BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, DC 

 

In the Matter of ) 

 ) 

2010 U.S.-Haneda Combination ) Docket DOT-OST-2010-0018 

Services Allocation Proceeding ) 

 ) 

APPLICATION OF 

UNITED AIR LINES, INC. 

FOR AN ALLOCATION OF SLOTS 

FOR U.S.-HANEDA COMBINATION SERVICE

 Communications with respect to this document should be addressed to: 

JULIE OETTINGER 

Managing Director – International 

& Regulatory Affairs 

UNITED AIR LINES, INC. 

1025 Connecticut Avenue, NW 

Suite 1210 

Washington, DC 20036 

MARY BARNICLE 

Manager – International & Regulatory 

Affairs 

UNITED AIR LINES, INC. 

77 West Wacker Drive, HDQIZ 

Chicago, IL 60601 

BRUCE H. RABINOVITZ 

DAVID HEFFERNAN 

WILMER CUTLER PICKERING 

 HALE AND DORR LLP 

1875 Pennsylvania Avenue, NW 

Washington, DC 20006 

(202) 663-6000 (Phone) 

(202) 663-6363 (Fax) 

bruce.rabinovitz@wilmerhale.com 

david.heffernan@wilmerhale.com 

Counsel for 

UNITED AIR LINES, INC. 

DATED: February 16, 2010 
TABLE OF CONTENTS 

Application of United Air Lines, Inc. for an

Allocation of Slots for U.S.- Haneda Combination Service

 Page 

I. Introduction. 1 

 

II. United Was a Key Supporter of the U.S.-Japan Open 4 

 Skies Agreement, Which is the Essential Predicate to 

 Enabling Scheduled U.S.-Flag Service to Haneda. 

III. Awarding United One of the Four Available Daily 5 

 Slot Pairs (For Haneda Service from San Francisco) 

 Will Maximize Public Benefits. 

 

IV. Responses to DOT Request for Information and Evidence. 13 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, DC 

 

In the Matter of ) 

 ) 

2010 U.S.-Haneda Combination ) Docket DOT-OST-2010-0018 

Services Allocation Proceeding ) 

 ) 

DATED: February 16, 2010 

APPLICATION OF 

UNITED AIR LINES, INC. 

FOR AN ALLOCATION OF SLOTS 

FOR U.S.-HANEDA COMBINATION SERVICE

Pursuant to Order 2010-1-17 (January 26, 2010) (the “Instituting Order”), United 

Air Lines, Inc. (“United”) submits this application for one (1) of the four pairs of daily 

U.S.-Haneda slots that are available for allocation to U.S. carriers under the U.S.-Japan 

Memorandum of Understanding, initialed on December 11, 2009 (“2009 MOU”). United 

will use these slots to introduce daily nonstop combination service between San 

Francisco and Tokyo Haneda International Airport using Boeing 777 aircraft. 

I. Introduction.

By Order 2010-1-17, the Department instituted this proceeding and invited U.S. 

carriers to file applications for an allocation of slots to operate daily nonstop scheduled 

combination services at Tokyo’s Haneda International Airport. A total of four daily slot 

pairs will become available after Haneda’s fourth runway becomes operational (currently 

scheduled for October 2010) and the 2009 MOU is signed, thereby implementing the 

U.S.-Japan Open Skies Agreement. As explained in the Instituting Order, the 
Application of United Air Lines, Inc. 

Page 2 

Department intends to conduct the proceeding with reduced evidentiary requirements “in 

a manner that will facilitate our reaching a prompt final decision” and “prompt utilization 

of the slots at issue here.”1/

 

United requests an allocation of one (1) pair of daily U.S.-Haneda slots in order to 

introduce daily nonstop combination service between San Francisco and Tokyo Haneda 

(SFO-HND) (Exhibit UA-1).2/

 This service will be operated with B777-200XQ aircraft 

currently in United’s fleet, with a total of 269 seats (Exhibit UA-2). United requests that 

the Department allocate the slots for an indefinite period.3/ 

 

1/

 Order 2010-1-17, at 2. The IATA slot filing deadline for the Winter 2010 traffic season 

is May 13, 2010. Accordingly, United requests that the Department make a final award of slots in 

this proceeding sufficiently in advance of that date to allow the slot recipients to prepare their 

filings in time to meet the IATA deadline. 

2/

 United holds authority to operate combination service between San Francisco and Tokyo 

Haneda. See United’s Certificate of Public Convenience and Necessity for Route 130 (Order 98-

6-22) (granting United authority to operate service between any point or points in the U.S., via 

any intermediate point or points, and any point or points in Japan, and any point or points 

beyond). The Department most recently renewed this authority by Order 2003-10-12, which was 

due to expire on October 14, 2008. United timely filed an application to renew the authority on 

March 14, 2008 in Dockets DOT-OST-1996-1131/1248/1873, which extends the authority 

automatically pending the Department’s final action on the application under 5 U.S.C. § 558(c). 

Thus, United requires only an allocation of one pair of daily slots at Haneda in order to introduce 

its proposed San Francisco-Haneda service. 

3/

 United is fit, willing, and able to properly operate scheduled combination services in 

foreign air transportation, including the U.S.-Haneda service it is proposing here. See Orders 98-

4-3 and 2006-1-1. United is a Delaware corporation with its principal place of business at 77 

West Wacker Drive, Chicago, Illinois 60601. United is a wholly-owned subsidiary of UAL 

Corporation. Both United and UAL Corporation are citizens of the United States of America 

within the meaning of 49 U.S.C. § 40102. United holds various certificates of public 

convenience and necessity and exemptions authorizing it to engage in scheduled foreign air 

transportation of persons, property and mail. United requests that the Department take official 

notice, pursuant to Rule 24 of its Rules of Practice, of all data previously filed to establish 

United’s fitness. 14 C.F.R. §§ 302.24(g), 302.303(c)(ii). 
Application of United Air Lines, Inc. 

