BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Motion and Application of

AMERICAN AIRLINES, INC.

Motion of 

HAWAIIAN AIRLINES, INC.

in the matter of 2010 U.S.–Haneda 

Combination Services Allocation Proceeding

Docket DOT-OST-2010-0018

APPLICATION OF AMERICAN AIRLINES, INC.

Howard Kass 

Vice President – Regulatory Affairs

Robert A. Wirick

Managing Director, Regulatory and 

International Affairs

Abigail Donovan

Director, Congressional and Federal 

Affairs

American Airlines, Inc.

1101 17th Street, N.W.

Washington, DC 20036

(202) 326.5153

howard.kass@aa.com

robert.wirick@aa.com

abigail.donovan@aa.com

Charles A. Hunnicutt

Patricia N. Snyder

Jason D. Tutrone

Thompson Hine LLP

1919 M Street, NW

Suite 700

Washington, DC 20036-1600

(202) 263.4189

charles.hunnicutt@thompsonhine.com

patricia.snyder@thompsonhine.com

jason.tutrone@thompsonhine.com

January 5, 2015
TABLE OF CONTENTS

I. Adding Service to Haneda is Critical to American’s International Strategy..............2

II. American’s Proposed Los Angeles-Haneda Service............................................4

III. American’s Proposal Will Best Serve the Public Interest......................................5

A. Delta’s Current Use of a U.S.-Haneda Slot Pair for Seattle-Haneda 

 Does Not Maximize the Public Benefits.....................................................6

B. Delta’s Self-Serving Retention of a Haneda Slot Pair, Which it is Woefully

 Underusing, is Thwarting Department Goals of Increasing Consumer Choice

 and Competition Among Carriers.............................................................10

C. American Will Make Full and Effective Use of the U.S.-Haneda Slot Pair............11

Attachment 1: American’s Responses to DOT Information Requests
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Motion and Application of

AMERICAN AIRLINES, INC.

Motion of 

HAWAIIAN AIRLINES, INC.

in the matter of 2010 U.S.–Haneda 

Combination Services Allocation Proceeding

Docket DOT-OST-2010-0018

APPLICATION OF AMERICAN AIRLINES, INC.

On October 2, 2014, American Airlines, Inc. (“American”) filed a Motion before 

the Department seeking review of the usage of one U.S.-Haneda slot pair by Delta Air 

Lines, Inc. (“Delta”) on the Seattle-Tokyo (Haneda) route allocated by Order 2013-2-4. 

The Department agreed that a review was warranted and instituted this proceeding to 

determine “the disposition of the U.S.-Haneda slot pair currently allocated to Delta . . . 

for services between Seattle, Washington and Tokyo’s Haneda Airport.”1 Because the 

U.S.-Japan bilateral limits U.S.-Haneda service by U.S. carriers to only four slot pairs, 

this proceeding is essential to protecting the public interest. As the Department stated: 

“The principal objective in this proceeding will be to maximize public benefits with this 

scarce resource.”2 Maximizing public benefits means greater travel options, more

choices for consumers, and increased competition among airlines and alliances.

 

1 U.S.-Haneda Combination Services Allocation, Order 2014-12-9 slip op. at 1 (Dep’t of Transp. Dec. 15, 

2014).

2

 Id. at 5.
Application of American Airlines, Inc.

Page 2 of 12

American hereby submits this application for one slot pair to be used in the Los 

Angeles-Haneda market pursuant to 49 U.S.C. § 40109, 14 C.F.R. Part 302, subpart C of 

the Department’s regulations, and Order 2014-12-9. Our service proposal provides:

 Year-round daily service in the largest U.S.-Tokyo market, Los AngelesHaneda.

 Convenient connections in both directions to 25 markets at Los Angeles, 

American’s West Coast gateway, in the Summer season and to 32 connections 

in both directions in the Winter season – more than any other Los AngelesHaneda carrier.

 Boeing 777-200 equipment with 247 seats: 16 First Class, 37 Business Class, 

and 194 Economy; planned 2015 configurations will increase seats to 260.3

 Significant addition of cargo capacity to this important Asian market.

 Commencement within 60 days of issuance of a Final Order by the 

Department.

To achieve the benefits described in this Application, the Department should reallocate to 

American the U.S.-Haneda slot pair currently used by Delta for Seattle-Haneda service to

allow American to offer its proposed Los Angeles-Haneda service. 

I. Adding Service to Haneda Is Critical to American’s International Strategy

American’s top international priority is building its Asian presence, which will 

allow it to compete more effectively in that region. As American’s President, Scott 

Kirby, and Senior Vice President and Chief Marketing Officer, Andrew Nocella, testify

in Exhibits AA-T-1 and AA-T-2, gaining access to Tokyo Haneda is a cornerstone of that 

strategy. By achieving Haneda service, American will be able to provide greater network 

 

3

Ex. AA-T-1; also, Ex. AA-103. American is currently reconfiguring its B777-200s to have 260 seats, with 

45 Business Class seats, 55 Main Cabin Extra seats, and 160 Economy seats. 
Application of American Airlines, Inc.

Page 3 of 12

coverage for the travelling public and shippers, and allow American to compete with the 

incumbent U.S. airlines serving Japan.

While the normal service start-up conditions requested by the Department is 90 

days, American recognizes the value of this scarce resource and commits to start service 

60 days after the issuance by the Department of a Final Order. American will make 

every effort to start earlier than its 60-day commitment, but, realistically and 

operationally, accelerating this already accelerated schedule may not be possible.

Increasing American’s presence at Haneda is critical, and it is fully committed to 

serving that market. Moreover, as our exhibits demonstrate, American’s proposal will:

 provide substantial inter-carrier competition to the two largest U.S. carriers 

serving Tokyo, and Japan, and all of Asia – Delta and United;4

 provide inter-alliance competition to SkyTeam and Star Alliance at Los 

Angeles;

5

 provide real, meaningful inter-gateway competition;6and

 provide real, meaningful intra-gateway competition.7

Historically, American has repeatedly tried to secure a more comprehensive 

network to Japan. Yet, American’s efforts have been either practically or legally 

impeded by the incumbent carriers’ opposition and strong market position, which is the 

product of their many decades headstart in Asia on American, which in turn, is the 

product of their privileged “incumbent” position. More recently, American’s efforts to 

provide competition to the incumbents has faced another challenge: Delta’s attempts at 

the government negotiation table to block further U.S.-Japan liberalization. As the 

 

4 Ex. AA-207.

5 Ex. AA-208.

6 Ex. AA-207.

7 Exs. AA-207-208.
Application of American Airlines, Inc.

Page 4 of 12

Department is quite aware, no U.S. carrier has been more vocal, active in, and supportive 

of U.S. Government attempts to further liberalize the U.S.-Japan aviation market than 

American. 

II. American’s Proposed Los Angeles-Haneda Service

American will provide year-round daily nonstop service between Haneda and Los 

Angeles. American’s proposed schedule will be:

Summer 2015 Schedule

Route Departure Time (local) Arrival Time (local)

LAX to HND 18:30 22:30 +1

HND to LAX 00:00 18:30 -1

Winter 2015 Schedule

Route Departure Time (local) Arrival Time (local)

LAX to HND 17:00 22:30 +1

HND to LAX 00:00 17:00 -1

American’s schedule complies with the Haneda curfew which, under the current U.S.-

Japan Memorandum of Understanding, permits U.S.-Haneda operations only between 

22:00 and 07:00. Departures from Haneda to U.S.-mainland points are not allowed 

before midnight. American’s schedule depends on actual slot availability at Haneda. Ex. 

AA-103.

American’s service will provide convenient both-direction connections between 

Haneda and 25 cities through its West Coast gateway, Los Angeles, in the summer 

season, and 32 cities in the winter season. Ex. AA-107. These connections will serve 

consumers across every region of the lower 48 states, including major U.S. population 
Application of American Airlines, Inc.

Page 5 of 12

centers such as Atlanta, Boston, Chicago, Dallas, Miami, New York, Philadelphia, San 

Francisco, and Washington, D.C. Ex. AA-107.

American proposes to operate the service with Boeing 777-200 (“B772”) aircraft. 

Initially, the aircraft will be in a 247-passenger configuration: 16 First Class, 37 Business 

Class, and 194 Economy Class. First and Business Class feature lie-flat seats, and all 

classes feature in-seat entertainment. Exs. AA-103-104. Throughout 2015, American 

will continue investing in its product and will phase in a new 260-seat configuration on 

the B772 fleet. 

Finally, American’s B772 will have at least 20 tons of cargo capacity per flight, a 

significant addition to the Haneda market. (In contrast, Delta’s Seattle-Haneda service 

offers 7.3 tons.) Exs. AA-108-109 & AA-222.

III. American’s Proposal Will Best Serve the Public Interest

The remainder of this Application and the accompanying exhibits explain how 

American’s proposed Los Angeles-Haneda daily service will improve competition and 

maximize the public benefits by ending Delta’s significant and appalling underuse of a 

valuable slot pair for Seattle-Haneda. It also outlines the supporting information that the 

Department requested in Order 2014-12-9.

The accompanying direct testimonies of American’s President, Scott Kirby, and

Senior Vice President and Chief Marketing Officer, Andrew Nocella, convey American’s 

commitment to expanding Haneda access and the critical importance of Los AngelesHaneda service to American’s future. Exs. AA-T-1 & AA-T-2. The accompanying

direct exhibits also show that American’s Los Angeles-Haneda proposal will provide vast 
Application of American Airlines, Inc.

Page 6 of 12

and immediate benefits to U.S. consumers and shippers in Southern California and 

throughout the United States. Specifically:

 Exhibit Series 100 identifies the contours of the proposed service, including 

the best connecting-market access of any airline.

 Exhibit Series 200 explains why Los Angeles is an ideal Haneda gateway and 

how American will bolster competition via a Los Angeles gateway.

 Exhibit Series 300 shows that American’s service will provide far greater 

public benefit than Delta’s Haneda service.

 Exhibit Series 400 summarizes the public benefits of American’s Los 

Angeles-Haneda proposal.

 Exhibit Series 500 details the connecting information for American’s Los 

Angeles-Haneda proposal.

 Exhibit Series 600 are letters of support for American’s Los Angeles-Haneda 

proposal.

The Department has two choices in this proceeding. It can allow Delta to retain a

U.S.-Haneda slot pair currently allocated to the Seattle-Haneda route, despite no use at all 

of that scarce resource for months at a time and underutilization in other months. Or, it 

can reallocate that slot pair to American, which will operate a daily, year-round B772

service on the Los Angeles-Haneda route to the benefit of consumers. 

A. Delta’s Current Use of a U.S.-Haneda Slot Pair for Seattle-Haneda 

Does Not Maximize the Public Benefits

A short review of the history of Delta’s “use” of this slot pair is very telling. In 

the original (first) U.S.-Haneda Combination Services Allocation Proceeding in 2010, 

Delta proposed Detroit-Haneda service. It promised that the service would operate 
Application of American Airlines, Inc.

Page 7 of 12

daily.8 It promised that it would operate the service with B747-400 aircraft with 403 

seats.9 It promised that the combination of Los Angeles or Seattle (for which it also 

applied) and Detroit service to Haneda would enable it to cover the entire United States –

the U.S. western/mountain region via Los Angeles or Seattle and the U.S. eastern region 

via Detroit.10 The Department relied on Delta’s service promises and commitments in 

allocating this slot pair to Delta to operate Detroit-Haneda service. Exs. AA-301-304.

Delta did not deliver what it promised. No sooner was the ink dry on the 

Department’s Order than Delta pulled the 403-seat B747-400 from the Detroit route after 

just 37 flights. After the two month service hiatus caused by the tragic tsunami, Delta 

resumed service but with a significantly smaller 269-seat B777. The B777 aircraft also

proved too large for Detroit-Haneda so, after just another three months of operations and 

76 flights, Delta eliminated service for almost eight months. Then, when it resumed 

service for summer 2012, it once again downgauged the Detroit-Haneda aircraft to a 241-

seat A330-200 aircraft. Exhibit AA-302 shows the effects of the downgrade and Delta’s 

performance over time.

Delta thus failed to follow through on its two “Detroit Promises” – B747 aircraft 

and daily service. Additionally, Delta’s promised “dual gateway/dual geography/dual 

access” plan never materialized due to the failure of the Detroit gateway – another Delta

“Detroit Promise” unfulfilled.

 

8

See Application of Delta, Feb. 16, 2010, Docket DOT-OST-2010-0018, p. 1. 

9

Id at 4.

10 Id at 2.
Application of American Airlines, Inc.

Page 8 of 12

Months later, Delta petitioned the Department to switch the U.S. gateway for this 

Haneda slot pair from Detroit to Seattle. By applying for Seattle, Delta set up a situation 

in which it had two west coast gateways that overlap and compete with one another for 

Haneda traffic (i.e., Los Angeles and Seattle),11 and two Seattle-Tokyo routes (one to 

Haneda, one to Narita) that also overlap and compete with each other. Exhibit Series 300 

graphically shows the degradation in Delta’s U.S.-Haneda services over time. 

Delta’s promises about its Seattle-Haneda service, like its promises about Detroit 

service, were forgotten almost as soon as the Department’s approval was finalized. 

Delta’s first “Seattle Promise” – the promised B767-300ER – was downgraded to a B767 

with fewer seats. Ex. AA-309. Delta’s second “Seattle Promise” – to operate daily, yearround service – was not only broken, but broken in the extreme. In fact, Delta has not 

operated daily scheduled Seattle-Haneda service since November. The result can only be 

described as: SEATLESS IN SEATTLE. Exhibits AA-304 and AA-310-314 show 

graphically the story of a carrier allowing a service to deteriorate over time. Delta is 

neglecting the Seattle-Haneda route (evidenced by very low load factors), but not the 

Seattle-Narita route, which Delta continues to operate on a daily scheduled basis (at very 

high load factors). Exs. AA-322-323.

Delta does not attempt to justify the abdication of its responsibility to the 

Department and the travelling public to provide the promised daily scheduled service but, 

instead, to provide no service at all in winter and irregular service patterns during other 

parts of the year. Rather, Delta says that, because it is meeting the Department’s 

 

11 Ex. AA-318, showing the overlap markets juxtaposed with the Seattle-specific markets.
Application of American Airlines, Inc.

Page 9 of 12

dormancy rules, the Department cannot do anything about its abuse of a valuable slot 

pair, irrespective of the public interest. Indeed, Delta now threatens that, if the 

Department tries to do something about it, it will take the Department to court. (See

Delta Pet. for Reconsideration at 8, Dec. 23, 2014).

With respect to Delta’s Seattle-Haneda performance, the facts show that:

 Delta down-gauged the B767 configuration it promised, to a configuration 

with approximately six percent fewer seats;12

 Delta will have operated the route only 41 percent of the time – 421 flights 

in 1034 days (through March 31, 2015);13

 Delta will have gone for nearly three months without offering a single 

flight –from November 23, 2014 to February 13, 2015;14

 Delta will have operated seven or fewer flights in three months –

November 2014 (seven flights), February 2015 (seven flights) and March 

2015 (three flights);

15 and

 Delta will have operated only 17 flights in a 182-day period.16

Delta may have provided just enough service to keep the frequencies from 

automatically reverting to the Department, but, nevertheless, it has eviscerated the public 

interest of making full and effective use of a scarce resource. Delta’s use of a valuable 

Haneda slot pair to operate a seasonal service, where it (1) operates a paltry 17 flights in a 

182-day span; (2) does not operate for months at a time; and (3) operates the smallest 

aircraft type capable of nonstop Seattle-Tokyo service is not maximizing the public 

benefits of a scarce resource.

 

12 Ex. AA-309.

13 Ex. AA-310.

14 Ex. AA-311.

15 Ex. AA-312.

16 Ex. AA-312.
Application of American Airlines, Inc.

Page 10 of 12

B. Delta’s Self-Serving Retention of a Haneda Slot Pair, Which it is 

Woefully Underusing, is Thwarting Department Goals of Increasing 

Consumer Choice and Competition Among Carriers

Not only is the United States not realizing the maximum aviation or economic 

benefits achievable by the proper use of this resource, but Delta’s non-use/underuse of 

the slot pair and its unwillingness (or refusal) to return it also thwarts the public interest 

by keeping it from being put to a higher and better use. Delta’s actions are inhibiting an 

increase in robust competition in many ways.

First, Delta is hindering inter-U.S. carrier competition. American is the only U.S. 

airline serving Japan that has no Haneda authority. By hoarding a Haneda slot pair that it 

is using only sporadically (at best), Delta is preventing American from using that slot pair 

to provide daily year-round service from Los Angeles and, in the process, inject a new 

U.S. competitor to Haneda.

Second, Delta is also thwarting overall carrier competition in U.S.-Haneda

markets. Every U.S. and Japanese carrier serving the Transpacific route, except 

American, has Haneda authority – Delta, United Air Lines, Inc. (“United”), Hawaiian

Airlines, Inc., Japan Airlines Co. Ltd. (“JAL”), and All Nippon Airways Co., Ltd. 

(“ANA”). Ex. AA-207. By preventing American from operating Haneda service, Delta 

is keeping a vigorous and important competitor out of the market, and depriving 

consumers of an additional travel option.

Third, American’s Los Angeles-Haneda service will provide vigorous and 

beneficial U.S. carrier competition to the Los Angeles-Haneda services operated by Delta 

and ANA. Ex. AA-400.
Application of American Airlines, Inc.

Page 11 of 12

Fourth, at Los Angeles, both the SkyTeam and Star alliances (through the Haneda 

services of Delta and ANA, respectively) are present. There is no Los Angeles-Haneda 

service available on oneworld, although Los Angeles is the largest U.S.-Haneda O&D 

market. Exs. AA-203 & AA-208. By allowing American to operate its proposed Los 

Angeles-Haneda service, the Department will be injecting complete, three-way alliance 

competition in the largest Haneda O&D market from the U.S. 

Finally, by preventing American from operating the Los Angeles-Haneda route, 

Delta is stymieing beneficial inter-gateway and inter-alliance competition between 

American at Los Angeles and United at San Francisco.

C. American Will Make Full and Effective Use of the U.S.-Haneda Slot 

Pair

In contrast to Delta’s record of performance in both Detroit and Seattle, 

American’s Los Angeles-Haneda service will fully utilize the slot pair and will provide 

superior economic and public interest benefits:

 American will use the largest aircraft for Los Angeles-Haneda service (B772

with 247 seats) – larger by 19 percent and 39 seats than Delta’s B767 and 

larger by 11 percent and 24 seats than ANA’s B777;

17

 American’s B772 at Los Angeles will be larger than the B767 that Delta uses 

at Seattle – by 36 seats and 17 percent;

18

 American’s B772 will provide nearly three times more cargo capacity than 

Delta’s Seattle B767, which is an important and valuable benefit to shippers in 

the largest trading region of the world – Asia – and, on an annual basis, one 

million more pounds of cargo capacity than Delta’s Seattle B767;

19

 

17 Ex. AA-213.

18 Exs. AA-309 & AA-213.

19 Ex. AA-222.
Application of American Airlines, Inc.

Page 12 of 12

 American’s Los Angeles-Haneda service will provide more unique 

connections in both directions than Delta’s Seattle-Haneda service (all of 

which, it should be noted, overlap and duplicate the connections on Delta’s 

Seattle-Narita service);

20 and 

 The size of American’s Los Angeles-Haneda unique connecting market 

Tokyo O&D is twice the size of Delta’s Seattle-Haneda unique connecting 

market.

21

Clearly, under any measure of “maximizing public benefits,” American’s 

proposed daily year-round B772 Los Angeles-Haneda service is immeasurably superior 

to Delta’s current irregular, sporadic Seattle-Haneda service. American’s service will 

inject and increase competition among airlines and alliances and provide greater choice 

for consumers.

