BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

---------------------------------------------------------------

:

In the Matter of :

:

2010 U.S.-HANEDA COMBINATION : Docket DOT-OST-2010-0018

SERVICE ALLOCATION PROCEEDING :

:

---------------------------------------------------------------

CONSOLIDATED REPLY OF

UNITED AIR LINES, INC.

Communications with respect to this document should be sent to:

Hershel I. Kamen

Senior Vice President-Alliances,

 Regulatory and Policy

Daniel A. Weiss

Managing Director-International

 Affairs and Regulatory

UNITED AIR LINES, INC.

77 West Wacker Drive-HDQIZ

10th Floor HDQIZ

Chicago, IL 60601

(312) 997-7573

hershel.kamen@united.com

dan.weiss@united.com

Steve Morrissey

Managing Director-Regulatory

 Affairs and Policy

UNITED AIR LINES, INC.

1225 New York Avenue, NW

Suite 1100-DCAIZ

Washington, DC 20005

(202) 521-4400

steve.morrissey@united.com

September 13, 2012

Thomas Newton Bolling

Vice President and Deputy General Counsel

Jonathan T. Linde

Managing Director and Senior Counsel-

 Regulatory

UNITED AIR LINES, INC.

77 West Wacker Drive

16th Floor HDQLD

Chicago, IL 60601

(312) 997-8068

thomas.bolling@united.com

jonathan.linde@united.com

Lorraine B. Halloway

Gerald F. Murphy

Steven J. Seiden

CROWELL & MORING LLP

1001 Pennsylvania Avenue, N.W.

Washington, DC 20004-2595

(202) 624-2500

lhalloway@crowell.com

gmurphy@crowell.com

sseiden@crowell.com

Counsel for

United Air Lines, Inc.
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

---------------------------------------------------------------

:

In the Matter of :

:

2010 U.S.-HANEDA COMBINATION : Docket DOT-OST-2010-0018

SERVICE ALLOCATION PROCEEDING :

:

---------------------------------------------------------------

CONSOLIDATED REPLY OF

UNITED AIR LINES, INC.

I. INTRODUCTION

The answers submitted by the other applicants underscore why United’s1application to 

provide new competitive service at Tokyo Haneda and to serve the large West Coast-Tokyo 

market at its San Francisco hub gateway should be selected under the Department’s public 

interest standards – which are based on providing the most benefits to the greatest number of 

consumers.

Members of the public who stand to reap the significant consumer benefits that would 

flow from United’s proposed San Francisco-Tokyo Haneda flights have urged the selection of 

United’s proposal in this proceeding. San Francisco International Airport and the United and 

Continental Master Executive Councils of the Air Line Pilots Association, International have 

submitted answers supporting United’s application. They join Democratic Leader Nancy Pelosi, 

other members of Congress, San Francisco Mayor Edwin Lee, and the San Francisco Chamber of 

Commerce, among other civic and business partners, in supporting United’s application. Exhibit 

 

1 Common names are used for airlines.
Consolidated Reply of United

Page 2

UA-R-119. All of these supporters recognize that United’s San Francisco-Tokyo Haneda 

proposal best meets the needs of the flying public and their communities.

None of the proposals submitted by the other applicants – all of which already have 

access to Tokyo Haneda – should be selected over United’s proposal to provide new entrant San 

Francisco-Tokyo Haneda service:

 Delta asks the Department to award Tokyo Haneda service to its non-hub at Seattle, a 

gateway that is nearly three times smaller than United’s San Francisco hub and which 

would depend almost exclusively on codeshare services operated by another airline for 

behind gateway connections. Delta’s proposal would mean that U.S. West Coast 

consumers are limited to only selecting Delta for U.S. carrier service to Tokyo Haneda,

as its aim is to prevent United from entering the market. Finally, the Department has 

already found Delta’s Seattle gateway to be inferior to United’s San Francisco gateway in 

the previous proceeding due to Seattle’s comparatively small size and limited connecting 

opportunities. Nothing has been presented in this year’s proceeding that would make the 

Department want to reverse its position on Seattle (Delta) versus San Francisco (United). 

 Hawaiian’s application to provide service in an island tourist market that would offer no 

connections to the U.S. mainland whatsoever does not compare with the significant 

public benefits offered by United’s proposal, especially since it would benefit virtually no 

U.S. consumers.

 American’s proposal to use these scarce Haneda slots to duplicate existing nonstop U.S. 

carrier service at an already well-served gateway cannot match the consumer benefits that 

would be provided by United’s San Francisco hub and should be rejected.

The Department’s public interest standards compel the selection of the proposal that 

would provide the most benefits to the greatest number of nonstop U.S.-Tokyo passengers and 

their communities. In evaluating which applicant should be authorized to serve which gateway, 

the Department should consider the carriers’ ability to flow traffic through their proposed 

gateways on their own connecting flights, the size of the local markets to be served, the carriers’

track records of instituting and maintaining service between U.S. gateways and Tokyo, and new 

competition for incumbent U.S. airlines that already offer nonstop service at Tokyo Haneda. 

Based on these criteria, United’s San Francisco-Tokyo Haneda proposal is the clear winner.
Consolidated Reply of United

Page 3

II. ANSWERS SUBMITTED BY THE OTHER APPLICANTS DEMONSTRATE 

WHY UNITED’S PROPOSAL SHOULD BE SELECTED

The arguments raised by each of the other applicants demonstrate why United’s San 

Francisco-Tokyo Haneda proposal should be selected.

