grant of slots to American, United, or Conti nental would be highly problematic and in conflict

with their pending antitrust immunity requests.

Under the antitrust immunity provisions of the federal transportation code, the

Secretary “shall disapprove ” an agreement that “substantially reduces or eliminates

competition.” DOT may, however, grant antit rust immunity when (1) the arrangement “is

necessary . . . to achieve important public benefits” and (2) those benefits “cannot be

achieved by reasonably available alternatives that are materially less anticompetitive.” 49

U.S.C. §§ 41308, 41309(b). If American, United or Continental were to receive an award of

Haneda slots here, then subsequently receive a grant of immunity which eliminates

# Reply of Delta

Page 8

competition between these carriers and their respective Japanese partners at Haneda, it

would “substantially reduce or eliminate compet ition” in an important relevant market. The

Department cannot rely on open entry at Haneda to mitigate the effects of eleminating

competition between alliance partners at Haneda – because open entry does not exist at

Haneda. No “important public benefits” would be achieved by granting discretionary slot

awards to American, Continental or United – then immunizing the use of those limited-entry

slots for use in concert with the dominant Japanese flag carriers operating at Haneda. It is

materially less anticompetitive to award slot s to independent carriers to compete with the

immunized alliances operating at Haneda, than to grant the dominant alliances more slots

and restrict competition by others.

The importance of the highly preferred Haneda airport to service and competition in

the U.S.-Tokyo market cannot be overstated. Haneda is located just 15 minutes from

downtown Tokyo, whereas Narita is over an hour by car, bus, or train and located 45 miles

outside the city. Just as the Department st ated that Heathrow and Gatwick are separate

relevant markets at London, so are Haneda and Narita at Tokyo. Haneda is highly preferred

by Tokyo travelers as Heathrow is to London travelers. As the Department found, “by a

three to one margin, passengers in the U.S.-UK market travel to/from Heathrow, even when

alternate Gatwick service as available.” onew orld Show Cause Order 2010-2-8 at 20. For

these same reasons, Haneda is an important and distinct relevant market that will need to

be considered in the pending U.S.-Japan antitrust immunity cases.

In entering into the draft MOU with Japan, and in subsequent communications with

the Government of Japan, the Department stated that it would not prejudge the outcome of

the immunity cases. Throughout the course of the negotiations, the Department indicated

that in the immunity cases it will determi ne whether competitive conditions exist at Japan’s

critical airports – such that the grant of ATI can be supported and without fear that the

applicants would be able to raise fares and charge supra-competitive prices.

# Reply of Delta

Page 9

The applications of the Star and oneworld carriers – seeking Haneda limited-entry

allocations on top of the awards already enjoyed by their Japanese partners is

fundamentally at odds with their bids to secure antitrust immunity – since the grant of those

applications depends on a competitive marketplace. Apart from the slots at issue in this

case and the slots held by the Japanese members of Star and oneworld, Haneda is closed

to new entry. There is no buy-sell mechanism for obtaining access to Haneda (as there is at

Heathrow) and there would be only very limited one-stop competition to Haneda via

intermediate gateways. By seeking to usurp limited-entry slots that would otherwise be

used by independent carriers to provide competition at Haneda, the Star and oneworld

carriers have created a tension which threatens the Department’s ability to conclude that

immunity would be in the public interest, and at minimum will complicate and delay the

cases so that appropriate remedies can be considered.

In the recent American/British Airways proceeding, the Department (which was

concerned about the lack of access at slot-restricted Heathrow and the elimination of

competition between American and British Airways as a result of the grant of immunity)

ordered a divestiture of slots to help restore com petitive conditions at the airport. Given the

lack of any market-based mechanism for carriers such as Delta to acquire slots and provide

competition, the need for slot divestitures would be even more essential here. The

Department can readily avoid this result by refusing to grant slots to U.S. carriers seeking

immunity with the Japanese Haneda incumbents. 8

8 

# For the reasons stated above, Delta believes that the preferred course is to presume that

antitrust immunity would be granted (as it must for open skies and Haneda service to come

into effect) and refrain from granting slots to the Star and oneworld applicants. If, however,

slots were granted to any Star or oneworld carrier before the antitrust immunity issues are

resolved, Delta should be designated as backup for Haneda slot divestiture conditions

resulting from the antitrust immunity order.

# Reply of Delta

Page 10

III. Delta Will Be Smaller Than Star and oneworld.

The implementation of the U.S.-Japan open skies agreement – together with the

grant of antitrust immunity to the Star and oneworld carriers which must precede open skies

– will have a profound effect on the competitive landscape. Contrary to the suggestion of

the other applicants, Delta is not attempting to perpetuate a “dominant” position though its

request for Haneda slots. Delta is simply r equesting the slots it needs to provide effective

competition for the traveling public. Grant of Delta’s Haneda requests will provide the public

with an effective third alliance competitor. The following data for U.S. point of sale bookings,

taken directly from Star’s antitrust immunity application, demonstrates that Delta will have

the smallest share of U.S.-Japan traffic among the three major alliances:

# Reply of Delta

Page 11

Likewise, in terms of U.S.-Tokyo departures, combining the operations of United and

Continental and ANA, and American and JAL, shows that Delta will not have “far more

departures” than its competitors as alleged by United. DL-R-103.

Assuming antitrust immunity is granted (as it must for open skies to come into effect)

Star and oneworld will leapfrog Delta in terms of U.S.-Japan and U.S.-Tokyo passengers.

Delta will have a more difficult time competing for Tokyo passengers because the Star and

oneworld alliances will be able to exploit the advantages of presence and incumbency by

virtue of the Haneda hubs maintained by JAL and ANA at this critical limited-entry airport.

Under the metal-neutral joint ventures, the Star and oneworld carriers say they will engage

in common marketing strategies -- giving them advantages in competing for time sensitive

passengers and key corporate accounts, especially since many Tokyo customers will desire

service from both airports. Delta’s overall Tokyo departures (now only from Narita) are

dwarfed by the combined shares of the Star and oneworld carriers operating from both

Narita and Haneda.

In order to maintain a competitive market structure, it is very important to consumers

and to Delta to maintain a viable third alliance competitor at Haneda. Delta needs sufficient

slots to provide a strong competitive counterweight the immunized Star and oneworld

alliances operating from Haneda.

American, United, and Continental try to paint Delta’s request as somehow “greedy”

or “excessive.” Yet, the slot allocations requested by these carriers, together with those

allocated to their Japanese partners, will give the Star and oneworld immunized alliances

equal or greater Haneda slots than requested by Delta. Delta must compete on a standalone basis against the incumbent alliance carriers at Haneda. For example, if American

were to receive the two slots pairs it requested for JFK and Los Angeles, together with JAL,

oneworld would have four Haneda slot pairs . If Continental were to receive slots for Newark

and Guam, and United for San Francisco, Star would have five Haneda slot pairs . DL-R-

# Reply of Delta

Page 12

108. Put in proper perspective, Delta’s request for Haneda slot pairs is reasonable to

promote competition for the traveling public – and offset the competitive effects of

immunized alliances leveraging their combined strength at Tokyo’s most important and most

restricted airport.

IV. Delta’s Haneda Gateways Will Maximize Service and Competitive

Benefits.

The grant of Delta’s proposals will best enhance the competitive market structure

and ensure effective 3-way alliance competition against the immunized alliances with

incumbent hubs at Haneda. Delta has proposed a comprehensive pattern of Haneda

service from key U.S. gateways including Seattle, Detroit, Los Angeles and Honolulu.

A. Delta’s Seattle Proposal Provides the Greatest Benefits to the West

Coast Including the Pacific Northwest.

Delta’s Seattle-Haneda proposal will assist the Department’s goal of maximizing

U.S.-Haneda service benefits and competition for the traveling public. Seattle-Tokyo is an

important local market serving the business needs of the Pacific Northwest and major U.S.

multinational corporations located in Seattle including Microsoft, Boeing, Amazon, Costco,

Nordstrom, Weyerhaeuser, the Gates Foundation, and Nintendo. Seattle is also the best

situated West Coast hub with the ability to serve the entire West Coast -- unlike

United/Star’s San Francisco gateway which is unreasonably circuitous for major Pacific

Northwest cities such as Seattle and Portland. Delta’s partnership with Alaska Airlines,

together with Delta’s own-metal services, will enable Delta to provide nonstop-to-nonstop

Haneda service for 55 U.S. cities. DL-R-301.

