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 structure 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 from 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 elimination 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 treated, 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 immunity to jointly plan routes, set prices, and 

share revenues, but ignore their immunity when 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 inclusion 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 promote 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 Department 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 (American, Lan Airlines and Lan Peru) will have 

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

comparison, the SkyTeam Alliance (Delta and Continental) will have a smaller market 

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

Applicants should not substantially 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 levels 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 percent. 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 competition if the competitors have 

free and open access to the marketplace. This is precisely the 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 Continental 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 antitrust 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 competition” 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 slots 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 stated 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.” oneworld 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 determine 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 competitive 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 requesting 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 global 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 implemented. 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-entry 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. gateway 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 Haneda 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 delay-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 immunized alliances. Every Eastern U.S. city 

claimed by Continental or American at New York 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 American 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 that 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 cases. 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 found 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-sensitive 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 design, 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 commercial access through its immunized joint 

venture14 – 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 exacerbating 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 Honolulu 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 sensitive, 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 travelers who value Haneda’s unique advantages of 

convenience the most. Delta’s services provide 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 scarce 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 acknowledged 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 ANGELES 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 Proposal 
R-100 Series

Delta’s Proposals Provide Effe

Competition to the Star and One

Incumbent Alliances at Hane
Delta Will be the Smallest Alliance Competitor to Japan 

40.2%

29.2%

24.5

0%5%

10%15%20%25%30%35%40%45%

NH/NQ+UA+CO AA+JL/JO DL/NW

U.S. 50 States To/From Japan Booking ShareU.S. Point Of Origin

Source: Joint Application of United, Continental, and ANA for Antitrust Immunity, Exh

JA-11, December 23, 2009, OST-2009-0350. See also American/JAL ATI Application a

United and Continental’s ATI Application with ANA Demonstrates That 

Significantly Larger Than Delta/SkyTeam ATI in the U.S.-Japan 
Delta Will be the Smallest Alliance Competitor to Tokyo

U.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 A

Share
Immunized Star and Oneworld Equal Delta’s Operation

at Narita and Will Far Surpass Delta at Haneda

NH+UA+CO=119 AA+JL=106
American’s ATI Application Concedes That Oneworld

Will 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

AA

Sta

One

DL

Sky
United and Continental Can No Longer Be Considered 

Competitors in International Markets

Order 2009-7-10 ApprovedGlobal ATI for United, 

Continental, Air Canada, et al
United and Continental Also Ignore Their Pending Antitrust

Immunity Application with ANA in Which They HighlightTheir Metal-Neutral Joint Venture 

“The Pacific JV will foster ‘metal neutrality’ – a commercial environment in which joint venture partners share common economic incentives to promote the interests of their alliance over their individual corporate interests. By pooling resources to improve the overall service offering and sharing the resulting gains and losses, the Joint Applicants will harmonize their joint network and become indifferent as to which partner collects the revenue and operates the aircraft on a given itinerary.”- Joint Application of ANA, Continental and United at 12, December 23, 2009, OST-2009-0350
To Game the Route Case, United and Continental

Pretend They Will Be Transpacific Competitors

3

Continental erroneously eContinental Micronesia’s 2Guam-Tokyo.
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

U.S.-Haneda Daily Slot Pairs Assuming Full Grant of United/Con

American, or Delta Applications

0123456

United/Continental/ANA American/JAL Delta

5

4

4

ANA 2

UA SFO

CO EWRCO GUM

AA LAX

AA JFK

JAL 2
Oneworld 

JL

50%

Star ATI (UA, CO, 

NH)

50%

An Allocation of Haneda Slots to Delta is Necessaryto Enable Inter-Alliance Competition

Current U.S.-Haneda Slot Share
Narita is Not a Substitute for Haneda -

Haneda is the Preferred Airport Serving the Metro Tokyo Area

• Haneda is the busiest airport in Japan and 4th busiest in the world

• Haneda is located in downtown Tokyo; Narita is 45+ miles away from ce

Source: Google Maps. Map copyright Google.