Page 3 

United’s proposed San Francisco-Tokyo Haneda service would maximize the 

public benefits available from an award of these slots. Many of these benefits are 

detailed in Section III below, and may be summarized as follows: 

• United’s San Francisco-Haneda proposal will establish nonstop scheduled 

combination service between United’s primary U.S. hub gateway for Asia 

services and Tokyo’s downtown airport. 

• United’s proposed Haneda service will benefit from strong local demand for 

Tokyo service from the greater San Francisco metropolitan area, which is one 

of the largest local O&D markets for Tokyo service in the United States. 

• United’s proposed San Francisco-Tokyo Haneda service will offer strong 

connectivity at both ends of the route: 

o San Francisco is a popular, convenient, non-circuitous gateway for 

passengers traveling to Tokyo from cities across the entire mainland 

United States. United’s nonstop service to Haneda from its west coast hub 

at San Francisco International Airport will allow it to offer online 

connections between Haneda and a total of 27 airports in addition to SFO. 

o At Haneda, passengers will benefit from United’s code-share alliance with 

All Nippon Airways (“ANA”) and its wholly-owned subsidiary, Air 

Japan, which will enable United to maximize connecting service 

opportunities via Haneda with cities in Japan and other Asian countries. 

• United’s proposed flight schedule will maximize connecting service options 

for the greatest possible number of U.S. consumers. 

• United’s proposal – featuring a West Coast gateway at San Francisco – is well 

structured to respond to strong U.S. mainland demand for well-timed service 

to Tokyo’s close-in Haneda Airport. 

• United’s choice of aircraft (the B777-200XQ with a three-class seating 

configuration) is well suited for service to Haneda and will provide a highlevel of passenger options and comfort on these long-haul flights. 

• United’s B777 aircraft will provide ample cargo capacity between San 

Francisco (where United operates a cargo hub) and Haneda. 
Application of United Air Lines, Inc. 

Page 4 

• United’s experience in serving U.S.-Japan and U.S.-Asia markets and its 

strong market presence in the U.S. and Asia will enable United to make the 

best use of the available slots. 

II. United Was a Key Supporter of the U.S.-Japan Open Skies Agreement, Which 

is the Essential Predicate to Enabling Scheduled U.S.-Flag Service to Haneda.

 This proceeding – and, more importantly, the valuable opportunities it presents for 

U.S. carriers to re-introduce scheduled service at Haneda – would not be possible but for 

the U.S. Government’s successful negotiation of an Open Skies Agreement with Japan. 

The Department and the negotiating team led by Deputy Assistant Secretary John Byerly 

deserve enormous credit for securing this landmark agreement, which will liberalize 

restrictions on U.S. passenger and cargo services, some of which have been in effect for 

more than 50 years. As Assistant Secretary Kurland recently noted, the Open Skies 

Agreement “has the potential to be truly transformative for travelers and shippers, not only 

between the U.S. and Japan, but in markets throughout Asia. It will offer both U.S. and 

Japanese airlines new opportunities to match service with consumer demand . . . .”4/ 

 United was a consistent and vigorous supporter of the U.S. Government’s efforts 

to persuade the Japanese Government to enter into an open skies agreement. United 

committed substantial resources and effort over many years to the cause of persuading 

the Japanese Government, other airlines, and key stakeholders as to the substantial 

commercial opportunities and public benefits such an agreement would provide. 

 

4/

 Remarks of Susan Kurland, Assistant Secretary for Aviation and International Affairs, 

U.S. Department of Transportation, at the Conference of the American Bar Association’s Forum 

on Air & Space Law, Washington, DC, Jan. 27, 2010, at 1-2. 
Application of United Air Lines, Inc. 

Page 5 

 The opportunity for U.S. scheduled carriers to again serve Tokyo’s close-in 

Haneda Airport is a key benefit of the Open Skies Agreement. Given the potential value 

of Haneda services to U.S. consumers and the limited number of Haneda service 

opportunities that are available to U.S. carriers, it is imperative that the Department 

allocate the available slots to the carriers that can maximize the benefits of Haneda 

service for the largest possible number of U.S. passengers. As explained further in 

section III below, United’s proposed Haneda service from San Francisco, its primary U.S. 

hub/gateway for Asia services, clearly will rank among the four service proposals that 

offer the greatest public benefits. 

III. Awarding United One of the Four Available Daily Slot Pairs (for Haneda 

Service from San Francisco) Will Maximize Public Benefits. 

 In the Instituting Order, the Department (following the approach it has taken in 

past allocation proceedings) makes clear that its “principal objective” in allocating the 

slots at issue here is “to maximize the public benefits that will result from introducing 

U.S.-flag carrier service in the U.S.-Haneda market.”5/

 To achieve that objective, the 

Department will have to “consider which applicant or applicants will most likely offer 

and maintain service that best meets the needs of the traveling and shipping public.”6/

 

The Department “will also consider the effects of the applicants’ service proposals on the 

overall competitive environment, including effects on the market structure and on 

 

5/ Order 2010-1-17, at 1. 

6/

 Id. at 1-2. 
Application of United Air Lines, Inc. 

Page 6 

competition in the U.S.-Japan market.”7/ Because the U.S.-Japan market already is 

highly competitive and will remain so after the slots at issue in this proceeding have been 

allocated and are in use, the Department, in weighing the public benefits that each 

applicant’s proposed service would offer, should focus primarily on the comparative 

service advantages of each proposal. In addition, the Department plans to “consider other 

factors historically used for carrier selection, where relevant.”8/ In this case, the relevant 

public benefit considerations dictate awarding one of the four pairs of daily Haneda slots 

to United for service at San Francisco. 

