BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Motions and Application of 

AMERICAN AIRLINES, INC.

HAWAIIAN AIRLINES, INC. 

In the matter of 2010 U.S.-Haneda Combination 

Services Allocation Proceeding

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Docket DOT-OST-2010-0018 

CONSOLIDATED ANSWER

OF DELTA AIR LINES, INC.

Communications with respect to this document should be addressed to:

Glen Hauenstein

Executive Vice President 

 & Chief Revenue Officer

Robert J. Cortelyou

Senior Vice President – Network Planning

DELTA AIR LINES, INC.

1030 Delta Boulevard

Atlanta, Georgia 30320

Alexander Van der Bellen

Managing Director and Associate General 

Counsel – Regulatory and International Affairs

DELTA AIR LINES, INC. 

1212 New York Avenue, N.W. 

Washington, D.C. 20005

(202) 842-4184

sascha.vanderbellen@delta.com

January 12, 2015
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Motion and Application of 

AMERICAN AIRLINES, INC.

HAWAIIAN AIRLINES, INC. 

In the matter of 2010 U.S.-Haneda Combination 

Services Allocation Proceeding

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Docket DOT-OST-2010-0018 

CONSOLIDATED ANSWER 

OF DELTA AIR LINES, INC.

Delta Air Lines Inc. (“Delta”) hereby responds to the Applications of American Airlines

Inc. (“American”) and Hawaiian Airlines, Inc. (“Hawaiian”). In 2013 Delta established the first 

and only nonstop Haneda gateway from the Pacific Northwest region at Seattle. As the service 

has taken root – fueled in large part by Delta’s strong commitment to growing the Seattle hub –

we have seen significant market improvements in traffic and profitability.

American’s and Hawaiian’s efforts to strip Seattle and Washington State of their only 

Haneda flight and move the slots to abundantly served states in California and Hawaii is 

contrary to the public interest and the Department’s prior findings in selecting Seattle. Delta is 

currently operating Seattle-Haneda service in full compliance with the terms and conditions 

specified in Order 2013-2-4 (“Allocation Order”), including the dormancy condition. Although 

Delta is operating at a temporarily reduced level, Delta has firm plans, has allocated aircraft, is 

actively marketing, and will operate daily service at the start of the IATA Summer Season, 

effective March 29, 2015 and beyond.1

1 Delta reiterates that it does not concede the lawfulness of the Department’s decision to 

reexamine the allocation of the Seattle-Haneda frequencies or of any final decision to reallocate 

the same slots to another carrier. Delta expressly incorporates by reference its Petition for 

 
Delta Consolidated Answer

Page 2

1. The Public Benefits of Seattle-Haneda service are superior to American’s and 

Hawaiian’s Proposals.

If service were taken away from Seattle it would be the largest U.S.-Tokyo O&D gateway 

without nonstop service to Haneda. Seattle would also be the largest west coast business 

center without Haneda service, placing Seattle and the Pacific Northwest region at a

disadvantage to the well-served cities of San Francisco and Los Angeles (to say nothing of 

Hawaii which currently enjoys 3 of 8 Haneda opportunities). Seattle-Haneda must be 

maintained for the following reasons:

• Seattle will continue as an important and unique mainland gateway, providing 

122,000 annual Tokyo passengers with nonstop access to Haneda.2

 

Intergateway competition will be preserved with San Francisco and Los Angeles 

which both have two existing Haneda flights.

• 47 cities will receive round-trip connections, and an additional 38 cities will 

receive one-way connecting service to Haneda via Seattle. Seattle’s geographic 

location provides the largest catchment area and best network coverage of the 

United States. 

• The Pacific Northwest region will maintain its only convenient access to Haneda 

because the existing west coast gateways are too far south and unreasonably 

circuitous. 

• Delta’s growing Seattle network, served with Delta and Delta Connection aircraft,

is bringing more traffic and true online connections to the marketplace, improving 

service and competition for U.S.-Haneda passengers. 

• Delta’s proposal will preserve and enhance vigorous 3-way competition among 

the major alliances serving Japan. Delta is the only effective competitor to the 

United/ANA and American/JAL immunized alliances, both of which have major 

hub operations at Haneda.

• Unlike American, Delta’s service maintains a unique new Haneda gateway at 

Seattle, rather than duplicating existing Haneda services at Los Angeles. It 

would be patently unfair for Los Angeles to enjoy three Haneda slot pairs while 

Seattle would be relegated to none. 

Reconsideration of December 22, 2014, and, for the reasons set forth in that document, urges 

that further proceedings be stayed pending reconsideration of Order 2014-12-9. Order 2014-12-

9 is arbitrary and capricious and contrary to law, and any final decision by the Department to 

reallocate the slots would be unlawful for the same reasons.