• Narita to Tokyo (Ma

46 miles

• Haneda to Tokyo (M

13 miles 46 miles

13 miles

A

C
R-200 Series

Selection of Delta’s Haneda Pro

Will Maximize Public Benef
Delta’s Proposals Will Bring the Greatest Capacity

to the U.S.-Haneda Market

294,190 294,190 294,190

217,540

201,480 196,370 188,340 186,880 180

0

50,000

100,000150,000200,000250,000300,000350,000

Delta DTW

747-400

Delta LAX

747-400

Delta HNL

747-400

Delta SEA

A330-300

Continental

EWR 777-

200

 United

SFO 777-

200

Hawaiian

HNL 767-

300

Continental

GUM 767-

400

Am

LA

Annual Seats

Sources: Exhibits DL-115, DL-124, DL-133, DL-106, CO-114, UA-2, HA-App-3, CO-115, AA-104, and AA-102

Seats Per Flight: 403 403 403 298 276 269 258 256 
Delta’s Detroit and Seattle Gateways Will Serve the Most 

Nonstop-to-Nonstop U.S. Points to Haneda

90

50

40

19

11 10

9

4

0

20406080

100120

Delta DTW Delta SEA Continental

EWR

United SFO American

LAX

American

JFK

Delta LAX Hawa

HN

Nonstop-to-Nonstop U.S. Points(Within 10% Circuity)

Note: Includes U.S. points with no more than 10% circuity to Haneda via U.S. gateway and included in applicant’s connecting sch

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-
Delta’s Detroit and Seattle Connecting Traffic Bases to 

Haneda Are Larger Than Any Other Applicant’s

1,434,020

886,662

602,505

369,208

267,001 245,029

169,325 128,

0

200,000400,000600,000800,000

1,000,0001,200,0001,400,0001,600,000

Delta SEA Delta DTW United 

SFO

Continental

EWR

American

LAX

Delta LAX American

JFK

Hono

HN

Base Passengers in U.S. – Tokyo Connecting Markets(Within 10% Circuity)

Note: Includes U.S. points with no more than 10% circuity to Haneda via U.S. gateway and included in applicant’s connecting sch

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-
Delta’s Seattle and Detroit Gateways Will Serve the Largest 

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

1,511,348

918,938

807,854

721,033 668,783 646,811

0

200,000400,000600,000800,000

1,000,0001,200,0001,400,0001,600,000

Delta SEA Delta DTW United SFO Continental

EWR

American LAX Delta LAX 

Local and Connecting Base Passengers in U.S. – Tokyo Markets(Within 10% Circuity)

Note: Includes U.S. points with no more than 10% circuity to Haneda via U.S. gateway and included in applicant’s connecting sch

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-
R-300 Series

Delta’s Seattle Proposal Prov

the Greatest Benefits to th

Pacific Northwest
BUR BUR

SBA SBA

STS

OAK

SFO

SJC SJC

ONT ONT ONT

LAX LAX

SNA SNA

ALW

YKM PSC PSC PSC PSC PUW

EAT EAT EAT GEG FCA FCA

FAT FAT FAT

PDX

EUG

To ANC, FAI, JNU, SIT, KTN To ANC, FAI, JNU, SIT, KTN To ANC, FAI, JNU, SIT, KTN To ANC, FAI, JNU, SIT, KTN To ANC, FAI, JNU, SIT, KTN To ANC, FAI, JNU, SIT, KTN

ATL ATL ATL

BIL BIL BIL

BLI BLI BLI

BOI BOI BOI 

BZN BZN

CVG

DEN

DFW

DTW

GTF GTF GTF GTF GTF GTF GTF

HLN

LAS LAS

LGB LGB LGB

LWS LWS

MEM

MFR MFR MFR

MSO

MSP MSP MSP MSP

ORD ORD

PHX PHX

PSP PSP

RDD RDD

RDM

RNO RNO RNO

SAN SAN

SLC

SMF SMF SMF

Seattle is an Ideal West Coast Gateway to HanedaDelta Will Provide Nonstop-to-Nonstop Haneda Service for 55 U.S. Points 