The grant of slots to Delta for Seattle-Haneda service will enhance competitive

service options for west coast passengers to Tokyo, who would otherwise face a

Star/oneworld duopoly. Absent an award to United, San Francisco is highly likely to receive

# Reply of Delta

Page 13

nonstop service from ANA, United’s joint venture partner. The west coast is particularly

attractive for Haneda service in light of the restrictions on schedules and operations.

Furthermore, in addition to the U.S. and Japanese services that would be authorized under

the 2009 MOU, Japan and Canada have already reached agreement that provides for

expanded Haneda opportunities for Japanese and Canadian carriers at airports including

Vancouver. Notably, United already enjoys glob al antitrust immunity with Air Canada, which

operates a large hub at Vancouver. Seattle and Vancouver compete aggressively for traffic

in the Pacific Northwest, and Delta will compete for western passengers by offering service

to Tokyo’s preferred airport from Seattle.

Delta will rely on the substantial additional network feed provided by Alaska Airlines,

Seattle’s hometown hub carrier. According to JD Power’s 2009 North American Airline

Satisfaction Study, Alaska is the highest rated traditional network carrier, ranking together

with Delta in the top three. DL-R-305. United, despite its claims in this case of “award

winning service” in fact ranked last in every customer service category. Id . Last year, Delta

and Alaska announced an important new domestic marketing alliance, which was reviewed

by the Department and is now being implem ented. DL-R-304. Under the preferred

partnership arrangement, Alaska has committed incremental capacity exclusively to feed

Delta’s international services from Seattle (and Los Angeles). United’s assertion that

Alaska services should be disregarded is without merit, and its assertion that Delta would

provide “ no connecting service to Haneda through SEA” is ridiculous. (UA Answer at 15,

emphasis original). While rejecting Delta’s SEA connections on Alaska, United goes on to

claim credit for the beyond-Haneda network of its own partner, ANA. DL-R-306. Not only

is there strong connecting service at Seattle today, if Delta is awarded Haneda authority

from Seattle, Delta and Alaska would seek to promote the growth and connectivity of their

# Reply of Delta

Page 14

network, just as United claims that it would “retime some of these flights for optimal

connection to SFO-HND.” (See, Exhibit UA-3)

The Department’s stated objective in this case is “to maximize public benefits that

will result from introducing U.S. flag service in the U.S.-Haneda market .” 9 

# The U.S.-Haneda

market (representing the most convenient airport in Tokyo) would be harmed by dedicating

any of this precious and very limited capacity to beyond-Haneda markets. United, while

conceding the poor quality of its beyond-Haneda connections on ANA (United Application at

8), nonetheless claims “strong connectivity at both ends of the route.” Id. at 3, emphasis

original. Any reliance on ANA’s poor quality beyond connections would decrease the value

to U.S.-Haneda customers at this critical limited-ent ry airport. Connecting markets can and

should be served via open airports that do not deprive U.S.-Haneda passengers of scarce

capacity. Delta intends to fully utilize any allocation of Haneda slots to benefit U.S.-Haneda

customers. United’s plans to use Haneda as a conduit for connecting passengers is a

waste of scarce resource, particularly considering that United already serves ANA’s largest

beyond-Haneda markets either with its own metal, via alternative ANA gateways in Japan

that are not limited entry, or on immunized basis with other partners. In fact, United has so

many immunized partners that it has apparently elected to freeze Air Canada and Asiana

out of its transpacific joint venture (despite the benefits United previously claimed would

result from a grant of immunity between United and those carriers). 10 

# Inexplicably, United

and Continental jockey for position in this case against one another ignoring (perhaps

intentionally) the fact that they already have transpacific immunity with one another and will

be part of the same transpacific joint venture with ANA. DL-R-105-107.

9 

# Order 2010-1-17 at 1.

10 

# See, Star Joint Application for Antitrust Immunity, Docket OST-2009- OST-2009-0350.

# Reply of Delta

Page 15

Delta proposes to operate its Seattle-Haneda service using large capacity Airbus

330-300 aircraft outfitted with 298 passenger seats, delivering 20,000 more seats annually

(11 percent more) than United’s B777 proposal. DL-R-302. Notwithstanding its inferior

capacity, United claims that Delta’s A330 proposal for Seattle is somehow a weakness,

since Delta proposes B747 aircraft at its other gateways. As Delta explains in its application,

A330’s are proposed for Seattle because those aircraft are already based at Seattle. Delta

does not base 747 aircraft, pilots, or maintenance at Seattle, making it logistically difficult to

operate a 747. The proposed A330 schedule to and from Haneda dovetails with Delta’s

existing Seattle-Amsterdam flight, making for an efficient equipment rotation and providing

U.S.-Haneda passenger with a modern, comfortable, and high capacity aircraft.

B. Delta’s Detroit Gateway Maximizes Competition for the Largest Number of

Eastern U.S. Passengers.

Detroit is Delta’s primary Eastern U.S. gat eway for service to Asia and will provide

convenient Haneda connections benefitting more potential U.S.-Haneda passengers than

any other gateway at issue in this proceeding. The comprehensive network coverage of

Delta’s Detroit hub, together with Delta’s status as an unaligned competitor, will help to

protect the traveling public from the potential harmful effects of immunized cooperation by

the Star and oneworld alliances operating at the restricted Haneda airport. All told, Delta’s

Detroit hub will provide nonstop-to-nonstop H aneda service for 106 U.S. points, serving a

traffic base of nearly 1 million annual Tokyo passengers. 11 

# DL-R-204, 401.

New York/Newark is the only other Eastern gateway proposed for service in this

case. While New York is a large local market, it has a smaller catchment area with fewer

connecting flights operating from congested and del ay-prone airports. Moreover, whatever

may be said of New York/Newark service by Continental or American, the same would be

11 

# MIDT YE November 2009

# Reply of Delta

Page 16

true of service by their respective ATI partners. The Star and oneworld alliances are free to

plan and implement New York/Newark -Haneda service through their respective steering

committees. 12



# However, selecting a Star or oneworld carrier for New York service at the expense of

Delta’s large hub gateway at Detroit would deprive the entire Eastern half of the United

States of Haneda competition to discipline the im munized alliances. Every Eastern U.S. city

claimed by Continental or American at New Yo rk can be served by Delta as effectively or

more effectively from Detroit – along with scores of additional Eastern cities that would not

receive service via New York. DL-R-406.

12 

# Under their immunized joint ventures Amer ican and Continental are “indifferent” as to

which carrier operates the aircraft. An award to American or Continental at the expense of

Delta’s Detroit proposal would reduce Eastern U.S.-Haneda competition from three carriers

to two – creating a competitive monopoly (or at best a duopoly) affecting over 900,000

passengers in more than 100 U.S. cities t hat would enjoy convenient and competitive

service by a third independent pricer from Detroit. DL-R-204, 401.

# Reply of Delta

Page 17

Delta is proposing its largest aircraft – the Boeing 747-400 for service at Detroit.

The 403 seat capacity of the 747 will help to maximize the value of the scarce Haneda slots

that are available to U.S. carriers. By contrast the New York/Newark proposals of American

and Continental use smaller B777 aircraft that would benefit fewer passengers and fail to

maximize the benefits of the limited entry Haneda opportunities:

Delta’s large capacity B747 proposal is favored under the carrier selection criteria

applied by the Department in recent similar ca ses. As the Department explained in Order

2007-2-10 (2006 China Case), “shortfall of available nonstop service options emphasizes

the importance of injecting as much nonstop capacity into the. . .market as possible when

awarding these frequencies .” (Page 5 emphasis added). The Department went on to select

United because it would “provid[e] the most capacity in this proceeding with B-747

aircraft . . .” Id. Here, Delta’s Detroit proposal with B747 aircraft provides 63 percent more

capacity than American at JFK, and 46 percent more capacity than Continental at Newark.

# Reply of Delta

Page 18

DL-R-402. The Department has previously f ound much smaller capacity differences to be

decisionally significant. In rejecting Continental’s Newark-Shanghai proposal in favor of

United, the Department selected United because it would offer “22 percent more capacity

than Continental.” Order 2007-1-4 at 17.

