BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Answer of the 

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. AND HAW AllAN AIRLINES, INC. 

Communications with respect to this document should be addressed to: 

Mark Reis 

Managing Director 

Seattle - Tacoma International Airport 

Kazue Ishiwata 

Senior Manager Air Service Development 

Seattle-Tacoma International Airport 

Port of Seattle 

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 of Seattle 

Legal Department 

P. 0. Box 1209 

Seattle, WA 98111 

(206) 787-3216 (tel) 

(206) 787-3205 (fax) 

safora.i@portseattle.org 
Answer of the Port of Seattle 

DOT -OST -2010-0018 

BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D..C. 

Answer of the 

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. MOTION AND HAWAIIAN AIRILNES, INC. 

I. Delta's SEA-HND Slot Pair Provide 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 of the Port of Seattle 

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 of public 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's proposed service would further serve the public interest by providing 

a number of western 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 of service over a less circuitous northwest 

gateway." 

• "Allowing Delta to move from Detroit to Seattle would also advance one of the 

prime objectives we sought to achieve ... , namely, seeking with our limited 

number ofHaneda opportunities to address a diversity of public 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 of the 

U.S.-Haneda gateways, ... consistent with our established approach for the award 

of limited Haneda slot opportunities that would serve the public interest." 

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Answer of the Port of Seattle 

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 of Hawaii now enjoys three of the eight total U.S.-Haneda routeopportunities available to U.S. and Japanese carriers." Consistent with our 

ongoing goal of using our limited Haneda rights to address a variety of public 

interest objectives, including the objective of geographically diverse gateways, we 

tentatively find that the public interest would be better served by opening Haneda 

nonstop access to a new region of the country, the Pacific Northwest, than by 

allocating a fourth Haneda route to Hawaii." 

III. The Case for a Seattle-Haneda Slot Pair is Stronger Today With Delta's 

Growing Presence in Seattle. 

Since the launch of the 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 of passengers 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. 

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Answer of the Port of Seattle 

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. It has only been 16 months since the inauguration of Delta's SeattleHaneda service. The familiarity of Seattle 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 of American and Hawaiian in this 

proceeding. 

Respectfully submitted, 

PORT OF SEATTLE 

By: 

Deputy General Counsel 

DATED: October 17,2014 

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Answer of the Port of Seattle 

DOT -OST -2010-0018 

CERTIFICATE OF SERVICE 

I hereby certify that one copy of the foregoing Answer was served this 17th day 

of October, 2014, on all parties identified on the 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@del ta.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 

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