Haneda

Note: Includes service operated by Alaska/HorizonSource: Exhibits DL-108-111

SEA
Delta’s Seattle Service Would Offer Over 20,000 More 

Annual Nonstop Seats to/from Haneda Than United’s San Francisco Proposal

196,370

217,540

180,000190,000200,000210,000220,000

United (SFO) Delta (SEA)

Sources: Exhibits DL-106 and UA-2 

Annual Seats

+11%

0
SEA SEA

ALW

PUW

GEG GEG GEG

PSC PSC PSC

ONT ONT ONT

LAX LAX LAX

SNA SNA SNA PSP PSP PSP

BUR BUR BUR

SAN SAN SAN

SBA SBA SBA

SFO SFO SFO

STS STS STS

ATL ATL ATL

BIL BIL BILBIL

BLI BLI BLI BLI

BOI BOI BOI BOI 

BZN BZN BZN

CVG CVG CVG

DEN DEN DEN

DFW

DTW

EAT EAT EAT

EUG EUG EUG

FAT FAT FAT

FCA FCA FCA

GTF GTF GTF

HLN HLN HLN

LAS LAS LAS

LGB LGB LGB

LWS LWS LWS

MCO MCO MCO

MEM MEM

MFR MFR MFR

MSO MSO MSO

MSP MSP MSP

OAK OAK OAK

ORD ORD ORD

PDX PDX PDX

PHX PHX PHX

RDD RDD RDD

RDM RDM

RNO RNO RNO

SJC SJC SJC

SLC SLC SLC SMF SMF SMF

YKM YKM

Seattle’s Pacific Northwest Location Enables Non-Circuituous Connections to HanedaFrom Across the Entire Continental U.S. 

10% C

10% Circuity

DL U.S. Behind Points Served 50

Note: Includes service operated by Alaska/HorizonSource: Exhibits DL-108-111
Delta and Alaska Airlines Have an Extensive 

Marketing Alliance
Alaska Airlines Was the Overall Highest Rated “Traditional

Network” Carrier in 2009; United Was Tied for Last Place

Source: JD Power 2009 North American Airline Satisfaction Studyhttp://www.jdpower.com/travel/ratings/airline-ratings/traditional-network/sortcolumn-1/descending/page-#page-anchor
United Dismisses Delta’s Connecting Feed from Alaska Airlines, 

Yet Takes Credit for ANA’s Connecting Feed at Haneda

• Alaska’s Feed to Delta 

Serve U.S.-Haneda O&

• ANA’s Feed to United 

Serve U.S.- Asia (BeyoPassengers That CoulUnrestricted (or Less 
Connections Between Delta and Alaska at Seattle 

are Easy With the Airport’s Train System
Seattle’s On-time Performance is 8 Points Higher Than

San Francisco’s 

74%

82%

68%70%72%74%76%78%80%82%84%

SFO SEA

Source: DOT on-time data, CY 2009. http://www.bts.gov/programs/airline_information/airline_ontime_tables/2009_12/html/table04.html

On-Time Arrivals(Percent)