American argues that on-time performance should be considered as a significant

factor and that “the applicant and airport with the better on-time record should be favored.”

AA Answer at 16. This is especially important in this case “not only because consumers

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.” Id . Detroit’s

on-time performance is markedly superior to JFK – as proved by American’s own exhibits.

DL-R-407. Based on 2009 DOT statistics, Detroit achieved an on-time arrival rate of 82

percent, besting JFK by 8 percentage points, and Newark by 16 percentage points. Id.

Given the tight operational constraints imposed on Haneda service – and the fact that these

services will be most desired by time-sensit ive travelers – Delta agrees that on-time

performance should be a significant consideration.

Another factor favoring the selection of Detroit is its state-of-the art and consumer

friendly 120-gate terminal facility, which is backed by significant airside capacity. The

terminal was specifically designed to make international connections easy and efficient.

There is a Federal Inspection Services (FIS) station located in the center of the mile-long

terminal building, which is able to process 3,200 passengers an hour. The Express Tram

monorail station is positioned immediately adjacent to the FIS facility, allowing passengers

to reach either end of the terminal building in less than two minutes. The Detroit terminal

has received numerous accolades for its des ign, aesthetics, and efficiency, including

recognition by J.D. Power & Associates, Airports Council International, and Airport Revenue

# Reply of Delta

Page 19

News, as being among the most consumer friendly and innovative airports in the United

States.

D. Delta’s Los Angeles Proposal Will Provide Important Competitive Benefits

in the Largest Mainland U.S. Market to Tokyo.

Delta and American have each proposed nonstop Los Angles-Haneda service.

However, the proposals are vastly different in terms of the service and competitive benefits

they will create. Los Angeles is the largest mainland U.S.-Japan O&D market, and it is

situated in the west coast region that is most attractive for Haneda service due to the

schedule constraints imposed by JCAB. Given these attributes, Los Angeles is likely to

receive nonstop Haneda service from JAL or ANA, or both. 13 

# Los Angeles-Haneda service

by JAL gives American fully effective comme rcial access through its immunized joint

venture 14 

# – but leaves unfulfilled the Department’s critical public interest objective of

maximizing service and competition for the traveling public.

By contrast, the selection of Delta for service at Los Angles would create a third

competitive option to the entrenched oneworld and Star alliance carriers that are firmly

ensconced at Haneda. In light of the strong existing presence by JAL and ANA at Haneda,

Delta submits that the public interest is better served by allocating Los Angeles-Haneda

slots to a third alliance carrier without a Japanese partner that can provide meaningful

13 

# The immunized alliance steering committees will be able to make joint route planning

decisions based on the Haneda slots allocated to JAL and ANA.

14 

# American cites a series of prior DOT route case decisions where the Department has

granted a carrier direct service authority, notwithstanding the existence of an arms-length

codeshare arrangement. Those cases are completely inapposite. Here, American and JAL

are not mere arm-length codeshare partners – but are seeking the extraordinary relief of

antitrust immunity to form a “metal neutral” joint venture eliminating all competition between

them and promoting “indifference” as to the operating carrier. American’s suggestion that it

should be treated for carrier selection purposes as a simple JAL codeshare partner cannot

be reconciled with the position it has taken in the antitrust immunity proceeding.

Furthermore, as acknowledge by American, it is unprecedented for a carrier to be vying for

limited-entry authority at the same time it is seeking antitrust immunity in an “open skies”

market.

# Reply of Delta

Page 20

competition -- rather than further exacer bating the Haneda advantages already enjoyed by

the Star and oneworld alliance carriers.

With over 400,000 local O&D passengers, Los Angeles generates more than twice

as many passengers as United’s proposed San Francisco gateway. DL-R-504. And,

although Honolulu generates large numbers of local passenger by virtue of its appeal to

Japanese leisure passengers, Los Angeles would benefit more than twice as many U.S.

origin passengers which are particularly relevant to the Department’s public interest

determination. DL-R-503. The are numerous U.S. Fortune 500 companies and Japanese

multinational corporations located in the greater Los Angeles area – all of which stand to

benefit from the new nonstop access to Tokyo’s preferred downtown airport.

Delta will operate much larger 747 aircraft, providing 63 percent more capacity or

more than 100,000 more annual seats than American. DL-R-502. As discussed above, the

Department considers aircraft capacity to be a key decisional factor in maximizing public

benefits in limited entry markets.

Delta’s substantial network at Los Angeles, together with its domestic alliance

partner, Alaska Airlines, will extend Haneda service benefit to interior U.S. points, further

bolstering competition with the Star and oneworld alliance carriers. Based on current

schedules, Delta and Alaska Airlines will provide nonstop-to-nonstop service via Los

Angeles for 18 U.S. points. DL-R-501. However, Delta and Alaska will expand schedules

and improve connectivity as new services are implemented under their domestic alliance.

Alaska independently schedules its network, but in doing so is mindful of the benefits of

maximizing connectivity to Delta’s international services. Delta service on the Los AngelesHaneda route is an important new service operating in a non-traditional time channel -- so it

is not surprising that current schedules do not reflect the full potential of Delta’s future

network connectivity at LAX.

# Reply of Delta

Page 21

E. Delta’s Honolulu-Haneda Service Provides the Greatest Benefits for

the Pacific Islands.

1. Hawaiian at Honolulu.

Delta’s 403-seat B747 proposal would maximize service benefits on the HonoluluHaneda route, delivering 56 percent more seats (106,000 annually) than Hawaiian’s B767

proposal. DL-R-605. This will enhance U.S. flag competition with the Japanese flag

incumbents, who are already serving H onolulu on a charter basis from Haneda.

Nonetheless, Delta is mindful of the importance the Department places on new entry.

Hawaiian Airlines, like Delta, lacks a Japanese alliance partner, and, absent an award in this

case, Hawaiian would be limited to offering charter service at Haneda. In these

circumstances, Delta would have no objection to Hawaiian receiving one slot pair for

Honolulu-Haneda scheduled service, with Delta receiving backup authority on the route.

Leisure passengers are the least time s ensitive, and, because they are generally

more willing to consider alternative services to save money, they are also the least likely to

suffer any harmful effects from the restrictions that limit competitive service at Haneda.

Therefore, Delta believes that the Department should prioritize the awards to promote

competition for time sensitive travel ers who value Haneda’s unique advantages of

convenience the most. Delta’s services prov ide a critical third competitive option in

hundreds of U.S.-Japan markets that would otherwise be subject to a Star/oneworld duopoly

on Haneda service.

All of the benefits of Hawaiian’s service proposal can and will be realized with a

single slot pair. There is no utility to a second “wingtip” flight using smallest aircraft at issue

in this case. Hawaiian acknowledges it has larger capacity A330 aircraft on order and that it

could upgauge to if the response to its service is positive. DL-R-606. Providing Hawaiian a

single slot pair will incentivize Hawaiian to use larger and more efficient aircraft – as well as

preserving scarce slots that are critically needed at key mainland gateways to combat the

# Reply of Delta

Page 22

expanding Haneda presence of the Star and oneworld alliance carriers. There are 600

Haneda charter opportunities that can be used by Hawaiian to augment service on the route,

without expending a second pair of critically sca rce scheduled service slots that can be used

to provide new service at an additional U.S. gateway. DL-ANS-608.

With only four slot pairs available, Honolulu should not receive more than a single

slot pair – since any further allocation would come at the expense of Delta’s large and

important mainland gateway that will benefit U.S. passengers . While Honolulu-Tokyo is an

important route, passengers are 94% Japan-originating. DL-R-601. Service at Delta’s

mainland gateways of Seattle, Detroit, and Los Angeles will benefit a much larger

percentage of U.S. origin passengers which are more important than Japanese leisure traffic

in the Department’s public interest analysis.

Hawaiian’s answer appears to drop any claim that its service would provide

connecting benefits to U.S. west coast gateways. This is not surprising given that service

via the South Pacific would be highly circuitous, inconvenient, and ineffective. DL-R-604.