 No carrier currently may provide scheduled nonstop U.S.-Haneda service, even 

though Haneda, with its convenient location in close proximity to downtown Tokyo and 

extensive connections to other cities in Japan and Asia, is an attractive airport for such 

service. Given the limited number of slots available for U.S. carrier service at Haneda, it 

is imperative that the Department select the proposals that will best meet the needs of the 

greatest number of U.S. consumers, including both nonstop and connecting passengers. 

United’s proposed SFO-HND service using B777 aircraft will certainly rank among the 

top four proposals in this respect. 

 The combination of substantial local San Francisco-Tokyo O&D traffic and 

convenient online one-stop connections to and from Haneda via San Francisco for 

passengers from 27 other airports, which together account for 40% of all U.S.-Tokyo 

 

7/

 Id. at 2. 

8/

 Id. 
Application of United Air Lines, Inc. 

Page 7 

passengers, will deliver high load factors for United’s San Francisco-Haneda service 

(Exhibit UA-3). The projected high level of demand for United’s proposed service is not 

surprising because the Western United States accounts for 36% of all U.S.-Tokyo O&D 

traffic, with California alone accounting for 27% of all such traffic (Exhibits UA-4, UA5). 

 The flight-hour restrictions on scheduled U.S. mainland service at Haneda make 

gateways located in the midwestern, central, southern and eastern regions of the U.S. 

mainland less attractive because the flight timings would not be as conducive to 

maximizing connecting service opportunities for U.S. passengers as a West Coast 

gateway. United’s SFO-HND proposal also has distinct advantages for U.S. passengers 

as compared to instituting Haneda service at Hawaii, Guam or Saipan, which would 

benefit primarily Japanese-origin travelers. Moreover, those markets already enjoy 

charter service to Haneda, and will continue to do so. Indeed, with their focus on leisure 

travelers, these markets are better suited to charter service, which does not require an 

allocation of slots in this proceeding. Thus, United’s San Francisco hub is the ideal 

location for Haneda service due to its geographical location, strong local market demand, 

and ability to provide convenient connections at a large number of U.S. cities that 

together account for more than half of the total U.S. mainland passenger traffic to Tokyo 

(Exhibit UA-6). 

In brief, the public benefits of United’s proposed San Francisco-Haneda service 

include the following: 
Application of United Air Lines, Inc. 

Page 8 

Strong Local Market Demand. The San Francisco-Tokyo market is the third 

largest U.S.-Tokyo local O&D market (Exhibit UA-7). All of those passengers will 

benefit directly from United’s nonstop service to Haneda. 

Maximizing Connecting Service Opportunities For U.S. Passengers. Tokyobound passengers from throughout the United States will benefit from the connecting 

service opportunities at United’s San Francisco hub. United offers service to 57 U.S. 

destinations from SFO, with 242 daily departures.9/

 That extensive connectivity will 

allow United to offer well-timed online, single-connect roundtrip service to Haneda from 

27 airports behind San Francisco.10/

 

 Passengers will further benefit from United’s alliance with ANA and its whollyowned subsidiary, Air Japan, which serve more than 40 nonstop destinations in Japan and 

Asia from Haneda (Exhibit UA-10). To be sure, the flight-hour restrictions applicable to 

U.S. carrier service at Haneda – which will only permit flight arrivals at Haneda after 10 

p.m. and departures from Haneda to the U.S. mainland after midnight – inevitably will 

limit connecting service opportunities for all applicants, particularly for connections to 

points beyond Haneda on westbound flights. The Department, nevertheless, should make 

the most of the opportunities that do exist by giving preference to slot applications from 

carriers that can maximize connecting service options at Haneda despite the restrictions 

on the number of U.S. carrier flights and the timing of those flights at the airport. United 

 

9/

 Exhibits UA-8, UA-9; OAG, Feb. 2010. 

10/

 Exhibit UA-3. In addition, 13 other U.S. airports will receive one-way, single-connect 

service on United to or from Haneda via San Francisco. 
Application of United Air Lines, Inc. 

Page 9 

is particularly well situated to do just that. Based on ANA’s and Air Japan’s current 

schedules, United will be able to offer 19 eastbound connections from 11 airports behind 

Haneda (Exhibit UA-11) as soon as its proposed SFO-HND service is initiated.11/

 

Beyond that, United plans to work with ANA to re-time flights to improve connecting 

service opportunities at Haneda, and United expects those opportunities to improve over 

time as capacity at Haneda increases and the airport continues to be opened to additional 

U.S. and other international services. In particular, ANA is likely to increase its services 

at Haneda, including the introduction of its own service to the United States from the 

airport. This should provide ANA a significant additional incentive to re-time its intraAsia flights to improve connections with U.S. transpacific flights, thereby generating 

opportunities not only for ANA but also for United to build more and better-timed 

connections at Haneda. Thus, United – both immediately upon implementing its San 

Francisco-Haneda service and over the longer term – will be able to offer passengers 

superior connecting service options at Haneda. Such connections constitute an important 

benefit for U.S. passengers and another compelling reason why the Department should 

award a pair of Haneda slots to United for its San Francisco service. 

Effect on Market Structure and Competition in U.S.-Japan Air Services. In 

terms of market structure, U.S. mainland demand for service to Tokyo is heavily focused 

 

11/

 All of these connections would involve a connecting time at Haneda of less than five 

hours. Due to the prohibition against U.S. carrier arrivals at Haneda before 10 p.m., current 

schedules would not allow for westbound connections beyond Haneda within a comparable 

connecting timeframe. 
Application of United Air Lines, Inc. 

Page 10 

in the western states, which account for 36% of all U.S.-Tokyo O&D traffic, with 

California alone accounting for 27% of all such traffic (Exhibits UA-4, UA-5). United’s 

Haneda service at its San Francisco hub will maximize benefits for U.S. passengers 

because it is ideally located and has extensive connections, particularly to cities located in 

the western states that collectively account for such a high percentage of total U.S. 

demand for service to Tokyo. 

