BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Motion and Answer of

HAWAIIAN AIRLINES, INC.

in the matter of 2010 U.S.

- Haneda

Combination Services Allocation Proceeding Docket DOT

- OST

- 2010

- 0018

CONSOLIDATED ANSWER AND REPLY OF AMERICAN AIRLINES, INC.

TO MOTION AND ANSWER OF HAWAIIAN AIRLINES, INC.

Howard Kass

Vice President

– Regulatory Affairs

Robert A. Wirick

Managing Director, Regulatory and

International Affairs

Abigail Donovan

Director, Congressional and Federal

Affairs

American Airlines, Inc.

1101 17th Street, N.W.

Washington, DC 20036

(202) 326.5153

howard.kass@aa.com

robert.wirick@aa.com

abigail.donovan@aa.com Charles A. Hunnicutt

Patricia N. Snyder

Thompson Hine LLP

1919 M Street, NW

Suite 700

Washington, DC 20036

- 1600

(202) 263 .4189

charles.hunnicutt@thompsonhine.com

patricia.snyder@thompsonhine.com

October 2 1 , 2014October 21, 2014 BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Motion and Answer of

HAWAIIAN AIRLINES, INC.

in the matter of 2010 U.S.

- Haneda

Combination Services Allocation Proceeding Docket DOT

- OST

- 2010

- 0018

CONSOLIDATED ANSWER AND REPLY OF AMERICAN AIRLINES, INC.

TO MOTION AND ANSWER OF HAWAIIAN AIRLINES, INC.

Delta Air Lines (“Delta”) has effectively abandoned the Seattle

- Haneda market

for the winter and part of the shoulder season, operating just 17 round trips between

October 5, 2014 and March 31, 2015. Under the U.S.

- Japan bilateral, U.S. carriers are

limit ed to four daily round trips to Haneda . T hose four frequencies 1 are extremely

valuable to consumer s traveling between the United States and Haneda.

American Airlines , Inc. (“American”) and Hawaiian Airlines, Inc. (“Hawaiian”)

agree that the Department sho uld withdraw Delta’s Seattle

- Haneda frequency and

reallocate it to another carrier. Hawaiian offers the Department an alternate path for

withdrawing the frequency from that proposed by American; however, the result is the

same

– a better use of the frequency. O f course, the carrier s disagree as to who should

1 Although the Haneda route rights are sometimes referred to as slots, they do not give carriers a right to a

specific time of operation, as an airport slot would. In substance, they are a right to operate a daily service, usually

referred to as frequencies, and we adopt that terminology here.Consolidated Answer and Reply of American Airlines, Inc.

To Motion and Answer of Hawaiian Airlines

Page 2 of 2

receive the allocation. American will further address th is issue and other points in its

response to Delta’s consolidated answer of October 17, 2014

.

American urges the Department to move forward and give the frequency to

American , basing its action on the greater public benefits that American can provide in

today’s conditions

.

Respectfully submitted,

Howard Kass

Robert A. Wirick

Abigail Don ovanCERTIFICATE OF SERVICE

I

, Abigail Donovan

, certify that, on October 2 1 , 2014 , I caused to be served a

copy of the foregoing Consolidated Answer and Reply of American Airlines, Inc. to the

Motion and Answer of Hawaiian Airlines, Inc. by email upon those addressees listed

below:

paul.gretch@dot.gov (DOT)

brian.hedberg@dot.gov (DOT)

brett.kruger@dot.gov (DOT)

tod d.homan@dot.gov (DOT)

peter.irvine@dot.gov (DOT)

EngleTS@state.gov ( Dep’t of State )

cristinasa@state.gov (Dep’t. of State)

eugene.alford@ita.doc.gov (Dep’t. of

Commerce)

howard.kass@aa.com (American)

Abigail.donovan@aa.com (American)

Robert.wirick@aa.com (American)

Charles.hunnicutt@thompsonhine.com

(American)

Pat.snyder@thompsonhine.com (American)

sascha.vanderbellen@delta.com (Delta)

chris.walker@delta.com (Delta) Mike.Donatelli@alpa.org ( Delt a MEC/ALPA)

jhill@cooley.com (Hawaiian)

Perkmann@cooley.com (Hawaiian)

bberlin@cooley.com (Hawaiian)

glindsey@lawa.org ( Los Angeles World

Airports)

ishiwata.k@portseattle.org ( Port of Seattle)

safora.i@portseattle.org ( Port of Seattle)

dan.weiss@united.com (United)

thomas.bolling@united.com (United)

abby.bried@united.com (United)

james.conneely@united.com (United)

steve.Morrissey@united.com (United)

gmurphy@crowell.com (United)

sseiden@crowell.com (United)

info@airlineinfo.com (AirlineInfo.com )

____________________________ Abigail Donovan