# Reply of Delta

Page 23

As illustrated by the following table, Delta’s Seattle and Los Angeles proposals provide

much more convenient and effective routings for West Coast Passengers:

Considering the need for effective Haneda competition from the mainland U.S. to

combat the Star and oneworld alliances, at most a single pair should be allocated for

Hawaiian service at Honolulu. As acknowl edged by Hawaiian, it previously competed a

charter carrier in the U.S.-Japan market (and could do so at Haneda). Hawaiian was

previously allocated but failed to implement scheduled service on the Honolulu-Narita route

under the 1998 MOU. Hawaiian is thus free to supplement its Haneda service both with

charters as well as scheduled service at Narita which would be available under open skies.

2. Continental at Guam

Guam is another Japan-origin leisure market that is currently eligible for Haneda

charters and is eligible to receive more such service under the new agreement. Delta and

Continental both serve Guam on a scheduled basis from Narita. There is no justification for

giving Continental a competitive advantage from the preferred airport at Delta’s expense –

# Reply of Delta

Page 24

especially when Continental will reap the benefits of a major Haneda presence from its

partner, ANA.

Continental makes much of its “hub” at Guam, claiming the benefit of Haneda

connections for “Saipan, Honolulu, Majuro, Kwajalein, Kosrae, Pohnpei and Truk.”

Continental Answer at 9. However, Honolulu will likely receive nonstop Haneda service,

Saipan has nonstop flights from Narita, and the remainder of Continental’s tiny connecting

markets pale in comparison to the scores of U.S. mainland cities that would be served by

Delta from Seattle, Detroit, and Los Angeles. Finally, at only 1,500 miles, Haneda-Guam is

a short haul regional route and fails to maximize the operational and economic benefits that

would be realized by U.S. carriers providing service on long-haul intercontinental routes.

V. Conclusion.

For the foregoing reasons, Delta requests the allocation of slot pairs to provide new

daily Haneda service from Seattle, Detroit and Los Angeles, with either primary or backup

authority for Honolulu.

Respectfully submitted,

_________________________________ Alexander Van der Bellen

Managing Director, Government Affairs

& Associate General Counsel

DELTA AIR LINES, INC.

# Index of Reply Exhibits



# Exhibit Title

i R-100 SERIES: DELTA’S PROPOSALS PROVIDE EFFECTIVE

COMPETITION TO THE STAR AND ONEWORLD INCUMBENT

ALLIANCES AT HANEDA

DL-R-101 Delta Will be the Smallest Alliance Competitor to Japan

DL-R-102 Delta Will be the Smallest Alliance Competitor to Tokyo

DL-R-103 Immunized Star and Oneworld Equal Delta’s Operation at Narita and Will Far

Surpass Delta at Haneda

DL-R-104 American’s ATI Application Concedes That Oneworld Will Be Larger Than

Delta/SkyTeam in the U.S.-Japan Market

DL-R-105 United and Continental Can No Longer Be Considered Competitors in

International Markets

DL-R-106 United and Continental Also Ignore Their Pending Antitrust Immunity

Application with ANA in Which They Highlight Their Metal-Neutral Joint

Venture

DL-R-107 To Game the Route Case, United and Continental Pretend They Will Be

Transpacific Competitors

DL-R-108 Grant of American or United/Continental’s Applications Would Result in the

Same or More U.S.-Haneda Slots by Those Alliances as Requested by Delta

DL-R-109 An Allocation of Haneda Slots to Delta is Necessary to Enable Inter-Alliance

Competition

DL-R-110 Narita is Not a Substitute for Haneda - Haneda is the Preferred Airport

Serving the Metro Tokyo Area

R-200 SERIES: SELECTION OF DELTA’S HANEDA PROPOSALS WILL

MAXIMIZE PUBLIC BENEFITS

DL-R-201 Delta’s Proposals Will Bring the Greatest Capacity to the U.S.-Haneda

Market

DL-R-202 Delta’s Detroit and Seattle Gateways Will Serve the Most Nonstop-toNonstop U.S. Points to Haneda

DL-R-203 Delta’s Detroit and Seattle Connecting Traffic Bases to Haneda Are Larger

Than Any Other Applicant’s

DL-R-204 Delta’s Seattle and Detroit Gateways Will Serve the Largest Combined Local

and Connecting U.S. – Tokyo Traffic Base Among U.S. Mainland Gateways

R-300 SERIES: DELTA’S SEATTLE PROPOSAL PROVIDES THE

GREATEST BENEFITS TO THE PACIFIC NORTHWEST

DL-R-301 Seattle is an Ideal West Coast Gateway to Haneda: Delta Will Provide

Nonstop-to-Nonstop Haneda Service for 55 U.S. Points

DL-R-302 Delta’s Seattle Service Would Offer Over 20,000 More Annual Nonstop Seats

to/from Haneda Than United’s San Francisco Proposal

# Index of Reply Exhibits



# Exhibit Title

ii DL-R-303 Seattle’s Pacific Northwest Location Enables Non-Circuituous Connections to

Haneda From Across the Entire Continental U.S.

DL-R-304 Delta and Alaska Airlines Have an Extensive Marketing Alliance

DL-R-305 Alaska Airlines Was the Overall Highest Rated “Traditional Network” Carrier

in 2009; United Was Tied for Last Place

DL-R-306 United Dismisses Delta’s Connecting Feed from Alaska Airlines, Yet Takes

Credit for ANA’s Connecting Feed at Haneda

DL-R-307 Connections Between Delta and Alaska at Seattle are Easy With the Airport’s

Train System

DL-R-308 Seattle’s On-time Performance is 8 Points Higher Than San Francisco’s

R-400 SERIES: DELTA’S DETROIT GATEWAY PROVIDES THE MOST

EFFECTIVE AND COMPREHENSIVE COMPETITIVE COVERAGE OF THE

EASTERN U.S.

DL-R-401 Delta Will Provide Nonstop-to-Nonstop Haneda Service for 106 U.S. Points

Via Detroit

DL-R-402 Delta’s Detroit Service Would Offer 114,000 More Annual Seats to/from

Haneda Than American’s JFK Proposal and 93,000 More Annual Seats Than

Continental’s Newark Proposal

DL-R-403 Delta’s Primary Catchment Area From Detroit Provides Comprehensive and

Competitive Haneda Service for the Entire Eastern U.S.

DL-R-404 American’s JFK Gateway Serves Far Fewer Points in a Significantly Smaller

Catchment Area Than Delta’s Detroit Hub

DL-R-405 Continental’s Newark Hub Serves Far Fewer Points in a Significantly Smaller

Catchment Area Than Delta’s Detroit Hub

DL-R-406 Every Eastern U.S. Point Claimed by American at JFK and Continental at

Newark Can Be Served by Delta As Effectively or More Effectively Via

Detroit... Along With 56 Additional Eastern U.S. Cities That Would Not

Receive Any Service Via New York

DL-R-407 American’s Own Exhibit Illustrates Detroit’s On-time Performance is Far

Superior to JFK’s (and Newark’s)

R-500 SERIES: DELTA’S LOS ANGEL ES PROPOSAL IS SUPERIOR TO

AMERICAN’S

DL-R-501 Delta Los Angeles-Haneda Service Would Provide Strong

Competition at Star Alliance’s LAX Hub: Delta Will Provide Nonstop-toNonstop Haneda Service for 18 U.S. Points

DL-R-502 Delta’s Los Angeles Service Would Offer 114,000 More Annual Nonstop

Seats to/from Haneda Than American’s Los Angeles Proposal

# Index of Reply Exhibits



# Exhibit Title

iii DL-R-503 The Los Angeles-Tokyo Local Market Has Twice As Many U.S.-Originating

Passengers as the Honolulu-Tokyo Local Market

DL-R-504 Los Angeles is the Largest Mainland U.S.-Tokyo Market and is Nearly Twice

the Size of the San Francisco-Tokyo Local Market

R-600 SERIES: HAWAIIAN SHOULD NOT RECEIVE MORE THAN ONE

PAIR OF SLOTS FOR HONOLULU

DL-R-601 Honolulu-Tokyo Passengers Are Overwhelmingly Non-U.S. Point of Sale

DL-R-602 Honolulu is an Ineffective Gateway to Haneda for the Continental U.S.

DL-R-603 Honolulu is an Ineffective Gateway to Haneda for the Continental U.S.

DL-R-604 Honolulu is an Ineffective Gateway to Haneda for the Continental U.S.