 The market for air services between the United States and Japan is already highly 

competitive and will become even more so after the Open Skies Agreement becomes 

effective. Today, no fewer than eight different carriers (four U.S.-flag, two Japaneseflag, and two third-country carriers) operate nonstop service between the U.S. mainland 

and Tokyo.12/

 Under the 2009 MOU, designation and frequency restrictions on U.S. 

carriers will be abolished, and additional slots at Tokyo’s Narita Airport will become 

available. Thus, service offerings to Japan by U.S. carriers will be even more numerous 

and diversified than at present – so the market for U.S.-Japan air services is certain to 

remain highly competitive in the future, whatever decision the Department makes here. 

Against that background, United’s proposed San Francisco-Haneda service will enhance 

competition by giving passengers located across the U.S. mainland the option to access 

Tokyo’s downtown airport on United’s online network via its San Francisco hub. 

 

12/

 In addition, US Airways plans to introduce Phoenix-Tokyo Narita service in 2012. “US 

Airways Announces Slot Transaction With Delta Air Lines,” Aug. 12, 2009, available at 

http://phx.corporate-ir.net/phoenix.zhtml?c=196799&p=irol-newsArticle_print&ID=1319 (“US 

Airways will acquire from Delta the rights to operate daily service at two of the world’s most 

important business destinations – Sao Paulo, Brazil and Tokyo, Japan. . . . The Tokyo service is 

tentatively scheduled to operate from US Airways’ Phoenix hub using Airbus 330-200 aircraft.”). 
Application of United Air Lines, Inc. 

Page 11 

Superior Choice of Aircraft. Because of the B777-200XQ’s large, 269-seat 

capacity, the aircraft will be able to handle the demand for nonstop San Francisco-Tokyo 

Haneda service. The B777-200XQ will feature a three-cabin configuration, including 8 

First Class, 40 Business Class, 107 Economy Plus, and 114 Economy Class seats (Exhibit 

UA-2). In addition, the B777-200XQ aircraft is well suited for this service because it 

was designed for long stage length routes and features unmatched comfort along with 

ideal passenger amenities for a long-haul flight. United is currently in the process of 

upgrading the seating on its B777 aircraft and expects to use upgraded equipment for its 

San Francisco-Haneda service.13/

 United’s upgraded B777 will offer a broader range of 

service options to the traveling public than any other carrier, including a First-Class cabin 

with flat-bed seating and a total office environment, an expanded Business-Class cabin 

that also features flat-bed seats, and a capacious Economy-Class cabin featuring both 

Economy Plus and Economy seating (Exhibit UA-2).

Award-Winning Customer Service. The high quality of United’s international 

service will further assure the success of its proposed San Francisco-Haneda offering. 

United has won numerous awards for its international services, including its existing 

U.S.-Japan service (Exhibit UA-12), and there is every reason to expect that the service 

 

13/

 United’s program to upgrade the seating on its B777 fleet is ongoing and will likely 

continue through 2012, but United expects that by the time it would introduce the San FranciscoHaneda service, upgraded B777 equipment will be available and the Haneda route will be among 

the first routes where United will deploy the upgraded B777. 
Application of United Air Lines, Inc. 

Page 12 

United is proposing to institute between San Francisco and Haneda will receive similar 

plaudits. 

Cargo Service Benefits. The B777 also will provide reliable year-round cargo 

capacity for the long-haul San Francisco-Haneda (and broader U.S.-Japan/Asia) 

market.14/ United Cargo operates a large cargo hub at SFO with significant ground 

network feeder service that is well positioned to serve customers throughout the United 

States. United also plans to offer a full range of international cargo products to shippers 

in the U.S.-Haneda market, and sees strong demand for these products. 

* * * * * 

In conclusion, the Department should award United a pair of daily slots to 

introduce nonstop San Francisco-Haneda service because United’s proposal offers a 

unique set of consumer benefits. These include the combination of strong local O&D 

market demand for San Francisco-Haneda service and convenient online single-connect 

roundtrip service options for passengers traveling to and from an additional 27 airports. 

This combination will generate maximum benefits for the largest possible number of U.S. 

passengers, who will be offered convenient nonstop or online service to Tokyo’s close-in 

airport as well as to cities beyond Tokyo in Japan and elsewhere in Asia. Moreover, 

these passengers will enjoy United’s award-winning international service, along with the 

tremendous capacity and comfort of United’s B777 aircraft. It is imperative that the 

 

14/

 According to United’s internal estimates, with full passenger loads, the B777 will have a 

cargo capacity of 20 tons per flight on the San Francisco-Haneda route.
Application of United Air Lines, Inc. 

Page 13 

Department award these scarce and valuable operating rights to carriers that have the 

resources and expertise to maximize the benefits of Haneda service for the U.S. traveling 

public. United is amply qualified in this regard, having long been a leader in transpacific 

services, and San Francisco is the optimal location for this service because it is United’s 

primary hub/gateway for its network of services to Asia (Exhibit UA-13). 

IV. Responses to DOT Request for Information and Evidence.

 United has responded to Items 1 and 3 of Section II (“Request for Information and 

Evidence”) of Appendix A to the Instituting Order in the foregoing text and supporting 

exhibits to this Application. United responds to Items 2, 4, 5 and 6 as follows: 

 Item 2. A description of United’s current U.S.-Tokyo scheduled service is 

set forth in Exhibit UA-14. 

 Item 4. As stated above, United will operate the San Francisco-Haneda 

service using B777 aircraft. United currently has 52 B777 aircraft in its fleet, 46 of 

which are being used to support existing international services (Exhibit UA-15). All of 

United’s B777 aircraft comply with FAR-36. United will identify the specific aircraft to 

be used for the San Francisco-Haneda service following United’s receipt of an award of 

Haneda slots. It may be possible to accommodate the introduction of the Haneda service 

by re-timing some existing services without the need to discontinue any other service, but 

United will decide on any necessary service changes closer to the start date for the 

Haneda service. 
Application of United Air Lines, Inc. 