Wherefore, American respectfully urges the Department of Transportation to 

expeditiously grant its application to use one U.S.-Haneda slot pair at Los Angeles, and 

to grant such other or further relief as the Department deems appropriate. 

Respectfully submitted,

Howard Kass 

Robert A. Wirick

Abigail Donovan

 

20 Ex. AA-214.

21 Ex. AA-215.
Attachment 1 to American Application (U.S.-Haneda)

Responses to DOT Information Requests

Page 1 of 5

American’s Responses to the Department’s Information Requests

Information Request 1 (Service Proposal). American will provide year-round 

daily nonstop service between Haneda and Los Angeles International Airport. 

American’s proposed schedule complies with the Haneda curfew and times vary 

according to seasonal weather patterns. 

American’s proposed schedule will be:

Summer 2015 Schedule

Route Departure Time (local) Arrival Time (local)

LAX to HND 18:30 22:30+1

HND to LAX 00:00 18:30-1

Winter 2015 Schedule

Route Departure Time (local) Arrival Time (local)

LAX to HND 17:00 22:30+1

HND to LAX 00:00 17:00-1

1

As well established, under the current U.S.-Japan Memorandum of Understanding, 

operations between the U.S. and Haneda are permitted between 22:00 and 07:00, except 

that departures from Haneda to U.S.-mainland points are not allowed prior to midnight. 

These schedules also depend on actual slot availability at Haneda. While the normal 

service start-up conditions request by the Department is 90 days, American recognizes 

the value of this scarce resource and commits to start service 60 days after the issuance 

by the Department of a Final Order. American will make every effort to start earlier than 

 

1 Ex. AA-102.
Attachment 1 to American Application (U.S.-Haneda)

Responses to DOT information requests

Page 2 of 5

its 60-day commitment, but, realistically and operationally, accelerating this already 

accelerated schedule may not be possible.

American’s service will provide convenient both-direction connections between 

Haneda and 25 U.S. cities through its West Coast gateway, Los Angeles, in the summer 

season and 32 cities in the winter season. The connections will serve consumers across 

every region of the lower 48 states, including major U.S. population centers such as 

Atlanta, Boston, Chicago, Dallas, Miami, New York, Philadelphia, San Francisco, and 

Washington, D.C. Exhibits AA-501-502 contain nonstop-to-nonstop connecting 

schedules and elapsed times. There are no commercially viable beyond-Haneda markets.

American proposes to operate using the service with B772 aircraft. Initially, the 

aircraft will be in a 247-passenger configuration: 16 First Class, 37 Business Class, and 

194 Economy Class. First and Business Class feature lie-flat seats, and all classes feature 

in-seat entertainment. Ex. AA-104.

Throughout 2015, American will continue the investment in its product and will 

phase in a new 260-seat configuration on the B772 fleet. The 260-seat configuration will 

consist of 45 Business Class, 55 Main Cabin Extra, and 160 Economy seats. The new 

Business Class product will feature new, personal Business Suites, each having a larger 

lie-flat bed than existing seats and direct aisle access. Main Cabin Extra seating will 

provide customers with up to six more inches of legroom. Finally, each seat on the 

aircraft will be equipped with a power outlet, USB port, and on-demand entertainment. 

WiFi will be available throughout the cabin during large portions of the flight. Finally, as 
Attachment 1 to American Application (U.S.-Haneda)

Responses to DOT information requests

Page 3 of 5

shown in Exhibits AA-103 and AA-222, American’s B772 will have at least 20 tons of 

cargo capacity. 

Information Request 2 (Existing Service). Currently, American offers nonstop 

service between Tokyo’s Narita airport and Chicago (5x/6x per week), Dallas (twice

daily), and Los Angeles (daily). American’s oneworld partner Japan Airlines Co. Ltd. 

(“JAL”) operates both Haneda and Narita to the United States. Under a code-sharing 

arrangement between American and JAL, approved by the Department, JAL displays the 

JL designator code on each of American’s U.S.-Tokyo flights on a year round basis. (See

DOT-OST-1999-4994, Notice of Action Taken, February, 18, 1999.) In addition, 

American places its AA designator code on a year round basis on flights operated by JAL 

between Tokyo (Haneda) and Honolulu and San Francisco, and between Tokyo (Narita) 

and other U.S. points, including Boston, Chicago, Honolulu, Los Angeles, and San 

Diego.

Information Request 3 (Public Benefits). The public benefits are more 

thoroughly described at pages 5-11 of the Application and at Exhibit AA-401. In 

summary, American’s Los Angeles-Haneda service will provide competitive access to 

many new U.S. markets, will increase consumer choice in existing markets, and will 

inject much-needed competition into this strategically important market.

a. Service benefits. American will serve Los Angeles, the largest U.S.-mainland 

O&D market to Tokyo, 4.6 times larger than Seattle. Ex. AA-205. Today, Los 

Angeles is underserved in the U.S.–Tokyo market, with 37 percent fewer seats 

than Seattle per Tokyo O&D passenger. Ex. AA-210. American’s proposed 

service will inject needed Tokyo capacity at Los Angeles and will provide 

convenient one-stop connecting to the rest of the United States.
Attachment 1 to American Application (U.S.-Haneda)

Responses to DOT information requests

Page 4 of 5

b. Increased intra-gateway and inter-alliance competition. American’s new 

proposed service will increase competition and maximize the benefits from the 

Haneda slot pairs. At Los Angeles, American will compete with Delta and All 

Nippon Airways Co., Ltd. (“ANA”), as well as with United Air Lines, Inc. 

(“United”) at San Francisco. Additionally, the oneworld alliance will gain a Los 

Angeles-Haneda service for the first time, increasing inter-alliance competition 

with Delta (SkyTeam Alliance) and ANA (Star Alliance).

American will provide access to more connecting markets from Los Angeles than 

does Delta’s existing Los Angeles-Haneda/Narita and Seattle-Haneda services. 

Exs. AA-214-216, & -218. It will also provide access to connecting markets that 

ANA’s Los Angeles-Haneda service does not reach. Ex. AA-220.

American’s service will contribute to American’s expansion of its Los Angeles 

hub. Since 2013, it has added several new nonstop flights serving both domestic 

and international destinations. As part of American’s efforts to cement its status 

as a leading global airline, it is investing millions of dollars to transform and 

expand its Los Angeles operation. American will continue to make significant 

investments at Los Angeles, including broadening its route network and 

enhancing its facilities. Ex. AA-T-1.

c. Increased U.S.-Asia competition. American’s top international objective is to 

increase its presence in Asia, thereby enhancing its network offerings to 

consumers and competitive position as a leading U.S.-based global international 

air carrier. Asia continues to be among the fastest-growing aviation markets in 

the world.

Information Request 4 (Aircraft Availability). The B772 aircraft to operate the 

proposed Los Angeles-Haneda service are already within American’s fleet. American 

uses 47 B772s on both international and domestic routes. All of American’s B772s are 

FAR-36 compliant. 

Information Request 5 (Fuel Use and Availability). American estimates that it 

will consume 17,867,000 gallons of fuel annually to provide the proposed service. It 

anticipates no difficulty in obtaining fuel from its existing suppliers at Los Angeles and 

no difficult in re-establishing its relationship in Haneda. Ex. AA-103.
Attachment 1 to American Application (U.S.-Haneda)

Responses to DOT information requests

Page 5 of 5

Information Request 6 (Start-Up Condition). American will accept a 60-day 

start-up condition requiring institution of service. We respectfully request 60 days after 

the Department issues a final order re-allocating the slot pair to American (subject to 

obtaining the appropriate approvals from the Japanese government).
CERTIFICATE OF SERVICE

I, Abigail Donovan, certify that, on January 5, 2015, I caused to be served a copy of the 

foregoing Application of American Airlines, Inc. by email upon those addressees listed 

below:

paul.gretch@dot.gov(DOT)

brian.hedberg@dot.gov(DOT)

brett.kruger@dot.gov(DOT)

todd.homan@dot.gov(DOT)

peter.irvine@dot.gov(DOT)

EngleTS@state.gov(Dep’t of State)

cristinasa@state.gov(Dep’t. of State)

eugene.alford@ita.doc.gov(Dep’t. of 

Commerce)

ejames@jamhoff.com (Allied Pilots 

Association)

seth.waxman@wilmerhale.com (Delta)

sascha.vanderbellen@delta.com(Delta)

chris.walker@delta.com(Delta)

Mike.Donatelli@alpa.org(Delta 

MEC/ALPA)

john.allen@faa.gov (FAA)

jhill@cooley.com(Hawaiian)

Perkmann@cooley.com(Hawaiian)

Robert.Lamansky@hawaiianair.com(Hawai

ian)

glindsey@lawa.org(Los Angeles World 

Airports)

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

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

dan.weiss@united.com(United)

steve.morrissey@united.com(United)

gmurphy@crowell.com(United)

sseiden@crowell.com(United)

info@airlineinfo.com (AirlineInfo.com)

Abigail Donovan
1

APPLICATION AND DIRECT EXHIBITS

OF AMERICAN AIRLINES

2010 U.S.-HANEDA COMBINATION SERVICES ALLOCATION PROCEEDING 

(HANEDA 2014)

Docket DOT-OST-2010-0018

January 5, 2015

Tokyo Haneda

Los Angeles
Exhibit Number Title

AA-T-1 Direct Testimony of J. Scott KirbyAA-T-2 Direct Testimony of Andrew P. NocellaAA-100 Narrative to the 100 SeriesAA-101 American Airlines’ Proposed Los Angeles–Haneda ServiceAA-102 American Airlines’ Proposed LAX-HND Schedule and ServiceAA-103 American Airlines’ Proposed LAX-HND Operating StatisticsAA-104 American Airlines’ B777–200 Seat ConfigurationAA-105 American Airlines’ Connecting Aircraft Seat ConfigurationAA-106 American Airlines’ Los Angeles Hub Connects 58 Airports to LAXAA-107 American’s Proposed Los Angeles-Haneda Service Connecting Market Summary for Markets

Connecting in Both Directions

AA-108 American Airlines’ LAX-HND Cargo Capacity at 100% Load FactorAA-109 American Airlines’ LAX-HND Cargo Capacity at 80% Load FactorAA-200 Narrative to the 200 SeriesAA-201 Los Angeles Is, By Far, the Largest Continental U.S. Market to Tokyo – Twice as Large as the

Next Largest Market with Haneda Service (SFO) and 4.6 Times the Size of Seattle

AA-202 Los Angeles Has Almost 340,000 More Annual O&D Passengers to Tokyo Than Seattle

Direct Exhibits of American Airlines
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Direct Exhibits of American Airlines

Exhibit 

Number Title

AA-203 Los Angeles Is, By Far, the Largest Continental U.S. Market to Haneda

AA-204 Los Angeles Has Almost 80,000 More Annual O&D Passengers to Haneda Than Seattle

AA-205 Los Angeles–Tokyo Demand Is 4.6 Times the Demand of Seattle-Tokyo

AA-206 Los Angeles–Haneda Demand Is 4.9 Times the Demand of Seattle-Haneda

AA-207 American Is the Only U.S. Airline Serving Japan That Does Not Have Access to Haneda

AA-208 Oneworld Is the Only Alliance Without LAX Access to Haneda

AA-209 Los Angeles’ Tokyo O&D Is Almost Five The Size of Seattle’s O&D – Almost 340, 000 More Passengers

AA-210 LAX-Tokyo Is Underserved Relative to SEA-Tokyo: SEA Has 37% More Seats per O&D Tokyo Passenger 

Than Los Angeles

AA-211 LAX-Haneda Is Underserved Relative to SEA-Haneda Under Any Measure 

AA-212 The Los Angeles Market Needs More Flights Than Seattle to Accommodate Unfulfilled Demand

AA-213 American Will Be Able to Fill the Unmet Demand at LAX by Operating the Most Seats on LAX-HND . . . 

and More Premium Seats Than Delta

AA-214 American’s LAX-HND Service Will Serve More Unique U.S. Connecting Markets Than Delta’s Existing

SEA-HND Service

AA-215 American’s LAX-HND Connecting Markets Generate Over 210,000 More O&D Passengers Than Delta’s

SEA Connecting Markets

AA-216 American’s LAX-HND Service Will Serve Almost 2.5 Times as Many Unique Connecting Markets as 

Hawaiian’s Existing HNL-HND Service

DOT Docket OST-2010-0018

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Direct Exhibits of American Airlines

Exhibit 

Number Title

AA-217 American’s LAX-HND Connecting Markets Generate 324,000 More O&D Passengers Than Hawaiian’s

HNL Connecting Markets

AA-218 American’s Proposed LAX-HND Service Will Serve 20% More Unique U.S. Connecting Markets Than

Delta’s Existing LAX-HND Service

AA-219 American’s LAX Connecting Markets Generate Over 256,000 O&D Passengers

AA-220 American’s LAX-HND Service Will Serve 6 Times More Unique Connecting Markets Than ANA’s

Existing LAX-HND Service 

AA-221 American’s LAX-HND Connecting Markets Generate Almost One Million More O&D Passengers Than 

ANA’s LAX-NRT Connecting Markets

AA-222 American’s B777 Will Provide Superior Cargo Capacity to Delta’s B767

AA-300 Narrative to the 300 Series

AA-301 Delta’s Failed Detroit–Haneda Commitment

AA-302 Delta’s Failed Detroit–Haneda Commitment: Even Eliminating April and May 2011 as “Tsunami-Related” 

Service Interruption Months, Delta Operated Only 42% of the Flights and Offered Only 28% of the Seats It 

Promised to Provide in the Detroit–Haneda Market

AA-303 Delta’s Failed Detroit–Haneda Commitment: Flights Committed versus Flights Flown

AA-304 Delta’s Failed Detroit–Haneda Commitment: Seats Committed versus Seats Flown

AA-305 Delta’s Failed Los Angeles–Haneda Commitment

AA-306 Delta’s Failed Los Angeles–Haneda Commitment: Delta’s Dwindling Los Angeles–Haneda Aircraft Size

DOT Docket OST-2010-0018

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Direct Exhibits of American Airlines

Exhibit 

Number Title

AA-307 Delta’s Failed Los Angeles–Haneda Commitment: Seats Committed versus Seats Flown

AA-308 Delta’s Failed Seattle Commitments . . . And There are Several

AA-309 Delta’s Failed Seattle–Haneda Commitment: Delta Has Not Lived Up to Its Substantially-Scaled Back

Seattle-Haneda Service Proposal 

AA-310 Delta’s Failed Seattle–Haneda Commitment: Seatless in Seattle

Delta’s Current Seattle-Haneda “Offering”

AA-311 Delta’s Failed Seattle–Haneda Commitment: Seatless in Seattle

A Picture is Worth a 1,000 Words

AA-312 Delta’s Failed Seattle–Haneda Commitment: Seatless in Seattle

Delta Has Constructively Abandoned the Seattle-Haneda Market Since October 2014

AA-313 Delta’s Failed Seattle–Haneda Commitment: Seatless in Seattle

Since Delta Inaugurated Seattle-Haneda Service, It Will Have Operated a Daily Service in Only 4 of the 22 

Months

Through March 2015 and in Only One Month Since August 2013

AA-314 Delta’s Failed Seattle–Haneda Commitment: Seatless in Seattle

Delta Has Provided Over 62% Fewer Seats – Close to 289,000 Seats – Than It Committed to Provide Under 

Its Scaled-Back August 2012 Seattle-Haneda Service Proposal

AA-315 While Delta Has Abandoned the Seattle–Haneda Market, It Has Maintained Its Full Daily Schedule of

Seattle-Narita Flights

AA-316 . . . Delta Offers More Than Twice the Number of Seats on the Seattle-Narita Route as It Offers on the

Seattle-Haneda Route

DOT Docket OST-2010-0018

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Direct Exhibits of American Airlines

Exhibit 

Number Title

AA-317 Delta Competes With Itself at Seattle: Delta’s Seattle-Haneda Route Offers No Connecting U.S. Markets

Not Already Offered on Delta’s Seattle-Narita Route for U.S. Connecting Traffic

AA-318 Delta Competes With Itself to Haneda: There are More Overlap Markets Between Delta’s SEA-HND

and LAX-HND Services Than Unique Markets on Either Route

AA-319 Delta Competes With Itself to Tokyo: Delta’s Seattle-Haneda Route Competes and Overlaps with Delta’s 

Los Angeles-Narita Route for U.S. Connecting Traffic and . . . The Only Six Unique SEA-HND Connecting 

Points Account for Only 47 O&D Passengers (PPDEW) to Tokyo

AA-320 Delta Has the Lowest Load Factor, By Far, of Any Airline Operating U.S.–Haneda Service

AA-321 Delta Had Almost as Many Empty Seats as It Had Occupied Seats on Its Seattle-Haneda Flights

AA-322 Delta’s Seattle-Haneda Load Factor is 39% Lower Than Its Asia Load Factor and 40% Lower Than Its System 

Load Factor

AA-323 In Contrast to Delta’s SEA-HND Load Factor of 51%, Delta’s LAX-HND Route Experiences a Load Factor of 

77.4%, Delta’s SEA-NRT Route Experiences a Load Factor of 89.7%, and Its Los Angeles-Haneda Route 

Enjoys a Load Factor of 90.4%

AA-324 “Seasonality” Is an Excuse Concocted by Delta for Ceasing Seattle-Haneda Service; It Is Not a Reality

AA-401 Allocating to American a Haneda Slot Pair to Operate the Los Angeles-Haneda Route Maximizes the Public 

Benefits of a Scarce Resource

AA-501 Connecting Detail–Summer Westbound (LAX-HND); Connecting Detail–Summer Eastbound (HND-LAX)

AA-502 Connecting Detail–Winter Westbound (LAX-HND); Connecting Detail–Winter Eastbound (HND-LAX)

DOT Docket OST-2010-0018

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Direct Exhibits of American Airlines

Exhibit 

Number Title

AA-503 Cargo Capacity for Flights Connecting to American’s LAX-HND Service at 100% Load Factor

AA-504 Cargo Capacity for Flights Connecting to American’s LAX-HND Service at 80% Load Factor

AA-600 Letters of Support

DOT Docket OST-2010-0018

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8

Direct Testimony
American Airlines

Testimony of J. Scott Kirby 

President 

January 5, 2015 

My name is J. Scott Kirby and I am the President of American Airlines, Inc. ("American"). 

On behalf of American, and American's 1 00,000+ dedicated employees, I am proud to submit this 

testimony in support of our application to the U.S. Department of Transportation for the allocation 

of one slot pair to serve Tokyo's Haneda International Airport on a daily basis from Los Angeles, 

California, beginning promptly after the issuance of a Final Order by the Department. 

American appreciates that the Department will make its decision in this carrier-selection 

proceeding on the basis of what is the highest and best use of the scarce and highly valuable Haneda 

slot pair for the benefit of consumers and competition. The Department has consistently strived to 

make decisions that allow more choices for consumers by creating an environment in which all 

carriers have opportunities to compete. 

In this proceeding, the Department will have the ability not only to consider the best use of 

this Haneda .slot pair, but also will have the opportunity to enhance consumer benefits in the key 

U.S.-Japan market by providing more competition for the incumbent carriers. My testimony 

focuses on the commitment of American to provide a strong competitive balance in the U.S.-Asia 

market and to maximize the public benefits of the scarce resource ofHaneda slot pairs. 

Background 

After its merger with US Airways, American is the largest U.S. airline, operating nearly 

6,700 flights around the globe, to more than 335 locations in more than 50 countries. While these 

are impressive statistics, we still have much to do to achieve our goal of reestablishing American as 

the world's greatest airline, providing industry leading service to all parts of the world and offering 

a great product for customers. Indeed, our current marketing campaign centers on our "Going for 

Great." 