+8 points

0%

2009 Ranking: #27 #8
R-400 Series

Delta’s Detroit Gateway

Provides the Most Effective 

Comprehensive Competitiv

Coverage of the Eastern U.
To SJU To SJU To SJ

To SJ

LGA LGA

JFK JFK

HPN HPN

EWR

SWF SWF SWF

SBN SBN

FWA FWA MDW ORD ORD

DAY DAY

RIC RIC

CHO

AVP AVP

SCE SCE ABE ABE

ITHITH

SYR SYR

ELM

ALB ALB

MHT MHT MHT

BTV

ROC

BUF BUF BUF BUF BUF BUF

LAN LAN

MBS MBS

PLN PLN

MQT MQT MQT

GRB GRB CWA

MKE MKE

MSN MSN

GRR GRR

IND IND

CAK CAK

EVV EVV

SDF SDF SDF

DCA DCA

IAD

TPA TPA

MSY MSY MSY MSY IAH IAH

SAT SAT SAT

AUS AUS

DFW

TUL TUL TUL

OKC OKC

MCI MCI MCI

STL STL STL

CMI CMI CMI

BMI BMI BMI

PIA

MLI MLI MLI

CID CID

DSM

OMA OMA

RST RST RST

MSP MSP

DLH DLH

RSW

MIA MIA

APN APN

ATL ATL ATL

ATW

AVL AVL AVL

AZO

BDL BDL BDL BDL BDL BDL BDL BGM

BHM

BNA BNA

BOS BOS

BWI BWI BWI

CAE

CHS CHS CHS CHS

CLE CLE

CLT CLT CLT

CMH CMH

CRW

CVG

ERI ERI ERI ERI

FLL FLL FLL

FNT FNT FNT

GSO

GSP GSP

HSV

JAX JAX

LEX LEX

LSE LSE

MCO

MDT MDT MDT

MEM MYR MYR

ORF ORF ORF

PBI PBI PBI PBI

PIT PIT PHL PHL PHL PITPIT

PVD PVD

PW

RDU RDU RDU RDU

ROA ROA

SAV

TOL TOL TOL TOL TOL TOL TOL

TRI TRI TRI TRI

TVC TVC

TYS TYS

Delta Will Provide Nonstop-to-Nonstop Haneda Servicefor 106 U.S. Points Via Detroit

Haneda

Source: Exhibits DL-117-120

DTW
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

294,190

201,480

180,

0

50,000

100,000150,000200,000250,000300,000350,000

Delta DTW Continental EWR America

Annual 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
FNT FNT FNT

DTW

MBS MBS MBS

CAK CAK CAK

CLE CLE CLE

MDW

MSN MSN MSN

ORD ORD ORD

GRR GRR GRR

ITITIT

IT

ELEL

SDF SDF SDF

EVV EVV EVV

PIA PIA PIAPIA

ATWGRB GRB GRB

MDT MDT MDT

SCE SCE SCE

IAD IAD IADIAD

ROC ROC ROC

APN APN APN

ATL ATL ATL

AVL AVL AVL

AZO AZO AZO

BHM BHM

BMI BMI BMI

BNA BNA BNA

BUF BUF BUF

CAE CAE CAE

CCC

CHCHCH

CLT CLT CLT

CMH CMH CMH CMI CMI CMI

CRW

CVG CVG CVG

DAY DAY DAY 

ERI ERI ERI ERI

FWA FWA FWA

GSO GSO GSO

GSP GSP GSP

HSV HSV HSV

IND IND INDIND

JAX JAX JAX

LAN LAN LAN

LEX LEX LEX

MCO MCO MCO

MEM MEM

MKE MKE MKE

MLI MLI MLI

MSY MSY MSY

PIT PIT PITPIT 

PLN PLN PLN

ROA ROA ROA

RSW

SAV SAV SAV

SBN SBN SBN

STL STL STL

TOL TOL TOL

TPA TPA TPA

TRI TRI TRI TRI

TVC TVC TVC

TYS TYS TYS

Delta’s Primary Catchment Area From DetroitProvides Comprehensive and CompetitiveHaneda Service for the Entire Eastern U.S.

10% Circ

10% Circuity

DL U.S. Behind Points Served 90

Source: Exhibits DL-117-120
MCO MCO MCO

PIT PIT PITPIT

TPA TPA TPA

American’s JFK Gateway Serves Far Fewer Points in aSignificantly Smaller Catchment Area Than Delta’sDetroit Hub

JFK 10% Circuity

Source: Exhibits AA-107-110 and DL-117-120

10% Circuity

AA U.S. Behind Points Served 10DL U.S. Behind Points Served 90% DL Greater 800%

DTW 10% Circuity
IAD IAD IADIAD 

GSO GSO GSO

ATL ATL ATL

AVL AVL AVL

BUF BUF BUF

CHCHCH

CLE CLE CLE

CLT CLT CLT

CMH CMH CMH

JAX JAX JAX

MCO MCO MCO

PIT PIT PITPIT 

RORORO

RSW

SAV SAV SAV

TPA TPA TPA

TYS TYS TYS

Continental’s Newark Hub Serves Far Fewer Points in aSignificantly Smaller Catchment Area Than Delta’sDetroit Hub

EWR 10% Circuity

DTW 10% Circuity

Sources: Exhibits DL-117-120 and CO-122-123

10% Circuity

CO U.S. Behind Points Served 40DL U.S. Behind Points Served 90% DL Greater 125%
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....