2 MIDT data adjusted to account for direct sales. 

 
Delta Consolidated Answer

Page 3

• Unlike Hawaiian, Delta will use this limited Haneda opportunity to serve U.S. 

citizens and businesses, rather than transport Japanese tourists in the well 

served Haneda-Hawaii marketplace. Similar to American’s proposal, Hawaii 

already has three nonstop Haneda flights while an award to Hawaiian would 

deprive the Pacific Northwest of its only nonstop flight. 

When the Department granted Delta Seattle-Haneda slots it made a number of important 

public interest findings confirming the benefits of Seattle-Haneda service. See, Show Cause 

Order 2012-11-12 at pp. 5-6; confirmed by Final Order 2013-2-4. Particularly given that Delta 

has committed to a full pattern of daily service beginning on March 29, there is no justifiable 

basis for removing the slots from Seattle.

2. Delta is diligently working to develop the Seattle-Haneda route. 

Delta is moving aggressively to develop Seattle as a hub with new Delta and Delta 

Connection-operated service, both domestic and international. While – as the Department has 

been kept well aware -- it has been challenging to establish Haneda service, as we continue to 

implement our Seattle strategy we have seen passenger traffic and profitability surge. In fact, 

Delta’s Summer Season SEA-HND 2014 performance improved by 54% percent year-overyear. Encouraged by this strong summer 2014 performance, Delta has allocated aircraft, 

published schedules and is actively selling a full pattern of daily Seattle-Haneda service in 

summer 2015 and beyond.

 A major contributor to the improved success of the Seattle-Haneda flight is the 

increased Delta-operated connecting service into Seattle, which grew to 51 daily departures in 

August 2014, will grow again to 85 in 2015, and is anticipated to continue growing in 2016. This 
Delta Consolidated Answer

Page 4

growth represents an increase of 240 percent in Seattle flights, which will provide the necessary 

feed needed to make the Seattle-Haneda service a continued success:

3. American’s critique of Delta’s Haneda Service is hypocritical and without merit. 

While American is highly critical of Delta’s effort to make adjustments to its network to 

establish viable Haneda service – it conveniently ignores its own failed bid and “broken 

promises” to operate nonstop service from New York (JFK). American also made major 

reductions in its JFK-HND service – reducing its service pattern similar to Delta – (DL-A-301) 

before abandoning the route entirely in November 2013. American did not so much as bother

to seek authority for a new gateway (such as Los Angeles). By contrast Delta has worked 

diligently and persistently to find a workable Haneda solution until that airport can finally be 

brought under open skies. 

We note the irony of American’s exaggerated claim that DOT should strip Delta of its 

SEA-HND slot for “appalling underuse” in the off-peak winter schedule, while American has 

regularly made its own seasonal adjustments rendering limited international frequencies unused 

for 90 days or more over a period spanning more than a decade. Exhibit DL-A-303. No action 

was taken by the Department to recall American’s unused frequencies. The Department should 

squarely reject American’s call for a different and unprecedented result here.

25 29

51

85

2012 2013 2014 2015

Daily Delta to Delta Connections for SEA-HND 
Delta Consolidated Answer

Page 5

All carriers make adjustments to their schedules and aircraft size -- which is a normal, 

expected commercial response to observed market conditions. It is no secret that developing 

service from the mainland U.S. has been challenging; in fact, on several occasions Delta met 

with the Department staff and advised them that temporary seasonal reductions might be 

necessary. Delta never received any objections in the past to its seasonal reductions, and was 

given no notice that reduced winter operation this season could or would trigger a summary 

review of Seattle’s Haneda service. 

4. American Misrepresents the Competitive Environment on the Los Angeles-Tokyo and 

Seattle-Tokyo Routes. 

American claims that Los Angeles-Tokyo is under-served relative to Seattle-Tokyo, with 

a market that is five times larger, but has only twice the number of flights. Yet, American 

inexplicably fails to account for two of the eight widebody flights operating the Los AngelesTokyo route – specifically Delta’s LAX-NRT flight and ANA’s LAX-HND flight. Compare Exhibit 

AA-212, DL-A-101. When corrected for this gross error, American’s claims about the 

“underserved” nature of the Los Angeles market fall apart –LAX and SEA have roughly the 

same number of seats per Tokyo passenger. DL-A-102. And, if Seattle were to lose its only 

Haneda flight to add a third Haneda service at Los Angeles, Seattle would be underserved 

relative to LAX. 