A. Delta’s Proposal to Serve a Small U.S. Gateway With Few Online Connections, 

Making Delta the Only U.S. Carrier Allowed to Operate Between the West Coast 

and Haneda, Would Not Serve the Public Interest

Delta’s proposed Seattle-Tokyo Haneda service should be rejected here – just as it was 

in the initial Haneda slot proceeding – because there are larger gateways more deserving of the 

award for U.S. carrier service and market access deficiencies that need to be addressed. Indeed, 

the Department has already stated that Delta’s Seattle proposal offers a less compelling argument 

than United's San Francisco proposal: “we tentatively find that selection of Delta at Los Angeles 

would address greater service needs than selection of Delta's Seattle proposal, which we find far 

less compelling than Los Angeles in light of the strong Los Angeles local market, or United's 

San Francisco proposal.” Order 2010-5-7 at 11. Given that the Department previously selected 

Delta to serve the Los Angeles market, the next gateway to be selected in this proceeding based 

on size and consumer benefits is San Francisco, not Seattle. None of Delta’s attempts to distort 

facts, the Department’s precedent, and basic market principles, can hide the weaknesses of 

Delta’s proposal and its own position in the U.S.-Japan market. 

Not only is the San Francisco-Tokyo market nearly three times the size of the SeattleTokyo market (Exhibit UA-R-100), but United’s San Francisco-Haneda service will reach over 

600,000 more consumers than Delta at Seattle – even with Delta’s codesharing on Alaska. 

Exhibit UA-R-108 at 1. Excluding points that already connect to Delta’s existing Los AngelesHaneda service, that figure jumps to 1.5 million more consumers that would be reached by 

United’s proposed service. Id. at 2. Delta’s outsized reliance on Alaska-operated codeshare 
Consolidated Reply of United

Page 4

service to support its Seattle-Tokyo Haneda proposal also far exceeds the level of 

Alaska/Horizon-operated codeshare service that formed part of Delta’s Los Angeles-Tokyo 

Haneda proposal that was selected in the initial proceeding (86% versus 56%)2and was viewed 

by the Department as “augment[ing] the large Los Angeles-Tokyo local traffic base.” Order 

2010-5-7 at 9. The local Seattle-Tokyo market is also nearly five times smaller than the Los 

Angeles-Tokyo market (which already enjoys Delta nonstop service to Haneda) and nearly three 

times smaller than the San Francisco-Tokyo market. Exhibit UA-R-100. Additionally, because 

Delta cannot guarantee any level of Alaska-operated connecting services at Seattle over the long 

term since it does not control Alaska’s scheduling decisions, because the carriers cannot 

coordinate on pricing and inventory management, and because any Delta-ticketed customer 

bound for Tokyo could certainly displace a customer that Alaska may have ticketed for travel on 

its own network, the true incremental value of Delta’s connections is highly questionable. 

Delta’s claim of entitlement to the available Haneda slots because of the alleged “market 

dominance of the U.S.-Japan ATI alliances” (Answer of Delta at 3) simply does not withstand 

scrutiny. Delta itself has the largest capacity share (28.6%) of the West Coast-Tokyo market 

held by any carrier – and more than twice the share held by United (12.1%). Exhibit UA-R-106. 

In terms of interalliance competition, Delta and its immunized SkyTeam partner Korean also 

hold the largest capacity share of the West Coast-Tokyo market, including the share held by the 

immunized United/ANA alliance. Exhibit UA-R-107. While Delta correctly points out that the 

Department needs to “consider the ‘overall competitive environment’ and ‘market structure’” in 

 

2 Delta would only provide online connecting service to Haneda in four of the 28 

markets that it holds up as roundtrip connections to its proposed Seattle-Tokyo Haneda service, 

as compared to the 10 of 18 roundtrip connections that it claimed Alaska/Horizon would provide 

to Delta’s Haneda service at Los Angeles. Consolidated Answer of United at 5 (citing 

Application of Delta at 4; and Application of Delta dated Feb. 26, 2010 in this docket, Exhibits 

DL-126 to 129).
Consolidated Reply of United

Page 5

this proceeding (Answer of Delta at 5 (citing Order 2012-8-20)), it conveniently fails to mention

its already commanding presence on the West Coast and that the Department determined that its 

approval of the Star and oneworld applications in the recent U.S.-Japan Alliance Case would 

achieve a “balanced competitive inter-alliance dynamic in the U.S.-Japan market” and an 

“improved competitive balance in the U.S.-Asia market [that] would increase discipline versus 

SkyTeam.” Order 2010-10-4. Even Delta’s attempt to criticize United’s forthright disclosure 

with respect to its current year-round San Francisco-Tokyo Narita service in the event the 

Department selects United’s proposal belies Delta’s true competitive motivation for committing 

to maintain its existing Seattle-Tokyo Narita service alongside its proposed Seattle-Tokyo 

Haneda service: Delta “must maintain its Seattle-Narita hub schedule to provide connectivity to 

the rest of Asia.” Application of Delta at 6. This just calls into question the sustainability of 

Delta’s proposed Seattle-Tokyo Haneda service, in addition to the reasons discussed below.

In one of its more disingenuous claims, Delta asserts that “United and ANA have 

flexibility within their alliance to offer San Francisco-Haneda service at their discretion, but 

Seattle will only receive Haneda service if DOT approves Delta’s request.” Answer of Delta at 

9. As Delta knows, however, any pie chart depicting ANA and JAL’s total Tokya Haneda slot 

holdings (Answer of Delta, Exhibit DL-A-105) is meaningless. Regardless of the number of 

slots held by these Japanese carriers, each can only operate two slot pairs for service to the U.S. 

(see U.S.-Japan Memorandum of Understanding of October 25, 2010, Annex, Section 3), and 

United will continue to be the only U.S. carrier serving Japan that remains locked out of Haneda 

if the Department does not grant its application. Exhibit UA-R-101. In presuming that ANA 

would simply abandon the use of its own scarce Haneda slots in the two largest U.S.-Tokyo 

markets, Delta also asks the Department to ignore the valuable consumer benefits that it has 
Consolidated Reply of United

Page 6

already found to attach to ANA’s existing Haneda services at Los Angeles and Honolulu. See 

Order 2010-10-4 at 10; MIDT YE, July 2012; and Answer of Delta at 7. In “find[ing] no merit” 

in Northwest’s argument – similar to the one that its successor Delta proposes here with respect 

to ANA – that United should terminate its existing service and move its frequencies to another 

market that United had proposed to serve in a limited-entry route proceeding, the Department 

held that “[p]assengers are benefiting from that service, and we would not see it as advancing the 

public interest for United to deprive them of those benefits when we have an alternative available 

that would address a critical service need in the U.S.-China market.” Order 2007-2-10 at 8. 