DL-R-605 Delta’s Honolulu Service Would Offer 106,000 More Annual Nonstop Seats

to/from Haneda Than Hawaiian’s Honolulu Proposal

DL-R-606 Hawaiian’s “Wingtip” Flights Fail to Maximize Public Benefits

R-700 SERIES: CONTINENTAL SHOULD NOT RECEIVE A SCHEDULED

SERVICE AWARD FOR GUAM

DL-R-701 Guam-Tokyo Passengers Are Overwhelmingly Non-U.S. Point of Sale

DL-R-702 Based on U.S. Point-of-Sale Bookings, the Guam Local Market is

Substantially Smaller Than the Local Markets of Delta’s Proposed

Continental U.S. Gateways

DL-R-703 Continental and Delta Each Serve Guam from Narita

DL-R-704 Delta’s Honolulu Service Would Offer 107,000 More Annual Nonstop Seats

to/from Haneda Than Continental Micronesia’s Guam ProposalR-100 SeriesDelta’s Proposals Provide EffectiveCompetition to the Star and OneworldIncumbent Alliances at HanedaDelta Will be the Smallest Alliance Competitor to Japan40.2%29.2%24.5%0%5%10%15%20%25%30%35%40%45%NH/NQ+UA+CO AA+JL/JO DL/NW+KEU.S. 50 States To/From Japan Booking ShareU.S. Point Of OriginSource: Joint Applicationof United, Continental,and ANA for Antitrust Immunity, Exhibits JA-10 andJA-11, December 23, 2009, OST-2009-0350. See also American/JAL ATI Application at 27.United and Continental’s ATI Application with ANA Demonstrates That Star ATI Will BeSignificantly Larger Than Delta/SkyTeam ATI in the U.S.-Japan MarketDocket DOT-OST-2010-0018Exhibit DL-R-101Page 1 of 1Delta Will be the Smallest Alliance Competitor to TokyoU.S.-Tokyo Bookings (U.S. Point-of-Sale).Source: MIDT, CY 2009 (U.S. point of sale).40.7%29.4%25.0%0%5%10%15%20%25%30%35%40%45%Star ATI (UA/CO/NH) Oneworld ATI (AA/JL) SkyTeam ATI (DL/KE)ShareDocket DOT-OST-2010-0018Exhibit DL-R-102Page 1 of 1Immunized Star and Oneworld Equal Delta’s Operationat Narita and Will Far Surpass Delta at HanedaNH+UA+CO=119AA+JL=106Docket DOT-OST-2010-0018Exhibit DL-R-103Page 1 of 1American’s ATI Application Concedes That OneworldWill Be Larger Than Delta/SkyTeam in the U.S.-JapanMarket.Source: Joint Application of American and JAL for Antitrust Immunity at 27, February 12, 2010, OST-2010-0034.NH+UA+CO=31%AA+JL=33.4%Star = 28.0%Oneworld=38.0%DL+KE=31%SkyTeam=29.9%Docket DOT-OST-2010-0018Exhibit DL-R-104Page 1 of 1United and Continental Can No Longer Be ConsideredCompetitors in International MarketsOrder 2009-7-10 ApprovedGlobalATI for United,Continental, Air Canada, et alDocket DOT-OST-2010-0018Exhibit DL-R-105Page 1 of 1United and Continental Also Ignore Their Pending AntitrustImmunity Application with ANA in Which They HighlightTheir Metal-Neutral Joint Venture“The Pacific JV will foster ‘metalneutrality’ – a commercialenvironment in which joint venturepartners share common economicincentives to promote the interestsof their alliance over theirindividual corporateinterests. Bypooling resources to improve theoverall service offering and sharingthe resulting gains and losses, theJoint Applicants will harmonizetheir joint network and becomeindifferent as to which partnercollects the revenue and operatesthe aircraft on a given itinerary.”- Joint Application of ANA,Continental andUnited at 12,December 23, 2009, OST-2009-0350Docket DOT-OST-2010-0018Exhibit DL-R-106Page 1 of 1To Game the Route Case, United and ContinentalPretend They Will Be Transpacific Competitors3535Continental erroneously excludesContinental Micronesia’s 21 weeklyGuam-Tokyo.Docket DOT-OST-2010-0018Exhibit DL-R-107Page 1 of 1Grant of American or United/Continental’s ApplicationsWould Result in the Same or More U.S.-Haneda Slots byThose Alliances as Requested by DeltaU.S.-Haneda Daily Slot Pairs Assuming Full Grant of United/Continental,American, or Delta Applications0123456United/Continental/ANA American/JAL Delta544ANA 2UA SFOCO EWRCO GUMAA LAXAA JFKJAL 2Docket DOT-OST-2010-0018Exhibit DL-R-108Page 1 of 1Oneworld ATI (AA,JL)50%Star ATI (UA, CO,NH)50%An Allocation of Haneda Slots to Delta is Necessaryto Enable Inter-Alliance CompetitionCurrent U.S.-Haneda Slot ShareDocket DOT-OST-2010-0018Exhibit DL-R-109Page 1 of 1Narita is Not a Substitute for Haneda -Haneda is the Preferred Airport Serving the Metro TokyoArea•Haneda is the busiest airport in Japan and 4thbusiest in the world•Haneda is located in downtown Tokyo; Narita is 45+ miles away from central TokyoSource: Google Maps. Map copyright Google.•Narita to Tokyo (Marunouchi) :46 miles•Haneda to Tokyo (Marunouchi) :13 miles46 miles13 milesABBCDocket DOT-OST-2010-0018Exhibit DL-R-110Page 1 of 1R-200 SeriesSelection of Delta’s Haneda ProposalsWill Maximize Public BenefitsDelta’s Proposals Will Bring the Greatest Capacityto the U.S.-Haneda Market294,190 294,190 294,190217,540201,480196,370188,340186,880180,310 180,310050,000100,000150,000200,000250,000300,000350,000Delta DTW747-400Delta LAX747-400Delta HNL747-400Delta SEAA330-300ContinentalEWR 777-200UnitedSFO 777-200HawaiianHNL 767-300ContinentalGUM 767-400AmericanLAX 777-200AmericanJFK 777-200Annual SeatsSources: Exhibits DL-115, DL-124, DL-133, DL-106,CO-114, UA-2, HA-App-3, CO-115, AA-104, and AA-102Seats PerFlight:403 403 403 298 276 269 258 256 247 247Docket DOT-OST-2010-0018Exhibit DL-R-201Page 1 of 1Delta’s Detroit and Seattle Gateways Will Serve the MostNonstop-to-Nonstop U.S. Points to Haneda905040191110940020406080100120Delta DTW Delta SEA ContinentalEWRUnited SFO AmericanLAXAmericanJFKDelta LAX HawaiianHNLContinentalGUMNonstop-to-Nonstop U.S. Points(Within 10% Circuity)Note: Includes U.S. points with no more than 10% circuity toHaneda via U.S. gateway and included in applicant’s connecting schedule exhibits.Sources: Exhibits DL-108-111, DL-117-120, DL-126-129, UA-3,UA-6, CO-122-123, CO-124-125, AA-107-110, AA 111-114, HA-App-2Docket DOT-OST-2010-0018Exhibit DL-R-202Page 