# 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 ) ) ) ) ) ) ) ) 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 ) ) ) ) ) ) ) ) Docket DOT

- OST

- 2010

- 0018

CONSOLIDATED ANSWER

OF DELTA AIR LINES, INC

.

Delta Air Lines I nc. (“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

D elta 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 Pet ition 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 coas t business

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

disadvantage to the well

- serv ed 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



# I ntergateway 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 acce ss 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 bringin g 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 f inal 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

- H awaii 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 serv ice beginning on March 29, there is no justifiable

basis for removing the slots from Se attle

.

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 pr ofitability surge. In fact,

Delta’s Summer Season SEA

- HND 2014 performance improved by 54% percent year

- over

year. 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

- ope ra ted connecting service into Seattle, whi ch 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 it s 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 an d 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 main land U.S. has been challe nging; 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 reduc ed 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 operati ng the Los Angeles

Tokyo 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 Del ta “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 cha nnel from Delta’s Narita services

– improving service an d choice for

consumers. DL

- A

- 104. And, as discussed below in sectio n 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 it s 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 Seattle

To kyo 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 possibl e 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 inc entive 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 benef it 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 c ompetition on

U.S.

- Haneda routes and is essential to preventing further deterioration of the c om petitive market

s tructure. The two immunized U.S.

- Japanese alliances have inherent advantages over Delta,

which does not have a Japan alliance partner. As a SkyTeam membe r 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 contrad ict 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, pag e 28 (“[E]e nhanced 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 number s , American avoids

mentioning and makes no commitment to maintain LAX

- NRT se rvice 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 operate d 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 i t s LAX service from one airport to an o ther (particularly

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

the substantial benefits generated by maintain ing 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 Ha neda slots to benefit Japanese t ourists.

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

Northwest region deserves priority over Hawaiian’s propo sal 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 marke t is

even more heavily Japane se

- 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 o pportunities 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 evo lve 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 serv ice. 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

- to

point Japanese originating leisure traffic and Hawaiian can point to no valid reaso n 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 wint er 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 Tokyo

Seattle 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 E nvironment 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 1Travel 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 5Travel 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 MoreTravel 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 MoreTravel 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 MoreTravel 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

# C ERTIFICATE OF SERVICE

A copy of the foregoing document has been ser ved this 12 th 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