Delta persists in twisting the Department’s well-established precedent on metal neutrality 

in immunized joint ventures (including those in which Delta is a member) to suit its misguided 

competition arguments. In this proceeding, Delta for the first time has taken the position that 

U.S. carrier growth is incompatible with metal neutrality in an immunized joint venture –

arguing that “United cannot have it both ways” in reference to a false choice between antitrust 

immunity and a carrier’s desire to serve a covered route with its own aircraft and crews. Answer 

of Delta at 9; see also Application of Delta at 8-9. While the Department views “[t]he intended 

commercial effects of [immunized alliance] agreements [as] similar to those resulting from a 

merger” (Answer of Delta at 8 (citing Order 2010-10-4 at 5), metal neutrality is not a zero sum 

game. Despite its statements to the contrary, Delta has publicly agreed with its own pilots that

immunized alliances “creat[e] new opportunities for American workers – including Delta flight 

crews” (Consolidated Reply of SkyTeam Applicants dated Nov. 27, 2007 in Docket DOT-OST2007-28644 at 3 (internal citations omitted)) and “generate[] additional flying for [Delta’s] pilots 

and more service choices for passengers” (Reply of Delta, Virgin Blue and Pacific Blue dated 

April 6, 2010 in Docket DOT-OST-2009-0155 at 1-2 (internal citations omitted)). Delta’s 
Consolidated Reply of United

Page 7

newly-discovered position is an attempt to block United from competing at Haneda, and nothing 

more. 

Nevertheless, the Department has repeatedly made clear that a U.S. carrier’s participation 

in an immunized metal neutral joint venture does not mean that: (1) the U.S. carrier partner has 

lost the right to seek additional service opportunities using its own aircraft and crews; or (2) 

seeking such opportunities is inconsistent with the metal neutrality or consumer benefits on 

which the grant of immunity was based. Among the Department’s consistent statements that fly 

in the face of Delta’s position are the following:

 “The Department has...found that [immunized] alliances increase capacity over the longterm and reduce fares due to, among other factors, the elimination of double 

marginalization – both of which are substantial public benefits.” Order 2011-6-9 at 4.

 “[The joint venture] pools resources to achieve substantial efficiencies and cost savings 

that will help...the participants manage cyclical changes in the industry to preserve 

existing services, with a view towards growing capacity and enhancing competition 

between carriers and alliances.” Order 2009-4-5 at 19.

 “[The Department] believe[s] that American, Continental, and United, like their partners, 

have the incentive to increase capacity if possible, which could provide more 

opportunities for pilots and other labor groups.” Order 2010-10-4 at 17; see also, e.g., 

2009-4-5 at 19.

 “[T]he Star applicants and oneworld applicants will likely face strong incentives to 

maintain or expand capacity in the Chicago-Tokyo market. Failure to do so could 

ultimately hamper the alliances’ abilities to efficiently route connecting traffic. While the 

airlines may be able to reap additional profit in the non-stop market by cutting capacity, 

these gains could come at the expense of profits on behind and beyond routes that are 

essential to a robust and functional alliance.” Order 2010-10-4 at 11.

 “[The Star carriers] should face a countervailing incentive to increase capacity – not only 

to facilitate connecting traffic within their network but also to capture a greater share of 

those local passengers that have, until now, opted to utilize competitors’ connecting 

itineraries.” Id. at 12.
Consolidated Reply of United

Page 8

Thus, United in this proceeding is proposing to do precisely what the Department has found, 

over and over again, to be decisive – which is to offer competitive new U.S. carrier service for its 

customers, clients, communities and coworkers. 

Additionally, Delta’s proposal should be rejected because there are serious questions 

about Delta’s ability to sustain its proposed Seattle-Tokyo Haneda service. Delta’s non-hub 

operations at Seattle are more than 14 times smaller than those at Delta’s Detroit hub (Exhibit 

UA-R-109), which failed to support Tokyo Haneda service despite Delta’s claim that it was “the 

largest and most effective U.S. airline hub for service to Asia [with] nonstop-to-nonstop Haneda 

service to 106 U.S. points.” Application of Delta dated Feb. 26, 2010 in this docket, at 4. 

Delta’s Seattle-Tokyo Narita load factors also underperform as compared to Delta’s Narita 

service at both Detroit, where it has a hub, and Los Angeles, where it offers some connecting 

services. Exhibit UA-R-112. Delta failed to use these valuable Tokyo Haneda slots for less than

half of the 20-month period during which it was supposed to be providing Haneda service at 

Detroit.3 Exhibit UA-R-110. Adding to this is the fact that Delta has provided only 40% of the 

capacity it promised with both its Detroit-Haneda and Los Angeles-Haneda services (by 

downgauging from B-747 to A-330 aircraft) (Exhibits UA-R-110 and UA-R-111). Indeed, the 

benefits of Delta’s purported B-747 service at Detroit and Los Angeles were a key factor in the 

 

3 United has nothing but the utmost sympathy for Japan for having to cope with last 

year’s tragic earthquake and related developments, but given recently-announced new services 

between the U.S. and Japan, along with the interest shown in the Tokyo Haneda opportunity 

available in this proceeding, the market has clearly rebounded. Yet Delta still has not made good 

on its lauded B-747 capacity commitments for either of its Tokyo Haneda routes, or on its 

promise to provide consistent, daily service in the Detroit-Tokyo Haneda market. Exhibits UAR-110 and UA-R-111; see also Order 2010-5-7 at 10. By contrast, in seeking to extend the 

startup date for its San Francisco-Guangzhou service “United [maintained that it] would not 

oppose another carrier seeking reallocation of these frequencies to implement its own nonstop 

service between the U.S. mainland and Guangzhou.” Motion of United dated June 14, 2011 in 

Docket DOT-OST-2007-28567, at 1.
Consolidated Reply of United

Page 9

Department’s selection of those proposed gateways in the initial proceeding. See Order 2010-5-7 

at 10. 