1 of 1Delta’s Detroit and Seattle Connecting Traffic Bases toHaneda Are Larger Than Any Other Applicant’s1,434,020886,662602,505369,208267,001245,029169,325128,75200200,000400,000600,000800,0001,000,0001,200,0001,400,0001,600,000Delta SEA Delta DTW UnitedSFOContinentalEWRAmericanLAXDelta LAX AmericanJFKHonoluluHNLContinentalGUMBase Passengers in U.S. – Tokyo Connecting Markets(Within 10% Circuity)Note: Includes U.S. points with no more than 10% circuity toHaneda via U.S. gateway and included in applicant’s connecting schedule exhibits.Sources: Exhibits DL-108-111, DL-117-120, DL-126-129, UA-3, UA-6, CO-122-123, CO-124-125, AA-107-110, AA 111-114, HA-App-2; MIDT CY 2009Docket DOT-OST-2010-0018Exhibit DL-R-203Page 1 of 1Delta’s Seattle and Detroit Gateways Will Serve the LargestCombined Local and Connecting U.S. – Tokyo Traffic BaseAmong U.S. Mainland Gateways1,511,348918,938807,854721,033668,783646,811521,1500200,000400,000600,000800,0001,000,0001,200,0001,400,0001,600,000Delta SEA Delta DTW United SFO ContinentalEWRAmerican LAX Delta LAX American JFKLocal and Connecting Base Passengers in U.S. – Tokyo Markets(Within 10% Circuity)Note: Includes U.S. points with no more than 10% circuity toHaneda via U.S. gateway and included in applicant’s connecting schedule exhibits.Proposed U.S. gateway demand included (includes JFK, EWR, and LGA for CO EWR and AA JFK proposals).Sources: Exhibits DL-108-111, DL-117-120, DL-126-129, UA-3, UA-6, CO-122-123, CO-124-125, AA-107-110, AA 111-114, HA-App-2; MIDT CY 2009Docket DOT-OST-2010-0018Exhibit DL-R-204Page 1 of 1R-300 SeriesDelta’s Seattle Proposal Providesthe Greatest Benefits to thePacific NorthwestBURBURSBASBASTSOAKSFOSJCSJCONTONTONTLAXLAXSNASNAALWPUWPSCPSCPSCPSCYKMEATEATEATGEGFCAFCAFATFATFATPDXEUGTo ANC, FAI, JNU, SIT, KTNTo ANC, FAI, JNU, SIT, KTNTo ANC, FAI, JNU, SIT, KTNTo ANC, FAI, JNU, SIT, KTNTo ANC, FAI, JNU, SIT, KTNTo ANC, FAI, JNU, SIT, KTNATLATLATLBILBILBILBLIBLIBLIBOIBOIBOIBOSBZNBZNCVGDENDFWDTWGTFGTFGTFGTFGTFGTFGTFHLNJFKJFKLASLASLGBLGBLGBLWSLWSMCOMEMMFRMFRMFRMIAMIAMSOMSPMSPMSPMSPORDORDPHXPHXPSPPSPRDDRDDRDMRNORNORNOSANSANSLCSMFSMFSMFSeattle is an Ideal West Coast Gateway to HanedaDelta Will Provide Nonstop-to-Nonstop Haneda Service for 55 U.S. PointsHanedaNote: Includes service operated by Alaska/HorizonSource: Exhibits DL-108-111SEADocket DOT-OST-2010-0018Exhibit DL-R-301Page 1 of 1Delta’s Seattle Service Would Offer Over 20,000 MoreAnnual Nonstop Seats to/from Haneda Than United’sSan Francisco Proposal196,370217,540180,000190,000200,000210,000220,000United (SFO) Delta (SEA)Sources: Exhibits DL-106 and UA-2Annual Seats+11%0Docket DOT-OST-2010-0018Exhibit DL-R-302Page 1 of 1SEASEAALWPUWGEGGEGGEGPSCPSCPSCONTONTONTLAXLAXLAXSNASNASNAPSPPSPPSPBURBURBURSANSANSANSBASBASBASFOSFOSFOSTSSTSSTSATLATLATLBILBILBILBILBLIBLIBLIBLIBOIBOIBOIBOIBOSBOSBOSBZNBZNBZNCVGCVGCVGDENDENDENDFWDTWEATEATEATEUGEUGEUGFATFATFATFCAFCAFCAGTFGTFGTFHLNHLNHLNJFKJFKJFKLASLASLASLGBLGBLGBLWSLWSLWSMCOMCOMCOMEMMEMMFRMFRMFRMIAMIAMIAMSOMSOMSOMSPMSPMSPOAKOAKOAKORDORDORDPDXPDXPDXPHXPHXPHXRDDRDDRDDRDMRDMRNORNORNOSJCSJCSJCSLCSLCSLCSMFSMFSMFYKMYKMSeattle’s Pacific Northwest Location EnablesNon-Circuituous Connections to HanedaFrom Across the Entire Continental U.S.10% Circuity10% CircuityDL U.S. Behind Points Served 50Note: Includes service operated by Alaska/HorizonSource: Exhibits DL-108-111Docket DOT-OST-2010-0018Exhibit DL-R-303Page 1 of 1Delta and Alaska Airlines Have an ExtensiveMarketing AllianceDocket DOT-OST-2010-0018Exhibit DL-R-304Page 1 of 1Alaska Airlines Was the Overall Highest Rated “TraditionalNetwork” Carrier in 2009; United Was Tied for Last PlaceSource: JD Power 2009 North American Airline Satisfaction Studyhttp://www.jdpower.com/travel/ratings/airline-ratings/traditional-network/sortcolumn-1/descending/page-#page-anchorDocket DOT-OST-2010-0018Exhibit DL-R-305Page 1 of 1United Dismisses Delta’s Connecting Feed from Alaska Airlines,Yet Takes Credit for ANA’s Connecting Feed at Haneda•Alaska’s Feed to Delta at Seattle WouldServe U.S.-Haneda O&D Passengers•ANA’s Feed to Unitedat Haneda WouldServe U.S.- Asia (Beyond Haneda) O&DPassengers That Could Be Served ViaUnrestricted (or Less Restricted) HubsDocket DOT-OST-2010-0018Exhibit DL-R-306Page 1 of 1Connections Between Delta and Alaska at Seattleare Easy With the Airport’s Train SystemDocket DOT-OST-2010-0018Exhibit DL-R-307Page 1 of 1Seattle’s On-time Performance is 8 Points Higher ThanSan Francisco’s74%82%68%70%72%74%76%78%80%82%84%SFO SEASource: DOT on-time data, CY 2009.http://www.bts.gov/programs/airline_information/airline_ontime_tables/2009_12/html/table04.htmlOn-Time Arrivals(Percent)+8 points0%Docket DOT-OST-2010-0018Exhibit DL-R-308Page 1 of 12009 Ranking:#27 #8R-400 SeriesDelta’s Detroit GatewayProvides the Most Effective andComprehensive CompetitiveCoverage of the Eastern U.S.To SJUTo SJUTo SJUTo SJULGALGAJFKJFKHPNHPNEWRSWFSWFSWFSBNSBNFWAFWAMDWORDORDDAYDAYRICRICCHOAVPAVPSCESCEABEABEITHITHSYRSYRELMALBALBMHTMHTMHTBTVROCBUFBUFBUFBUFBUFBUFLANLANMBSMBSPLNPLNMQTMQTMQTGRBGRBCWAMKEMKEMSNMSNGRRGRRINDINDCAKCAKEVVEVVSDFSDFSDFDCADCAIADTPATPAMSYMSYMSYMSYIAHIAHSATSATSATAUSAUSDFWTULTULTULOKCOKCMCIMCIMCISTLSTLSTLCMICMICMIBMIBMIBMIPIAMLIMLIMLICIDCIDDSMOMAOMARSTRSTRSTMSPMSPDLHDLHRSWMIAMIAAPNAPNATLATLATLATWAVLAVLAVLAZOBDLBDLBDLBDLBDLBDLBDLBGMBGRBGRBHMBNABNABOSBOSBWIBWIBWICAECHSCHSCHSCHSCLECLECLTCLTCLTCMHCMHCRWCVGERIERIERIERIFLLFLLFLLFNTFNTFNTGSOGSPGSPHSVJAXJAXLEXLEXLSELSEMCOMDTMDTMDTMEMMYRMYRORFORFORFPBIPBIPBIPBIPHLPHLPHLPITPITPITPITPVDPVDPWMRDURDURDURDUROAROASAVTOLTOLTOLTOLTOLTOLTOLTRITRITRITRITVCTVCTYSTYSDelta Will Provide Nonstop-to-Nonstop Haneda Servicefor 106 U.S. Points Via DetroitHanedaSource: Exhibits DL-117-120DTWDocket