BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

2010 U.S.-HANEDA COMBINATION 

SERVICES ALLOCATION PROCEEDING 

 

 Docket DOT-OST-2010-0018 

CONSOLIDATED REPLY OF ALASKA AIRLINES, INC. 

AND HORIZON AIR INDUSTRIES, INC. d/b/a HORIZON AIR 

Communications with respect to this document should be addressed to: 

Kyle B. Levine, Esq. 

Associate General CounselCommercial Law and Litigation 

Alaska Airlines, Inc. 

19300 International Boulevard 

Seattle, Washington 98188 

Marshall S. Sinick, Esq. 

Edward W. Sauer, Esq. 

Squire Sanders and Dempsey, LLP 

1201 Pennsylvania Ave., NW 

Washington, DC 20004-0407 

202-626-6600 

msinick@ssd.com

esauer@ssd.com

Counsel to Alaska Airlines, Inc. and 

Horizon Air Industries, Inc. d/b/a Horizon Air

Megan Lawrence, Esq. 

Managing Director, Government Affairs 

 & Community Relations 

Alaska Airlines, Inc. 

19300 International Boulevard 

Seattle, Washington 98188 

Dated: March 8, 2010 
1 

BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

2010 U.S.-HANEDA COMBINATION 

SERVICES ALLOCATION PROCEEDING 

 

 Docket DOT-OST-2010-0018 

CONSOLIDATED REPLY OF ALASKA AIRLINES INC. 

AND HORIZON AIR INDUSTRIES, INC. d/b/a HORIZON AIR 

Alaska Airlines, Inc. (“Alaska”) and its affiliate Horizon Air Industries, Inc. d/b/a 

Horizon Air (“Horizon”) respectfully reply to the answer of Continental Airlines, Inc. 

(“Continental”) and United Airlines, Inc. (“United”) to the extent those answers oppose the 

Department’s selection of Seattle as a new gateway for U.S. carrier service to Japan’s Haneda 

Airport and, in that regard, Delta’s application to provide Seattle-Haneda nonstop service. This 

reply similarly addresses those portions of Continental’s and United’s answers opposing the 

selection of Los Angeles as a new gateway to Haneda and the applications of both American and 

Delta to provide the first U.S. carrier nonstop service between Los Angeles and Haneda. 

If the Department decides to select only one West Coast gateway for new Haneda service, 

Alaska and Horizon would strongly support the Department’s selection of the Seattle gateway 

and Delta’s proposal to provide daily nonstop service. However, if the Department should decide 

to select two West Coast gateways, Alaska and Horizon would also recommend Los Angeles as 

the second West Coast-Haneda gateway and the selection of either Delta or American to provide 

new Los Angeles-Haneda nonstop service. Alaska and Horizon’s substantial presence in Seattle 
2 

and Los Angeles would materially enhance the benefits to the traveling public of Delta’s as well 

as American’s proposed West Coast-Haneda services. 

Alaska and Horizon have comprehensive marketing relationships, including reciprocal 

frequent flyer programs, with Delta and American. Alaska’s and Horizon’s ability to carry a 

substantial number of passengers to and from international gateways at Seattle and Los Angeles 

would allow U.S. and Asian passengers traveling between Seattle or Los Angeles, on the one 

hand, and Japan’s Haneda Airport, on the other, the convenience of frequent, well-timed 

connections to points throughout the U.S., Canada and Mexico. Alaska and Horizon would like 

to assure the Department that they have every intention of maximizing their Seattle and Los 

Angeles networks to enhance the connecting opportunities for both Delta and American 

passengers. Indeed, under Alaska’s and Horizon’s alliance agreement with Delta, both carriers 

committed to providing incremental connecting flights to further enhance the travel experience 

of Delta’s connecting passengers. 

At Seattle, Alaska and Horizon account for approximately 48 percent of all enplaned 

passengers carrying nearly 7.4 million passengers in the 12 months ended August 2009. Alaska 

and Horizon operate 1787 weekly nonstop flights serving 69 destinations in Alaska, Canada, 

Mexico and the “Lower 48.1

 Beyond those telling metrics of Alaska’s and Horizon’s substantial 

Seattle presence, it is also generally acknowledged that Alaska enjoys a well-deserved 

representation for providing a superior level of service which has contributed to Alaska’s loyal 

passenger base. 

At Los Angeles, Alaska and Horizon carried more than 1.6 million passengers in the 12 

months ended August 2009, making Alaska the largest U.S. carrier between Los Angeles and 

 

1

 Alaska and Horizon’s August 2010 schedules. 
3 

Mexico. Alaska operates 323 weekly flights and serves 25 destinations in Alaska, Canada, the 

“Lower 48” and Mexico on a nonstop basis. 

Alaska and Horizon would also like to respond to United’s assertion that the Department 

should disregard the Alaska/Horizon beyond Seattle and Los Angeles2

 flights Delta depicts in its 

exhibits. United bases its argument on the fact that, since Delta does not control the schedule 

times of Alaska’s and Horizon’s flights, the comparative marketplace value of Delta’s 

Alaska/Horizon connections should be heavily discounted. United could not be more wrong. 

Alaska and Horizon work closely with both Delta and American in an effort to optimize 

connecting flight options and to minimize connecting times. The value and importance to 

Alaska and Horizon of attracting longhaul international connecting flights has always been a 

priority consideration in Alaska’s scheduling of its flights – and that will not change. A reliable 

barometer of Alaska’s focus on international longhaul connecting traffic is the fact that Alaska 

and Horizon in 2009 connected nearly 62,000 passengers traveling to/from Asian cities. 

CONCLUSION

Alaska and Horizon can transfer significant volumes of Haneda connecting traffic at its 

Seattle gateway as well as at its Los Angeles gateway and, if the Department decides to select 

only one West Coast-Haneda gateway, Alaska and Horizon would urge that Seattle be that 

gateway with Delta’s proposed service. However, if the Department decides to select two West 

Coast gateways, Alaska strongly supports Los Angeles as the second gateway with either Delta’s 

or American’s proposed service. 

 

2 See United Answer at 6 and 14 n. 14; United Exh. UA-A-5. 
4 

Respectfully submitted, 

___________________________________ 

Marshall S. Sinick, Esq. 

Squire Sanders and Dempsey, LLP 

1201 Pennsylvania Ave., NW 

Washington, DC 20004-0407 

202-626-6600 

Counsel to Alaska Airlines, Inc. and 

Horizon Air Industries, Inc. d/b/a Horizon Air

Dated: March 8, 2010 
5 

CERTIFICATE OF SERVICE

I hereby certify that copies of the foregoing Consolidated Reply of Alaska Airlines, Inc. 

and Horizon Air Industries, Inc. d/b/a Horizon Air has this day been served by electronic mail on 

the following: 

carl.nelson@aa.com

Robert.wirick@aa.com

Thomas.bolling@coair.com

dan.weiss@coair.com

hershel.kamen@coair.com

rbkeiner@crowell.com

gmurphy@crowell.com

Julie.oettinger@united.com

bruce.rabinovitz@wilmerhale.com

david.heffernan@wilmerhale.com

jhill@dowlohnes.com

perkman@dowlohnes.com

ldeavers@dowlohnes.com

hoyt.zia@hawaiianair.com

mark.arimoto@hawaiianair.com

sascha.vanderbellen@delta.com

esta.rosenberg@dot.gov

 

Marshall S. Sinick, Esq. 

Dated March 8, 2010 
6 

EXHIBIT 1