### BEFORETHE DEPARTMENT OFTRANSPORTATION WASHINGTON, D.C.

Answer ofthe PORT OF SEATTLE US-Haneda Combination Services Allocation Proceeding ) ) ) 

### ) Docket DOT-OST-2010-0018 ) ) )



### CONSOLIDATED ANSWER OFTHE PORT OF SEATTLE TO AMERICAN AIRLINES INC. AND HAWAllAN AIRLINES, INC.
Communications with respect to this document should be addressed to: MarkReis Managing Director Seattle

- Tacoma International Airport Kazue Ishiwata SeniorManagerAir Service Development Seattle-Tacoma InternationalAirport Port ofSeattle P

### .0. Box 68727 Seattle, WA 98168 (206) 787-4698 (tel) (206) 439-7782(fax) ishiwata.k@portseattle.org



### October 17, 2014 Isabel R. Safora Deputy General Counsel Port ofSeattle Legal Department P. 0. 

### Box 1209 Seattle, WA 98111 (206) 787-3216 (tel) (206) 787-3205 (fax) safora.i@portseattle.org

### Answer ofthe Port ofSeattle DOT-OST-2010-0018

BEFORETHE DEPARTMENT OFTRANSPORTATION WASHINGTON, D..C.

Answer ofthe PORT OF SEATTLE US-Haneda Combination Services Allocation Proceeding ) ) ) 

### ) Docket DOT-OST-2010-0018 ) ) )



### CONSOLIDATED ANSWER OF THE PORT OF SEATTLE TO AMERICAN AIRLINES INC. MOTIONAND HAWAIIAN AIRILNES, INC.
I. Delta's SEA-HND Slot PairProvide the Only Haneda Gateway in the Pacific Northwest Region. Delta's Seattle-Haneda slot pair offers the only direct connection from the Pacific Northwest region to Asia with minimum circuity for travelers connecting through Seattle. Revoking Delta's Seattle-Haneda slots and awarding to American or Hawaiian would not only inconvenience these travelers, but would also result in duplicative service to California and Hawaii, states that already enjoy the largest allocation ofU.S.-Haneda slots. Retaining the Seattle-Haneda gateway is also crucial to maintaining the competitive benefit to the region's travelers.Answer ofthe Port ofSeattle DOT-OST-2010-0018
II. The Department's 2013 public interest findings in awarding the SEA-HND frequency to Delta are even more compelling today and there is no cause to revisit those findings: In granting Delta's motion to move its Detroit-Haneda slot pair to Seattle (Order 2013-2-4), the Department made final its tentative findings ofpublic interest set forth in Order 2012-11-12. Those findings remain compelling today:
• "
... Delta's proposal would best serve the public interest by providing the first nonstop Haneda service on a significant mainland U.S-Tokyo route that currently lacks any such service, thereby establishing a new U.S. gateway to Haneda."
• "
... Delta'sproposed service would further serve the public interest by providing
a number ofwestern cities with a first one-stop connecting opportunity to Haneda."
• "
... [O]ther cities that now enjoy one-stop connections over more southerly gateways would gain the option ofservice over a less circuitous northwest gateway."
• "Allowing Delta to move from Detroit to Seattle would also advance one ofthe prime objectives we sought to achieve
..., namely, seeking with our limited number ofHaneda opportunities to address a diversity ofpublic interest goals."
• "
... [B]rings first-time Haneda service and first U.S.-flag Haneda service to the sixth-largest 0 & D market, while also promoting the geographic diversity ofthe U.S.-Haneda gateways, ... consistent with our established approach for the award oflimited Haneda slot opportunities that would serve the public interest."

2

### Answer ofthe Port ofSeattle DOT-OST-2010-0018

• "
... Los Angeles already has two daily nonstop flights to Haneda. Delta serves Los Angeles-Haneda with its own flights, and United offers Los Angeles-Haneda service through its code share with ANA. Given the very limited opportunities for U.S. carrier service to Haneda, we tentatively do not find American's arguments persuasive for adding more Haneda service at Los Angeles while other significant U.S.-Tokyo gateways have no access to Haneda."
• "
...the State ofHawaii now enjoys three ofthe eight total U.S.-Haneda routeopportunities available to U.S. and Japanese carriers." Consistent with our ongoing goal ofusing our limited Haneda rights to address a variety ofpublic interest objectives, including the objective ofgeographically diverse gateways, we tentatively find that the public interest would be better served by opening Haneda nonstop access to a new region ofthe country, the Pacific Northwest, than by allocating a fourth Hanedaroute to Hawaii." 

### III. The Case for a Seattle-Haneda Slot Pairis StrongerToday With Delta's Growing Presence in Seattle. Since the launch ofthe Seattle-Haneda flight, Delta has substantially increased its operations to position Seattle as its West Coast hub. By summer 2015, Delta will have
more than doubled its operations to 100 peak-day operations. This increase serves the growing number ofpassengers using Seattle as a gateway to Delta's international services, a trend which contributed to a 54% improvement in Delta's Seattle-Haneda route year-over-year. Delta's continued expansion in Seattle should only serve to increase passenger demand for Seattle-Haneda service.

3Answer ofthe Port ofSeattle DOT-OST-2010-0018


### IV. The Public Interest Would Not be Served by Granting the Motion of American Airlines. Delta's Seattle-Haneda service provides vital competition to the ATI alliances with Japanese carriers and increases the geographic options for travelers in the Pacific Northwest region. Ithas only been 16 months since the inauguration ofDelta's SeattleHaneda service. The familiarity ofSeattle travelers with this route is not yet optimal, but Seattle is working closely with Delta sales and marketing to improve and further develop this valuable route for the region. Neither American nor Hawaiian disputes that Delta is operating its SeattleHaneda slots in full compliance with the Department's dormancy conditions. As such, it would be unlawful and unwise to summarily withdraw slots from Seattle and put them up for reallocation to another gateway. We urge the Department to deny the motions ofAmerican and Hawaiian in this proceeding. Respectfully submitted, PORT OF SEATTLE By: Deputy General Counsel DATED: October 17,2014

4Answer ofthe Port ofSeattle DOT-OST-2010-0018
CERTIFICATE OF SERVICE
I hereby certify that one copy ofthe foregoing Answerwas served this 17th day ofOctober, 2014, on all parties identified onthe following service list via electronic mail. howard.kass@aa.com abigail.donovan@aa.com robert.wirick@aa.com charles.hunnicut@thompsonhine.com patricia.snyder@thomsponhine.com jhill@cooley.com perkmann@cooley.com bberlin@cooley.com dan.weiss@united.com thomas.bolling@united.com steve.morrissey@united.com lhalloway@crowell.com gmurphy@crowell.com Mike.Donatelli@alpa.org dino.atsalis@alpa.org Doug.Ralph@alpa.org sascha.vanderbellen@delta.com chris.walker@delta.com paul.gretch@dot.gov brian.hedberg@dot.gov brett.kruger@dot.gov todd.homan@dot.gov peter.irvine@dot.gov englets@state.gov cristinasa@state.gov eugene alford@ita.doc.gov info@airlineinfo.com

5