Note: Based on points listed in applicant’s connecting schedule exhibits.Sources: Exhibits DL-117-120, CO-122-123, and AA-107-110. 

Count

American 

Behind JFK 

U.S. Point

Served by 

Delta Via 

DTW?

1 BOS Yes2 BWI Yes3 CLE Yes4 CMH Yes5 DCA Yes6 DFW Yes7 MCO Yes8 MIA Yes9 ORD Yes

10 PIT Yes11 RDU Yes12 SJU Yes13 STL Yes14 STT No15 TPA Yes

Count

Continental 

Behind EWR 

U.S. Point

Served by 

Delta Via 

DTW?

1 ALB Yes2 ATL Yes3 AUS Yes4 AVL Yes5 AVP Yes6 BDL Yes7 BOS Yes8 BTV Yes9 BUF Yes

10 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 Yes

Count

C

B

24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 
....Along With 56 Additional Eastern U.S. Cities

That Would Not Receive Any Service Via New York

Note: 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. 

Count

Delta Behind 

DTW U.S. 

Point

Served by AA 

via JFK or CO 

via EWR?

1 ABE No2 APN No3 ATW No4 AZO No5 BGM No6 BGR No7 BHM No8 BMI No9 BNA No

10 CAE No11 CAK No12 CHO No13 CID No14 CMI No15 CRW No16 CWA No17 DLH No18 DSM No19 ELM No

Count

Delta Behind 

DTW U.S. 

Point

Served by AA 

via JFK or CO 

via 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 No

Count

Delt

DT

39 40 41 42 43 44 O45 46 47 48 49 50 51 52 53 54 55 56 
American’s Own Exhibit Illustrates Detroit’s On-time 

Performance is Far Superior to JFK’s (and Newark’s)

Source: Exhibit AA-R-111
R-500 Series

Delta’s Los Angeles Propos

is Superior to American’s
ATL ATL

CVG

DTW

IND

LAS

MEM

MSP

PRC

RNO

SAN SAN

SLC SLC SLC SLC

T

RDD RDD RDD RDD

MMH

Delta Los Angeles-Haneda Service Would Provide Strong Competition at Star Alliance’s LAX Hub Delta Will Provide Nonstop-to-Nonstop Haneda Service for 18 U.S. Points 

Haneda

Note: Includes service operated by Alaska/HorizonSources: Exhibits DL-126-129; MIDT CY 2009.

LAX

The Los Angeles local market and 

Delta’s 18 connecting U.S. points 

via LAX account for 1 million 

Tokyo passengers annually.
Delta’s Los Angeles Service Would Offer 114,000

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

180,310

294,190

0

50,000

100,000150,000200,000250,000300,000

American

(LAX)

Delta (LAX)

Sources: Exhibits DL-124 and AA-104 

Annual Seats

+63%
The Los Angeles-Tokyo Local Market Has Twice As Many

U.S.-Originating Passengers as the Honolulu-TokyoLocal Market

60,961

125,617

0

20,00040,00060,00080,000

100,000120,000140,000

Honolulu Los Angeles

Source: MIDY CY 2009

U.S. Point-of-SaleU.S.-Tokyo O&D Passengers

+106%
Los Angeles is the Largest Mainland U.S.-Tokyo Market

and is Nearly Twice the Size of the San Francisco-TokyoLocal Market

205,349

401,782

0

50,000

100,000150,000200,000250,000300,000350,000400,000450,000

San Francisco

(United)

Los Angeles

(Delta)

Source: MIDY CY 2009

U.S.-Tokyo O&D Passengers

+96%
R-600 Series

Hawaiian Should Not Recei

More Than One Pair of Slot

For Honolulu
6.3%

93.7%

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

Source: MIDT CY 2009

Honolulu-Tokyo Passengers

U.S. Point of Sale

Non-U.S. Point 
HNL HNL

HND HND

Honolulu is an Ineffective Gateway to Haneda for theContinental U.S.