We have a lot of work in front of us and one of the greatest challenges is increasing 

American's footprint in Asia It is no secret that American trails Delta and United in terms of our 

Asia presence and, thus, our ability to provide our customers with greater service options and travel 

choices. Some of this is due to historical reasons that have, as a practical and legal matter, 

precluded American from competing on an even footing with United and Delta, which, through 

their acquisition of Pan American's Asian routes and Northwest, respectively, inherited incumbency 
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status in Japan and a many decades headstart on American. It is therefore absolutely necessary that 

we build American's Asia presence so we can offer consumers greater choices and be able to 

compete with Delta and United. This is, in fact, our top international priority at American. 

No airline can have a strong presence in Asia without having a strong presence in Japan, and 

specifically in Tokyo- one of Asia's premier business and leisure destinations. Now that Haneda 

has re-opened to services between Tokyo and the U.S., in order to have a meaningful presence in 

Tokyo, service to Haneda is a necessity. Like LaGuardia in New York and Reagan National in 

Washington, D.C., Haneda is close to downtown, and heavily business-oriented, making it a popular 

airport for travel in and out of Tokyo. Today, American is the only U.S. global network carrier that 

cannot operate its own aircraft at Haneda, depriving our customers from the service options and 

convenience available to Delta and United customers. 

Moreover, as demonstrated in our exhibits, as I briefly describe below, and as more fully 

explained in the testimony of Andrew P. Nocella, American's Senior Vice President and Chief 

Marketing Officer, not only is the grant of American's application in this proceeding critical to our 

development of Tokyo, and our overall Asia presence, it also fulfills the Department's overriding 

objective of maximizing the public benefits by providing: (1) superior consumer travel options and 

choices; (2) superior competitive benefits by injecting a new competitor at Haneda; (3) new intragateway competition at LAX; (4) additional inter-gateway competition between LAX and SFO; (5) 

first-time inter-alliance competition at LAX among all three alliances; and (6) a service that will use 

the Haneda slot pair 365 days a year. 

A New American Strategy for Asia Post-Merger with ~S Airways 

Before the American-US Airways merger was completed, many hours were spent 

undertaking a thorough review of American and US Airways' services and strategy around the 

world, including the Asia-Pacific region. This examination provided a blueprint of where the new 

American was well-positioned, but also showed where we needed to improve the network. This 

review, in which I was deeply involved, permitted a fresh look and a new perspective to the service 

deficit facing the new American in Asia. Completing this study enabled us to hit the ground 

running, and to immediately begin implementing an enhanced Asia-Pacific strategy for American. 

Our analysis identified four major areas of improvement that would help us fulfill our goal 

of achieving a market penetration level in Asia that is competitive with Delta and United: (1) a 

deeper overall Asia presence and service pattern; (2) a return as soon as possible to Tokyo's most 

important airport, Haneda; (3) enhanced focus on American's Los Angeles hub as an Asian 

gateway; and (4) and substantial investment in product upgrade from airports to aircraft and checkin lobbies to inflight entertainment-- investments essential to attract new customers and retain our 

loyal customers for these long-haul flights and to enhance all of our customers' experience, from 

before the flight is booked until their checked bags are delivered. 

Consistent with our priorities, American has already made progress in the first of these areas 

(see the next section) and the fourth (see the section below). Gaining access to Haneda in this 

proceeding would accomplish the second objective and is a key building block in the development 

of the third objective. 
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American's Asia-Pacific Expansion 

The first 12 months since the merger have seen American already expanding and 

strengthening its presence in the Asia-Pacific regio~ one of the world's fastest growing aviation 

areas, and providing consumers greater travel options and opportunities. Specifically, in 2014 

alone, American: 

• Inaugurated new daily Dallas/Fort Worth (DFW)-Hong Kong nonstop service to the 

American route network; 

• Inaugurated daily DFW-Shangbai service, complementing American's existing service 

from Chicago and Los Angeles; 

• Received Department of Transportation authority to begin a new daily flight between 

DFW and Beijing in May 2015; and, 

• Improved schedules, beginning in summer 2015, on our current U.S.-China services, 

with the acquisition of better slot times in Beijing and Shanghai. 

The next step is to fill the remaining critical gap - service to Haneda, where American 

currently bas no slot pair allocation, and, thus, is unable to provide its own service, unable to 

provide consumers with greater travel options and unable to provide competition to Delta and 

United. · 

American's Investment and Expansion at its Los Angeles Hub 

American is the largest carrier at Los Angeles, and is developing LAX as its West Coast 

gateway to better compete long-term with Delta and United, both which already benefit from strong 

gateways on the West Coast- Seattle and San Francisco, respectively, as well as the large number 

of Asian airlines serving LAX. Indeed, in 2014, we added five new destinations and seven new 

flights to our Los Angeles hub. We have also invested in our infrastructure by transforming and 

reinventing our Los Angeles facilities, all to provide more efficient and more enjoyable travel 

experiences for all consumers. 

American's Investment in Fleet Overhaul 

After taking delivery of nearly 100 new aircraft in 2014, American already has the youngest 

fleet of the global U.S. air carriers. Yet, our work is not done. American is investing billions in 

creating a fleet that offers our customers a world-class travel experience, and will enable the new 

American to more proudly represent the United States around the globe. This year, American will 

take delivery of 112 new aircraft, including the B787, and an additional 84 new aircraft in 2016. 
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In addition to taking delivery of new aircraft, we are refurbishing our Boeing 777-200, 767-

300, and 757 fleets with new seats, refreshed cabins, and onboard power outlets - improvements 

that will enhance the inflight experiences of all consumers. When complete, nearly every American 

intercontinental wide-body jet will feature fully lie-flat seats with direct aisle access in premium 

cabins, and nearly all American aircraft, including our large regional jets, will have WiFi capability. 

We have made great progress in our goal of enhancing the travel experiences available to 

both business and leisure passengers. Yet, what American has achieved so far in the Asia-Pacific 

region, at Los Angeles International Airport, and in renewing and upgrading its product is not the 

culmination of our work, it is only the start. We have much more work to do, and we will do it; but 

the first international network priority we must address to provide greater options to the traveling 

public is the lack of any Haneda service by American. 

American's Superior Haneda Proposal 

This proceeding is a critical step, not only to fulfill our objective to compete directly at 

Haneda, but to ensure that the public benefits from these limited resources are maximized. 

Our proposed daily year-round Boeing 777 service will give millions of travelers and 

shippers a new, viable travel option to Haneda that they don't have today. As more fully explained 

by Mr. Nocella, American's proposed Haneda service also will provide substantial inter-carrier 

competition to the two largest U.S. carriers serving Asia, Delta and United, as well as to the 

Japanese and third country airlines serving LAX; provide inter-alliance competition to SkyTeam 

and Star Alliance; and provide real, meaningful inter- and intra-gateway competition. Only an 

allocation· to American will maximize the public benefits and produce the greatest consumer 

benefits and the greatest economic "return" on the utilization of the scarce national resource of 

Haneda slot pairs. 

We have come a long way injust one year since our merger. We are all proud of what the 

new American has achieved to this point, but we are equally excited about what the future 

achievements will mean for American, for competition, for our customers and for all travelers and 

consumers, as well as the cargo shipper community. On behalf of the millions of American 

customers and over 100,000 proud American employees, we look forward to building on these 

achievements as a new competitor at Tokyo's Haneda airport in 2015 and respectfully request the 

Department to allocate to American the Haneda slot pair that is the subject of this proceeding to 

allow American to operate a daily, year-round B777 service from Los Angeles to Haneda 

Thank you. 

Respectfully Submitted, 

J. Scott Kirby 
American Airlines" "--

Testimony of Andrew P. Nocella 

Senior Vice President and Chief Marketing Officer 

January 5, 2015 

My name is Andrew P. Nocella, and I am the Senior Vice President and Chief Marketing 

Officer of American Airlines, Inc. I submit this testimony in support of American's application to 

the U.S. Department of Transportation for the award of one slot pair to serve Tokyo's Haneda 

International Airport on a daily basis from Los Angeles, California, beginning in 2015. 

As the testimony of American's President, Scott Kirby, indicates, expanding American's 

current level of services offered in Asia is a top priority for the new American. In Mr. Kirby's 

testimony, he describes the efforts that the new American has undertaken to begin the process of 

enlarging American's presence in this most important region of the world, and one in which, 

historically, American has lacked a presence sufficient to compete with Delta and United. As the 

senior officer with full responsibility for American's network and commercial offerings, I concur 

with everything that Mr. Kirby states, but especially the importance we at American place on 

building up our Asia service offering for the benefit of consumers and shippers. 

Importance of Haneda Service to American 

We have in the one year since the merger, and the start of the new American, achieved a lot. 

However, much more remains to be done to give American a strong competitive presence in Asia's 

most important markets. Addressing the lack of any American service at all to Haneda is critical to 

American's Asia presence, enhancing our network to be competitive with United and Delta, and 

giving the travelling public meaningful choices. Gaining access to Haneda heads the list of 

American's top international priorities. 

American service to Haneda is critical because having a strong presence in Japan is an 

anchor for any U.S. airline's Asian service. However, an airline cannot have a strong Asian 

presence if it does not have a strong presence in Japan. A strong presence in Japan means a strong 

presence in Tokyo. And, since the reopening of U.S. carrier services to Haneda, a strong presence in 

Tokyo requires a presence in Haneda, albeit not a large presence because of the current bilateral 

limitations limiting the United States to only four slot pairs, but at least a presence on a comparable 

footing to United and Delta. 

This is because Haneda is Tokyo's close-in airport. It is, by far, the preferred airport for the 

business traveler going to or from Japan. All U.S. passenger airlines serving Japan and all Japanese 
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airlines serving the United States have Haneda authority except for American. American simply 

cannot compete on that basis and provide consumers with greater travel options. Consumers have 

no access on American aircraft to Haneda, and the choice for them is to either go to Narita on 

American or go to Haneda on an airline other than American. In essence, consumers are deprived 

of the ability to have an "American/Haneda" option, and American passengers alone have no ability 

to choose between flying into or out ofHaneda or Narita, unlike passengers on every other U.S. and 

Japanese carrier flying between the United States and Japan. 

American's Proposed LAX-Haneda Service Provides Superior Public Benefits to Delta's Very 

Infrequent Seattle-Haneda Service 

American's Los Angeles-Haneda service would fully utilize the Haneda slots and would 

provide superior economic and public interest benefits: 

• American will utilize the largest aircraft for LAX-Haneda service (B777 with 247 seats) 

- larger by 19% and 39 seats than Delta's B767 and larger by 11% and 25 seats than 

ANA's B777 (Exhibit AA-104; AA-213); 

• American's B777 at LAX will be larger than the B767 that Delta uses at Seattle- by 36 

seats and 17% (Exhibit AA-1 04; AA-306); 

-•· American's LAX-Haneda service will provide -more unique connections in both 

directions than Delta's Seattle-Haneda service (Exhibit AA-214), (which, I should add, 

··· overlaps and duplicate the connections on Delta's Seattle-Narita service - Exhibit AA317), and more unique connections in both directions than Delta's Los Angeles-Haneda 

service (Exhibit AA-218); and, 

• American's Los Angeles-Haneda unique connecting markets Tokyo O&D generates 

200,000 more passengers than Delta's Seattle-Haneda unique connecting market Tokyo 

O&D (Exhibit AA-215) and 256,000 more Tokyo O&D than Delta's Los AngelesHaneda unique connecting market Tokyo O&D (Exhibit AA-219). 

In all significant respects, American's plan to use the Haneda slot pair that is the subject of this 

proceeding is, far and away, superior to Delta's on again-off again use of those slots for SeattleHaneda service. First, with respect to Delta's Seattle-Haneda service, American's direct exhibits 

show, among other things: 

• Delta has operated the Seattle-Haneda route 421 days of the possible 1,034 days since it 

inaugurated that route through March 30, 2015 -- only 41% of the time (Exhibit AA310); 

• Delta has operated a daily schedule only four months out of the 22 months that it will 

have operated the route through March 2015 (Exhibit AA-313); 
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• Delta will have gone for weeks and months- in fact 82 days in a row (November 23, 

2014 through February 12, 2015) without providing any service on the Seattle-Haneda 

route and will operate only 17 flights in the 182 day period from October 1, 2014 to 

March 31, 2015 (Exhibit AA-311); and, 

• Delta's load factor on the Seattle-Haneda route, by any standard, is abysmal at 51.1%, 

and it is, by a wide margin, the lowest of all load factors of any service between the 

United States and Haneda (Exhibit AA-320). 

Delta's Seattle-Haneda service speaks for itself: whatever benefits Delta touted about its 

Seattle-Haneda service have been eliminated or substantially diminished by Delta's non-existent or 

minimal flight schedules; Delta's woeful utilization of this slot pair is not an optimum, or even a 

good, use of this valuable resource or a maximization of U.S. economic benefits; and it does not 

provide any, let alone robust, competition on any basis deemed important by the Department. It is 

hard to inject competition when you don't fly, but it is easy to prevent competition when you deny 

others the opportunity to utilize appropriately the scarce Haneda slot pair, as well as block progress 

at the negotiating table. 

And, while Delta maintains control of the Seattle-Haneda slot pair by operating sporadically, 

it should be noted that: 

• Every other Haneda service, operated by U.S. and Japanese carriers alike, operates on a 

daily basis (Exhibit AA-324, p 5-7); 

• Delta continues to operate its Seattle-Narita service on a daily basis and with a larger 

aircraft (Exhibit AA-324, p 2); and 

• Despite irregular operations, at best, on the Seattle-Haneda route, Delta continues to 

have the most flights between the United States and Tokyo of any airline, Japanese or 

U.S. (Exhibit AA-313) 

None of the public or economic benefits that the valuable Haneda flights can provide is being 

realized by Delta holding this Haneda slot pair and not utilizing it, day in and day out, week in and 

week out, month in and month out. Every other airline operating to Haneda - U.S., Japanese, or 

third country - is maximizing the benefits of its Haneda slot pair by operating on at least a daily 

basis. 

Robust Competition Would be Enhanced bv American's Proposed LAX-Haneda Service 

Delta's failure to operate a daily service on the Seattle-Haneda route significantly 

underutilizes a scarce and valuable aviation resource of the United States. Not only is the United 

States not realizing the maximum aviation or economic benefits achievable by proper utilization of 

this resource, but both the public interest and competition are being thwarted by Delta's nonutilization and underutilization of the Haneda slot pair and its unwillingness either to operate the 
Page 4 of 5 

service on a year-round daily basis or return the Seattle-Haneda slot pair so that they can be put a 

higher and better use. Delta's actions are inhibiting robust competition in a number of ways: 

• Inter-U.S. carrier competition: Delta is thwarting inter-U.S. carrier competition. 

American is the only U.S. airline that has no Haneda authority (Exhibit AA-207). By 

retaining a Haneda slot pair which it is not using in any meaningful or appropriate 

fashion, Delta is preventing American from using that slot pair to provide daily, yearround service from Los Angeles and, in the process, inject a new U.S. competitor to 

Haneda. 

• Inter-carrier competition: Delta is also thwarting overall carrier competition to Haneda. 

Every other U.S. and Japanese carrier serving Japan has Haneda authority (Delta, 

United, Hawaiian, JAL and ANA) except American (Exhibit AA-207). By preventing 

American from operating its proposed LAX-Haneda, Delta is keeping a vigorous and 

important competitor out of the market. 

• Intra-gateway competition: American's Los Angeles-Haneda service will provide real 

and beneficial U.S. carrier competition to Delta's Los Angeles-Haneda service in the 

largest US-Tokyo O&D market, as well as additional intra-gateway competition to ANA 

at Los Angeles. 

• Intra-gateway alliance competitiOn: At Los Angeles, only the SkyTeam and Star 

alliances (through the Haneda services of Delta and ANA, respectively) are present. 

There is no LAX-Haneda service available on oneworld, even though LAX is the largest 

Haneda O&D market in the U.S. By allowing American to operate its proposed LAXHaneda service, the Department will be injecting complete, three-way alliance 

competition in this, the largest Haneda O&D market from the U.S. 

• Enhanced inter-gateway, inter-alliance competition: By preventing American from 

operating the LAX-Haneda route, Delta is stymieing beneficial inter-gateway and interalliance competition between American at LAX and United at SFO. 

Clearly, by maintaining control of valuable Haneda slot pair that are, unarguably, being 

underutilized, at best, and unutilized, at worst, and by shutting American out of Haneda service at 

all, Delta is preventing robust competitive forces to work in the marketplace. This situation also 

deprives a substantial segment of the travelling and shipping public -and all of American's 

passengers- from having any access to Haneda on American's services. None of this maximizes 

the economic benefits to the United States, enhances competition or serves or benefits the 

consumer. 

As I stated at the beginning of my testimony, gammg access to Tokyo's Haneda 

International Airport is a top American priority. Seeing that the valuable and scarce Haneda slot 

assets are utilized in a fashion that maximizes consumer benefits, competition and economic 

benefits to the entire United States is clearly a Department objective. By allocating to American the 

authority to operate Los Angeles-Haneda service, both of these important objectives can be 

achieved. 
Page 5 of 5 

I thank you for the opportunity to present this testimony on behalf of American and on 

behalf of our tremendous and caring workforce. We are incredibly fortunate to have had the 

opportunity to steward American Airlines to a position of industry leadership and create an 

environment in which its employees are proud to work and an airline on which our customers are 

proud to fly. The management of American fully intends to continue down this path and to provide 

all consumers with the greatest and most passenger friendly services possible. Being able to fly Los 

Angeles-Haneda is an important step in fulfilling that objective. 

Thank you. 

Andrew P. Nocella 
9

Series 100: Schedule and 

Equipment
NARRATIVE TO THE 100 SERIES OF EXHIBITS

The 100 Series of Exhibits details American Airlines’ proposed Los Angeles-Haneda service, and provides required 

information as detailed in the Instituting Order. 

Exhibit AA-101 is a map depicting American Airlines’ proposed Los Angeles-Tokyo Haneda service. Exhibit AA-102 shows 

the detailed schedule for the Los Angeles-Haneda service, including flight numbers, aircraft type (Boeing 777-200), departure/arrival 

times and elapsed times to/from Los Angeles and Tokyo Haneda. This information is provided for summer and winter season. 

Exhibit AA-103 illustrates the detailed operating statistics for the proposed route including estimated fuel burn and the seating 

configuration of the 777-200 aircraft (AA-104).

Exhibit AA-105 shows the seating configurations of American and US Airways aircraft that will connect at Los Angeles. 

Exhibit AA-106 illustrates the size and breadth of the American’s Los Angeles hub which connects our passengers to 58 airports on 

five continents. 

Exhibit AA-107 shows the number of connections that the American LAX-Haneda service will connect in both directions 

during both the summer and winter traffic seasons. More detailed schedule information is also provided in AA Exhibits 501 and 502. 

Exhibits AA-108 and 109 provide summaries of American’s daily cargo capability on the Los Angeles-Haneda route.