Page 14 

 Item 5. United’s estimated fuel consumption for its proposed service is set 

forth in Exhibit UA-16. United anticipates no difficulty in obtaining fuel to operate its 

proposed service. 

 Item 6. Responses to Interrogatories

 (a) If the carrier is selected for primary authority, will it accept a 

condition requiring institution of service by a date specified by the Department? What 

date should the Department specify? 

 United will accept a slot allocation subject to a condition that it 

must begin utilizing the slots by a date specified by the Department. United is prepared 

to commence San Francisco-Haneda service by the later of 90 days following the date of 

issuance of a final order allocating Haneda slots or October 31, 2010 (which is the first 

day of the IATA Winter 2010/2011 traffic season). United, however, requests that the 

Department, in crafting any start-up condition for inclusion in a final order awarding 

Haneda slots, take into account the particular challenges that will confront all U.S. 

carriers as they prepare to introduce transpacific service at an overseas airport that is not 

currently served by any U.S. scheduled carrier. The carriers that are awarded slots in this 

proceeding will have to secure slot times at Haneda, establish a station at Haneda, and 

arrange for all of the local airport facilities and services necessary to support long-haul 

service to and from the United States, including ensuring the availability of ground 

support facilities and services during the nighttime hours of operation necessitated by the 

flight-time restrictions applicable to U.S. carrier service at Haneda. In light of these 
Application of United Air Lines, Inc. 

Page 15 

unique challenges, United requests that the Department recognize in its final order that 

carriers may require greater flexibility in implementing service at Haneda than that 

afforded by the condition the Department has imposed in other cases requiring carriers to 

commence service within 90 days. 

 (b) If the carrier is selected for backup authority, will it accept a 

condition that (i) permits it to implement the authority within the first year should the 

primary carrier withdraw from the market, and (ii) the authority expires at the end of one 

year should the authority not be activated? 

 United will accept an award of back-up authority subject to such a 

condition. 

 (c) If an applicant is not awarded all of the pairs of slots that it 

has requested, would the applicant accept partial grant of its request? How would a 

partial allocation be used, and what would the start-up date be, if different from above? 

Also, what is the minimum number of pairs of slots that a carrier will accept?

 United is seeking one (1) pair of daily slots for Haneda service. 

United would not accept an award of fewer than one (1) pair of daily slots.

(d) Rank, in order of priority and preference, the U.S. points 

proposed for Haneda service for which the carrier seeks slot allocation in this 

proceeding, and if awarded, the number of pairs of slots needed for each market. 

 United is only proposing service to Haneda from San Francisco 

and requires only one (1) pair of daily slots for such service. 

Index of Exhibits for United 

Docket DOT-OST-2010-0018 

US1DOCS 7447620v1

EXHIBITS OF UNITED AIR LINES, INC. 

NO. TITLE

UA-1 United’s Proposed Schedule For San Francisco – Tokyo Haneda Service 

UA-2 United Will Operate SFO-HND Using Boeing 777-200 Aircraft With 269 Seats; 

United's B777-200 Aircraft Features Three-Cabin Premium International Service 

UA-3 United Will Offer Roundtrip Online Connections To Haneda From 27 Airports Via 

San Francisco; United’s Round Trip Online Single Connections To SFO-HND (By 

Origin); United’s Round Trip Online Single Connections From HND-SFO (By 

Destination)

UA-4 The Western States Account For 36% Of All U.S. – Tokyo O&D Traffic 

UA-5 California Has By Far The Most U.S.-Tokyo O&D Traffic Of Any State, With 

Almost Triple That Of The Next Largest State 

UA-6 United’s SFO-HND Flight Will Reach More Than Half Of The Total U.S. To Tokyo 

Demand 

UA-7 San Francisco is Among The Largest U.S. – Tokyo O&D Markets 

UA-8 United Serves 57 U.S. Domestic Airports Nonstop To/From San Francisco 

UA-9 United Operates An Extensive Domestic and International Service Network At Its 

San Francisco Hub 

UA-10 ANA Operates Nearly 200 Daily Departures To Over 40 Airports From TokyoHaneda 

UA-11 United Will Offer 19 Eastbound Connections (From 11 Airports) Via Haneda To 

San Francisco 

UA-12 United Airlines’ Recent Awards 

UA-13 San Francisco Is United's Primary Hub For Service To Asia 

UA-14 United’s Current U.S. – Tokyo Nonstop Scheduled Services 

UA-15 United's Existing Nonstop Routes Served With Boeing 777 Aircraft 

UA-16 SFO-HND Projected Fuel Burn 
United’s Proposed Schedule For s Proposed Schedule For 

San Francisco San Francisco – Tokyo Haneda Service Tokyo Haneda Service

HND-SFO Daily 777 01:10 17:15 

SFO-HND Daily 777 19:05 23:35 

Flight Frequency Equipment Departure Arrival

Winter 2010/2011 Schedule:

HND-SFO Daily 777 00:00 17:20 

SFO-HND Daily 777 19:05 22:20 

Flight Frequency Equipment Departure Arrival

Summer 2011 Schedule:
United Will Operate SFO United Will Operate SFO

-HND Using HND Using 

Boeing 777 Boeing 777

-200 Aircraft With 269 Seats 200 Aircraft With 269 Seats

Boeing 777-200 XQ

International Premium Product

8F/40C/107Y+/114Y = 269 Total
United's B777 United's B777-200 Aircraft Features 200 Aircraft Features 

Three-Cabin Premium International Service Cabin Premium International Service

United’s International First Class Suites:

Highlights• International first class suite recl

6’6” bed, that can be up to 23.5 i

• 15.4 inch flat panel screen with m

hours of on-demand programminfilms and games

• 20 XM music channels and Appl• 110v outlets: standard 110v pow

no adapter 

• USB port: charges your electron

digital camera

• Noise cancelling headphones• 4 way lumbar support • Numerous stowage compartmen
United’s International Business Class Seats

Highlights• United is the first major U.S. carr

seats in business class (Novembtilting. No sliding. Perfectly flat, 

• 180 degree flat bed seat, which a

completely recline to a full 6’ 4” b

• 15.4 inch flat panel screen with m

hours of on-demand programminfilms and games

• 20 XM music channels and Appl• 110v outlets and USB port: stand

outlets require no adapter

• USB port: charges your electron

digital camera

• Noise cancelling headphones• Adjustable seat comfort: six way 

headrest with four way lumbar su

United's B777 United's B777-200 Aircraft Features 200 Aircraft Features 

Three-Cabin Premium International Service Cabin Premium International Service
United Will Offer Roundtrip Online Connection

United Will Offer Roundtrip Online Connection

To Haneda From 27 Airports Via San Francisc

To Haneda From 27 Airports Via San Francisc

Sources: MIDT, CY2009. U.S. to Tokyo (HND/NRT). U.S. point of origin.OAG, November 2010, includes United Express.All flights are roundtrip connections using standard minimum/4 hr. maximum connect times based on November 2010 schedules. United anticipates slightly retiming some of these flights for optimal connections to SFO-HND.

YEG

LAX

YVR

YYJ

SEA

PDX

EUG

BOI

YYC

SLC

RNO

ACV

RDD

CIC

SMF

SFO MOD

MRY

FAT

SBP LAS

SBA

BUR

SNA

SAN PHX

DEN

ORD

San Francisco Plus 23 U.S. Airports Below Account For 40% Of All U.S.-Tokyo O&D In
Source: OAG, November 2010, includes United Express.

All flights are roundtrip connections using standard minimum/4 hr. maximum connect times based on November 2010 schedules. United anticipates slightly retiming some of these flights for optimal connections to SFO-HND.

United Will Offer Roundtrip Online Connection

United Will Offer Roundtrip Online Connection

To Haneda From 27 Airports Via San Francisc

To Haneda From 27 Airports Via San Francisc

Code City State Code City State Code Ci

BOI Boise Idaho LAS Las Vegas Nevada SLC Salt La

BUR Burbank California LAX Los Angeles California SAN San D

YYC Calgary Alberta MOD Modesto California SBP San Luis 

ORD Chicago Illinois MRY Monterey California SBA Santa B

CIC Chico California SNA Orange County California SEA Seattle/T

DEN Denver Colorado PHX Phoenix Arizona YVR VancYEG Edmonton Alberta PDX Portland Oregon YYJ Vict

EUG Eugene Oregon RDD Redding California

ACV Eureka/Arcata California RNO Reno Nevada

FAT Fresno California SMF Sacramento California
United’s Round Trip Online Single s Round Trip Online Single 

Connections To SFO Connections To SFO-HND (By Origin) HND (By Origin)

Origin Destination Airline Flight # Dept. Time Arvl. Time 

Source: OAG, November 2010, includes United Express.All flights are roundtrip connections using standard minimum/4 hr. maximum connect times based on November 2010 schedules. United has slightly retimed some of these flights for optimal connections to SFO-HND.

ACV SFO OO 6063 1555 1710 

BOI SFO OO 6159 1740 1820 

BUR SFO OO 6410 1655 1810 

CIC SFO OO 6193 1422 1520 

DEN SFO UA 735 1515 1654 

EUG SFO OO 6408 1512 1637 

FAT SFO OO 6258 1545 1635 

LAS SFO UA 544 1635 1806 LAX SFO UA 170 1700 1810 

MOD SFO OO 6661 1705 1740 

MRY SFO OO 6662 1730 1809 

ORD SFO UA 973 1500 1735 

PDX SFO UA 96 1630 1812 PHX SFO UA 94 1630 1731 

RDD SFO OO 6824 1435 1545 

RNO SFO OO 6616 1412 1516 

SAN SFO UA 930 1530 1701 

SBA SFO OO 6845 1550 1701 SBP SFO OO 6203 1704 1815 SEA SFO UA 204 1506 1710 

SLC SFO OO 6095 1645 1800 

SMF SFO OO 6010 1707 1758 

SNA SFO OO 6160 1505 1628 

YEG SFO OO 6115 1318 1533 

YVR SFO UA 887 1515 1734 YYC SFO OO 6348 1330 1521 

YYJ SFO OO 6055 1530 1740 
United’s Round Trip Online Single s Round Trip Online Single 

Connections From HND Connections From HND-SFO (By Destination

SFO (By Destination

Origin Destination Airline Flight # Dept. Time Arvl. Time 

Source: OAG, November 2010, includes United Express.All flights are roundtrip connections using standard minimum/4 hr. maximum connect times based on November 2010 schedules. United has slightly retimed some of these flights for optimal connections from HND-SFO.

SFO ACV OO 6041 1900 2015 SFO BOI OO 6398 1955 2225 SFO BUR OO 6131 2030 2139 SFO CIC OO 6196 1845 1941 SFO DEN UA 482 1850 2219 SFO EUG OO 6503 1945 2121 SFO FAT OO 6268 1905 1955 SFO LAS UA 887 1915 2046 SFO LAX UA 931 1900 2024 SFO MOD OO 6650 2045 2125 SFO MRY OO 6679 1902 1941 SFO ORD UA 152 1845 45 SFO PDX UA 544 1900 2043 SFO PHX UA 496 1916 2212 SFO RDD OO 6825 2115 2204 SFO RNO OO 6597 1845 1937 SFO SAN UA 901 1855 2022 SFO SBA OO 6847 1855 2018 SFO SBP OO 6531 1830 1936 SFO SEA UA 479 1904 2103 SFO SLC OO 6418 1845 2127 SFO SMF OO 6092 1950 2035 SFO SNA UA 140 1930 2104 SFO YEG OO 6366 1945 2336 SFO YVR UA 170 1913 2123 SFO YYC OO 6414 1955 2335 SFO YYJ OO 6124 1955 2208 
The Western States Account For The Western States Account For 

36% Of All U.S. 36% Of All U.S. 