B. With Virtually No Benefit to U.S. Consumers and No Connections to the U.S. 

Mainland, Hawaiian’s Proposal Should be Rejected Out of Hand

In the nearly 200 pages comprising its answer in this proceeding, Hawaiian cannot 

manage to overcome the inherent flaws of its Kona-Tokyo Haneda proposal. At nearly three 

times smaller than the San Francisco-Tokyo market and with no connections to the U.S. 

mainland, the Kona-Tokyo market also consists of less than 3% local passengers. Consolidated 

Answer of United, Exhibits UA-A-116 and UA-A-117; see also Application of Hawaiian, 

Exhibit HA-App2012-2. Thus, Hawaiian’s proposal will benefit virtually no U.S. consumers. 

This stands in stark contrast to the Department’s selection of Hawaiian’s Honolulu-Tokyo 

Haneda proposal in the initial proceeding: “given that Honolulu represents the largest overall 

U.S.-Tokyo market, [the Department found] that the large local traffic base should make 

Hawaiian’s proposal viable and sustainable” notwithstanding its reliance on “Japan-originating 

leisure traffic” and “minimal connecting opportunities.” Order 2010-5-7 at 9. Despite 

Hawaiian’s best efforts to conflate the two, at less than 7% of the Hawaii-Tokyo market, Kona is 

not Honolulu (much less the entire state of Hawaii). Exhibit UA-R-115; see also Answer of 

Hawaiian at 7-9. Nor does the fact that “Tokyo-Kona has no nonstop service [make it] the most 

underserved market in this proceeding.” Answer of Hawaiian at 4. Hawaiian, or any other U.S. 

or Japanese carrier for that matter, is free to offer service in the open skies Kona-Tokyo Narita 

market. Indeed, JAL offered Tokyo Narita-Kona service for many years, but finally dropped it 

in October 2011 after it was unable to sustain its operation in the market. Exhibit UA-R-113. 

Hawaiian strongly argues that its proposal to operate the largest aircraft at issue in this 

proceeding requires that it be selected. Answer of Hawaiian, Exhibits HA-2012A-108 and HA-
Consolidated Reply of United

Page 10

2012A109. What Hawaiian fails to calculate is that the largest aircraft, combined with the 

smallest proposed gateway, means lots of empty seats. Even assuming Hawaiian were to capture 

100% of the local O&D market, the load factor on Hawaiian’s Kona-Tokyo Haneda flights 

would be less than 42%. Exhibit UA-R-114. 

Hawaiian makes the same type of erroneous argument as Delta when it comes to the 

Haneda slots held by Japanese carriers. Even if it were the case that “Japanese carriers are able 

to exercise some degree of control over the slots allocated to their alliance partners” (Answer of 

Hawaiian at 17), United remains the only U.S. carrier serving Japan that does not have access to 

Haneda with its own aircraft and crews. The Department chose to allocate one daily pair of 

Haneda slots to American, which has an immunized Japanese alliance partner, in the initial 

proceeding (see Order 2010-7-2), and Hawaiian fails to explain why United should not receive 

equal treatment.

C. American’s Proposal Would Unnecessarily Duplicate Delta’s Existing Haneda 

Service at Los Angeles and Pales in Comparison to United at San Francisco

American has simply not made the case for the Department to allocate a second valuable 

pair of daily Tokyo Haneda slots for service that would duplicate Delta’s existing service at Los 

Angeles. While it may be the largest West Coast-Tokyo market, Los Angeles already has more 

than adequate service to Tokyo – with nearly twice as many (67) nonstop weekly frequencies. 

Exhibit UA-R-116. Granting American’s application would perpetuate this imbalance while 

leaving the second largest West Coast-Tokyo gateway without nonstop U.S. carrier service and 

United without the ability to operate to Haneda with its own aircraft and crews for the 

foreseeable future. 

American’s argument that its Los Angeles-Haneda proposal must be selected over United 

at San Francisco “[i]n the interest of competitive balance among the three global alliances” also 
Consolidated Reply of United

Page 11

rings hollow. As discussed below, American also has a history of reducing Tokyo Narita 

capacity when awarded slots at Tokyo Haneda. But if American was really concerned about 

maintaining competitive service levels it wouldn’t be cutting flights in favor of Tokyo Haneda 

service and would be willing to make a commitment as to the future of its existing Los AngelesTokyo Narita flight. See Application of American at 9. Contrary to American’s assertion, the 

Department has recently concluded that the immunized oneworld alliance has a “sufficient stake 

[in the U.S.-Japan market] to exert competitive pressure on SkyTeam and Star” and that a 

“balanced competitive dynamic for the three alliances [exists in the] nonstop [U.S.-Japan] 

market.” Order 2010-10-4 at 8. Yet, American is seeking a second pair of daily Haneda slots 

while trying to justify keeping Star without U.S. carrier access to Haneda. Moreover, United at 

its San Francisco hub would offer 31 roundtrip connections to its proposed Haneda service, as 

compared to American’s 23 connections at Los Angeles. Consolidated Answer of United, 

Exhibit UA-A-123. 

The valuable slots dedicated to American’s Haneda service at New York/JFK sat unused 

for more than half of the 20 months during which American was required to operate them.4 

Exhibit UA-R-118. American also completely discontinued its New York/JFK-Tokyo Narita 

service in 2012 shortly after recommencing the New York/JFK-Tokyo Haneda service for which 

it was connected in the initial proceeding. Exhibit UA-R-117. The Department should not risk 

further underutilization of these scarce Haneda slots with another award to American, 

particularly in light of its precedents in limited-entry route proceedings disfavoring duplicative 

service proposals (see, e.g., Orders 2009-3-14; 2007-9-25; and 2007-2-10) and “enhanc[ing] 

 

4

See supra note 3.
Consolidated Reply of United

Page 12

competition by creating opportunities for new entrant carriers to gain market access.” Order 

2009-3-14 (citing Orders 2008-3-4 and 2007-9-25).