American’s claim that Delta “competes” with itself on LAX and SEA routes to Tokyo 

misses the point and is incorrect. While Haneda and Narita both serve the metropolitan Tokyo 

region, Haneda accesses the key downtown business region and operates in a completely 

different time channel from Delta’s Narita services – improving service and choice for 

consumers. DL-A-104. And, as discussed below in section 6, American’s current LAX-NRT 

and proposed LAX-HND flights would compete with themselves in the same manner – unless 

American follows the course it has signaled by eliminating its LAX-NRT flight. 
Delta Consolidated Answer

Page 6

Finally, contrary to American’s claims, U.S.-Tokyo routes – and Seattle in particular –

experience significant variations in seasonal demand. There is 35% less demand for SeattleTokyo in the winter than summer months. DL-A-302. However, as noted above, Delta’s 

expanding Seattle hub network will work to offset these seasonal variations in the future. 

5. American already has access to Haneda via its partnership with JAL.

American’s claim that it “is the only U.S. airline serving Japan without Haneda authority”

is false. (p.10). In fact, American enjoys important advantages with a large partner and major 

hub at Haneda. To that end, American conveniently overlooks that it is operating across the 

Pacific as one airline with JAL, one of the largest competitors in the U.S.-Japan marketplace 

with a huge incumbent position at Haneda:

American currently enjoys the benefit of two U.S.-Haneda slots Haneda under its joint 

venture with JAL, which American and JAL certify they have implemented. Exhibit DL-2. 

American’s stated objective in forming its immunized alliance was to create a metal-neutral joint 

venture in which each carrier was indifferent to the actual operator of the aircraft:

The Joint Applicants seek approval for a highly-integrated, revenue-sharing joint venture 

that will strengthen their alliance by eliminating each carrier’s economic incentive to 

maximize its own revenue. Only the closer cooperation made possible through a joint 

venture based on metal neutrality – or indifference as to which airline actually carries a 

customer – will maximize the consumer benefits that immunized alliances make 

DL

24%

AA/JL

29%

UA/NH

38%

Other

9%

US-Japan ASMs by Immunized Alliance

OAG, Mar '15

Other

18%

SkyTeam 

2%

oneworld

33%

Star 

47%

HND Slots by Alliance

OAG, Mar '15
Delta Consolidated Answer

Page 7

possible. This is because metal neutrality removes each carrier’s incentive to act 

opportunistically in ways that inure to its own short-term financial advantage, to the 

detriment of the efficiencies and consumer benefits that could otherwise be delivered by 

the alliance. American/JAL Antitrust Immunity Application, Docket DOT-OST-2010-

0034, p.7.

Today, American codeshares on each and every one of JAL’s U.S.-Japan flights, 

including JAL’s HND-San Francisco and highly lucrative HND-Honolulu flights. When the 

Department approved the American/JAL immunized alliance it stated: "The intended 

commercial effects of the ATI Applicants’ respective joint business agreements are similar to 

those resulting from a merger." (Japan ATI Order 2010-10-4 at 5). If American and JAL are not 

working together to jointly realize the full benefit of JAL’s two Haneda flights, then they have 

failed to realize the claimed benefits of their ATI alliance and should no longer be entitled to 

antitrust immunity.3

Delta service at Seattle will continue progress toward three-way alliance competition on 

U.S.-Haneda routes and is essential to preventing further deterioration of the competitive market 

structure. The two immunized U.S.-Japanese alliances have inherent advantages over Delta, 

which does not have a Japan alliance partner. As a SkyTeam member and major U.S.-Japan 

competitor, Delta is the only carrier capable of offering a competitive alternative to the west 

coast Haneda services of oneworld (JL) and Star (UA) at San Francisco and Star (ANA) at Los 

Angeles. The DOT has consistently sought to promote inter-alliance competition.4

 Maintaining 

3 Moreover, American and JAL could serve Los Angeles-Haneda today simply by moving JAL’s 

SFO-HND flight to LAX. Given the recently authorized United SFO-HND service, there is a 

strong possibility that the oneworld carriers might make this decision on their own initiative. It 

would make absolutely no sense (and contradict the Department’s stated public interest 

objectives for U.S.-Haneda flying) to strip Delta of its SEA-HND slots that are used to operate 

from the Pacific Northwest to allow American/JAL to pile on more flights on the already 

saturated LAX-HND route. 

4 See Order 2009-7-10, page 17 (“We also examined the changes in inter-alliance 

competition.... The ability of the ‘non-hub’ alliance members to compete at [a hub of another 

alliance] can benefit both business and leisure passengers.”); Order 2010-2-8, page 28 

(“[E]enhanced inter-alliance competition is beneficial for consumers across many markets....”)

 
Delta Consolidated Answer

Page 8

Delta’s SEA-HND service helps to promote the Department’s public interest objectives. 

Conversely, the loss of a slot pair would marginalize Delta in the U.S.-Haneda marketplace, 

leaving Delta with just a single daily flight to compete against the multiple daily trans-Pacific 

flights and large Haneda hubs operated by Star and oneworld. This would increase market 

dominance by the U.S.-Japan ATI alliances and undermine Delta’s ability to compete in the 

U.S.-Tokyo and U.S.-Japan marketplace.