Note: Mileage is statute mileage.Source: Exhibits DL-104 and HA-App-1-2 

Delta SEA-HND

Miles: 4,790

Circuity: 0%

Roundtrip Elapsed Time Summer: 19:45

Roundtrip Elapsed Time Winter: 19:50

Hawaiian SEA-HNL-HND

Miles: 6,521

Circuity: 36%

Roundtrip Elapsed Time Summer: 44:05

Roundtrip Elapsed Time Winter: 35:00
HNL HNL

HND HND 

Honolulu is an Ineffective Gateway to Haneda for theContinental U.S.

Note: Mileage is statute mileage.Source: Exhibits DL-122 and HA-App-1-2 

Delta LAX-HND

Miles: 5,474

Circuity: 0%

Roundtrip Elapsed Time Summer: 22:00

Roundtrip Elapsed Time Winter: 22:35

Hawaiian LAX-HNL-HND

Miles: 6,397

Circuity: 17%

Roundtrip Elapsed Time Summer: 42:15

Roundtrip Elapsed Time Winter: 34:50
Honolulu is an Ineffective Gateway to Haneda for the

Continental 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-2 

Hawaiian’s Proposed Continental U.S. Connecting Points Are 

Conveniently Served by Delta’s Seattle and Los Angeles Pr

U.S. Point DL via SEA HA via HNL DL via SEA HA via HNL DL via SE

LAS 2% 19% 28:05 35:05 27:57 

LAX* Nonstop 17% 22:00 42:15 22:35 

OAK 6% 21% 27:55 one-way only 30:34 

PDX 2% 33% 23:50 35:00 24:50 PHX 2% 17% 29:47 37:49 29:54 SAN 5% 16% 30:13 one-way only 29:02 

SEA Nonstop 36% 19:45 44:05 19:50 

SFO 6% 21% 29:04 one-way only 27:42 

SJC 6% 21% 29:00 one-way only 29:47 

SMF 5% 23% 27:45 one-way only 29:29 

Summer

Roundtrip Elapsed Time

W

Circuity Roundtrip 
Delta’s Honolulu Service Would Offer 106,000 More 

Annual Nonstop Seats to/from Haneda ThanHawaiian’s Honolulu Proposal

188,340

294,190

0

50,000

100,000150,000200,000250,000300,000

Hawaiian (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%
Hawaiian’s “Wingtip” Flights Fail to Maximize

Public Benefits

188,340

214,620

150,000170,000190,000210,000230,000250,000

Hawaiian 767-

300 Proposal

Hawaiian A330

Proposal

Source: HA-App-3

Annual Seats

+14%

• Hawaiian could increase HNL-HND capacity by 14% by 

larger A330 aircraft

• No new connecting benefits are realized from two fligh

exactly the same time channel

0
R-700 Series

Continental Should Not Rece

A Scheduled Service Awar

for Guam
0.9%

99.1%

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

Source: MIDT CY 2009

Guam-Tokyo Passengers

U.S. Point of Sale

Non-U.S. Point of S
Based on U.S. Point-of-Sale Bookings, the Guam

Local Market is Substantially Smaller Than the LocalMarkets of Delta’s Proposed Continental U.S. Gateways

125,617

39,030

16,434

0

20,00040,00060,00080,000

100,000120,000140,000

Los Angeles Seattle Detroit 

U.S. Point-of-SaleU.S.-Tokyo O&D Passengers

Source: MIDT CY 2009 (U.S. point-of-sale only)
GUM GUM

NRT NRT

Continental and Delta Each Serve Guam from Narita

Delta’s Narita-Guam Flights Would Be Placed at a Se

Competitive Disadvantage if Only Continental Was Allo

Serve Guam From Tokyo’s Preferred Airport
Delta’s Honolulu Service Would Offer 107,000 More 

Annual Nonstop Seats to/from Haneda ThanContinental Micronesia’s Guam Proposal

186,880

294,190

0

50,000

100,000150,000200,000250,000300,000

Continental

Micronesia

(GUM)

Delta (HNL)

Sources: Exhibits DL-133 and CO-115 

Annual Seats

+57%
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