Additional cargo information is also available in Exhibits AA-503 and 504. 
10

#LetAAFlyHaneda

American Airlines’ Proposed Los Angeles–Haneda Service

Tokyo-Haneda (HND)

Los Angeles (LAX)

DOT Docket OST-2010-0018

Exhibit AA-101

Page 1 of 1
11

#LetAAFlyHaneda

AMERICAN AIRLINES

LAX–HND Daily Nonstop Service

Summer

(March-October)

2015

AA 125 Flight Number AA 126

Daily Frequency Daily

B772* Equipment B772

1830 Los Angeles (LAX) 1830(-1)

| ^

| |

| |

V |

2230 (+1) Tokyo Haneda (HND) 0000

12:00 Elapsed Time 10:30

AMERICAN AIRLINES

LAX–HND Daily Nonstop Service

Winter

(October-March)

2015-16

AA 125 Flight Number AA 126

Daily Frequency Daily

B772 Equipment B772

1700 Los Angeles (LAX) 1700(-1)

| ^

| |

| |

v |

2230 (+1) Tokyo Haneda (HND) 0000

12:30 Elapsed Time 10:00

American Airlines’ Proposed LAX-HND Schedule and Service

DOT Docket OST-2010-0018

Exhibit AA-102

Page 1 of 1

* B772 = Boeing 777-200 
12

#LetAAFlyHaneda

American Airlines’ Proposed LAX-HND Operating Statistics

DOT Docket OST-2010-0018

Exhibit AA-103

Page 1 of 1

Source: American Airlines

AMERICAN AIRLINES

LAX–HND Service

Annual Operating Statistics (Daily)

Summer and Winter

Aircraft B772

Departures 730

Segment Miles 5,488

Plane Miles 4,006,240

ASMs 989,541,280

Fuel Burn (Gallons/Hour) 2,320 

Fuel Consumption (000 Gallons) 17,867

Seating Configuration 

First Class 16

Business Class 37

Economy Class 194

Total 247

FUEL AVAILABILITY - American anticipates no difficulty in obtaining fuel from its

existing suppliers at Los Angeles and anticipates no difficulty in re-establishing its relationships at 

Haneda.

AIRCRAFT AVAILABILITY - American will use the 777-200 aircraft currently in its fleet. Service 

will initially be operated with the 247-seat configuration. In 2015, AA will continue to phase-in its 

new retrofitted 260-seat product, with the 45J, 55 Main Cabin Extra, and 160Y configuration. One 

first class seat is blocked from sale to conform with crew rest obligations.
13

#LetAAFlyHaneda

American Airlines’ B777–200 Seat Configuration

Cabin Class Seats

First Class 16

Business Class 37

Economy Class 194

Total 247

Source: American Airlines

DOT Docket OST-2010-0018

Exhibit AA-104

Page 1 of 1

AIRCRAFT AVAILABILITY - American will use the 777-200 aircraft currently in 

its fleet. Service will initially be operated with the 247-seat configuration. In 

2015, AA will continue to phase-in its new retrofitted 260-seat product, with the 

45J, 55 Main Cabin Extra, and 160Y configuration. One first class seat is 

blocked from sale to conform with crew rest obligations.
14

#LetAAFlyHaneda

American Airlines’ Connecting Aircraft Seat Configuration

Source: American Airlines

DOT Docket OST-2010-0018

Exhibit AA-105

Page 1 of 1
15

#LetAAFlyHaneda

American Airlines’ Los Angeles Hub Connects 58 Airports to LAX

* Seasonal service; ** Service offered by Qantas; *** Service offered by Iberia Airlines 1Atlanta service starts March 5, 2015

Source: American Airlines and OAG flight schedules

Tokyo (NRT)

Shanghai

Edmonton

Vancouver

Eugene

Sacramento

San Francisco

San Jose

Monterey

Fresno

San Diego

San Jose Del Cabo

Lihue

Honolulu

Maui

Kona

Brisbane**

Sydney**

Melbourne**

Salt Lake City Reno Las Vegas

Denver

Vail*

Aspen*

Toronto

Chicago

Indianapolis

Columbus

Pittsburgh

Philadelphia

Boston

New York (JFK)

Washington, D.C. (DCA)

Charlotte

Raleigh/Durham

Washington, D.C. (IAD)

London (LHR)

Madrid*** Tampa

Orlando

West Palm Beach

Miami

Atlanta1

Sao Paulo

St. Louis

Nashville

NW Arkansas

Oklahoma City

Dallas/Fort Worth

Austin

Houston (IAH)

El Paso

San Antonio

Phoenix

 Tucson

 Santa Fe

 Albuquerque

DOT Docket OST-2010-0018

Exhibit AA-106

Page 1 of 1
16

#LetAAFlyHaneda

American’s Proposed Los Angeles-Haneda Service Connecting Market 

Summary for Markets Connecting in Both Directions – Summer Schedule

DOT Docket OST-2010-0018

Exhibit AA-107

Page 1 of 2

MIA

Note: Connecting details can be found at Exhibit AA-501.

Source: OAG flight schedules for August 15, 2015, as of December 24, 2014

25 Markets

PHX ATL

LAS

JFK

SMF

SFO

SJC

BOS

ORD

DFW

RNO

PBI

IAD

CLT

PHL

DEN

EUG

FAT

MRY

BNA

TPA

MCO

LAX

YVR

YYZ
17

#LetAAFlyHaneda Note: Connecting details can be found at Exhibit AA-502

Source: OAG flight schedules for March 19, 2015, as of December 24, 2014

DOT Docket OST-2010-0018

Exhibit AA-107

Page 2 of 2

MIA

PHX

SAN

AUS

TUS

IAH

SLC

GRU

SAT

ELP

ATL

LAS

JFK

SMF

SFO

SJC

BOS

ORD

DFW

RNO

PBI

IAD

CLT

PHL

DEN

EUG

FAT

MRY

BNA

TPA

MCO

LAX

YVR

American’s Proposed Los Angeles-Haneda Service Connecting Market 

Summary for Markets Connecting in Both Directions – Winter Schedule

32 Markets
18

#LetAAFlyHaneda

American Airlines’ LAX-HND Cargo Capacity at 100% Load Factor

Haneda Monthly Cargo Capacity-Per Flight

at 100% Passenger Load Factor

Equipment Seats Orig Dest Season Month

Payload

lbs

Pax Demand 

(%LF)

Equivalent 

Pax Count

Pax & Bags 

Payload-lbs

Cargo Capability 

Based on Pax

Demand

B777-223ER 247 LAX HND Dec 101,800 100 247 59,280 42,520

Winter Jan 101,800 100 247 59,280 42,520

Feb 101,800 100 247 59,280 42,520

Mar 101,800 100 247 58,045 43,755

Spring Apr 101,800 100 247 58,045 43,755

May 101,800 100 247 58,045 43,755

Jun 101,800 100 247 58,045 43,755

Summer Jul 101,800 100 247 58,045 43,755

Aug 101,800 100 247 58,045 43,755

Sep 101,615 100 247 59,280 42,335

Fall Oct 101,615 100 247 59,280 42,335

Nov 101,615 100 247 59,280 42,335

Annual 

Average 101,754 100 247 58,663 43,091

B777-223ER 247 HND LAX Dec 101,800 100 247 59,280 42,520

Winter Jan 101,800 100 247 59,280 42,520

Feb 101,800 100 247 59,280 42,520

Mar 101,800 100 247 58,045 43,755

Spring Apr 101,800 100 247 58,045 43,755

May 101,800 100 247 58,045 43,755

Jun 101,800 100 247 58,045 43,755

Summer Jul 101,800 100 247 58,045 43,755

Aug 101,800 100 247 58,045 43,755

Sep 101,800 100 247 59,280 42,520

 Fall Oct 101,800 100 247 59,280 42,520

 Nov 101,800 100 247 59,280 42,520

Annual 

Average 101,800 100 247 58,663 43,138

Note: Cargo capacity of connecting flights can be found at Exhibit 503

Source: American Airlines

DOT Docket OST-2010-0018

Exhibit AA-108

Page 1 of 1
19

#LetAAFlyHaneda

American Airlines’ LAX-HND Cargo Capacity at 80% Load Factor 

DOT Docket OST-2010-0018

Exhibit AA-109

Page 1 of 1

Haneda Monthly Cargo Capacity-Per Flight

at 80% Passenger Load Factor

Equipment Seats Orig Dest Season Month Payload lbs

Pax Demand 

(%LF)

Equivalent 

Pax Count

Pax & Bags 

Payload-lbs

Cargo Capability 

Based on Pax

Demand

B777-223ER 247 LAX HND Dec 101,800 80 198 47,424 54,376

Winter Jan 101,800 80 198 47,424 54,376

Feb 101,800 80 198 47,424 54,376

Mar 101,800 80 198 46,436 55,364

Spring Apr 101,800 80 198 46,436 55,364

May 101,800 80 198 46,436 55,364

Jun 101,800 80 198 46,436 55,364

Summer Jul 101,800 80 198 46,436 55,364

Aug 101,800 80 198 46,436 55,364

Sep 101,615 80 198 47,424 54,191

Fall Oct 101,615 80 198 47,424 54,191

Nov 101,615 80 198 47,424 54,191

Annual 

Average 101,754 80 198 46,930 54,824

B777-223ER 247 HND LAX Dec 101,800 80 198 47,424 54,376

Winter Jan 101,800 80 198 47,424 54,376

Feb 101,800 80 198 47,424 54,376

Mar 101,800 80 198 46,436 55,364

Spring Apr 101,800 80 198 46,436 55,364

May 101,800 80 198 46,436 55,364

Jun 101,800 80 198 46,436 55,364

Summer Jul 101,800 80 198 46,436 55,364

Aug 101,800 80 198 46,436 55,364

Sep 101,800 80 198 47,424 54,376

 Fall Oct 101,800 80 198 47,424 54,376

 Nov 101,800 80 198 47,424 54,376

Annual 

Average 101,800 80 198 46,930 54,870

Note: Cargo capacity of connecting flights can be found at Exhibit 504

Source: American Airlines
20

Series 200: 

American’s Proposed Los Angeles-Haneda 

Service is Superior to Delta’s Sporadic Use 

of the Haneda Slot Pair on Seattle-Haneda
NARRATIVE TO THE 200 SERIES OF EXHIBITS

The 200 Series of Exhibits details why American’s proposed Los Angeles-Haneda service maximizes the public benefits of the 

Haneda slot pair under review in this proceeding, and why the Department should allocate that slot pair to American. The 200 Series

of Exhibits focuses broadly on the relative size of the Los Angeles-Tokyo market and, more specifically, on the Los Angeles-Haneda 

market. Additionally, the Exhibits demonstrate why Los Angeles merits first-ever American and first-ever oneworld service to

Haneda. Exhibits AA-201 and AA-203 highlight that Los Angeles is the largest continental U.S. market to Tokyo. Exhibit AA-210 

demonstrates that the Los Angeles-Tokyo market is underserved compared to the Seattle-Tokyo market.

Exhibits AA-202, 204, 205 and 206 provide direct comparisons of the broader Los Angeles-Tokyo market with the SeattleTokyo market, as well as the Los Angeles-Haneda market with the Seattle-Haneda market. Exhibit AA-206 demonstrates that the Los 

Angeles-Haneda market is approximately five times the size of the Seattle-Haneda market. Exhibits AA-211, 212, and 213 indicate

that Los Angeles-Haneda is underserved in terms of seats relative to Seattle-Haneda. These exhibits also demonstrate that Los 

Angeles is seat deficit relative to Seattle, given the significantly larger Los Angeles-Tokyo O&D demand than Seattle-Tokyo. Exhibit 

AA-213 also shows that American would offer the most seats of any carrier flying between Los Angeles and Haneda, and would offer 

more premium seats than Delta. 

Exhibits AA-207 and 208 depict that American is the only U.S. carrier serving Japan that does not have access to Haneda. 

Exhibit AA-208 similarly illustrates that oneworld is the only alliance without Los Angeles-Haneda service, and that an additional 

alliance entrant would provide much needed competition to the SkyTeam and Star alliances’ Haneda services at Los Angeles – the 

largest Tokyo O&D market in the continental United States.
Exhibit AA-214 demonstrates that American’s Los Angeles-Haneda service will connect more unique U.S. behind-gateway 

cities than Delta’s existing Seattle-Haneda service. A corollary exhibit, AA-215, shows how American’s Los Angeles-Haneda service 

will generate over 210,000 more O&D passengers than Delta’s current Seattle connecting markets. Exhibit AA-216 illustrates that 

American’s Los Angeles-Haneda flight will serve nearly 2.5 times as many unique connecting markets as Hawaiian’s HonoluluHaneda service. Exhibit AA-217 shows that American’s Los Angeles-Haneda connecting markets will generate 324,000 more O&D 

passengers than Hawaiian’s Haneda connecting markets. Exhibit AA-218 illustrates that American will serve 20 percent more unique 

connecting markets than Delta’s existing Los Angeles-Haneda service. Exhibit AA-219 shows American’s Los Angeles connecting 

markets will generate over 256,000 O&D passengers. Exhibits AA-220 shows that American’s Los Angeles-Haneda service will 

serve six times more unique connecting markets than ANA’s Los Angeles-Haneda Service, and exhibit AA-221 shows that American 

will generate almost one million more O&D passengers than ANA’s Los Angeles-Narita connecting markets.

Exhibit AA-222 completes the description of American’s Los Angeles-Haneda service proposal, and shows that American will 

offer more cargo capacity for shippers than Delta on the Los Angeles-Haneda route and almost 20 million more pounds of cargo 

capacity annually than Delta’s Seattle and Los Angeles services to Haneda.

The conclusion of this 200 Series of Exhibits is that Los Angeles clearly has substantial unmet demand today for an additional 

Haneda service and that, by allocating to American the indisputably underutilized slot pair currently used by Delta for Seattle-Haneda,

the Department can remedy American’s and oneworld’s conspicuous absence from the Los Angeles-Haneda market; can increase 

competition significantly; and, can ensure the maximization of the public benefits of this scarce resource. 
21

#LetAAFlyHaneda

593

408

292

141 132 129

97 86 80 75 70 59 53 52 49 49 41

LAX JFK SFO LAS ORD SEA BOS IAD SAN MCO EWR SJC PDX DTW IAH ATL DFW

Continental U.S. PPDEW to Tokyo (NRT/HND)

Year Ending November 2014 

Los Angeles Is, By Far, the Largest Continental U.S. Market to 

Tokyo – Twice as Large as the Next Largest Market with Haneda 

Service (SFO) and 4.6 Times the Size of Seattle

Source: O&D passengers, MIDT YE November 2014

DOT Docket OST-2010-0018

Exhibit AA-201

Page 1 of 1
22

#LetAAFlyHaneda

432,525

93,892

LAX SEA

Annual O&D Passengers to Tokyo (NRT/HND)

Year Ending November 2014 

Los Angeles Has Almost 340,000 More Annual O&D 

Passengers to Tokyo Than Seattle

Source: O&D passengers, MIDT YE November 2014

DOT Docket OST-2010-0018

Exhibit AA-202

Page 1 of 1
23

#LetAAFlyHaneda

137

89

36

28

9

4 4 4 3 3 3 2 2 2 2 2 2

LAX SFO LAS SEA JFK SAN MCO PDX BOS PHX IAH ATL ORD DTW SLC IAD EWR

Continental U.S. PPDEW to Haneda

Year Ending November 2014 

Los Angeles Is, By Far, the Largest Continental U.S. Market to Haneda

Source: O&D passengers, MIDT YE November 2014

DOT Docket OST-2010-0018

Exhibit AA-203

Page 1 of 1
24

#LetAAFlyHaneda

99,681

20,377

LAX SEA

Annual O&D Passengers to Haneda

Year Ending November 2014 

Los Angeles Has Almost 80,000 More Annual O&D 

Passengers to Haneda Than Seattle

Source: O&D passengers, MIDT YE November 2014

DOT Docket OST-2010-0018

Exhibit AA-204

Page 1 of 1
25

#LetAAFlyHaneda

Los Angeles–Tokyo Demand Is 4.6 Times the Demand of Seattle-Tokyo

593

129

LAX SEA

PPDEW to Tokyo (NRT/HND)

Year Ending November 2014 

Source: O&D passengers, MIDT YE November 2014

DOT Docket OST-2010-0018

Exhibit AA-205

Page 1 of 1
26

#LetAAFlyHaneda

137

28

LAX SEA

PPDEW to Haneda

Year Ending November 2014 

Source: O&D passengers, MIDT YE November 2014

DOT Docket OST-2010-0018

Exhibit AA-206

Page 1 of 1 Los Angeles-Haneda Demand Is 4.9 Times the Demand 

of Seattle-Haneda
27

#LetAAFlyHaneda

LAX

SEA

SFO

HNL

Delta

Delta

United

Hawaiian

U.S. Airline Routes to Haneda

HND

American Is the Only U.S. Airline Serving Japan That Does 

Not Have Access to Haneda

Source: 2015 flight schedules 

DOT Docket OST-2010-0018

Exhibit AA-207

Page 1 of 1

American LAX-HND Service Would Provide:

 - A New Competitor in the U.S.-Haneda Market

 - A New Competitor at LAX

 - First-time oneworld Presence at LAX
28

#LetAAFlyHaneda

U.S. And Japanese Airline LAX-Haneda Routes

Oneworld Is the Only Alliance Without LAX Access to Haneda

SkyTeam

Star

Source: 2015 flight schedules 

DOT Docket OST-2010-0018

Exhibit AA-208

Page 1 of 1

HND LAX

American LAX-HND Service Would Provide First-time 

oneworld Competition to SkyTeam and Star Alliances at LAX
29

#LetAAFlyHaneda

Los Angeles’ Tokyo O&D Is Almost Five Times The Size of

Seattle’s O&D – Almost 340,000 More Passengers

432,525

93,892

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

450,000

500,000

LAX SEA

Continental U.S.–Tokyo Annual Passengers

YE November 2014

LAX O&D Almost 

5 Times the Size 

of SEA O&D

Source: MIDT YE November 2014

DOT Docket OST-2010-0018

Exhibit AA-209

Page 1 of 1
30

#LetAAFlyHaneda

LAX-Tokyo Is Underserved Relative to SEA-Tokyo: 

SEA Has 37% More Seats per O&D Tokyo Passenger Than Los Angeles

3.1

2.2

Seattle Seats/O&D LAX Seats/O&D

Departing Seats per Tokyo O&D Passenger

Year Ending June 2014

Note: YE June 2014 used as reference period because Delta operated with more regular frequency during that period. If Delta SEA-HND were assumed to operate daily, that would 

further increase the over-service gap between SEA and LAX in terms of seats per O&D passenger.

Source: MIDT and OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-210

Page 1 of 1

Departing Seats 296,559 965,633

O&D Passengers to/from 

Tokyo

96,634 432,334

Departing Seats/O&D Pax 3.1 2.2

Difference 37%
31

#LetAAFlyHaneda

LAX-Haneda Is Underserved Relative to SEA-Haneda Under Any Measure 

3.6

1.6

SEA HND Seats/O&D LAX HND Seats/O&D

Departing Seats per Haneda O&D Passenger

Year Ending June 2014

Note: Assumes Delta operated daily SEA-HND 767 flight with 211 seats during the year ending June 2014.

Source: MIDT and OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-211

Page 1 of 1

2.9

1.6

SEA HND Seats/O&D LAX HND Seats/O&D

Delta’s Service

as Operated

Delta’s

Promised Daily Service

Commitment

Departing Seats 62,841 165,118 77,015 165,118

HND O&D Pax 21,401 101,598 21,401 101,598

Departing 

Seats/O&D

2.9 1.6 3.6 1.6

Difference 81% 121%

LAX Underserved

by 81%

LAX Underserved

by 121%
32

#LetAAFlyHaneda

The Los Angeles Market Needs More Flights Than Seattle to 

Accommodate Unfulfilled Demand

432,525

93,892

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

450,000

500,000

LAX SEA

Los Angeles O&D Is Almost 5X Larger Than 

Seattle’s

LAX 5X Seattle

Los Angeles only has 2X the number of 

Tokyo flights as Seattle

LAX 2X Seattle

Continental U.S.-Tokyo Annual Passengers

YE November 2014

SEA

LAX

TYO

Source: MIDT YE November 2014, OAG flight schedules

...yet

DOT Docket OST-2010-0018

Exhibit AA-212

Page 1 of 1
33

#LetAAFlyHaneda

American Will Be Able to Fill the Unmet Demand at LAX by Operating 

the Most Seats on LAX-HND . . . and More Premium Seats Than Delta

Cabin Class Seats Retrofitted

First Class 16 --

Business Class 37 45

Economy Class 194 55/160

Total 247 260 *

American Airlines 777-200

Source: American Airlines, carrier websites

DOT Docket OST-2010-0018

Exhibit AA-213

Page 1 of 1

Cabin Class Seats

First Class 0

Business Class 70

Economy Class 153

Total 223

All Nippon 

777-200

Cabin Class Seats

First Class 0

Business Class 36

Economy Class 172

Total 208

Delta Air Lines

767-300

* Service will initially be operated with the 247-seat configuration. In 2015, American will 

continue to phase-in its new retrofitted 260-seat product, with the 45J, 55 Main Cabin 

Extra, and 160Y configuration. One first class seat is blocked from sale to conform with 

crew rest obligations.
34

#LetAAFlyHaneda

American’s LAX-HND Service Will Serve More Unique U.S. 