6. American’s claimed new capacity benefits are illusory. 

American’s exhibits filed with its original Application showed that American assigned the 

same flight number to its proposed LAX-HND flight as its existing LAX-NRT flight. Although 

American has now attempted to cover this up by assigning new flight numbers, American avoids 

mentioning and makes no commitment to maintain LAX-NRT service despite being called out on 

it in the initial round of pleadings. Furthermore, American’s gimmick of proposing an unrealistic

60 day startup in a long haul widebody market is further indication that American intends to 

swap the Tokyo markets operated with its existing equipment. Thus, it would appear that 

American intends to drop its own LAX-NRT service just as it canceled its own JFK-NRT service 

when it launched JFK-HND and left its partner JAL to fly JFK-NRT. American is playing a zero 

sum game. Allowing American to switch its LAX service from one airport to another (particularly 

when LAX has two existing Haneda flights) provides no public interest benefits compared with 

the substantial benefits generated by maintaining Seattle as a unique gateway serving the 

Pacific Northwest. By contrast, Delta will continue to serve NRT from Seattle, and Delta’s 

Haneda flight represents true incremental capacity in the marketplace to the benefit of 

consumers. 

7. Maintaining the Pacific Northwest’s only Haneda service a superior U.S. public 

interest use than using 4 of 8 Haneda slots to benefit Japanese tourists. 

Delta’s proposal to maintain the only Haneda service to Seattle and the Pacific 

Northwest region deserves priority over Hawaiian’s proposal to add a fourth Haneda-Hawaii 
Delta Consolidated Answer

Page 9

flight at Kona. Hawaii already receives three nonstop Haneda services operated by Hawaiian 

Airlines, JAL and ANA. Combined, these services represent 37.5% of all available Haneda 

slots. If Hawaiian’s Kona proposal were granted, 50% of Haneda slots (four of eight) would be 

operated to the Hawaiian Islands. The overwhelming majority of passengers on existing 

Tokyo-Hawaii flights (95%) are Japanese tourists (DL-A-401), and the Tokyo-Kona market is 

even more heavily Japanese-originating (96%). DL-A-402. It is not in the public interest to have 

so many limited entry opportunities concentrated in Hawaii to the exclusion of a Pacific 

Northwest gateway that provides service to U.S. citizens and U.S. businesses seeking access 

to Tokyo’s preferred close-in airport.

Hawaiian claims that “access to Kona is only available through Honolulu; as such the 

availability of nonstop service will be attractive to Japanese-originating tourists.” (p.6). Yet, 

Hawaiian ignores the open entry opportunities available to Kona from Tokyo Narita – a major 

achievement under the open skies agreement the United States secured with Japan. Haneda 

is the preferred business airport serving downtown Tokyo. And, as Japan’s airport policies 

continue to evolve it is likely that more leisure and charter traffic will shift to Narita. U.S. 

customers and U.S. businesses should receive public interest priority over Japan’s tourists. 

Moreover, Hawaiian should not enjoy a U.S. flag monopoly on Haneda-Hawaii service. Instead 

of offering Narita-Kona service which it is free to do today, Hawaiian seeks only to operate from 

the constrained Haneda airport.

By contrast, in order to take on the American/JAL and United/ANA joint ventures and 

maintain effective 3-way alliance competition from key U.S. business markets, it is vital for Delta

to maintain service at Seattle and grow its U.S.-Haneda network. Tokyo-Kona traffic is point-topoint Japanese originating leisure traffic and Hawaiian can point to no valid reason these 

passengers cannot be accommodated by it at Narita.
Delta Consolidated Answer

Page 10

8. Conclusion

Delta is demonstrably and deeply committed to growing its Seattle hub and to daily flying 

of the Seattle-Haneda route beginning this March and continuing through the winter and 

summer seasons beyond. It is manifestly in the public interest to allow Delta to do so, rather 

than to revoke Seattle’s only Haneda connection in favor of the over-served Los Angeles or 

Hawaii gateways. 

Respectfully submitted,

_________________________________

Alexander Van der Bellen

Managing Director, Regulatory and 

International Affairs

 & Associate General Counsel

DELTA AIR LINES, INC.
Delta Answer Exhibits

Section I: American’s Misstatement of the Tokyo-Los Angeles and TokyoSeattle Competitive Environment

Section II: Seattle Provides a Superior Connecting Gateway to Haneda

Section III: American’s Failure to Deliver on its Haneda Commitments

Section IV: Scarce Haneda Slots Should Benefit U.S. Public, Not Just Japanese 

Tourists
Section I: American’s Misstatement of the Tokyo-Los Angeles and 

Tokyo-Seattle Competitive Environment
American Misrepresents the Competitive 

Los Angeles-Tokyo Environment Docket DOT-OST-2010-0018

Exhibit DL-A-101

Page 1 of 1

• AA claims that Los Angeles-Tokyo O&D is 5x larger than Seattle-Tokyo yet has only twice (6x daily)

the number of flights (Exhibit AA-212).