DOT-OST-2010-0018Exhibit DL-R-401Page 1 of 1Delta’s Detroit Service Would Offer 114,000 More Annual Seatsto/from Haneda Than American’s JFK Proposal and 93,000More Annual Seats Than Continental’s Newark Proposal294,190201,480180,310050,000100,000150,000200,000250,000300,000350,000Delta DTW Continental EWR American JFKAnnual Seats+63%+46%Sources: Exhibits DL-115, CO-114 (CO capacity reflects removal of 9 seats from B777 as explained in note on CO-114), and AA-102.Docket DOT-OST-2010-0018Exhibit DL-R-402Page 1 of 1LGALGALGAEWREWREWRHPNHPNHPNSWFSWFSWFSWFSWFSWFJFKJFKJFKFNTFNTFNTDTWMBSMBSMBSCAKCAKCAKCLECLECLEMDWMSNMSNMSNORDORDORDGRRGRRGRRITHITHITHITHSYRSYRSYRELMELMSDFSDFSDFEVVEVVEVVPIAPIAPIAPIAATWGRBGRBGRBMDTMDTMDTSCESCESCEIADIADIADIADROCROCROCMIAMIAMIAABEABEABEALBALBALBAPNAPNAPNATLATLATLAVLAVLAVLAVPAVPAVPAZOAZOAZOBDLBDLBDLBGMBGMBGRBGRBGRBHMBHMBMIBMIBMIBNABNABNABOSBOSBOSBTVBTVBTVBUFBUFBUFBWIBWIBWICAECAECAECHOCHOCHOCHSCHSCHSCLTCLTCLTCMHCMHCMHCMICMICMICRWCVGCVGCVGDAYDAYDAYDCADCADCAERIERIERIERIFLLFLLFLLFWAFWAFWAGSOGSOGSOGSPGSPGSPHSVHSVHSVINDINDINDINDJAXJAXJAXLANLANLANLEXLEXLEXMCOMCOMCOMEMMEMMHTMHTMHTMKEMKEMKEMLIMLIMLIMSYMSYMSYMYRMYRMYRORFORFORFPBIPBIPBIPBIPHLPHLPHLPITPITPITPITPLNPLNPLNPVDPVDPVDPWMPWMPWMPWMRDURDURDURICRICRICRICROAROAROARSWSAVSAVSAVSBNSBNSBNSTLSTLSTLTOLTOLTOLTPATPATPATRITRITRITRITVCTVCTVCTYSTYSTYSDelta’s Primary Catchment Area From DetroitProvides Comprehensive and CompetitiveHaneda Service for the Entire Eastern U.S.10% Circuity10% CircuityDL U.S. Behind Points Served 90To SJUSource: Exhibits DL-117-120Docket DOT-OST-2010-0018Exhibit DL-R-403Page 1 of 1JFKJFKBOSBOSBOSBWIBWIBWIDCADCADCAMCOMCOMCOMIAMIAMIAPITPITPITPITRDURDURDUTPATPATPAAmerican’s JFK Gateway Serves Far Fewer Points in aSignificantly Smaller Catchment Area Than Delta’sDetroit HubJFK 10% CircuitySource: Exhibits AA-107-110 and DL-117-12010% CircuityAA U.S. Behind Points Served 10DL U.S. Behind Points Served 90% DL Greater 800%DTW10% CircuityTo STTand SJUDocket DOT-OST-2010-0018Exhibit DL-R-404Page 1 of 1DCADCADCAIADIADIADIADGSOGSOGSOMIAMIAMIAEWREWRALBALBALBATLATLATLAVLAVLAVLAVPAVPAVPBDLBDLBDLBOSBOSBOSBTVBTVBTVBUFBUFBUFBWIBWIBWICHSCHSCHSCLECLECLECLTCLTCLTCMHCMHCMHFLLFLLFLLITHITHITHITHJAXJAXJAXMCOMCOMCOMDTMDTMDTMHTMHTMHTMYRMYRMYRORFORFORFPBIPBIPBIPBIPHLPHLPHLPITPITPITPITPVDPVDPVDPWMPWMPWMPWMRDURDURDURICRICRICRICROCROCROCRSWSAVSAVSAVSYRSYRSYRTPATPATPATYSTYSTYSContinental’s Newark Hub Serves Far Fewer Points in aSignificantly Smaller Catchment Area Than Delta’sDetroit HubEWR 10% CircuityDTW10% CircuitySources: Exhibits DL-117-120 and CO-122-12310% CircuityCO U.S. Behind Points Served 40DL U.S. Behind Points Served 90% DL Greater 125%To SJUDocket DOT-OST-2010-0018Exhibit DL-R-405Page 1 of 1Every Eastern U.S. Point Claimed by American at JFK andContinental at Newark Can Be Served by Delta AsEffectively or More Effectively Via Detroit....Note: Based on points listed in applicant’s connecting schedule exhibits.Sources: Exhibits DL-117-120, CO-122-123, and AA-107-110.CountAmericanBehind JFKU.S. PointServed byDelta ViaDTW?1 BOS Yes2 BWI Yes3 CLE Yes4 CMH Yes5 DCA Yes6 DFW Yes7 MCO Yes8 MIA Yes9 ORD Yes10 PIT Yes11 RDU Yes12 SJU Yes13 STL Yes14 STT No15 TPA YesCountContinentalBehind EWRU.S. PointServed byDelta ViaDTW?1 ALB Yes2 ATL Yes3 AUS Yes4 AVL Yes5 AVP Yes6 BDL Yes7 BOS Yes8 BTV Yes9 BUF Yes10 BWI Yes11 CHS Yes12 CLE Yes13 CLT Yes14 CMH Yes15 CVG Yes16 DAY Yes17 DCA Yes18 DFW Yes19 FLL Yes20 GSO Yes21 IAD Yes22 IAH Yes23 ITH YesCountContinentalBehind EWRU.S. PointServed byDelta ViaDTW?24 JAX Yes25 MCO Yes26 MDT Yes27 MHT Yes28 MIA Yes29 MYR Yes30 ORF Yes31 PBI Yes32 PHL Yes33 PIT Yes34 PVD Yes35 PWM Yes36 RDU Yes37 RIC Yes38 ROC Yes39 RSW Yes40 SAT Yes41 SAV Yes42 SJU Yes43 STT No44 SYR Yes45 TPA Yes46 TYS YesDocket DOT-OST-2010-0018Exhibit DL-R-406Page 1 of 2....Along With 56 Additional Eastern U.S. CitiesThat Would Not Receive Any Service Via New YorkNote: Based on points listed in applicant’s connecting schedule exhibits (excludes EWR, LGA, JFK)Sources: Exhibits DL-117-120, CO-122-123, and AA-107-110.CountDelta BehindDTW U.S.PointServed by AAvia JFK or COvia EWR?1 ABE No2 APN No3 ATW No4 AZO No5 BGM No6 BGR No7 BHM No8 BMI No9 BNA No10 CAE No11 CAK No12 CHO No13 CID No14 CMI No15 CRW No16 CWA No17 DLH No18 DSM No19 ELM NoCountDelta BehindDTW U.S.PointServed by AAvia JFK or COvia EWR?20 ERI No21 EVV No22 FNT No23 FWA No24 GRB No25 GRR No26 GSP No27 HPN No28 HSV No29 IND No30 LAN No31 LEX No32 LSE No33 MBS No34 MCI No35 MDW No36 MEM No37 MKE No38 MLI NoCountDelta BehindDTW U.S.PointServed by AAvia JFK or COvia EWR?39 MQT No40 MSN No41 MSP No42 MSY No43 OKC No44 OMA No45 PIA No46 PLN No47 ROA No48 RST No49 SBN No50 SCE No51 SDF No52 SWF No53 TOL No54 TRI No55 TUL No56 TVC NoDocket DOT-OST-2010-0018Exhibit DL-R-406Page 2 of 2American’s Own Exhibit Illustrates Detroit’s On-timePerformance is Far Superior to JFK’s (and Newark’s)Source: Exhibit AA-R-111Docket DOT-OST-2010-0018Exhibit DL-R-407Page 1 of 1R-500 SeriesDelta’s Los Angeles Proposalis Superior to American’sATLATLCVGDTWFLLFLLFLLFLLINDJFKLASMCOMEMMSPPRCRNOSANSANSLCSLCSLCSLCTPADCARDDRDDRDDRDDMMHDelta Los Angeles-Haneda Service Would Provide StrongCompetition at Star Alliance’s LAX HubDelta Will Provide Nonstop-to-Nonstop Haneda Service for 18 U.S. PointsHanedaNote: Includes service operated by Alaska/HorizonSources: Exhibits DL-126-129; MIDT CY 2009.LAXThe Los Angeles local market andDelta’s 18 connecting U.S. pointsvia LAX account for 1 millionTokyo passengers annually.Docket DOT-OST-2010-0018Exhibit DL-R-501Page 1 of 1Delta’s Los Angeles Service Would Offer 114,000More Annual Nonstop Seats to/from Haneda ThanAmerican’s Los Angeles Proposal180,310294,190050,000100,000150,000200,000250,000300,000American(LAX)Delta (LAX)Sources: Exhibits DL-124 and AA-104Annual Seats+63%Docket DOT-OST-2010-0018Exhibit DL-R-502Page 1 of 1The Los Angeles-Tokyo Local Market Has Twice As ManyU.S.