– Tokyo O&D Traffic Tokyo O&D Traffic

Source: MIDT, CY2009. U.S. to Tokyo (HND/NRT). U.S. point of origin.

Eastern U.S. = CT, ME, MA, NH, RI, VT, NJ, NY, PA, DE, DC, FL, GA, MD, NC, SC, VA, WV, PR, VI.Central U.S. = IL, IN, MI, OH, WI, AL, KY, MS, TN, IA, KS, MN, MO, NE, ND, SD, AR, LA, OK, TX.Western U.S. = AZ, CO, ID, MT, NV, NM, UT, WY, CA, OR, WA. Does not include Alaska. 

Percentage of all U.S. to Tokyo O&D Passengers36% 29% 22% 13% 0%5% 10% 15% 20% 25% 30% 35% 40%

Western U.S. Eastern U.S. Central U.S. Hawaii / Guam 

Saipan
California Has By Far The Most U.S. California Has By Far The Most U.S.

-Tokyo O&D Traffic Tokyo O&D Traffic 

Of Any State, With Almost Triple Of Any State, With Almost Triple That Of The Next Largest S

 That Of The Next Largest 

Source: MIDT, CY2009. U.S. to Tokyo (HND/NRT). U.S. point of origin.

27%

10%

8%

6%

0%5%

10%15%20%25%30%

California New York Hawaii Texas

Percentage of all U.S. to Tokyo O&D Passengers
United’s SFO-HND Flight Will Reach More HND Flight Will Reach More 

Than Half Of The Total U.S. To Tokyo Deman

Than Half Of The Total U.S. To Tokyo Deman

Sources: MIDT, CY2009. U.S. to Tokyo (HND/NRT). U.S. point of origin.OAG, November 2010.Notes: Does not include demand from Canadian cities that connect to SFO-HND.

* United anticipates slightly retiming some of these flights for optimal connections to SFO-HND.

** There are 6 one-way connections from U.S. via SFO to Tokyo-Haneda (BOS, CEC, IAD, JFK, MSP and OTH). 

9%

31%

15%

55%

0%

10%20%30%40%50%60%

SFO Local

Market

27 Round Trip

Connections*

One Way

Connections**

Total 

Coverage

% Demand Coverage (U.S. to Tokyo)
San Francisco is Among The San Francisco is Among The 

Largest U.S. Largest U.S. 

– Tokyo O&D Markets Tokyo O&D Markets

Source: MIDT, CY2009. U.S. to Tokyo (HND/NRT). U.S. point of origin.

LAX=LAX,SNA,BUR,ONT. NYC=EWR,JFK, LGA. SFO=SFO,SJC,OAK. CHI=ORD,MDW. 

83,682

67,877

51,700

40,457

28

0

10,00020,00030,00040,00050,00060,00070,00080,00090,000

100,000

LAX NYC SFO HNL CH

Annual U.S. to Tokyo O&D passengers
United Serves 57 U.S. Domestic United Serves 57 U.S. Domestic 

Airports Nonstop To/From San Francisco Airports Nonstop To/From San Francisco

Source: OAG, February 2010.

Code City State Code City State Code City 

ABQ Albuquerque New Mexico MCI Kansas City Missouri PHX Phoen

ASE Aspen Colorado LMT Klamath Falls Oregon PIT Pittsbur

AUS Austin Texas KOA Kona Hawaii PDX Portlan

BFL Bakersfield California LAS Las Vegas Nevada RDD Reddin

BWI Baltimore Maryland LIH Lihue Hawaii RDM Redmo

BOI Boise Idaho LAX Los Angeles California RNO Reno 

BOS Boston Massachusetts OGG Maui Hawaii SMF Sacrame

BZN Bozeman Montana MFR Medford Oregon SLC Salt Lake 

BUR Burbank California MSP Minneapolis/St. Paul Minnesota SAT San Anto

ORD Chicago-O'Hare Illinois MOD Modesto California SAN San Die

CIC Chico California MRY Monterey California SBP San Luis O

COS Colorado Springs Colorado JFK New York-JFK New York SBA Santa Bar

CEC Crescent City California EWR Newark New Jersey SEA Seattle/Ta

DFW Dallas/Fort Worth Texas OTH North Bend Oregon GEG Spokan

DEN Denver Colorado ONT Ontario California STL St. Lou

EUG Eugene Oregon SNA Orange County California TUS Tucso

ACV Eureka/Arcata California MCO Orlando Florida IAD Washington

FAT Fresno California PSP Palm Springs California

HNL Honolulu Hawaii PSC Pasco Washington

IAH Houston-Intercontinental Texas PHL Philadelphia Pennsylvania
United Operates An Extensive Domestic and United Operates An Extensive Domestic and 

International Service Network At Its San Francisco 

International Service Network At Its San Francisc

Source: OAG, February 2010, includes United Express.

United Operates Over 240 Daily Departures To 75 Airports From San Franc
ANA Operates Nearly ANA Operates Nearly 200 Daily Departures 200 Daily Departures 

To Over 40 Airports* From Tokyo To Over 40 Airports* From Tokyo-Haneda

Source: OAG, February 2010, includes ANA subsidiaries.* ANA is scheduled to begin nonstop HND-TSA service beginning October 2010.

HND
Source: OAG, November 2010. All intra-Asia segments operated by ANA / Air Japan.