• In reality, Los Angeles-Tokyo is served 8x daily and has been for the entirety of 2014.

• American inexplicably fails to list Delta’s LAX-Narita and ANA’s LAX-Haneda services.

• The Actual competitive landscape for Seattle-Tokyo and Los Angeles-Tokyo is as follows:

SEA

LAX

TYO

Source: OAG
• When these additional services are included, the ratio of seats to MIDT O&D passengers in the 

Seattle-Tokyo and Los Angeles Tokyo markets are nearly equal:

• American could increase the number of seats available in the LAX-TYO market by upgauging their 

LAX-NRT service to a 777-300ER rather than stripping the Pacific Northwest of its only Haneda

gateway.

American Misrepresents the Competitive 

Los Angeles-Tokyo Environment Docket DOT-OST-2010-0018

Exhibit DL-A-102

Page 1 of 1

LAX-TYO Passengers 423,525

LAX-TYO Seats 1,648,857

93,892 SEA-TYO Passengers

461,611 SEA-TYO Seats

3.8

4.9

LAX SEA

Seats per passenger

Source: OAG & MIDT
• Under AA’s proposal to deprive Seattle of its only Haneda flight, the ratio would skew heavily 

towards Los Angeles, resulting in under- service for Seattle:

• Seattle would be served by even fewer seats per passenger than LAX is currently, which American 

portrays as a severely underserved market.

• American’s proposal would also inconvenience the traveling public as it would remove the most 

convenient US-HND gateway, depriving most of the nation of non-circuitous connections at Seattle.

American Misrepresents the Competitive 

Los Angeles-Tokyo Environment Docket DOT-OST-2010-0018

Exhibit DL-A-103

Page 1 of 1

4.6

3.2

LAX SEA

Seats per passenger

LAX-TYO Passengers 423,525

LAX-TYO Seats 2,003,549

93,892 SEA-TYO Passengers

303,602 SEA-TYO Seats

Source: OAG & MIDT
• Delta’s SEA-Tokyo flights compliment each other. SEA-HND allows passengers to access the 

preferred downtown airport for Tokyo O&D traffic while SEA-NRT connects passengers to Delta’s 

intra-Asia destinations.

• Similarly, LAX-HND and SEA-HND flights compliment each in allowing passengers from different 

catchment areas access to Haneda. Taking away the SEA-HND flight would deprive Seattle and the 

Pacific Northwest of convenient options to Haneda.

• American has left unanswered whether they plan to continue flying LAX-NRT if they are awarded 

the Haneda frequencies at issue.

• In their initial application, American’s proposed LAX-HND service used the same flight 

numbers as LAX-NRT.

• American’s proposed 60-day startup time is unreasonable for a new, widebody international 

route unless they plans to transfer bookings from LAX-NRT to LAX-HND.

• If American decides it would rather not “compete with itself”, and cancels LAX-NRT, any seat 

access benefits to consumers is Los Angeles would disappear and Seattle and the Pacific 

Northwest would lose their only gateway to Haneda.

American Continues to Claim that Flights to Narita and Haneda

from the Same Gateways are Duplicative; Delta Strives to Offer 

Customers Choices and Flexibility at Seattle and Los Angeles

Docket DOT-OST-2010-0018

Exhibit DL-A-104

Page 1 of 1
Section II: Seattle Provides a Superior Connecting Gateway to 

Haneda
Seattle is Geographically Positioned to Optimally

Connect U.S. Traffic to Haneda

• Seattle connections are less circuitous versus other West Coast gateways for points across 

the US—including the Pacific Northwest, the Southeast and the East Coast.

• The vast majority of American’s listed “Unique Connection Markets” would require circuitous 

flights to connect on to AA’s proposed LAX-HND flight.

Docket DOT-OST-2010-0018

Exhibit DL-A-201

Page 1 of 1

SEA is a more direct route to HND 

for the most US cities

SEA

LAX
Seattle is an Ideal West Coast Gateway to Haneda 

Delta and Alaska Provide Nonstop Service to 74 U.S. Points 

Note: Includes service operated by Alaska/Horizon

Source: July 2015 schedules, Diio Mi

Docket DOT-OST-2010-0018

Exhibit DL-A-202

Page 1 of 1

To ANC, FAI, JNU, SIT, KTN

Haneda
American’s “Unique Connecting Markets” Ignore Delta’s 

Additional Codeshare Partnership with Alaska Airlines that 

Combined with Delta’s Own-Metal Network Connect Seattle to 74 

U.S. Points

• Of AA’s 15 “Unique Connecting Markets” Alaska serves 6 with timings that will conveniently 

connect passengers to Delta’s SEA-HND flight.