III. THE UNITED PROPOSAL BEST MEETS THE PUBLIC INTEREST CRITERIA 

FOR SELECTION

For all the reasons stated in this Consolidated Reply and in United’s Application and 

Consolidated Answer, the Department should select United’s proposal to serve the second largest 

West Coast-Tokyo market at its hub at San Francisco International Airport to maximize the 

public benefits available from the allocation of two pairs of Tokyo Haneda slots. United’s 

proposed flights will provide additional capacity and greater convenience for the large business 

communities in both San Francisco and Tokyo, the large Japanese and Asian populations in the 

San Francisco region, the large American community in Tokyo and travelers through United’s 

San Francisco hub network. See Application of United, Exhibits UA-106, 107 and 108. 

United’s proposed San Francisco-Tokyo Haneda service will also provide increased competition 

in the U.S.-Japan market by adding a fourth U.S. carrier at Haneda, by introducing new carrier 

competition for beyond points across the Western part of the U.S. that already have connecting 

service via Los Angeles, and by making daily nonstop U.S. carrier Tokyo Haneda service 

available in each of the two largest West-Coast Tokyo markets.


Docket DOT-OST-2010-0018

Haneda Service

Before The

Department Of Transportation

2012 U.S. – Tokyo Haneda Combination Services Allocation 

Proceeding Docket DOT-OST-2010-0018

Nonstop San Francisco – Tokyo Haneda

Reply Exhibits of:
Docket DOT-OST-2010-0018

Haneda Service

Index of Exhibits

Page 1 of 2

United Index Of Reply Exhibits

Exhibit

Number Tokyo - Haneda Service 

Number

Of Pages

UA-R-100 San Francisco Is The Second Largest West Coast -

Tokyo Market

1

UA-R-101 United Is Not Currently Permitted To Operate At Tokyo 

Haneda

1

UA-R-102 California Exports Have Grown 15.1% Between 2009 

And 2011, And Total Over $159 Billion

1

UA-R-103 California Exports To Japan Have Grown 9.6% Between 

2009 And 2011, And Total Over $13 Billion

1

UA-R-104 Japan Is California’s Second Largest Export Market In 

Asia

1

UA-R-105 The San Francisco Area Is Home To 31 Fortune 500 

Companies, The Most Out Of Any Gateway Competing In 

This Proceeding

2

UA-R-106 Delta Holds The Highest West Coast - Tokyo Capacity 

Share Of Any Carrier

1

UA-R-107 Delta And Its SkyTeam Immunized Partner Korean Hold 

The Highest West Coast - Tokyo Capacity Share

1

UA-R-108 United’s San Francisco -Tokyo Haneda Proposal Will 

Reach More Consumers Than Delta At Seattle Even With 

Delta’s Codesharing On Alaska Airlines

2

UA-R-109 Delta’s Seattle Operations Are Over 14 Times Smaller 

Than Delta’s Detroit Hub, Which Failed To Support Tokyo 

Haneda Service, Despite Delta Claiming Detroit As The 

Largest And Most Effective Airline Hub For Services To 

Asia

1

UA-R-110 Delta Did Not Meet Its Service Commitment Regarding 

Detroit - Tokyo Haneda Capacity

2

UA-R-111 Delta Did Not Meet Its Service Commitment Regarding 

Los Angeles - Tokyo Haneda Capacity

1
Docket DOT-OST-2010-0018

Haneda Service

Index of Exhibits

Page 2 of 2

United Index Of Reply Exhibits

Exhibit

Number Tokyo - Haneda Service 

Number

Of Pages

UA-R-112 Delta’s Seattle - Tokyo Narita Load Factor Underperforms 

Compared To Detroit - Tokyo Narita, Where Delta Has A 

Hub, And Compared To Los Angeles - Tokyo Narita 

Where Delta Operates Some Connecting Services

1

UA-R-113 Nonstop Service Between Kona and Tokyo Has Proven 

Unsuccessful

1

UA-R-114 Hawaiian’s Large Aircraft Size Is Unwarranted For The 

Small Kona - Tokyo Market Which Will Not Even Fill 50% 

Of Hawaiian’s Plane

1

UA-R-115 Hawaiian’s Proposed Gateway Of Kona Represents Less 

Than Seven Percent Of The State’s Traffic To/From 

Tokyo

1

UA-R-116 The Los Angeles - Tokyo Market Already Has More 

Service Than The San Francisco - Tokyo Market

1

UA-R-117 American Has A History Of Reducing Service When 

Awarded A Tokyo Haneda Slot Pair

1

UA-R-118 American Did Not Meet Its Service Commitment 

Regarding New York / JFK - Tokyo Haneda Capacity

1

UA-R-119 Letters Of Support 14
Docket DOT-OST-2010-0018

Haneda Service

UA-R-100

Page 1 of 1

San Francisco Is The Second Largest West Coast - Tokyo Market 

Source: MIDT YE July 2012

Note: Tokyo = Tokyo Haneda + Tokyo Narita

West Coast Tokyo

Point Passengers

Los Angeles 493,366

San Francisco 230,918

Seattle 85,386

San Diego 37,078

Portland 35,610
Docket DOT-OST-2010-0018

Haneda Service

UA-R-101

Page 1 of 1

United Is Not Currently Permitted To Operate At Tokyo Haneda

Source: August 2012 OAG

1/ Seven frequencies currently operated by Delta are at issue in this proceeding

U.S. Carrier Tokyo Haneda Weekly 

Frequencies

Delta 1/ 14

American 7

Hawaiian 7

United 0

14

7 7

0

0

2

4

6

8

10

12

14

16

Delta 1/ American Hawaiian United

Tokyo Haneda Weekly Frequencies
Docket DOT-OST-2010-0018

Haneda Service

UA-R-102

Page 1 of 1

California Exports Have Grown 15.1% Between 2009 And 2011, And 

Total Over $159 Billion 

Source: U.S. Census Data

California Exports ($MM) 