Connecting Markets Than Delta’s Existing SEA-HND Service

Markets connecting in BOTH directions

Overlap Unique to AA LAX-HND Unique to DL SEA-HND

Overlap

Unique to 

AA

LAX-HND

Unique to DL

SEA-HND

9 15 11

Source: OAG flight schedules, August 2015. LAX is considered an overlapping market.

DOT Docket OST-2010-0018

Exhibit AA-214

Page 1 of 1

CVG

FAI

ATL

LAS

MSP

JFK

PHX

SMF

SFO

SJC

BOS

ORD

DFW

MIA

RNO

SEA

PBI

IAD

CLT

PHL

GEG

PDX

SAN

DEN

EUG

FAT

MRY

BNA

TPA

DTW

MCO

LAX

ANC

JNU

SIT

BOI
35

#LetAAFlyHaneda

AA/DL Unique Connecting Markets and Tokyo O&D Passengers

387,776

173,010

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

450,000

AA DL

Year Ending November 2014

Source: O&D passengers, MIDT YE November 2014. Washington includes IAD and DCA.

DOT Docket OST-2010-0018

Exhibit AA-215

Page 1 of 1

Unique AA LAX-HND Tokyo O&D Unique DL SEA-HND Tokyo O&D

Boston 71,029 Anchorage 3,796

Charlotte 6,424 Boise 4,964

Chicago - ORD 96,506 Cincinnati 7,446

Dallas-Ft. Worth 30,003 Detroit 37,887

Eugene 1,168 Fairbanks 2,482

Fresno 1,095 Juneau 146

Miami 17,739 Minneapolis-St. Paul 17,739

Monterey, CA 365 Portland, OR 38,617

Nashville 14,454 San Diego 58,254

Orlando 55,042 Sitka 0

Philadelphia 11,169 Spokane 1,679

Reno 1,679 

Tampa 6,497 

Washington - IAD 73,219 

West Palm Beach 1,387 

Total 387,776 173,010 

American’s LAX-HND Connecting Markets Generate Over 210,000

More O&D Passengers Than Delta’s SEA Connecting Markets

Markets connecting in BOTH directions
36

#LetAAFlyHaneda

Hawaii

Overlap Unique to AA LAX-HND Unique to HA HNL-HND

Markets connecting in BOTH directions

Overlap

Unique to 

AA

LAX-HND

Unique to HA

HNL-HND

5 19 8

DOT Docket OST-2010-0018

Exhibit AA-216

Page 1 of 1 American’s LAX-HND Service Will Serve Almost 2.5 Times as Many Unique 

Connecting Markets as Hawaiian’s Existing HNL-HND Service

Source: OAG flight schedules, August 2015. LAX is considered an overlapping market.

HNL

ITO

LIH

LNY

MKK

OGG

KOA

ATL

LAS

JFK SMF

SFO

SJC

BOS

ORD

DFW

MIA

RNO

PBI

IAD

CLT

PHL

PDX

SAN

DEN

EUG

FAT

MRY

BNA

TPA

MCO

LAX

PHX
37

#LetAAFlyHaneda

AA/HA Unique Connecting Markets and Tokyo O&D Passengers

Source: O&D passengers, MIDT YE November 2014, and OAG flight schedules. Washington includes IAD and DCA.

504,649

180,456

0

100,000

200,000

300,000

400,000

500,000

600,000

AA HA

Year Ending November 2014

DOT Docket OST-2010-0018

Exhibit AA-217

Page 1 of 1

Unique AA LAX-HND Tokyo O&D Unique HA HNL-HND Tokyo O&D 

Atlanta 35,989 Hilo 4,818 

Boston 71,029 Kona 57,305 

Charlotte 6,424 Lanai 219 

Chicago – ORD 96,506 Lihue 4,453 

Dallas-Ft. Worth 30,003 Maui 16,790 

Denver 20,294 Molokai - 

Eugene 1,168 Portland 38,617 

Fresno 1,095 San Diego 58,254 

Miami 17,739 

Monterey, CA 365 

Nashville 14,454 

Orlando 55,042 

Philadelphia 11,169 

Phoenix 17,520 

Reno 1,679 

San Jose, CA 43,070 

Tampa 6,497 

Washington - IAD 73,219 

West Palm Beach 1,387 

Total 504,649 180,456 

American’s LAX-HND Connecting Markets Generate 324,000 More

O&D Passengers Than Hawaiian’s HNL Connecting Markets

Markets connecting in BOTH directions
38

#LetAAFlyHaneda

Overlap Unique to AA LAX-HND Unique to DL LAX-HND

Overlap

Unique to 

AA

LAX-HND

Unique to DL

LAX-HND

11 12 10

Source: OAG flight schedules, August 2015.

MIA

DOT Docket OST-2010-0018

Exhibit AA-218

Page 1 of 1

American’s Proposed LAX-HND Service Will Serve 20% More 

Unique U.S. Connecting Markets Than Delta’s Existing LAX-HND Service

Markets connecting in BOTH directions

CVG

IND

MEM

OAK

PHX

PDX

RDU

SAN

ATL

LAS

MSP

JFK

SMF

SFO

SJC

BOS

ORD

DFW

RNO

SEA

PBI

IAD

CLT

PHL

DEN

EUG

FAT

MRY

BNA

TPA

DTW

MCO

LAX
39

#LetAAFlyHaneda

AA Unique Connecting Markets and Tokyo O&D Passengers

Source: O&D passengers, MIDT YE November 2014. Washington MIDT includes IAD and DCA.

Unique AA LAX-HND Tokyo O&D 

Charlotte 6,424 

Chicago - ORD 96,506 

Dallas-Ft. Worth 30,003 

Denver 20,294 

Eugene 1,168 

Fresno 1,095 

Monterey, CA 365 

Nashville 14,454 

Philadelphia 11,169 

Reno 1,679 

Washington – IAD 73,219 

West Palm Beach 1,387 

Total 256,376 

DOT Docket OST-2010-0018

Exhibit AA-219

Page 1 of 1 American’s LAX Connecting Markets Generate Over 256,000

O&D Passengers

Markets connecting in BOTH directions
40

#LetAAFlyHaneda

American’s LAX-HND Service Will Serve 6 Times More 

Unique Connecting Markets Than ANA’s Existing LAX-HND Service 

Markets connecting in BOTH directions, connecting markets for NH are operated by UA

Overlap Unique to AA LAX-HND Unique to NH LAX-HND

Overlap

Unique to 

AA

LAX-HND

Unique to NH

LAX-HND

2 21 3

Source: OAG flight Schedules

ATL

LAS

JFK

SMF

SFO

SJC

BOS

ORD

DFW

MIA

RNO

PBI

IAD

CLT

PHL

DEN

EUG

FAT

MRY

BNA

TPA

MCO

LAX PHX

TUS

SAN

SLC

DOT Docket OST-2010-0018

Exhibit AA-220

Page 1 of 1
41

#LetAAFlyHaneda

AA/NH (UA*) Unique Connecting Markets and Tokyo O&D Passengers

Source: O&D passengers, MIDT YE November 2014, and flight schedules. NH connecting markets operated by UA.. Washington includes DCA and IAD. 

New York includes JFK, LGA and EWR. 

1,061,78

5

75,628

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

AA NH

Year Ending November 2014

DOT Docket OST-2010-0018

Exhibit AA-221

Page 1 of 1

Unique AA LAX-HND Tokyo O&D Unique NH LAX-NRT Tokyo O&D

Atlanta 35,989 Salt Lake City 14,308 

Boston 71,029 San Diego 58,254 

Charlotte 6,424 Tucson 3,066 

Chicago- O’Hare 96,506

Dallas/Ft. Worth 30,003 

Denver 20,294 

Eugene 1,168 

Fresno 1,095 

Miami 17,739 

Monterey, CA 365 

Nashville 14,454 

New York Kennedy 358,649 

Orlando 55,042 

Philadelphia 11,169 

Reno 1,679 

Sacramento 3,066 

San Francisco 212,941 

San Jose , CA 43,070 

Tampa 6,497 

Washington-IAD 73,219 

West Palm Beach 1,387 

Total 1,061,785 75,628 

American’s LAX-HND Connecting Markets Generate Almost One Million

More O&D Passengers Than ANA’s LAX-NRT Connecting Markets

Markets connecting in BOTH directions

1,061,785

75,628
42

#LetAAFlyHaneda

American’s B777 Will Provide Superior Cargo Capacity to Delta’s B767

10,704,720

0

5,000,000

10,000,000

15,000,000

20,000,000

25,000,000

30,000,000

35,000,000

American Delta

Annual Cargo Capacity

(pounds)

Source: Delta submissions to U.S. Department of Transportation, American Airlines

DOT Docket OST-2010-0018

Exhibit AA-222

Page 1 of 1

Cargo Capacity

Average per Flight

Both Directions – Winter and Summer 

Assumes 100% Load Factor

43,114

14,664

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

45,000

50,000

American Delta

 

31,473,220 

American would provide 

over 20 Million more 

pounds of annual cargo

capacity than Delta

B777-200 B767 B777-200 B767
43

Series 300

Delta’s History of Serving Haneda:

Numerous Promises, Failed Commitments, 

Musical Gateways, Fiction-Based Excuses 

and, Finally, Seatless in Seattle
NARRATIVE TO THE 300 SERIES OF EXHIBITS

The 200 Series of Exhibits demonstrated the superiority of American’s proposed Los Angeles-Haneda service and the 

significant public benefits that service would produce. The 300 Series of Exhibits focuses on Delta’s use of its Haneda slot pair 

allocation for Seattle-Haneda and Delta’s significant misuse and underutilization of that slot pair, both at Detroit, which was the 

originally selected gateway, and at Seattle.

The 300 Series of Exhibits describes the several commitments Delta made to serve Haneda and its failures to do so in a manner 

that serves the traveling public. In these Exhibits, American describes in detail the many commitments that Delta made to the 

Department and the traveling public to use the scarce Haneda resource, and its repeated failures to do so.

Exhibit AA-301 illustrates that Delta made the promise to serve the Detroit-Haneda market with a B747-400 aircraft

containing 403 seats, yet downgauged that aircraft to an A330 with only 241 seats, a nearly 60 percent reduction in capacity. Exhibits

AA-302, AA-303, and AA-304 show that Delta operated a mere 42 percent of the frequencies promised, and, when coupled with the 

downgauge to the A330, only 29 percent of the seats that it had pledged were offered to customers.

Exhibits AA-305 and AA-306 show that Delta’s habit of broken promises continued, this time in the Los Angeles-Haneda 

market. It took Delta merely 35 days to downgauge the 403-seat B747-400 to a 269-seat B777 in the Los Angeles-Haneda market. 

Then, after only six months, Delta downgauged the aircraft yet again from the B777 to a 241 seat A330. Finally, since March 2013,

Delta has operated a 208 seat B767 aircraft. Exhibit AA-307 illustrates how Delta is now providing approximately 50 percent of the 

seats it promised on the Los Angeles-Haneda route. 
With respect to its current Seattle-Haneda service, Exhibits AA-308-314 show how Delta also has not lived up to its 

commitments concerning that market. Between June 1, 2013 and March 31, 2015, Delta will have operated the Seattle-Haneda route 

only 40.8 percent of the time. The Exhibit shows that Delta will operate Seattle-Haneda only 17 days during a 182-day period. 

While essentially abandoning the Seattle-Haneda market, Delta has maintained daily service from Seattle to Tokyo Narita. 

Exhibits AA-315 and AA-316 show that Delta has maintained its full Seattle-Narita schedule and offers more than double the number 

of seats on the Seattle-Narita route as it offers on the Seattle-Haneda route. Exhibits AA-317 through AA-319 show how Delta is 

competing against itself in both the Seattle market (serving both Narita and Haneda) and the Haneda market (serving both Seattle and 

Los Angeles). 

Exhibits AA-320 through AA-323 demonstrate the astonishingly low load factor of Delta’s Seattle-Haneda service compared 

to other airlines operating in the U.S.-Haneda market, and on Delta’s other Tokyo services. In Exhibit AA-324, American presents 

over 10 pages of evidence that clearly illustrate that, contrary to Delta’s excuse for not providing service in the Seattle-Haneda market, 

neither Haneda nor Tokyo as a whole is a seasonal market. 
44

#LetAAFlyHaneda

Delta’s Failed Detroit–Haneda Commitment

Delta Detroit Commitment Delta’s Actual Service

Aircraft B747-400 A330 (Downgraded after only 37 B747-400 flights)

Seats (per Flight) 403 241

Seats (Annual) 294,190 75,674

ASM’s (Annual) 1,885,757,900 486,432,472

Annual Departures 730 314 (2012)

Service Start Date January 2011 February 2011, then

Suspended April 2011

Resumed June 2011

Suspended September through most of April 2012

Ended October 2012

Source: Delta submissions to U.S. Department of Transportation, OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-301

Page 1 of 1
45

#LetAAFlyHaneda

Delta Operated Only 42% of the

Detroit–Haneda Flights It Promised to Operate

Delta Offered Only 28% of the Detroit–Haneda 

Seats It Promised to Provide

546

732

1278

226

314

540

2011 2012 Total

220,030

294,996

515,026

70,307 75,674

145,981

2011 2012 Total

(February-December)

57.1% 

less than 

committed

57.8% 

less than 

committed

58.6% 

less than 

committed

74.3% less 

than 

committed

71.7% 

less than 

committed

68.1% less 

than 

committed

Delta’s Failed Detroit–Haneda Commitment: Even Eliminating April and May 2011 as 

“Tsunami-Related” Service Interruption Months, Delta Operated Only 42% of the Flights and 

Offered Only 28% of the Seats It Promised to Provide in the Detroit–Haneda Market

Flights Committed 

versus 

Flights Actually Operated

Seats Committed

versus

Seats Actually Operated

(February-December)

Source: Delta submissions to U.S. Department of Transportation, OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-302

Page 1 of 1
46

#LetAAFlyHaneda

0

10

20

30

40

50

60

70

Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec

Flights Flown Flights Committed

2011

Delta’s Failed Detroit–Haneda Commitment: Flights 

Committed versus Flights Flown

2012

Source: Delta submissions to U.S. Department of Transportation, OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-303

Page 1 of 1

  
47

#LetAAFlyHaneda

0

5,000

10,000

15,000

20,000

25,000

30,000

Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec

Seats Flown Seats Committed

Delta’s Failed Detroit–Haneda Commitment: Seats 

Committed versus Seats Flown

2011 2012

Source: Delta submissions to U.S. Department of Transportation, OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-304

Page 1 of 1

 
48

#LetAAFlyHaneda

Delta’s Failed Los Angeles–Haneda Commitment

Delta’s

Los Angeles Commitment Delta’s Actual Service

Aircraft B747-400 B747-400 -> B777 -> A330 -> B767 (currently)

Seats (per Flight) 403 403 -> 269 -> 241 -> 208 (currently)

Seats (Annual) 294,190 148,044(currently)

Source: Delta submissions to U.S. Department of Transportation, OAG flight schedules, YE December 2014

DOT Docket OST-2010-0018

Exhibit AA-305

Page 1 of 1
49

#LetAAFlyHaneda

403

269

241

208

February-March 

2011

(37 Flights Only)

48% decrease in 

seats offered

Delta’s DOT 

Commitment

And After 

Only 35 

Flights

And, Then And, Now

Delta’s Failed Los Angeles–Haneda Commitment:

Delta’s Dwindling Los Angeles–Haneda Aircraft Size

June – November 

2011

November 2011-March 2013 March 2013-Present

10% 

decrease

14% 

decrease

Source: OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-306

Page 1 of 1

33% 

decrease
50

#LetAAFlyHaneda

Delta’s Failed Los Angeles–Haneda Commitment:

Seats Committed versus Seats Flown

294,190

151,840

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

Delta’s Service 

Commitment

Delta’s

Actual Service

Delta Is Providing Nearly 50% Fewer Seats on the

Los Angeles–Haneda Route Than It Proposed

Annual Seats

48.4% Fewer Seats Offered 

By Delta on 

Los Angeles-Haneda Route 

Than Delta Proposed

Source: Delta submissions to U.S. Department of Transportation, OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-307

Page 1 of 1
51

#LetAAFlyHaneda

Delta’s Failed Seattle Commitments . . . And There Are Several

In Its Proposal to Switch out SEA for DTW, Delta Reduced the Aircraft Type and Size

Originally Proposed for SEA from A330-300/298 seats to B767-300ER HD/225 seats 

-– a 24.5%Seat Reduction . . . 

 But, Still, it committed to Daily Service However . . .