Docket DOT-OST-2010-0018

Exhibit DL-A-203

Page 1 of 1

Source: OAG & Exhibit AA-215

161,257

173,010

154,000

156,000

158,000

160,000

162,000

164,000

166,000

168,000

170,000

172,000

174,000

AA DL

Unique O&D Passengers

Points that Alaska serves that connect to 

DL SEA-HND at least part of the year

Using AA’s own methodology shows higher 

unique O&D passengers for DL’s SEA-HND 

than AA’s proposed LAX-HND
Section III: American Historically Underserved Haneda (and Brazil)
American’s Failed New York-Haneda Commitment

• American’s proposal to serve JFK-HND committed to DOT to provide 247 daily seats with the 

following service pattern: 

Docket DOT-OST-2010-0018

Exhibit DL-A-301

Page 1 of 1

Source: OAG & Exhibit AA-304

Seats Flown Seats Promised
Seattle – Tokyo winter demand is more seasonal than other 

Haneda gateways 

• Seattle – Tokyo winter demand is 35% less than in summer months.

– Seattle August demand spikes 55% relative June, climbing more than LAX, SFO, or HNL

-40%

-25%

-10%

5%

20%

35%

50%

APR MAY JUN JUL AUG SEP OCT NOV DEC JAN FEB MAR

HNL LAXSFO SEA

U.S. – Tokyo demand seasonality

Source: MIDT 2010 – 2013 average indexed to June

Sum Win % Chg

SEA 163 106 -35%

HNL 1,916 1,874 -2%

LAX/

SFO 967 951 -2%

U.S. – Tokyo PDEW

Docket DOT-OST-2010-0018

Exhibit DL-A-302

Page 1 of 1
Travel Period Mktg Al Mon Tue Wed Thu Fri Sat Sun Ops/Week

Jan-02 AA 7 8 8 8 8 8 7 54

Feb-02 AA 7 8 8 8 8 8 7 54

Mar-02 AA 7 7 7 8 8 8 7 52

Apr-02 AA 7 7 7 8 8 8 7 52

May-02 AA 7 7 7 8 8 8 7 52

Jun-02 AA 8 9 8 9 8 8 9 59

Jul-02 AA 8 9 8 9 8 8 9 59

Aug-02 AA 8 9 8 9 8 8 9 59

Sep-02 AA 8 8 9 9 9 9 9 61

Oct-02 AA 6 5 6 6 5 6 6 40

Nov-02 AA 6 5 6 6 5 6 6 40

Dec-02 AA 6 5 6 6 5 6 6 40

Jan-03 AA 7 6 6 7 6 7 6 45

Feb-03 AA 7 6 6 7 6 7 6 45

Mar-03 AA 7 6 6 7 6 7 6 45

Apr-03 AA 7 6 6 6 6 6 6 43

May-03 AA 5 6 6 6 5 6 6 40

Jun-03 AA 5 6 6 6 5 6 6 40

Jul-03 AA 6 6 6 6 6 6 6 42

Aug-03 AA 6 6 6 6 6 6 6 42

Sep-03 AA 6 6 6 6 6 6 6 42

Oct-03 AA 6 6 6 6 6 6 6 42

Nov-03 AA 6 6 6 6 6 6 6 42

Dec-03 AA 6 6 6 6 6 6 6 42

Jan-04 AA 7 7 7 7 8 8 7 51

Feb-04 AA 7 7 7 7 8 8 7 51

Mar-04 AA 7 7 7 7 8 8 7 51

Apr-04 AA 7 6 6 6 7 7 7 46

May-04 AA 7 6 6 7 7 7 7 47

Jun-04 AA 7 8 8 8 8 8 7 54

Jul-04 AA 7 8 8 8 8 8 7 54

Aug-04 AA 7 8 8 8 8 8 7 54

Sep-04 AA 7 6 7 6 8 7 8 49

Oct-04 AA 7 6 7 6 8 7 8 49

Nov-04 AA 7 6 7 6 8 7 8 49

Dec-04 AA 7 8 8 8 8 8 7 54

= periods of frequency underutilization

AA U.S.-Brazil frequencies 2002-2014

American has a Chronic History of Allowing Limited Entry 

Frequencies to Remain Dormant for Periods of 90 Days or More Docket DOT-OST-2010-0018