$120,080

$143,192

$159,122

$0

$20,000

$40,000

$60,000

$80,000

$100,000

$120,000

$140,000

$160,000

$180,000

2009 2010 2011

California Exports ($MM) 

2009 $120,080

2011 $159,122

Growth 15.1%
Docket DOT-OST-2010-0018

Haneda Service

UA-R-103

Page 1 of 1

California Exports To Japan Have Grown 9.6% Between 2009 And 2011, 

And Total Over $13 Billion 

Source: U.S. Census Data

California Exports To Japan ($MM) 

California Exports To Japan 

($MM) 

2009 $10,902

2011 $13,096

Growth 9.6%

$10,902

$12,180

$13,096

$0

$2,000

$4,000

$6,000

$8,000

$10,000

$12,000

$14,000

2009 2010 2011
Docket DOT-OST-2010-0018

Haneda Service

UA-R-104

Page 1 of 1

Source: U.S. Census Data

Japan Is California’s Second Largest Export Market In Asia

Top California Export Markets In Asia ($MM) - 2011

$14,188

$13,096

$8,426

$7,664

$6,245

$4,139

$0

$2,000

$4,000

$6,000

$8,000

$10,000

$12,000

$14,000

$16,000

China Japan South Korea Hong Kong Taiwan Singapore
Docket DOT-OST-2010-0018

Haneda Service

UA-R-105

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The San Francisco Area Is Home To 31 Fortune 500 Companies, 

The Most Out Of Any Gateway Competing In This Proceeding

Source: Fortune Magazine
Docket DOT-OST-2010-0018

Haneda Service

UA-R-105

Page 2 of 2

The San Francisco Area Is Home To 31 Fortune 500 Companies, 

The Most Out Of Any Gateway Competing In This Proceeding

Source: Fortune Magazine

31

14

8

0

0

5

10

15

20

25

30

35

San Francisco Los Angeles Seattle Kona

Count Of Fortune 500 Companies
Docket DOT-OST-2010-0018

Haneda Service

UA-R-106

Page 1 of 1

Delta Holds The Highest West Coast - Tokyo Capacity Share Of Any 

Carrier 

Source: August 2012 OAG

Note: Delta currently operates 35 weekly West Coast - Tokyo Frequencies

Note: Other includes American, JAL, Singapore Airlines and Malaysian Airlines 

Rebuttal To DL-A-101

DL-A-104

DL-A-105

DL-A-201

DL-A-202

West Coast – Tokyo 

Weekly Seat Share

Los Angeles

San Francisco

Portland

Seattle

Current Delta West Coast Tokyo Gateways

Rank Carrier Share

1 Delta 28.6%

2 ANA 21.0%

4 United 12.1%

6 Korean 5.9%

Other 32.4%

Total 100.0%
Docket DOT-OST-2010-0018

Haneda Service

UA-R-107

Page 1 of 1

Delta And Its SkyTeam Immunized Partner Korean Hold The Highest 

West Coast - Tokyo Capacity Share

Source: August 2012 OAG

Note: Delta currently operates 35 weekly West Coast - Tokyo frequencies

Note: Other includes American, JAL, Singapore Airlines and Malaysian Airlines

Note: Neither United nor ANA hold antitrust immunity with Singapore Airlines

West Coast – Tokyo 

Weekly Seat Share

Current Delta West Coast Tokyo Gateways

Los Angeles

San Francisco

Portland

Seattle

Rebuttal To DL-A-101

DL-A-104

DL-A-105

DL-A-201

DL-A-202

Carrier Share

Delta + Korean 34.5%

United + ANA 33.1%

Other 32.4%

Total 100.0%
Docket DOT-OST-2010-0018

Haneda Service

UA-R-108

Page 1 of 2

United’s San Francisco - Tokyo Haneda Proposal Will Reach More 

Consumers Than Delta At Seattle Even With Delta’s Codesharing On 

Alaska Airlines

Source: MIDT YE July 2012, Tokyo Haneda applications

Note: Roundtrip U.S. connections

Point Market Size Point Market Size

San Francisco 230,918 Seattle 85,386

Boise 3,803

Boston 66,459 Atlanta 40,347

Burbank 123 Detroit 43,529

Chicago 95,905 Minneapolis/St. Paul 24,265

Chico 121 Salt Lake City 19,598

Cleveland 7,292

Dallas/Ft. Worth 43,902

Denver 18,630 Anchorage 4,262

Eugene 1,069 Bellingham 103

Eureka 91 Boise 3,803

Fresno 1,224 Bozeman 963

Houston 42,380 Burbank 123

Las Vegas 97,448 Juneau 126

Los Angeles 493,366 Kalispell 150

Medford 420 Ketchikan 56

Modesto 65 Las Vegas 97,448

Monterey 721 Los Angeles 493,366

New York / JFK & Liberty 378,278 Medford 420

Ontario 304 Missoula 297

Orange County 1,282 Oakland 451

Phoenix 21,153 Orange County 1,282

Portland 35,610 Pasco 764

Redding 366 Phoenix 21,153

Redmond 383 Portland 35,610

Reno 1,851 Pullman 99

Sacramento 3,597 Sacramento 3,597

San Diego 37,078 San Diego 37,078

San Luis Obispo 262 San Francisco 230,918

Santa Barbara 1,067 San Jose 4,420

Seattle 85,386 Spokane 1,455

Washington / Dulles 89,294 Walla Walla 51

Delta Only Catchment Area 213,125

Total 1,759,848 Delta + Alaska Catchment Area 1,151,120

Delta Online Connections

Connections Operated By Alaska

United's Proposed Catchment Area Delta's Proposed Catchment Area

Rebuttal To DL-A-101

Comparison Including Delta Points That Also Connect At Los Angeles 
Docket DOT-OST-2010-0018