Delta Seattle–Haneda Proposal

February 2010

Delta Seattle–Haneda Proposal

August 2012

Source: Delta submissions to U.S. Department of Transportation, OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-308

Page 1 of 1
52

#LetAAFlyHaneda

Delta’s Failed Seattle–Haneda Commitment:

Delta Has Not Lived Up to Its Substantially-Scaled Back Seattle-Haneda Service Proposal 

298

225

211

Delta’s Original 

Proposal

(February 2010)

Delta’s Scaled-back

Proposal

(August 2012)

24.5% 

decrease

29.2 % decrease

. . . And, Still Again, Delta Has Not Lived Up to Its Commitments, Resulting In 

What Delta is Operating

(When it Operates)

6.2% 

reduction

Delta Has Downgraded the B767 It Operates on the

Seattle-Haneda Route – When it Operates – to 211 Seats

Source: Delta submissions to U.S. Department of Transportation, OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-309

Page 1 of 1
53

#LetAAFlyHaneda

Delta’s Failed Seattle–Haneda Commitment: Seatless in Seattle

1,034

421

June 1, 2013 – March 31, 

2015

(1,034 days)

Delta’s

Total Flights 

Operated/Scheduled

Delta Will Have Operated the 

Seattle-Haneda Route Only 

40.8% of the Time

(June 1, 2013 – March 31, 2015)

Delta’s Current Seattle-Haneda “Offering” 

Flights Committed by Delta versus Flights Actually Operated

Source: Delta submissions to U.S. Department of Transportation, OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-310

Page 1 of 1
54

#LetAAFlyHaneda

Delta’s Failed Seattle–Haneda Commitment: Seatless in Seattle

OCTOBER 2014

SUN MON TUE WED THU FRI SAT

1 2 3 4

5 6 7 8 9 10 11

12 13 14 15 16 17 18

19 20 21 22 23 24 25

26 27 28 29 30 31

NOVEMBER 2014

SUN MON TUE WED THU FRI SAT

1

2 3 4 5 6 7 8

9 10 11 12 13 14 15

16 17 18 19 20 21 22

23 24 25 26 27 28 29

30

DECEMBER 2014

SUN MON TUE WED THU FRI SAT

1 2 3 4 5 6

7 8 9 10 11 12 13

14 15 16 17 18 19 20

21 22 23 24 25 26 27

28 29 30 31

JANUARY 2015

SUN MON TUE WED THU FRI SAT

1 2 3

4 5 6 7 8 9 10

11 12 13 14 15 16 17

18 19 20 21 22 23 24

25 26 27 28 29 30 31

FEBRUARY 2015

SUN MON TUE WED THU FRI SAT

1 2 3 4 5 6 7

8 9 10 11 12 13 14

15 16 17 18 19 20 21

22 23 24 25 26 27 28

MARCH 2015

SUN MON TUE WED THU FRI SAT

1 2 3 4 5 6 7

8 9 10 11 12 13 14

15 16 17 18 19 20 21

22 23 24 25 26 27 28

29 30 31



A Picture Is Worth a 1,000 Words

Source: OAG flight schedules

 











































DOT Docket OST-2010-0018

Exhibit AA-311

Page 1 of 1













No service at all Only 7 days of service No service at all

No service at all Only 7 days of service Only 3 days of service
55

#LetAAFlyHaneda

Delta’s Failed Seattle–Haneda Commitment: Seatless in Seattle

Month Days

Delta Flights 

Operated/Scheduled

October 2014 31 0

November 2014 30 7

December 2014 31 0

January 2015 31 0

February 2015 28 7

March 2015 31 3

Total 182 17

Delta Has Constructively Abandoned the Seattle-Haneda Market Since October 2014

Source: OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-312

Page 1 of 1
56

#LetAAFlyHaneda

Delta’s Failed Seattle–Haneda Commitment: Seatless in Seattle

0

5

10

15

20

25

30

35

Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar

Seattle - Haneda Flights Days of Month

2013 2014 2015

• Only 4 months out of 22 with daily service

• 9 months with service 20 days or less

• 6 months with service 7 days or less

• 3 months with no service at all

Since Delta Inaugurated Seattle-Haneda Service, It Will Have Operated a Daily Service in Only 4 of 

the 22 Months Through March 2015 and in Only One Month Since August 2013

Source: OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-313

Page 1 of 1

  
57

#LetAAFlyHaneda

Delta’s Failed Seattle–Haneda Commitment: Seatless in Seattle

Delta’s Original

Proposal

(February 2010)

What Delta is Operating

Delta’s Scaled-back (When it Operates)

Proposal

(August 2012)

24.5% 

decrease

62.1% 

decrease

Delta Has Provided Over 62% Fewer Seats – Close to 289,000 Seats – Than It Committed to 

Provide Under Its Scaled-Back August 2012 Seattle-Haneda Service Proposal

Source: Delta submissions to U.S. Department of Transportation, OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-314

Page 1 of 1

616,264

465,300

175,158
58

#LetAAFlyHaneda

While Delta Has Abandoned the Seattle–Haneda Market, It Has 

Maintained Its Full Daily Schedule of Seattle-Narita Flights

0

5

10

15

20

25

30

35

Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar

Seattle - Narita Flights Seattle - Haneda Flights Days of Month

2013 2014 2015

Source: OAG flight schedules

And . . . 

DOT Docket OST-2010-0018

Exhibit AA-315

Page 1 of 1

  
59

#LetAAFlyHaneda

. . . Delta Offers More Than Twice the Number of Seats on the 

Seattle-Narita Route as It Offers on the Seattle-Haneda Route

396,551

175,158

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

450,000

Seattle–Narita 

(June 1, 2013 – March 

30, 2015)

Seattle–Haneda 

(June 1, 2013 – March 

30, 2015)

Round-trip Seats

On the Seattle-Haneda Route, 

Delta Offers Only 44.5% of the 

Seats Offered on Its

Seattle-Narita Route

Source: Delta submissions to U.S. Department of Transportation, OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-316

Page 1 of 1
60

#LetAAFlyHaneda

Overlap Unique to SEA-HND

Source: OAG flight schedules

ATL

LAS

MSP

JFK

PHX

SFO

SJC

SEA

GEG

PDX

SAN

DTW

LAX

Overlap

Unique to 

DL

SEA-HND

20 0

DOT Docket OST-2010-0018

Exhibit AA-317 Delta Competes With Itself at Seattle Page 1 of 1 :

Delta’s Seattle-Haneda Route Offers No Connecting U.S. Markets

Not Already Offered on Delta’s Seattle-Narita Route for U.S. Connecting Traffic

Markets connecting in BOTH directions

SMF CVG

DEN

BOI

FAI

ANC

JNU

SIT
61

#LetAAFlyHaneda

Delta Competes With Itself to Haneda:

There Are More Overlap Markets Between Delta’s SEA-HND and LAX-HND Services

Than Unique Markets on Either Route

Markets connecting in BOTH directions

Overlap Unique to DL SEA-HND Unique to DL LAX-HND

Overlap

Unique to 

DL

SEA-HND

Unique to DL

LAX-HND

12 8 9

Source: OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-318

Page 1 of 1

FAI

DEN

JNU

SIT

BOI

CVG

PDX

BOS

IND

MEM

MIA

MCO

TPA

OAK

RDU

ANC

ATL

LAS

MSP

JFK

PHX

SMF

SFO

SJC

SEA

SAN

DTW

LAX
62

#LetAAFlyHaneda

Delta Competes With Itself to Tokyo:

Delta’s Seattle-Haneda Route Competes and Overlaps with Delta’s 

Los Angeles-Narita Route for U.S. Connecting Traffic and . . .

Overlap Unique to SEA-HND Unique to LAX-NRT

Overlap

Unique to 

DL

SEA-HND

13 6

DOT Docket OST-2010-0018

Exhibit AA-319

Page 1 of 2

Source: OAG flight schedules, August 2015. LAX and SEA are considered overlapping markets

Markets connecting in BOTH directions

BOI

CVG

DEN

FAI

ANC

JNU

SIT

OAK

IND

MEM

TPA

RDU

CMH

MCI

AUS

DFW

SAT

ATL

LAS

MSP

JFK

PHX

SMF

SFO

SJC

SEA

GEG PDX

SAN

DTW

LAX

MSY MCO

SLC
63

#LetAAFlyHaneda

. . . The Only Six Unique SEA-HND Connecting Points Account for 

Only 47 O&D Passengers (PPDEW) to Tokyo

DL Unique Connecting Markets for SEA- HND 

Source: O&D passengers, MIDT YE November 2014, 

Unique to SEA-HND Tokyo O&D

Anchorage 5.2

Cincinnati 10.2

Denver 27.8

Fairbanks 3.4

Juneau 0.2

Sitka 0.0

Total 46.8

DOT Docket OST-2010-0018

Exhibit AA-319

Page 2 of 2

Markets connecting in BOTH directions
64

#LetAAFlyHaneda

Delta Has the Lowest Load Factor, By Far, of Any Airline 

Operating U.S.–Haneda Service

Airline U.S. Gateway Onboard 

Passengers Seats Load Factor

American JFK 8,376 12,981 64.5

Delta LAX 40,422 52,289 77.4

Delta SEA 21,154 41,418 51.1

Hawaiian HNL 65,087 80,115 81.2

JAL HNL 71,035 84,230 84.3

JAL SFO 37,110 50,406 73.6

ANA HNL 51,300 59,163 86.7

ANA LAX 51,167 60,947 84.0

Load Factor for all U.S.–Haneda Flights for Oct 2013 – Jun 2014

Even American’s JFK-HND Service, Which American Cancelled due to Commercially 

Unavailable Slot Times at Haneda, Had a Load Factor 13 Load Factor Points and 26.1% 

Higher Than Delta’s Seattle–Haneda Load Factor

Source: U.S. DOT T100, OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-320

Page 1 of 2
65

#LetAAFlyHaneda

Delta Has the Lowest Load Factor, By Far, of Any Airline 

Operating U.S.–Haneda Service

86.7 84.3 84.0

81.2

77.4

73.6

51.1

0

10

20

30

40

50

60

70

80

90

100

Load Factor %

Note: United currently operating SFO-HND service but no publicly available information because of the recent inauguration of that service

Source: U.S. DOT T100, OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-320

Page 2 of 2

ANA

HNL-HND

JAL

HNL-HND

ANA

LAX-HND

HA

HNL-HND

DL

LAX-HND

JAL

SFO-HND

DL

SEA-HND

October 2013 – June 2014
66

#LetAAFlyHaneda

Delta Had Almost as Many Empty Seats as It Had Occupied 

Seats on Its Seattle-Haneda Flights

21,286

20,375

12,000

13,000

14,000

15,000

16,000

17,000

18,000

19,000

20,000

21,000

22,000

Occupied Seats Empty Seats

Seats

Source: U.S. DOT T100

DOT Docket OST-2010-0018

Exhibit AA-321

Page 1 of 1

October 2013 – June 2014
67

#LetAAFlyHaneda

Delta’s Seattle-Haneda Load Factor Is 39% Lower Than Its 

Asia Load Factor and 40% Lower Than Its System Load Factor

85.3 84.2

51.1

0

10

20

30

40

50

60

70

80

90

Delta System Load Factor Delta Pacific Load Factor Delta SEA-HND Load Factor

Delta’s SEA-HND Load Factor is: 34 Load Factor 

Points and 40% Less Than Delta’s System Load Factor

Load Factor %

Note: For nine month period (for SEA-HND October 2013 to June 2014 – For System and Pacific load factor data for January to September 2014)

Source: Delta Press Release, October 2, 2014

DOT Docket OST-2010-0018

Exhibit AA-322

Page 1 of 1
68

#LetAAFlyHaneda

In Contrast to Delta’s SEA-HND Load Factor of 51%, Delta’s LAX-HND Route Experiences 

a Load Factor of 77.4%, Delta’s SEA-NRT Route Experiences a Load Factor of 89.7%, and 

Its Los Angeles-Haneda Route Enjoys a Load Factor of 90.4%

90.4 89.7

77.4

51.1

0

10

20

30

40

50

60

70

80

90

100

Delta LAX-NRT Delta SEA-NRT Delta LAX-HND Delta SEA-HND

Load Factor % • Delta’s LAX-NRT Flight Load Factor is 77.9% Higher Than Its SEA-HND Flight

• Delta’s SEA-NRT Flight Load Factor is 76% Higher Than Its SEA-HND Flight,

• Delta’s LAX-HND Flight Load Factor is 52% Higher Than Its SEA-HND Flight

Source: U.S. DOT T100, OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-323

Page 1 of 1

October 2013 – June 2014
69

#LetAAFlyHaneda

“Seasonality” Is an Excuse Concocted by Delta for Ceasing 

Seattle-Haneda Service; It is Not a Reality

• Delta displays no seasonality in its Seattle-Narita schedule

• ANA displays no seasonality in its Seattle-Narita schedule

• No other U.S. airline serving Haneda has a “seasonal” Haneda schedule

• No Japanese airline serving Haneda has a “seasonal” Haneda schedule

• No carrier (U.S., Japanese and third party) serving Haneda has a “seasonal” schedules

• Delta has no “seasonal” schedule for any of its services to Narita

• All other U.S. airlines serving Narita have a year-round service. No seasonal service

Source: OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-324

Page 1 of 10
70

#LetAAFlyHaneda

0

5

10

15

20

25

30

35

Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar

DL Seattle - Narita Flights Days of Month

“Seasonality” Is an Excuse Concocted by Delta for Ceasing 

Seattle-Haneda Service; It Is Not a Reality Days of Service

2013 2014 2015

Delta Operates a Daily Service on the Seattle-Narita Route Year-round -> No Seasonality

Source: OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-324

Page 2 of 10
71

#LetAAFlyHaneda

0

5

10

15

20

25

30

35

Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar

NH Seattle - Narita Flights Days of Month

“Seasonality” Is an Excuse Concocted by Delta for Ceasing 

Seattle-Haneda Service; It Is Not a Reality

2013 2014 2015

Days of Service

ANA Operates a Daily Service on the Seattle-Narita Route Year-round -> No Seasonality 

Source: OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-324

Page 3 of 10
72

#LetAAFlyHaneda

0

5

10

15

20

25

30

35

Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar

DL Los Angeles - Haneda Flights Days of Month

“Seasonality” Is an Excuse Concocted by Delta for Ceasing 

Seattle-Haneda Service; It Is Not a Reality Days of Service

2013 2014 2015

Delta Does Not Operate a “Seasonal” Service on Its Los Angeles-Haneda Route -> No Seasonality 

Source: OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-324

Page 4 of 10
73

#LetAAFlyHaneda

Los Angeles

Seattle

San Francisco

Honolulu

Daily Year-round

Haneda

“Seasonality” Is an Excuse Concocted by Delta for Ceasing 

Seattle-Haneda Service; It Is Not a Reality

Daily Year-round

Daily Year-round

Not Year-round, No Service Some 

Months, One Week (or less) Other Months

No Other U.S. Airline Serving Haneda Operates a “Seasonal” Service -> No Seasonality 

Source: 2015 OAG flight schedules 

DOT Docket OST-2010-0018

Exhibit AA-324

Page 5 of 10
74

#LetAAFlyHaneda

Daily Year-round

“Seasonality” Is an Excuse Concocted by Delta for Ceasing 

Seattle-Haneda Service; It Is Not a Reality

Daily Year-round

Daily Year-round Honolulu

Los Angeles

San Francisco

No Japanese Airline Operates a “Seasonal” Service On Its U.S.- Haneda Routes -> No Seasonality 

Note: ANA Honolulu service operated by Air Japan

Source: 2015 OAG flight schedules 

DOT Docket OST-2010-0018

Exhibit AA-324

Page 6 of 10

Haneda
75

#LetAAFlyHaneda

“Seasonality” Is an Excuse Concocted by Delta for Ceasing 

Seattle-Haneda Service; It Is Not a Reality

All Carriers Serving Haneda Have Year-round Schedules -> No Seasonality 

More Than Daily/Double Daily Year-round Service

More Than Double Daily Year-round Service

Daily Year-round Service

Less Than Daily Service

Haneda

SFO (JL, UA)

SGN (JL, SQ)

ICN (KE, OZ)

FRA (LH, NH)

MUC (LH, NH)

MNL (NH), (PR)

HAN (NH, VN)

YVR (NH)

DOH (QR)

YTO (AC)

LON (BA,JL,NH)

KUL (MH, JL) 

LAX

DXB (EK)

SHA 

JKT (GA)

HNL (HA)

BKK (NH)

BJS (CA)

PAR

(AF,JL,NH)

(TSA) (BR,CI,JL,NH) HKG (CX,JL,NH,UO)

SIN (JL,NH)

GMP (JL,KE,NH,OZ)

SEA (DL)

Source: 2015 OAG flight schedules 

DOT Docket OST-2010-0018

Exhibit AA-324

Page 7 of 10
76

#LetAAFlyHaneda

“Seasonality” Is an Excuse Concocted by Delta for Ceasing 

Seattle-Haneda Service; It Is Not a Reality

Delta Operates a Year-round Service on Its U.S.–Narita Routes and all Routes Daily Except 

Portland-> No Seasonal Service

Note: DL Portland service operates less than daily in some months, but never less than 21 times per month (approx. 5 times weekly) and never any months with no service

Source: OAG flight schedules

ATL

DTW

LAX

SEA

HNL

LAS

MSP PDX**

NRT

Daily Year-round

Daily Year-round

More Than

Daily Year-round

Double Trip

Daily Year-round

SPN

GUM

JFK

DOT Docket OST-2010-0018

Exhibit AA-324

Page 8 of 10
77

#LetAAFlyHaneda

“Seasonality” Is an Excuse Concocted by Delta for Ceasing 

Seattle-Haneda Service; It Is Not a Reality

All U.S. Carriers Operating U.S.–Narita Services Have Year-round Services -> No Seasonal Services

SPN

GUM

DFW

ORD

SFO DEN IAD

IAH

Daily Year-round

Double Trip

Daily Year-round

Daily Year-round

Daily Year-round

Daily Year-round

Daily Year-round

LAX

LAS

MSP

DTW

EWR

ATL

HNL

NRT JFK

SEA

PDX

DOT Docket OST-2010-0018

Exhibit AA-324

Page 9 of 10

Note: DL Portland service operates less than daily in some months, but never less than 21 times per month (approx. 5 times weekly) and never any months with no service

Source: OAG flight schedules
78

#LetAAFlyHaneda

“Seasonality” Is an Excuse Concocted by Delta for Ceasing 

Seattle-Haneda Service; It Is Not a Reality

All Japanese Carriers Operating U.S.–Narita Services Have 

Year-round Services -> No Seasonal Services

Source: OAG flight schedules

NRT

GUM

SJC

BOS

Daily Year-round SAN

Daily Year-round

Daily Year-round

Daily Year-round

Daily Year-round

SEA

HNL

SFO IAD

ORD

JFK

LAX

DOT Docket OST-2010-0018

Exhibit AA-324

Page 10 of 10
79

Series 400

American’s LAX-HND Proposal Maximizes

the Public Benefits
80

#LetAAFlyHaneda

Allocating to American a Haneda Slot Pair to Operate the

Los Angeles-Haneda Route Maximizes the Public Benefits of a Scarce Resource

Source: OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-401

Page 1 of 1

Benefit AA LAX-HND DL SEA-HND

New U.S. Carrier Service to Haneda 

(inter-carrier competition)

New U.S. Carrier Competitor at LAX 

(intra-gateway competition)

New (first-time) Three-Way Alliance 

Competition at LAX (Largest Continental 

U.S.-Tokyo O&D Market)

New Competitor/Competition for UA at 

SFO (inter-gateway competition)

Year-Round Service (No “Seasonality”)

Daily Service (No weeks, months, 

without service)

Provides More Seats to Haneda

Significant Cargo Capacity

Access to Haneda for AA Passengers




































81

Series 500

Connecting Flight Information
82

#LetAAFlyHaneda

Connecting Detail–Summer Westbound (LAX-HND)

Mktg Al Flight Orig Dep Time Arr Time Equip Seats

Elapsed 

Mins (to 

LAX)

Connection 

Time Mins

LAX-HND 

Flight Time 

Mins

Total 

Elapsed 

Mins (to 

HND)

AA 2614 ABQ 601 654 CRJ 50 113 606 720 1,489

AA 5399 SAT 610 705 CR9 79 175 595 720 1,569

AA 216 GRU 2230 710 777 247 755 680 720 2,402

AA 5368 PHX 600 722 CR9 76 82 668 720 1,546

AA 5395 IAH 610 731 CR9 79 201 659 720 1,659

AA 2617 TUS 604 735 CRJ 50 91 655 720 1,516

AA 2600 SJC 630 752 CRJ 50 82 638 720 1,490

AA 5398 OKC 700 754 CR9 76 174 636 720 1,606

AA 183 AUS 700 807 738 150 187 623 720 1,680

AA 2611 SLC 710 808 CRJ 50 118 622 720 1,510

AA 2604 SMF 640 812 CRJ 50 92 618 720 1,480

AA 2401 DFW 700 819 763 218 199 611 720 1,748

AA 5372 DEN 701 820 CR9 76 139 610 720 1,545

AA 1232 SFO 700 828 738 150 88 602 720 1,560

AA 169 LAS 730 840 M83 140 70 590 720 1,520

AA 365 ATL 700 841 319 128 281 589 720 1,718

AA 1361 BNA 630 854 738 150 264 576 720 1,710

US 491 PHX 728 855 752 190 87 575 720 1,572

AA 171 JFK 600 900 32B 102 360 570 720 1,752

AA 2608 MRY 750 904 CRJ 50 74 566 720 1,410

AA 2615 FAT 805 919 CRJ 50 74 551 720 1,395

AA 2599 EUG 700 920 CRJ 50 140 550 720 1,460

AA 1039 BOS 600 924 738 150 384 546 720 1,800

AA 2627 SAN 845 930 CRJ 50 45 540 720 1,355

AA 2605 SAF 830 933 CRJ 50 123 537 720 1,430

AA 1249 SFO 810 947 738 150 97 523 720 1,490

AA 1403 MIA 720 947 777 247 327 523 720 1,817

AA 1047 ORD 730 957 32B 181 267 513 720 1,681

US 417 CLT 750 957 321 187 307 513 720 1,727

Note: All flights operate daily

Source: OAG flight schedules for August 15, 2015, as of December 24, 2014

DOT Docket OST-2010-0018

Exhibit AA-501

Page 1 of 5

FROM: 

LAX-HND

Flight 125

Departure:

1830

Flight Time:

12:00

MCT

00:45

To LAX:
83

#LetAAFlyHaneda

Connecting Detail–Summer Westbound (LAX-HND) (cont.)