Exhibit DL-A-303

Page 1 of 5
Travel Period Mktg Al Mon Tue Wed Thu Fri Sat Sun Ops/Week

Jan-05 AA 7 8 8 8 8 8 7 54

Feb-05 AA 7 8 8 8 8 8 7 54

Mar-05 AA 7 8 8 8 8 8 7 54

Apr-05 AA 7 8 8 8 8 8 7 54

May-05 AA 7 6 6 7 7 7 7 47

Jun-05 AA 7 8 7 8 8 8 8 54

Jul-05 AA 7 8 7 8 8 8 8 54

Aug-05 AA 7 8 7 8 8 8 8 54

Sep-05 AA 7 6 6 7 8 8 7 49

Oct-05 AA 7 6 6 7 8 8 7 49

Nov-05 AA 7 8 7 8 8 8 8 54

Dec-05 AA 6 7 6 7 7 7 7 47

Jan-06 AA 8 8 8 9 8 9 9 59

Feb-06 AA 7 7 7 8 7 8 8 52

Mar-06 AA 6 7 6 7 7 7 7 47

Apr-06 AA 6 5 5 7 7 7 6 43

May-06 AA 6 5 5 7 7 7 6 43

Jun-06 AA 6 5 5 7 7 7 7 44

Jul-06 AA 6 7 6 7 7 7 7 47

Aug-06 AA 6 7 6 7 7 7 7 47

Sep-06 AA 6 5 5 5 6 6 6 39

Oct-06 AA 6 5 5 5 6 6 6 39

Nov-06 AA 6 5 5 7 6 7 7 43

Dec-06 AA 7 7 7 8 8 8 8 53

Jan-07 AA 7 8 7 8 8 8 8 54

Feb-07 AA 7 7 7 7 7 7 7 49

Mar-07 AA 6 7 7 7 7 7 6 47

Apr-07 AA 6 5 5 6 6 6 6 40

May-07 AA 6 5 5 6 6 6 6 40

Jun-07 AA 6 5 5 8 8 8 7 47

Jul-07 AA 6 8 7 8 8 8 7 52

Aug-07 AA 6 7 6 7 7 7 7 47

Sep-07 AA 6 5 5 5 6 6 6 39

Oct-07 AA 6 5 5 5 6 6 6 39

Nov-07 AA 7 7 7 7 7 6 6 47

Dec-07 AA 7 7 7 7 8 8 7 51

Docket DOT-OST-2010-0018

Exhibit DL-A-303

Page 2 of 5

American has a Chronic History of Allowing Limited Entry 

Frequencies to Remain Dormant for Periods of 90 Days or More
Travel Period Mktg Al Mon Tue Wed Thu Fri Sat Sun Ops/Week

Jan-08 AA 8 8 8 7 8 8 7 54

Feb-08 AA 7 7 7 6 7 7 6 47

Mar-08 AA 7 7 7 6 7 7 5 46

Apr-08 AA 5 6 5 6 6 6 6 40

May-08 AA 5 6 5 6 6 6 6 40

Jun-08 AA 6 8 6 8 7 8 8 51

Jul-08 AA 7 8 7 8 7 8 8 53

Aug-08 AA 6 7 6 7 7 7 7 47

Sep-08 AA 6 7 6 7 6 7 6 45

Oct-08 AA 6 7 6 7 6 6 6 44

Nov-08 AA 8 9 8 8 8 9 7 57

Dec-08 AA 8 9 8 9 10 10 10 64

Jan-09 AA 9 11 10 9 10 10 10 69

Feb-09 AA 8 8 8 8 9 9 9 59

Mar-09 AA 8 8 7 8 8 9 8 56

Apr-09 AA 6 8 7 7 7 8 7 50

May-09 AA 6 8 7 7 7 8 7 50

Jun-09 AA 6 8 7 8 8 9 9 55

Jul-09 AA 7 9 6 10 7 10 9 58

Aug-09 AA 7 9 6 10 7 10 9 58

Sep-09 AA 6 6 6 6 6 8 7 45

Oct-09 AA 6 6 6 6 6 8 7 45

Nov-09 AA 6 7 6 8 8 9 9 53

Dec-09 AA 8 8 8 8 8 10 9 59

Jan-10 AA 8 9 8 8 8 10 9 60

Feb-10 AA 8 9 8 8 8 9 9 59

Mar-10 AA 8 8 8 8 8 9 9 58

Apr-10 AA 7 8 7 8 7 8 7 52

May-10 AA 7 8 7 8 7 8 7 52

Jun-10 AA 7 8 7 9 8 9 8 56

Jul-10 AA 8 10 8 9 9 9 9 62

Aug-10 AA 8 10 8 9 9 9 8 61

Sep-10 AA 7 9 7 9 7 9 7 55

Oct-10 AA 7 9 7 9 7 9 7 55

Nov-10 AA 7 9 7 9 7 9 7 55

Dec-10 AA 9 9 10 9 10 11 11 69

Docket DOT-OST-2010-0018

Exhibit DL-A-303

Page 3 of 5

American has a Chronic History of Allowing Limited Entry 

Frequencies to Remain Dormant for Periods of 90 Days or More
Travel Period Mktg Al Mon Tue Wed Thu Fri Sat Sun Ops/Week