-Originating Passengers as the Honolulu-TokyoLocal Market60,961125,617020,00040,00060,00080,000100,000120,000140,000Honolulu Los AngelesSource: MIDY CY 2009U.S. Point-of-SaleU.S.-Tokyo O&D Passengers+106%Docket DOT-OST-2010-0018Exhibit DL-R-503Page 1 of 1Los Angeles is the Largest Mainland U.S.-Tokyo Marketand is Nearly Twice the Size of the San Francisco-TokyoLocal Market205,349401,782050,000100,000150,000200,000250,000300,000350,000400,000450,000San Francisco(United)Los Angeles(Delta)Source: MIDY CY 2009U.S.-Tokyo O&D Passengers+96%Docket DOT-OST-2010-0018Exhibit DL-R-504Page 1 of 1R-600 SeriesHawaiian Should Not ReceiveMore Than One Pair of SlotsFor Honolulu6.3%93.7%Honolulu-Tokyo Passengers Are Overwhelmingly Non-U.S.Point of SaleSource: MIDT CY 2009Honolulu-Tokyo PassengersU.S. Point of SaleNon-U.S. Point of SaleDocket DOT-OST-2010-0018Exhibit DL-R-601Page 1 of 1HNLHNLSEASEAHNDHNDHonolulu is an Ineffective Gateway to Haneda for theContinental U.S.Note: Mileage is statute mileage.Source: Exhibits DL-104 and HA-App-1-2Delta SEA-HNDMiles: 4,790Circuity: 0%Roundtrip Elapsed Time Summer: 19:45Roundtrip Elapsed Time Winter: 19:50Hawaiian SEA-HNL-HNDMiles: 6,521Circuity: 36%Roundtrip Elapsed Time Summer: 44:05Roundtrip Elapsed Time Winter: 35:00Docket DOT-OST-2010-0018Exhibit DL-R-602Page 1 of 1HNLHNLHNDHNDLAXLAXHonolulu is an Ineffective Gateway to Haneda for theContinental U.S.Note: Mileage is statute mileage.Source: Exhibits DL-122 and HA-App-1-2Delta LAX-HNDMiles: 5,474Circuity: 0%Roundtrip Elapsed Time Summer: 22:00Roundtrip Elapsed Time Winter: 22:35Hawaiian LAX-HNL-HNDMiles: 6,397Circuity: 17%Roundtrip Elapsed Time Summer: 42:15Roundtrip Elapsed Time Winter: 34:50Docket DOT-OST-2010-0018Exhibit DL-R-603Page 1 of 1Honolulu is an Ineffective Gateway to Haneda for theContinental U.S.*LAX elapsed times for DL based on DL’s nonstop LAX-HND proposal.Note: Best roundtrip elapsed time shown for each applicant based on applicant’s schedule exhibits.Source: Exhibits DL-104, DL-122, DL-108-111, DL-126-129 and HA-App-2Hawaiian’s Proposed Continental U.S. Connecting Points Are Much MoreConveniently Served by Delta’s Seattle and Los Angeles ProposalsU.S. Point DL via SEA HA via HNL DL via SEA HA via HNL DL via SEA HA via HNLLAS 2% 19% 28:05 35:05 27:57 34:50LAX* Nonstop 17% 22:00 42:15 22:35 34:50OAK 6% 21% 27:55 one-way only 30:34 34:10PDX 2% 33% 23:50 35:00 24:50 34:50PHX 2% 17% 29:47 37:49 29:54 37:59SAN 5% 16% 30:13 one-way only 29:02 33:40SEA Nonstop 36% 19:45 44:05 19:50 35:00SFO 6% 21% 29:04 one-way only 27:42 34:00SJC 6% 21% 29:00 one-way only 29:47 34:05SMF 5% 23% 27:45 one-way only 29:29 34:20SummerRoundtrip Elapsed TimeWinterRoundtrip Elapsed TimeCircuityDocket DOT-OST-2010-0018Exhibit DL-R-604Page 1 of 1Delta’s Honolulu Service Would Offer 106,000 MoreAnnual Nonstop Seats to/from Haneda ThanHawaiian’s Honolulu Proposal188,340294,190050,000100,000150,000200,000250,000300,000Hawaiian (HNL) Delta (HNL)Sources: Exhibits DL-133 and HA-App-3 (HA capacity reflects 6 seats blocked for crew as explained in note on HA-App-3)Annual Seats+56%Docket DOT-OST-2010-0018Exhibit DL-R-605Page 1 of 1Hawaiian’s “Wingtip” Flights Fail to MaximizePublic Benefits188,340214,620150,000170,000190,000210,000230,000250,000Hawaiian 767-300 ProposalHawaiian A330ProposalSource: HA-App-3Annual Seats+14%•Hawaiian could increase HNL-HND capacity by 14% by using itslarger A330 aircraft•No new connecting benefits arerealized from two flights inexactly the same time channel0Docket DOT-OST-2010-0018Exhibit DL-R-606Page 1 of 1R-700 SeriesContinental Should Not ReceiveA Scheduled Service Awardfor Guam0.9%99.1%Guam-Tokyo Passengers Are Overwhelmingly Non-U.S.Point of SaleSource: MIDT CY 2009Guam-Tokyo PassengersU.S. Point of SaleNon-U.S.Point of SaleDocket DOT-OST-2010-0018Exhibit DL-R-701Page 1 of 1Based on U.S. Point-of-Sale Bookings, the GuamLocal Market is Substantially Smaller Than the LocalMarkets of Delta’s Proposed Continental U.S. Gateways125,61739,03016,4347,882020,00040,00060,00080,000100,000120,000140,000Los Angeles Seattle Detroit GuamU.S. Point-of-SaleU.S.-Tokyo O&D PassengersSource: MIDT CY 2009 (U.S. point-of-sale only)Docket DOT-OST-2010-0018Exhibit DL-R-702Page 1 of 1GUMGUMNRTNRTContinental and Delta Each Serve Guam from NaritaDelta’s Narita-Guam Flights Would Be Placed at a SevereCompetitive Disadvantage if Only Continental Was Allowed toServe Guam From Tokyo’s Preferred AirportDocket DOT-OST-2010-0018Exhibit DL-R-703Page 1 of 1Delta’s Honolulu Service Would Offer 107,000 MoreAnnual Nonstop Seats to/from Haneda ThanContinental Micronesia’s Guam Proposal186,880294,190050,000100,000150,000200,000250,000300,000ContinentalMicronesia(GUM)Delta (HNL)Sources: Exhibits DL-133 and CO-115Annual Seats+57%Docket DOT-OST-2010-0018Exhibit DL-R-704Page 1 of 1

# CERTIFICATE OF SERVICE

A copy of the foregoing document has been served this 8th day of March, 2010, upon

the following persons via email:

carl.nelson@aa.com

dan.weiss@coair.com

hershel.kamen@coair.com

rbkeiner@crowell.com

mrosia@crowell.com

gmurphy@crowell.com

jeffrey.manley@united.com

julie.oettinger@united.com

howard.kass@usairways.com

benjamin.slocum@usairways.com

jhill@dowlohnes.com

ldeavers@dowlohnes.com

perkmann@dowlohnes.com

dmendersbee@zsrlaw.com

todd.homan@dot.gov

paul.gretch@dot.gov

keith.glatz@dot.gov

esta.rosenberg@dot.gov

byerlyjr@state.gov

eugene_alford@ita.doc.gov

joe.cambron@wcaa.us

ishiwata.k@portseattle.org

safora.i@portseattle.org

mike.orr@airlineinfo.com