Mktg Al Flight Orig Dep Time Arr Time Equip Seats

Elapsed 

Mins (to 

LAX)

Connection 

Time Mins

LAX-HND 

Flight Time 

Mins

Total 

Elapsed 

Mins (to 

HND)

AA 9 JFK 700 958 32B 102 358 512 720 1,692

AA 2442 DFW 838 1000 757 182 202 510 720 1,614

AA 1379 YYZ 745 1005 738 160 320 505 720 1,705

AA 5324 YVR 700 1007 CR9 79 187 503 720 1,489

AA 5359 YEG 830 1009 CR9 79 159 501 720 1,459

US 797 PHL 735 1016 321 187 341 494 720 1,742

AA 1351 TPA 835 1028 738 150 293 482 720 1,645

AA 2419 DFW 905 1030 763 218 205 480 720 1,623

AA 2625 RNO 900 1033 CRJ 50 93 477 720 1,340

AA 2606 SAN 1004 1050 CRJ 50 46 460 720 1,276

AA 1567 STL 900 1102 M83 140 242 448 720 1,550

AA 33 JFK 800 1105 32B 102 365 445 720 1,632

AA 28 MCO 900 1106 738 150 306 444 720 1,620

AA 53 DCA 830 1114 738 150 344 436 720 1,650

AA 25 BOS 800 1119 738 150 379 431 720 1,680

AA 263 IAD 850 1123 738 150 333 427 720 1,630

AA 5346 SLC 1030 1124 CR9 76 114 426 720 1,336

AA 312 SJD 1000 1133 738 150 153 417 720 1,440

AA 2357 PBI 840 1135 738 160 355 415 720 1,650

AA 5400 SJC 1020 1144 CR9 76 84 406 720 1,286

AA 2621 TUS 1012 1145 CRJ 50 93 405 720 1,268

US 1700 PHX 1015 1145 321 187 90 405 720 1,402

AA 2584 RNO 1015 1147 CRJ 50 92 403 720 1,265

AA 3238 ASE 1040 1148 CR7 63 128 402 720 1,313

AA 1081 ORD 915 1148 32B 181 273 402 720 1,576

AA 2424 DFW 1025 1150 32B 181 205 400 720 1,506

DOT Docket OST-2010-0018

Exhibit AA-501

Page 2 of 5

FROM: 

LAX-HND

Flight 125

Departure:

1830

Flight Time:

12:00

MCT

00:45

To LAX:

Note: All flights operate daily

Source: OAG flight schedules for August 15, 2015, as of December 24, 2014
84

#LetAAFlyHaneda

Connecting Detail–Summer Westbound (LAX-HND) (cont.)

Mktg Al Flight Orig Dep Time Arr Time Equip Seats

Elapsed 

Mins (to 

LAX)

Connection 

Time Mins

LAX-HND 

Flight Time 

Mins

Total 

Elapsed 

Mins (to 

HND)

AA 5404 SFO 1025 1155 CR9 79 90 395 720 1,284

AA 2580 SAN 1115 1200 CRJ 50 45 390 720 1,205

US 639 CLT 950 1200 321 187 310 390 720 1,607

AA 295 MIA 925 1202 32B 181 337 388 720 1,626

AA 2577 SMF 1025 1205 CRJ 50 100 385 720 1,255

US 727 PIT 1000 1205 319 124 305 385 720 1,534

AA 2425 DFW 1045 1207 763 218 202 383 720 1,523

AA 1 JFK 900 1210 32B 102 370 380 720 1,572

US 855 PHL 1000 1249 321 187 349 341 720 1,597

AA 2437 ATL 1110 1251 319 128 281 339 720 1,468

AA 2589 FAT 1140 1254 CRJ 50 74 336 720 1,180

AA 1155 ORD 1030 1258 32B 181 268 332 720 1,501

AA 255 JFK 1000 1302 32B 102 362 328 720 1,512

AA 1126 LAS 1155 1309 738 150 74 321 720 1,265

AA 2618 ABQ 1215 1314 CRJ 50 119 316 720 1,205

AA 952 AUS 1205 1315 M83 140 190 315 720 1,365

AA 5407 SAT 1230 1322 CR9 79 172 308 720 1,279

AA 2624 SAN 1246 1330 CRJ 50 44 300 720 1,114

AA 5419 PHX 1210 1331 CR9 76 81 299 720 1,176

AA 315 BOS 1015 1331 738 150 376 299 720 1,545

AA 2423 DFW 1211 1334 763 218 203 296 720 1,437

AA 2455 SFO 1205 1335 738 150 90 295 720 1,255

AA 5432 ELP 1235 1335 CR9 76 120 295 720 1,211

AA 5373 DEN 1220 1340 CR9 76 140 290 720 1,226

AA 19 JFK 1100 1401 32B 102 361 269 720 1,452

AA 2596 SJC 1245 1406 CRJ 50 81 264 720 1,115

AA 5358 IAH 1300 1417 CR9 79 197 253 720 1,249

AA 1063 ORD 1210 1437 32B 181 267 233 720 1,401

DOT Docket OST-2010-0018

Exhibit AA-501

Page 3 of 5

FROM: 

LAX-HND

Flight 125

Departure:

1830

Flight Time:

12:00

MCT

00:45

To LAX:

Note: All flights operate daily

Source: OAG flight schedules for August 15, 2015, as of December 24, 2014
85

#LetAAFlyHaneda

Connecting Detail–Summer Westbound (LAX-HND) (cont.)

Mktg Al Flight Orig Dep Time Arr Time Equip Seats

Elapsed 

Mins (to 

LAX)

Connection 

Time Mins

LAX-HND 

Flight Time 

Mins

Total 

Elapsed 

Mins (to 

HND)

AA 2575 RDM 1235 1446 CRJ 50 131 224 720 1,125

AA 5377 SFO 1325 1455 CR9 79 90 215 720 1,104

AA 215 LAS 1340 1500 738 160 80 210 720 1,170

AA 2607 SAN 1415 1501 CRJ 50 46 209 720 1,025

AA 5394 YVR 1200 1507 CR9 79 187 203 720 1,189

AA 2479 DFW 1350 1512 757 182 202 198 720 1,302

AA 2629 SLC 1420 1514 CRJ 50 114 196 720 1,080

AA 139 MIA 1235 1516 738 150 341 194 720 1,405

US 2023 PHX 1355 1521 321 187 86 189 720 1,182

AA 3 JFK 1230 1525 32B 102 355 185 720 1,362

AA 237 SJD 1353 1529 M83 140 156 181 720 1,197

AA 2593 TUS 1357 1530 CRJ 50 93 180 720 1,043

AA 1258 STL 1345 1545 M83 140 240 165 720 1,265

AA 2597 SMF 1420 1552 CRJ 50 92 158 720 1,020

AA 5425 AUS 1430 1555 CR9 79 205 155 720 1,159

AA 2609 RNO 1430 1606 CRJ 50 96 144 720 1,010

AA 2610 SAN 1525 1612 CRJ 50 47 138 720 955

AA 1143 SFO 1440 1612 738 150 92 138 720 1,100

AA 2582 FAT 1515 1631 CRJ 50 76 119 720 965

AA 2384 LAS 1515 1631 32B 181 76 119 720 1,096

US 538 PHL 1400 1640 321 187 340 110 720 1,357

AA 1060 ORD 1414 1643 32B 181 269 107 720 1,277

AA 287 MIA 1416 1652 738 150 336 98 720 1,304

AA 2459 DFW 1535 1657 763 218 202 93 720 1,233

AA 2591 EUG 1450 1708 CRJ 50 138 82 720 990

AA 1261 AUS 1600 1709 738 150 189 81 720 1,140

AA 2613 SAN 1640 1722 CRJ 50 42 68 720 880

AA 5392 SJC 1615 1739 CR9 76 84 51 720 931

AA 5381 OKC 1645 1742 CR9 79 177 48 720 1,024

AA 5356 SFO 1620 1750 CR9 79 90 40 720 929

AA 5387 DEN 1630 1752 CR9 79 142 38 720 979

FROM: 

LAX-HND

Flight 125

Departure:

1830

Flight Time:

12:00

MCT

00:45

DOT Docket OST-2010-0018

Exhibit AA-501

Page 4 of 5

To LAX:

Note: All flights operate daily

Source: OAG flight schedules for August 15, 2015, as of December 24, 2014
86

#LetAAFlyHaneda

Connecting Detail–Summer Eastbound (HND-LAX)

Note: All flights operate daily except for flight 762 to Phoenix which operates 4X per week.

Source: OAG flight schedules for August 15, 2015, as of December 24, 2014

FROM: 

HND-LAX

Flight 126

Arrival:

18:30

Flight Time:

10:30

MCT

1:30 

Mktg Al Flight Dest Dep Time Arr Time Equip Seats

Elapsed 

Mins (LAX 

to xxx)

Connection 

Time Mins

HND-LAX 

Flight Time 

Mins

Total 

Elapsed 

Mins (from 

HND)

AA 2622 FAT 2000 2104 CRJ 50 64 90 630 784

AA 5378 DEN 2015 2326 CR9 76 131 105 630 866

AA 5396 YVR 2015 2255 CR9 79 160 105 630 895

AA 192 BOS 2050 0519 738 150 329 140 630 1,099

AA 2623 MRY 2100 2211 CRJ 50 71 150 630 851

AA 2616 SMF 2100 2220 CRJ 50 80 150 630 860

AA 2465 SFO 2100 2222 738 150 82 150 630 862

AA 2628 EUG 2100 2257 CRJ 50 117 150 630 897

AA 1554 LAS 2101 2212 M83 140 71 151 630 852

US 762 PHX 2137 2304 321 187 87 187 630 904

AA 2620 RNO 2150 2309 CRJ 50 79 200 630 909

AA 204 MCO 2150 0539 738 150 289 200 630 1,119

AA 2471 MIA 2150 0554 738 150 304 200 630 1,134

AA 2579 SJC 2155 2301 CRJ 50 66 205 630 901

AA 10 JFK 2155 0619 32B 102 324 205 630 1,159

AA 74 IAD 2200 0603 738 150 303 210 630 1,143

US 707 PHL 2215 0620 321 187 305 285 630 1,220

AA 1514 YYZ 2245 0635 738 160 290 255 630 1,175

AA 1360 BNA 2330 0530 738 150 240 300 630 1,170

AA 30 JFK 2330 0800 32B 102 330 300 630 1,260

AA 1358 TPA 2335 0727 738 150 292 305 630 1,227

AA 219 ORD 2359 0602 738 160 243 329 630 1,202

AA 58 MIA 2359 0802 32B 181 303 329 630 1,262

AA 2366 PBI 0005 0745 738 160 280 335 630 1,245

AA 1116 ATL 0015 0734 319 128 259 345 630 1,234

US 1832 CLT 0020 0805 321 187 285 410 630 1,325

US 591 PHL 0030 0843 321 187 313 420 630 1,363

AA 1592 MIA 0030 0832 738 160 302 360 630 1,292

AA 1113 ORD 0040 0643 32B 181 243 370 630 1,243

AA 2400 DFW 0055 0557 763 218 182 385 630 1,197

AA 2406 DFW 0059 0602 738 160 183 389 630 1,202

DOT Docket OST-2010-0018

Exhibit AA-501

Page 5 of 5

From LAX:
87

#LetAAFlyHaneda

Connecting Detail–Winter Westbound (LAX-HND)

Note: All flights operate daily

Note: All flights operate daily

Source: OAG flight schedules for March 19, 2015, as of December 24, 2014

Mktg Al Flight Orig Dep Time Arr Time Equip Seats

Elapsed 

Mins (to 

LAX)

Connection 

Time Mins

LAX-HND 

Flight Time 

Mins

Total 

Elapsed 

Mins (to 

HND)

AA 2614 ABQ 601 654 CRJ 50 113 606 750 1,469

AA 5399 SAT 610 705 CR9 79 175 595 750 1,520

AA 216 GRU 2230 710 777 247 760 590 750 2,100

AA 5368 PHX 600 722 CR9 76 82 578 750 1,410

AA 2603 ELP 605 722 CRJ 50 137 578 750 1,465

AA 5395 IAH 610 731 CR9 79 201 569 750 1,520

AA 2617 TUS 604 735 CRJ 50 91 565 750 1,406

AA 2600 SJC 630 752 CRJ 50 82 548 750 1,380

AA 5398 OKC 700 754 CR9 76 174 546 750 1,470

AA 183 AUS 700 807 738 150 187 533 750 1,470

AA 2611 SLC 710 808 CRJ 50 118 532 750 1,400

AA 2604 SMF 640 812 CRJ 50 92 528 750 1,370

AA 2401 DFW 700 819 763 218 199 521 750 1,470

AA 5372 DEN 701 820 CR9 76 139 520 750 1,409

AA 1232 SFO 700 828 738 150 88 512 750 1,350

AA 169 LAS 730 840 M83 140 70 500 750 1,320

AA 365 ATL 700 841 319 128 281 499 750 1,530

AA 1361 BNA 630 854 738 150 264 486 750 1,500

US 491 PHX 728 855 752 190 87 485 750 1,322

AA 171 JFK 600 900 32B 102 360 480 750 1,590

AA 2608 MRY 750 904 CRJ 50 74 476 750 1,300

AA 2615 FAT 805 919 CRJ 50 74 461 750 1,285

AA 2599 EUG 700 920 CRJ 50 140 460 750 1,350

AA 2627 SAN 845 930 CRJ 50 45 450 750 1,245

AA 2605 SAF 830 933 CRJ 50 123 447 750 1,320

AA 1249 SFO 810 947 738 150 97 433 750 1,280

AA 1403 MIA 720 947 777 247 327 433 750 1,510

US 417 CLT 750 957 321 187 307 423 750 1,480

AA 1047 ORD 730 957 32B 181 267 423 750 1,440

AA 9 JFK 700 958 32B 102 358 422 750 1,530

AA 2442 DFW 838 1000 757 182 202 420 750 1,372

AA 5324 YVR 700 1007 CR9 79 187 413 750 1,350

AA 5359 YEG 830 1009 CR9 79 159 411 750 1,320

FROM: 

LAX-HND

Flight 125

Departure:

1700

Flight Time:

12:30

MCT

00:45

DOT Docket OST-2010-0018

Exhibit AA-502

Page 1 of 5

To LAX:
88

#LetAAFlyHaneda

Connecting Detail–Winter Westbound (LAX-HND)(cont.)

Mktg Al Flight Orig Dep Time Arr Time Equip Seats

Elapsed 

Mins (to 

LAX)

Connection 

Time Mins

LAX-HND 

Flight Time 

Mins

Total 

Elapsed 

Mins (to 

HND)

US 797 PHL 735 1016 321 187 341 404 750 1,495

AA 1351 TPA 835 1028 738 150 293 392 750 1,435

AA 2419 DFW 905 1030 763 218 205 390 750 1,345

AA 2625 RNO 900 1033 CRJ 50 93 387 750 1,230

AA 1439 BOS 700 1046 738 150 406 374 750 1,530

AA 2606 SAN 1004 1050 CRJ 50 46 370 750 1,166

AA 1567 STL 900 1102 M83 140 242 358 750 1,350

AA 33 JFK 800 1105 32B 102 365 355 750 1,470

AA 28 MCO 900 1106 738 150 306 354 750 1,410

AA 53 DCA 830 1114 738 150 344 346 750 1,440

AA 263 IAD 850 1123 738 150 333 337 750 1,420

AA 5346 SLC 1030 1124 CR9 76 114 336 750 1,200

AA 2357 PBI 840 1135 738 160 355 325 750 1,430

AA 5400 SJC 1020 1144 CR9 76 84 316 750 1,150

US 1700 PHX 1015 1145 321 187 90 315 750 1,155

AA 2621 TUS 1012 1145 CRJ 50 93 315 750 1,158

AA 2584 RNO 1015 1147 CRJ 50 92 313 750 1,155

AA 1081 ORD 915 1148 32B 181 273 312 750 1,335

AA 2424 DFW 1025 1150 32B 181 205 310 750 1,265

AA 5404 SFO 1025 1155 CR9 79 90 305 750 1,145

US 639 CLT 950 1200 321 187 310 300 750 1,360

AA 2580 SAN 1115 1200 CRJ 50 45 300 750 1,095

AA 295 MIA 925 1202 32B 181 337 298 750 1,385

US 727 PIT 1000 1205 319 124 305 295 750 1,350

AA 2577 SMF 1025 1205 CRJ 50 100 295 750 1,145

AA 2425 DFW 1045 1207 763 218 202 293 750 1,245

AA 1 JFK 900 1210 32B 102 370 290 750 1,410

AA 25 BOS 900 1219 738 150 379 281 750 1,410

US 855 PHL 1000 1249 321 187 349 251 750 1,350

AA 2577 SMF 1025 1205 CRJ 50 100 295 750 1,145

AA 2425 DFW 1045 1207 763 218 202 293 750 1,245

AA 1 JFK 900 1210 32B 102 370 290 750 1,410

AA 25 BOS 900 1219 738 150 379 281 750 1,410

DOT Docket OST-2010-0018

Exhibit AA-502

Page 2 of 5

FROM: 

LAX-HND

Flight 125

Departure:

1700

Flight Time:

12:30

MCT

00:45

To LAX:

Note: All flights operate daily

Source: OAG flight schedules for March 19, 2015, as of December 24, 2014
89

#LetAAFlyHaneda

Connecting Detail–Winter Westbound (LAX-HND)(cont.)