Jan-11 AA 10 11 11 11 11 12 11 77

Feb-11 AA 10 11 11 10 10 12 11 75

Mar-11 AA 9 10 10 10 10 12 11 72

Apr-11 AA 7 9 9 10 9 11 9 64

May-11 AA 7 9 9 10 9 11 9 64

Jun-11 AA 7 9 9 10 10 11 10 66

Jul-11 AA 10 11 10 10 10 11 10 72

Aug-11 AA 10 11 10 10 10 11 10 72

Sep-11 AA 7 9 9 10 9 11 9 64

Oct-11 AA 7 9 9 10 9 11 9 64

Nov-11 AA 7 9 9 10 10 11 10 66

Dec-11 AA 8 11 11 12 13 12 13 80

Jan-12 AA 12 13 13 12 13 12 13 88

Feb-12 AA 12 13 12 11 11 12 11 82

Mar-12 AA 10 12 11 11 11 12 11 78

Apr-12 AA 9 10 9 10 9 11 9 67

May-12 AA 9 10 9 10 9 11 9 67

Jun-12 AA 9 10 9 12 12 12 12 76

Jul-12 AA 12 13 12 12 12 12 12 85

Aug-12 AA 12 13 12 12 12 12 12 85

Sep-12 AA 10 11 10 11 10 12 10 74

Oct-12 AA 11 12 11 12 11 13 11 81

Nov-12 AA 11 13 12 13 14 14 13 90

Dec-12 AA 13 14 14 16 16 16 15 104

Jan-13 AA 16 15 16 16 16 16 15 110

Feb-13 AA 16 15 16 16 16 16 15 110

Mar-13 AA 15 14 14 15 15 15 14 102

Apr-13 AA 13 12 12 13 13 15 13 91

May-13 AA 13 12 12 13 13 15 13 91

Jun-13 AA 13 13 15 16 16 16 15 104

Jul-13 AA 16 15 15 16 16 16 15 109

Aug-13 AA 15 15 14 16 15 16 14 105

Sep-13 AA 11 11 11 11 11 14 12 81

Oct-13 AA 12 11 12 12 13 14 13 87

Nov-13 AA 12 11 12 12 13 13 12 85

Dec-13 AA 15 16 15 16 16 16 15 109

Docket DOT-OST-2010-0018

Exhibit DL-A-303

Page 4 of 5

American has a Chronic History of Allowing Limited Entry 

Frequencies to Remain Dormant for Periods of 90 Days or More
Travel Period Mktg Al Mon Tue Wed Thu Fri Sat Sun Ops/Week

Jan-14 AA 16 17 17 17 18 17 17 119

Feb-14 AA 16 17 17 17 18 17 17 119

Mar-14 AA 14 13 13 14 14 15 14 97

Apr-14 AA 14 12 14 13 14 15 14 96

May-14 AA 16 17 16 17 17 17 16 116

Jun-14 AA 16 16 17 17 17 17 16 116

Jul-14 AA 17 16 17 17 17 17 15 116

Aug-14 AA 17 16 17 17 17 17 15 116

Sep-14 AA 13 12 13 13 13 14 13 91

Oct-14 AA 13 12 13 13 13 15 14 93

Docket DOT-OST-2010-0018

Exhibit DL-A-303

Page 5 of 5

American has a Chronic History of Allowing Limited Entry 

Frequencies to Remain Dormant for Periods of 90 Days or More
Section IV: Scarce Haneda Slots Should Benefit U.S. Consumers, Not 

Just Japanese Tourists
• Hawaiian’s proposal would overwhelmingly benefit Japanese tourists to Hawaii, while 

depriving most of the U.S. from the most convenient Haneda connecting gateway at Seattle.

Scarce Haneda Slots Should Benefit U.S. Consumers, Not Just 

Japanese Tourists

Source: MIDT 2014

Docket DOT-OST-2010-0018

Exhibit DL-A-401

Page 1 of 1

Japan 95%

U.S. 4%

Other 1%

Hawaii-Tokyo O&D Passengers by Point of Sale
• The imbalance of public benefits is even greater for Kona-Tokyo traffic:

Scarce Haneda Slots Should Benefit U.S. Consumers, Not Just 

Japanese Tourists

Source: MIDT 2014

Docket DOT-OST-2010-0018

Exhibit DL-A-402

Page 1 of 1

Japan 96%

U.S. 3%

Other 0%

Kona-Tokyo O&D Passengers by Point of Sale
CERTIFICATE OF SERVICE

A copy of the foregoing document has been served this 12th day of January, 2015, upon 

the following persons via email:

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

Ishiwata.K@portseattle.org

Safora.I@portseattle.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