Haneda Service

UA-R-108

Page 2 of 2

United’s San Francisco - Tokyo Haneda Proposal Will Reach More 

Consumers Than Delta At Seattle Even With Delta’s Codesharing On 

Alaska Airlines

Source: MIDT YE July 2012, Tokyo Haneda applications

Note: Roundtrip U.S. connections

Comparison Excluding Delta Points That Also Connect At Los Angeles 

Point Market Size Point Market Size

San Francisco 230,918 Seattle 85,386

Boise 3,803

Boston 66,459

Burbank 123 None 0

Chicago 95,905

Chico 121

Cleveland 7,292

Dallas/Ft. Worth 43,902

Denver 18,630 Anchorage 4,262

Eugene 1,069 Bellingham 103

Eureka 91 Boise 3,803

Fresno 1,224 Bozeman 963

Houston 42,380 Burbank 123

Las Vegas 97,448 Juneau 126

Los Angeles 493,366 Kalispell 150

Medford 420 Ketchikan 56

Modesto 65 Medford 420

Monterey 721 Missoula 297

New York / JFK & Liberty 378,278 Orange County 1,282

Ontario 304 Pasco 764

Orange County 1,282 Pullman 99

Phoenix 21,153 Spokane 1,455

Portland 35,610 Walla Walla 51

Redding 366

Redmond 383

Reno 1,851

Sacramento 3,597

San Diego 37,078

San Luis Obispo 262

Santa Barbara 1,067

Seattle 85,386

Washington / Dulles 89,294

Delta Only Catchment Area 85,386

Total 1,759,848 Delta + Alaska Catchment Area 99,340

United's Proposed Catchment Area Delta's Proposed Catchment Area

Delta Online Connections

Connections Operated By Alaska

Rebuttal To DL-A-101
Docket DOT-OST-2010-0018

Haneda Service

UA-R-109

Delta’s Seattle Operations Are Over 14 Times Smaller Than Delta’s Page 1 of 1

Detroit Hub, Which Failed To Support Tokyo Haneda Service, Despite 

Delta Claiming Detroit As The Largest And Most Effective Airline Hub 

For Services To Asia

Source: August 2012 OAG. Delta 2010 Tokyo Haneda application, page 4

Total Weekly Departures

239

3,395

0

500

1,000

1,500

2,000

2,500

3,000

3,500

4,000

Delta @ SEA Delta @ DTW

Delta’s Operations

At SEA Are 14.2 Times

Smaller Than Delta’s

DTW Hub

“Delta’s Detroit hub is the largest and most effective U.S. 

airline hub for service to Asia, and will provide nonstop-tononstop Haneda service for 106 U.S. points.”

Delta 2010 Tokyo Haneda Application:

Rebuttal To DL-A-102
Docket DOT-OST-2010-0018

Haneda Service

UA-R-110

Page 1 of 2

Delta Did Not Meet Its Service Commitment Regarding Detroit - Tokyo 

Haneda Capacity

Rebuttal To DL-A-204

“Delta is proposing its largest aircraft – the Boeing 

747-400 for Detroit. The 403 seat capacity of the 

747 will help to maximize the value of the scarce 

Haneda slots that are available to U.S. carriers.”

Delta 2010 Tokyo Haneda Application:

Source: August 2012 OAG. Delta 2010 Tokyo Haneda application, page 4

1/ Figures assume daily, year round service, which Delta has failed to operate 

2/ Of all nine months Delta has operated DTWHND, for only two months did Delta meet 

its commitment to operate 747-400 aircraft Aircaft Type 2/ 747-400 Aircraft Type A330

Aircraft Seats 403 Aircraft Seats 243

Daily Round Trip Seats 806 Daily Round Trip Seats 486

Annual Round Trip Seats 294,190 Annual Round Trip Seats 177,390

DL Capacity Promised For DTWHND 1/ DL Actual Capacity Offered For DTWHND 1/

Delta Is Providing 40%

Less Capacity Than It Promised
Docket DOT-OST-2010-0018

Haneda Service

UA-R-110

Page 2 of 2

Source: OAG

Year/Month Weekly Frequencies

2011-02 7

2011-03 7

2011-04 None

2011-05 None

2011-06 7

2011-07 7

2011-08 7

2011-09 None

2011-10 None

2011-11 None

2011-12 None

2012-01 None

2012-02 None

2012-03 None

2012-04 None

2012-05 7

2012-06 7

2012-07 7

2012-08 7

Delta's Operational History For DTW-HND

Rebuttal To DL-A-204

Delta Did Not Meet Its Service Commitment Regarding Detroit - Tokyo 

Haneda Capacity
Docket DOT-OST-2010-0018

Haneda Service

UA-R-111

Page 1 of 1

Delta 2010 Tokyo Haneda Application:

Source: August 2012 OAG. Delta 2010 Tokyo Haneda application, page 5 

1/ Of all 17 months Delta has operated LAXHND, for only two months did Delta meet its 

commitment to operate 747-400 aircraft

Delta Is Providing 40%

Less Capacity Than It Promised

“Delta will use large capacity 747-

400 aircraft for maximizing service, competitive, 

and public interest benefits.”

Aircaft Type 1/ 747-400 Aircraft Type A330

Aircraft Seats 403 Aircraft Seats 243

Daily Round Trip Seats 806 Daily Round Trip Seats 486

Annual Round Trip Seats 294,190 Annual Round Trip Seats 177,390

DL Capacity Promised For LAXHND DL Actual Capacity Offered For LAXHND

Rebuttal To DL-A-204

Delta Did Not Meet Its Service Commitment Regarding Los Angeles -

Tokyo Haneda Capacity
Docket DOT-OST-2010-0018

Haneda Service

UA-R-112

Delta’s Seattle Page 1 of 1 - Tokyo Narita Load Factor Underperforms Compared To 

Detroit - Tokyo Narita, Where Delta Has A Hub, And Compared To Los 

Angeles - Tokyo Narita Where Delta Operates Some Connecting 

Services 

Source: Superset data, full year 2011

Rebuttal To DL-A-102

DL-A-103

89%

87%

81%

76%

78%

80%

82%

84%

86%

88%

90%

Los Angeles Detroit Seattle

FY 2011 Tokyo Narita Load Factor
Docket DOT-OST-2010-0018

Haneda Service

UA-R-113

Page 1 of 1

Nonstop Service Between Kona And Tokyo Has Proven Unsuccessful

Rebuttal To HA-2012A-201 to 207

Source: OAG

Note: JAL used to operate nonstop NRT to KOA, with return service via HNL. JAL service 