All flights are roundtrip connections using standard minimum/4 hr. maximum connect times based on November 2010 schedules.

United Will Offer 19 Eastbound Connections United Will Offer 19 Eastbound Connections 

(From 11 Airports) Via Haneda To San Francis

(From 11 Airports) Via Haneda To San Francis

HND

OKA

KMI

KMJ

FUK

HIJ

ITM

KIX

YGJ

CTS AKJ

GMP

S
Origin Destination Airline Flight # Dept. Time Arvl. Time 

AKJ HND NH 4738 1930 2115 

CTS HND NH 4798 2000 2140 CTS HND NH 82 2040 2220 CTS HND NH 4726 2100 2235 CTS HND NH 4728 2130 2305 CTS HND NH 970 2125 2310 

FUK HND NH 270 1945 2115 FUK HND NH 272 2035 2205 FUK HND NH 990 2130 2255 

GMP HND NH 1294 2020 2215 

HIJ HND NH 688 2045 2200 

ITM HND NH 40 2020 2130 

KIX HND NH 150 2120 2230 

KMI HND NH 618 2000 2135 

KMJ HND NH 650 2000 2135 

OKA HND NH 136 2000 2210 OKA HND EL 992 2020 2230 OKA HND NH 994 2100 2310 

YGJ HND EL 820 2000 2120 

United Will Offer 19 Eastbound Connections United Will Offer 19 Eastbound Connections 

(From 11 Airports) Via Haneda To San Francis

(From 11 Airports) Via Haneda To San Francis

Source: OAG, November 2010. All intra-Asia segments operated by ANA / Air Japan.All flights are roundtrip connections using standard minimum/4 hr. maximum connect times based on November 2010 schedules.
2009 Awards:

 Best North American Airline – Travel Trade Gazette Asia And Business Traveller Asia-P

 United Mileage Plus Voted Best Frequent Flyer Rewards Program By Readers – Globa Leading Edge Award For Best Domestic Carrier With Business Class Service – Execut Best Overall Provider Of Airfare Deals – Travelzoo Best Frequent Travel Programs And Offers (Elite Choice Competition) – Freddie Award

2008 Awards:

 Best North American Airline – Travel Trade Gazette Asia and Business Traveller Asia-P

 Traveler Innovation & Design Award 2008 (International First And Business Class Prod

 Leading Edge Award For Best Domestic Carrier With Business Class Service – Execut Best Premium Economy Class In The World (2nd Year In A Row) – Business Traveler

 Best Frequent Flyer Program – Global Traveler

 Top 10 Airline Meals (Charlie Trotter) – aviation.com

United Airlines United Airlines’ Recent Awards Recent Awards
San Francisco Is United's San Francisco Is United's 

Primary Hub For Service To Asia Primary Hub For Service To Asia

Source: OAG, February 2010.

Map here

SIN

SGN

BKK

HKG TPE

PVG

PEK

ICN

KIX

NRT

United Operates Six Transpacific Routes From San Francisco Plus 7 Beyond (Intra-
United’s Current U.S. s Current U.S. – Tokyo 

Nonstop Scheduled Services Nonstop Scheduled Services

Washington (IAD) – Tokyo (NRT) B747 Daily

Seattle (SEA) – Tokyo (NRT) B777 Daily

San Francisco (SFO) – Tokyo (NRT) B747 Daily

Los Angeles (LAX) – Tokyo (NRT) B777 Daily

Honolulu (HNL) – Tokyo (NRT) B777 Daily

Chicago (ORD) – Tokyo (NRT) B747 Daily

United Operated Aircraft Frequency

Source: OAG, February 2010. All of the above services are year-round.

United Codeshare (NH) Aircraft Frequency

San Francisco (SFO) – Tokyo (NRT) B777 Daily

Chicago (ORD) – Tokyo (NRT) B777 Daily

New York (JFK) – Tokyo (NRT) B777 Daily

Los Angeles (LAX) – Tokyo (NRT) B777 Daily

Honolulu (HNL) – Tokyo (NRT) B767 Daily

Chicago (ORD) – Tokyo (NRT) B777 Daily
United's Existing Nonstop Routes United's Existing Nonstop Routes 

Served With Boeing 777 Aircraft Served With Boeing 777 Aircraft

Source: OAG, February 2010.Note: United currently has a fleet of 52 Boeing 777 aircraft. 46 are international configured 3-cabin aircraft, 

while 6 are domestic configured 2-cabin aircraft that are currently being used to serve Hawaii.

BRU-IAD GIG-GRU IAD-SFO NRT-PEK

BRU-LHR GRU-IAD ICN-NRT NRT-SEA

CDG-IAD HNL-NRT ICN-SFO NRT-SIN

DEN-IAD HNL-ORD KIX-SFO OGG-ORD

DEN-LAX HNL-SFO KOA-OGG OGG-SFO

DEN-ORD IAD-KWI KOA-ORD ORD-PEK

DEN-SFO IAD-LAX LAX-LHR ORD-PVG

DXB-IAD IAD-LHR LAX-NRT ORD-SFO

FRA-IAD IAD-MUC LHR-SFO PEK-SFO

FRA-ORD IAD-ORD MUC-ORD PVG-SFO
SFO-HND Projected Fuel Burn HND Projected Fuel Burn

Route Aircraft Direction Per Trip (gals) Per Trip (lbs) Per Year (gals

Total 43,402 291,000 15,841,730 

HND-SFO B777-222ER Eastbound 19,699 131,000 7,190,135 

SFO-HND B777-222ER Westbound 23,703 160,000 8,651,595 

Assumptions:• Numbers are based on a standard routing• Aircraft operating at full capacity• Based on a full year of operations• Average of winter and summer schedule with average wind conditions

• Based on its current experience in serving Japan, United does not anticipate any difficulty in o

necessary fuel through its usual sources