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 21, 2014
October 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 

limited to four daily round trips to Haneda. Those four frequencies1are extremely 

valuable to consumers traveling between the United States and Haneda.

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

agree that the Department should 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. Of course, the carriers 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 this 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 Donovan
CERTIFICATE OF SERVICE

I, Abigail Donovan, certify that, on October 21, 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)

todd.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 (Delta 

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