began prior to November 2009

Year/Month Weekly Frequencies

2009-11 7

2009-12 7

2010-01 7

2010-02 7

2010-03 7

2010-04 7

2010-05 7

2010-06 7

2010-07 7

2010-08 7

2010-09 7

2010-10 7

JAL's Now Defunct Tokyo - Kona Service

Stop
Docket DOT-OST-2010-0018

Haneda Service

UA-R-114

Page 1 of 1

Hawaiian’s Large Aircraft Size Is Unwarranted For The Small Kona -

Tokyo Market Which Will Not Even Fill 50% Of Hawaiian’s Plane

Rebuttal To HA-2012A-108

HA-2012A-109

HA-2012A-902

Source: MIDT YE July 2012. Hawaiian 2012 Tokyo Haneda application

Note: Tokyo = Tokyo Haneda + Tokyo Narita

1/ Calculated as 89,530 annual demand / 365 days / 2 for each direction

2/ Assumes, generously, that Hawaiian will capture 100% of the local O&D market

Aircraft Type A330

Aircraft Seats 294

Kona - Tokyo Market Size Per Day Each Way 1/ 123

Estimated Hawaiian Load Factor 2/ 42%

Estimated Empty Seats On Hawaiian' Aircraft 171

Estimated % Of Empty Seats On Hawaiian's Aircraft 58%

Hawaiian's Proposal
Docket DOT-OST-2010-0018

Haneda Service

UA-R-115

Page 1 of 1

Hawaiian’s Proposed Gateway Of Kona Represents Less Than Seven 

Percent Of The State’s Traffic To/From Tokyo

Rebuttal To HA-2012A-301 to 321

Source: MIDT YE July 2012. Hawaiian 2012 Tokyo Haneda application

Note: Tokyo = Tokyo Haneda + Tokyo Narita Hawaii - Tokyo Market Size 1,324,153

Kona - Tokyo Market Size 89,530

Kona Share Of State Total 6.8%

Hawaii - Tokyo Statistics
Docket DOT-OST-2010-0018

Haneda Service

UA-R-116

Page 1 of 1

The Los Angeles - Tokyo Market Already Has More Service Than The 

San Francisco - Tokyo Market

Source: August 2012 OAG

Count = Number of distinct airlines operating 

Rebuttal To AA-Pleading, Page 1

San Francisco – Tokyo Service

Los Angeles

San Francisco

Los Angeles – Tokyo Service

Airline Count Weekly Frequencies

4 35

Airline Count Weekly Frequencies

8 67
Docket DOT-OST-2010-0018

Haneda Service

UA-R-117

Page 1 of 1

American Has A History Of Reducing Service When Awarded A Tokyo 

Haneda Slot Pair

Rebuttal To AA-R-106

AA-R-108

Source: OAG

Year - Month JFK-HND JFK-NRT

2012-01 7

2012-02 7

2012-03 7

2012-04 7

2012-05 7

2012-06 7 Stop

2012-07 7

2012-08 7

2012-09 7

2012-10 7

2012-11 7

2012-12 7

2013-01 7

2013-02 7

2013-03 7

American's New York / JFK - Tokyo Service
Docket DOT-OST-2010-0018

Haneda Service

UA-R-118

Page 1 of 1

Rebuttal To AA-Pleading, Page 1

Source: OAG

Year/Month Weekly Frequencies

2011-02 7

2011-03 7

2011-04 None

2011-05 None

2011-06 None

2011-07 7

2011-08 7

2011-09 None

2011-10 None

2011-11 None

2011-12 None

2012-01 None

2012-02 None

2012-03 None

2012-04 None

2012-05 None

2012-06 7

2012-07 7

2012-08 7

American's Operational History For JFK-HND

American Did Not Meet Its Service Commitment Regarding New York / 

JFK- Tokyo Haneda Capacity
Docket DOT-OST-2010-0018

Haneda Service

Letters Of Support

UA-R-119

Page 1 of 14 

United provides letters of support for daily, nonstop 

service between San Francisco and Tokyo Haneda 

from various Members of Congress, civic leaders 

and customers
Docket DOT-OST-2010-0018

Haneda Service

Letters Of Support

UA-R-119

Page 2 of 14 
Docket DOT-OST-2010-0018

Haneda Service

Letters Of Support

UA-R-119

Page 3 of 14 
Docket DOT-OST-2010-0018

Haneda Service

Letters Of Support

UA-R-119

Page 4 of 14
Docket DOT-OST-2010-0018

Haneda Service

Letters Of Support

UA-R-119

Page 5 of 14 
Docket DOT-OST-2010-0018

Haneda Service

Letters Of Support

UA-R-119

Page 6 of 14 
Docket DOT-OST-2010-0018

Haneda Service

Letters Of Support

UA-R-119

Page 7 of 14 
Docket DOT-OST-2010-0018

Haneda Service

Letters Of Support

UA-R-119

Page 8 of 14 
Docket DOT-OST-2010-0018

Haneda Service

Letters Of Support

UA-R-119

Page 9 of 14 
Docket DOT-OST-2010-0018

Haneda Service

Letters Of Support

UA-R-119

Page 10 of 14
Docket DOT-OST-2010-0018

Haneda Service

Letters Of Support

UA-R-119

Page 11 of 14 
Docket DOT-OST-2010-0018

Haneda Service

Letters Of Support

UA-R-119

Page 12 of 14 
Docket DOT-OST-2010-0018

Haneda Service

Letters Of Support

UA-R-119

Page 13 of 14 
Docket DOT-OST-2010-0018

Haneda Service

Letters Of Support

UA-R-119

Page 14 of 14