Mktg Al Flight Orig Dep Time Arr Time Equip Seats

Elapsed 

Mins (to 

LAX)

Connection 

Time Mins

LAX-HND 

Flight Time 

Mins

Total 

Elapsed 

Mins (to 

HND)

US 855 PHL 1000 1249 321 187 349 251 750 1,350

AA 2437 ATL 1110 1251 319 128 281 249 750 1,280

AA 2589 FAT 1140 1254 CRJ 50 74 246 750 1,070

AA 1155 ORD 1030 1258 32B 181 268 242 750 1,260

AA 255 JFK 1000 1302 32B 102 362 238 750 1,350

AA 1126 LAS 1155 1309 738 150 74 231 750 1,055

AA 2618 ABQ 1215 1314 CRJ 50 119 226 750 1,095

AA 952 AUS 1205 1315 M83 140 190 225 750 1,165

AA 5407 SAT 1230 1322 CR9 79 172 218 750 1,140

AA 2624 SAN 1246 1330 CRJ 50 44 210 750 1,004

AA 5419 PHX 1210 1331 CR9 76 81 209 750 1,040

AA 2423 DFW 1211 1334 763 218 203 206 750 1,159

AA 2455 SFO 1205 1335 738 150 90 205 750 1,045

AA 5432 ELP 1235 1335 CR9 76 120 205 750 1,075

AA 5373 DEN 1220 1340 CR9 76 140 200 750 1,090

AA 19 JFK 1100 1401 32B 102 361 179 750 1,290

AA 2596 SJC 1245 1406 CRJ 50 81 174 750 1,005

AA 5358 IAH 1300 1417 CR9 79 197 163 750 1,110

AA 1063 ORD 1210 1437 32B 181 267 143 750 1,160

AA 2575 RDM 1235 1446 CRJ 50 131 134 750 1,015

AA 5377 SFO 1325 1455 CR9 79 90 125 750 965

AA 215 LAS 1340 1500 738 160 80 120 750 950

AA 2607 SAN 1415 1501 CRJ 50 46 119 750 915

AA 5394 YVR 1200 1507 CR9 79 187 113 750 1,050

AA 2479 DFW 1350 1512 757 182 202 108 750 1,060

AA 2629 SLC 1420 1514 CRJ 50 114 106 750 970

AA 139 MIA 1235 1516 738 150 341 104 750 1,195

US 2023 PHX 1355 1521 321 187 86 99 750 935

AA 3 JFK 1230 1525 32B 102 355 95 750 1,200

AA 237 SJD 1353 1529 738 160 156 91 750 997

AA 2593 TUS 1357 1530 CRJ 50 93 90 750 933

AA 1258 STL 1345 1545 M83 140 240 75 750 1,065

AA 2597 SMF 1420 1552 CRJ 50 92 68 750 910

AA 2609 RNO 1430 1606 CRJ 50 96 54 750 900

AA 2610 SAN 1525 1612 CRJ 50 47 48 750 845

AA 1143 SFO 1440 1612 738 150 92 48 750 890

DOT Docket OST-2010-0018

Exhibit AA-502

Page 3 of 5

FROM: 

LAX-HND

Flight 125

Departure:

1700

Flight Time:

12:30

MCT

00:45

To LAX:

Note: All flights operate daily

Source: OAG flight schedules for March 19, 2015, as of December 24, 2014
90

#LetAAFlyHaneda

Connecting Detail–Winter Eastbound (HND-LAX)

Mktg Al Flight Dest Dep Time Arr Time Equip Seats

Elapsed 

Mins (LAX 

to xxx)

Connection 

Time Mins

HND-LAX 

Flight Time 

Mins

Total 

Elapsed 

Mins (from 

HND)

AA 5356 SJC 1840 1946 CR9 79 66 100 600 766

AA 5381 SAT 1840 2330 CR9 79 170 100 600 870

AA 5387 IAH 1840 2349 CR9 79 189 100 600 889

AA 5427 PHX 1845 2011 CR9 76 86 105 600 791

AA 215 GRU 1850 1045 777 247 715 110 600 1,425

AA 2626 SLC 1855 2138 CRJ 50 103 115 600 818

AA 182 AUS 1855 2351 738 150 176 115 600 891

AA 2619 SAN 1905 1952 CRJ 50 47 125 600 772

AA 2493 LAS 1915 2029 738 150 74 135 600 809

AA 2590 TUS 1935 2104 CRJ 50 89 155 600 844

AA 5392 PHX 1940 2108 CR9 76 88 160 600 848

AA 2622 FAT 2000 2104 CRJ 50 64 180 600 844

AA 2588 ELP 2005 2300 CRJ 50 115 185 600 900

AA 5378 DEN 2015 2326 CR9 76 131 195 600 926

AA 5396 YVR 2015 2255 CR9 79 160 195 600 955

AA 192 BOS 2050 0519 738 150 329 230 600 1,159

AA 2623 MRY 2100 2211 CRJ 50 71 240 600 911

AA 2616 SMF 2100 2220 CRJ 50 80 240 600 920

AA 2465 SFO 2100 2222 738 150 82 240 600 922

AA 2628 EUG 2100 2257 CRJ 50 117 240 600 957

AA 1554 LAS 2101 2212 M83 140 71 241 600 912

DOT Docket OST-2010-0018

Exhibit AA-502

Page 4 of 5

FROM: 

HND-LAX

Flight 126

Arrival:

17:00

Flight Time:

10:00

MCT

1:30 

From LAX:

Note: All flights operate daily

Source: OAG flight schedules for March 19, 2015, as of December 24, 2014
91

#LetAAFlyHaneda

Connecting Detail–Winter Eastbound (HND-LAX)(cont.)

Mktg Al Flight Dest Dep Time Arr Time Equip Seats

Elapsed 

Mins (LAX 

to xxx)

Connection 

Time Mins

HND-LAX 

Flight Time 

Mins

Total 

Elapsed 

Mins (from 

HND)

AA 2620 RNO 2150 2309 CRJ 50 79 290 600 969

AA 204 MCO 2150 0539 738 150 289 290 600 1,179

AA 2471 MIA 2150 0554 738 150 304 290 600 1,194

AA 2579 SJC 2155 2301 CRJ 50 66 295 600 961

AA 10 JFK 2155 0619 32B 102 324 295 600 1,219

AA 74 IAD 2200 0603 738 150 303 300 600 1,203

US 707 PHL 2215 0620 321 187 305 285 600 1,190

AA 1360 BNA 2330 0530 738 150 240 390 600 1,230

AA 30 JFK 2330 0800 32B 102 330 390 600 1,320

AA 1358 TPA 2335 0727 738 150 292 395 600 1,287

AA 219 ORD 2359 0602 738 160 243 419 600 1,262

AA 58 MIA 2359 0802 32B 181 303 419 600 1,322

AA 2366 PBI 0005 0745 738 160 280 425 600 1,305

AA 1116 ATL 0015 0734 319 128 259 435 600 1,294

US 1832 CLT 0020 0805 321 187 285 410 600 1,295

US 591 PHL 0030 0843 321 187 313 420 600 1,333

AA 1592 MIA 0030 0832 738 160 302 450 600 1,352

AA 1113 ORD 0040 0643 32B 181 243 460 600 1,303

AA 2400 DFW 0055 0557 763 218 182 475 600 1,257

AA 2406 DFW 0059 0602 738 160 183 479 600 1,262

DOT Docket OST-2010-0018

Exhibit AA-502

Page 5 of 5

FROM: 

HND-LAX

Flight 126

Arrival:

17:00

Flight Time:

10:00

MCT

1:30 

From LAX:

Note: All flights operate daily

Source: OAG flight schedules for March 19, 2015, as of December 24, 2014
92

Source: American Airlines #LetAAFlyHaneda

DOT Docket OST-2010-0018

Exhibit AA-503

Page 1 of 5

Per Flight

100% Passenger Load Factor

Equipment Seats Orig Dest Season Month Payload lbs

Pax Demand 

(%LF)

Equivalent 

Pax Count

Pax & Bags 

Payload-lbs

Cargo Capability 

Based on Pax

Demand

B777-223ER 247 INTL LAX Dec 101,800 100 247 59,280 42,520

Winter Jan 101,800 100 247 59,280 42,520

Feb 101,800 100 247 59,280 42,520

Mar 101,800 100 247 58,045 43,755

Spring Apr 101,800 100 247 58,045 43,755

May 101,800 100 247 58,045 43,755

Jun 101,800 100 247 58,045 43,755

Summer Jul 101,800 100 247 58,045 43,755

Aug 101,800 100 247 58,045 43,755

Sep 101,800 100 247 59,280 42,520

Fall Oct 101,800 100 247 59,280 42,520

Nov 101,800 100 247 59,280 42,520

Annual 

Average 101,800 100 247 58,663 43,138

B767-323ER 225 INTL LAX Dec 80,700 100 225 54,000 26,700

Winter Jan 80,700 100 225 54,000 26,700

Feb 80,700 100 225 54,000 26,700

Mar 80,700 100 225 52,875 27,825

Spring Apr 80,700 100 225 52,875 27,825

May 80,700 100 225 52,875 27,825

Jun 80,700 100 225 52,875 27,825

Summer Jul 80,700 100 225 52,875 27,825

Aug 80,700 100 225 52,875 27,825

Sep 80,700 100 225 54,000 26,700

 Fall Oct 80,700 100 225 54,000 26,700

 Nov 80,700 100 225 54,000 26,700

Annual 

Average 80,700 100 225 53,438 27,263

Cargo Capacity for Flights Connecting to American’s

LAX-HND Service at 100% Load Factor
93

#LetAAFlyHaneda

Cargo Capacity for Flights Connecting to American’s

LAX-HND Service at 100% Load Factor

Source: American Airlines

DOT Docket OST-2010-0018

Exhibit AA-503

Page 2 of 5

Per Flight

100% Passenger Load Factor

Equipment Seats Orig Dest Season Month

Payload

lbs

Pax Demand 

(%LF)

Equivalent 

Pax Count

Pax & Bags 

Payload-lbs

Cargo Capability 

Based on Pax

Demand

B757-223ER 174 US LAX Dec 48,200 100 174 41,760 6,440

Winter Jan 48,200 100 174 41,760 6,440

Feb 48,200 100 174 41,760 6,440

Mar 48,200 100 174 40,890 7,310

Spring Apr 48,200 100 174 40,890 7,310

May 48,200 100 174 40,890 7,310

Jun 48,200 100 174 40,890 7,310

Summer Jul 48,200 100 174 40,890 7,310

Aug 48,200 100 174 40,890 7,310

Sep 48,200 100 174 41,760 6,440

Fall Oct 48,200 100 174 41,760 6,440

Nov 48,200 100 174 41,760 6,440

Annual 

Average 48,200 100 174 41,325 6,875

 

Per Flight

100% Passenger Load Factor

B767-223 Seats US LAX Dec 61,700 100 169 40,560 21,140

169 Winter Jan 61,700 100 169 40,560 21,140

Feb 61,700 100 169 40,560 21,140

Mar 61,700 100 169 39,715 21,985

Spring Apr 61,700 100 169 39,715 21,985

May 61,700 100 169 39,715 21,985

Jun 61,700 100 169 39,715 21,985

Summer Jul 61,700 100 169 39,715 21,985

Aug 61,700 100 169 39,715 21,985

Sep 61,700 100 169 40,560 21,140

Fall Oct 61,700 100 169 40,560 21,140

Nov 61,700 100 169 40,560 21,140

Annual 

Average 61,700 100 169 40,138 21,563
94

#LetAAFlyHaneda

Cargo Capacity for Flights Connecting to American’s

LAX-HND Service at 100% Load Factor

Source: American Airlines

DOT Docket OST-2010-0018

Exhibit AA-503

Page 3 of 5

Per Flight

100% Passenger Load Factor

Equipment Seats Orig Dest Season Month

Payload

lbs

Pax Demand 

(%LF)

Equivalent 

Pax Count

Pax & Bags 

Payload-lbs

Cargo Capability 

Based on Pax

Demand

B767-323ER 225 US LAX Dec 80,700 100 225 54,000 26,700

Winter Jan 80,700 100 225 54,000 26,700

Feb 80,700 100 225 54,000 26,700

Mar 80,700 100 225 52,875 27,825

Spring Apr 80,700 100 225 52,875 27,825

May 80,700 100 225 52,875 27,825

Jun 80,700 100 225 52,875 27,825

Summer Jul 80,700 100 225 52,875 27,825

Aug 80,700 100 225 52,875 27,825

Sep 80,700 100 225 54,000 26,700

Fall Oct 80,700 100 225 54,000 26,700

Nov 80,700 100 225 54,000 26,700

Annual 

Average 80,700 100 225 53,438 27,263

Per Flight

100% Passenger Load Factor

B757-223 Seats US LAX Dec 49,200 100 188 45,120 4,080

188 Winter Jan 49,200 100 188 45,120 4,080

Feb 49,200 100 188 45,120 4,080

Mar 49,200 100 188 44,180 5,020

Spring Apr 49,200 100 188 44,180 5,020

May 49,200 100 188 44,180 5,020

Jun 49,200 100 188 44,180 5,020

Summer Jul 49,200 100 188 44,180 5,020

Aug 49,200 100 188 44,180 5,020

Sep 49,200 100 188 45,120 4,080

Fall Oct 49,200 100 188 45,120 4,080

Nov 49,200 100 188 45,120 4,080

Annual 

Average 49,200 100 188 44,650 4,550
95

#LetAAFlyHaneda

Cargo Capacity for Flights Connecting to American’s

LAX-HND Service at 100% Load Factor

Source: American Airlines

DOT Docket OST-2010-0018

Exhibit AA-503

Page 4 of 5

Per Flight

100% Passenger Load Factor

Equipment Seats Orig Dest Season Month

Payload

lbs

Pax Demand 

(%LF)

Equivalent 

Pax Count

Pax & Bags 

Payload-lbs

Cargo Capability 

Based on Pax

Demand

MD80 140 US LAX Dec 36,900 100 140 33,600 3,300

Winter Jan 36,900 100 140 33,600 3,300

Feb 36,900 100 140 33,600 3,300

Mar 36,900 100 140 32,900 4,000

Spring Apr 36,900 100 140 32,900 4,000

May 36,900 100 140 32,900 4,000

Jun 36,900 100 140 32,900 4,000

Summer Jul 36,900 100 140 32,900 4,000

Aug 36,900 100 140 32,900 4,000

Sep 36,900 100 140 33,600 3,300

Fall Oct 36,900 100 140 33,600 3,300

Nov 36,900 100 140 33,600 3,300

Annual 

Average 36,900 100 140 33,250 3,650

Per Flight

100% Passenger Load Factor

 

737-823 Seats US LAX Dec 39,700 100 160 38,400 1,300

160 Winter Jan 39,700 100 160 38,400 1,300

Feb 39,700 100 160 38,400 1,300

Mar 39,700 100 160 37,600 2,100

Spring Apr 39,700 100 160 37,600 2,100

May 39,700 100 160 37,600 2,100

Jun 39,700 100 160 37,600 2,100

Summer Jul 39,700 100 160 37,600 2,100

Aug 39,700 100 160 37,600 2,100

Sep 39,700 100 160 38,400 1,300

Fall Oct 39,700 100 160 38,400 1,300

Nov 39,700 100 160 38,400 1,300

Annual 

Average 39,700 100 160 38,000 1,700
96

#LetAAFlyHaneda

Cargo Capacity for Flights Connecting to American’s

LAX-HND Service at 100% Load Factor

Source: American Airlines

DOT Docket OST-2010-0018

Exhibit AA-503

Page 5 of 5

Per Flight

100% Passenger Load Factor

 

Equipment Seats Orig Dest Season Month

Payload

lbs

Pax Demand 

(%LF)

Equivalent 

Pax Count

Pax & Bags 

Payload-lbs

Cargo Capability 

Based on Pax

Demand

E140 44 US LAX Dec 10,756 100 44 9,680 1,076

Winter Jan 10,756 100 44 9,680 1,076

Feb 10,756 100 44 9,680 1,076

Mar 10,756 100 44 9,680 1,076

Spring Apr 10,756 100 44 9,680 1,076

May 10,756 100 44 9,680 1,076

Jun 10,756 100 44 9,680 1,076

Summer Jul 10,756 100 44 9,680 1,076

Aug 10,756 100 44 9,680 1,076

Sep 10,756 100 44 9,680 1,076

Fall Oct 10,756 100 44 9,680 1,076

Nov 10,756 100 44 9,680 1,076

Annual 10,756 100 44 9,680 1,076

Average

Equipment Seats Orig Dest Season Month

Payload

lbs

Pax Demand 

(%LF)

Equivalent 

Pax Count

Pax & Bags 

Payload-lbs

Cargo Capability 

Based on Pax

Demand

CRJ70 70 US LAX Dec 18,800 100 70 15,400 3,400

Winter Jan 18,800 100 70 15,400 3,400

Feb 18,800 100 70 15,400 3,400

Mar 18,800 100 70 15,400 3,400

Spring Apr 18,800 100 70 15,400 3,400

May 18,800 100 70 15,400 3,400

Jun 18,800 100 70 15,400 3,400

Summer Jul 18,800 100 70 15,400 3,400

Aug 18,800 100 70 15,400 3,400

Sep 18,800 100 70 15,400 3,400

Fall Oct 18,800 100 70 15,400 3,400

Nov 18,800 100 70 15,400 3,400

Annual 18,800 100 70 15,400 3,400

Average
97

#LetAAFlyHaneda

Cargo Capacity for Flights Connecting to American’s

LAX-HND Service at 80% Load Factor

Source: American Airlines

DOT Docket OST-2010-0018

Exhibit AA-504

Page 1 of 5

Per Flight

80% Passenger Load Factor

Equipment Seats Orig Dest Season Month Payload lbs

Pax Demand 

(%LF)

Equivalent 

Pax Count

Pax & Bags 

Payload-lbs

Cargo Capability 

Based on Pax

Demand

B777-223ER 247 INTL LAX Dec 101,800 80 198 47,424 54,376

Winter Jan 101,800 80 198 47,424 54,376

Feb 101,800 80 198 47,424 54,376

Mar 101,800 80 198 46,436 55,364

Spring Apr 101,800 80 198 46,436 55,364

May 101,800 80 198 46,436 55,364

Jun 101,800 80 198 46,436 55,364

Summer Jul 101,800 80 198 46,436 55,364

Aug 101,800 80 198 46,436 55,364

Sep 101,800 80 198 47,424 54,376

Fall Oct 101,800 80 198 47,424 54,376

Nov 101,800 80 198 47,424 54,376

Annual 

Average 101,800 80 198 46,930 54,870

B767-323ER 225 INTL LAX Dec 80,700 80 180 43,200 37,500

Winter Jan 80,700 80 180 43,200 37,500

Feb 80,700 80 180 43,200 37,500

Mar 80,700 80 180 42,300 38,400

Spring Apr 80,700 80 180 42,300 38,400

May 80,700 80 180 42,300 38,400

Jun 80,700 80 180 42,300 38,400

Summer Jul 80,700 80 180 42,300 38,400

Aug 80,700 80 180 42,300 38,400

Sep 80,700 80 180 43,200 37,500

 Fall Oct 80,700 80 180 43,200 37,500

 Nov 80,700 80 180 43,200 37,500

Annual 

Average 80,700 80 180 42,750 37,950
98

#LetAAFlyHaneda

Cargo Capacity for Flights Connecting to American’s

LAX-HND Service at 80% Load Factor

Source: American Airlines

DOT Docket OST-2010-0018

Exhibit AA-504

Page 2 of 5

Per Flight

80% Passenger Load Factor

Equipment Seats Orig Dest Season Month Payload lbs

Pax Demand 

(%LF)

Equivalent 

Pax Count

Pax & Bags 

Payload-lbs

Cargo Capability 

Based on Pax

Demand

B757-223ER 174 US LAX Dec 48,200 80 139 33,408 14,792

Winter Jan 48,200 80 139 33,408 14,792

Feb 48,200 80 139 33,408 14,792

Mar 48,200 80 139 32,712 15,488

Spring Apr 48,200 80 139 32,712 15,488

May 48,200 80 139 32,712 15,488

Jun 48,200 80 139 32,712 15,488

Summer Jul 48,200 80 139 32,712 15,488

Aug 48,200 80 139 32,712 15,488

Sep 48,200 80 139 33,408 14,792

Fall Oct 48,200 80 139 33,408 14,792

Nov 48,200 80 139 33,408 14,792

Annual 

Average 48,200 80 139 33,060 15,140

 

Per Flight

80% Passenger Load Factor

B767-223 Seats US LAX Dec 61,700 80 135 32,448 29,252

169 Winter Jan 61,700 80 135 32,448 29,252

Feb 61,700 80 135 32,448 29,252

Mar 61,700 80 135 31,772 29,928

Spring Apr 61,700 80 135 31,772 29,928

May 61,700 80 135 31,772 29,928

Jun 61,700 80 135 31,772 29,928

Summer Jul 61,700 80 135 31,772 29,928

Aug 61,700 80 135 31,772 29,928

Sep 61,700 80 135 32,448 29,252

Fall Oct 61,700 80 135 32,448 29,252

Nov 61,700 80 135 32,448 29,252

Annual 

Average 61,700 80 135 32,110 29,590
99

#LetAAFlyHaneda

Cargo Capacity for Flights Connecting to American’s

LAX-HND Service at 80% Load Factor

Source: American Airlines

DOT Docket OST-2010-0018

Exhibit AA-504

Page 3 of 5

Per Flight

80% Passenger Load Factor

Equipment Seats Orig Dest Season Month Payload lbs

Pax 

Demand 

(%LF)

Equivalent 

Pax Count

Pax & Bags 

Payload-lbs

Cargo Capability 

Based on Pax

Demand

B767-323ER 225 US LAX Dec 80,700 80 180 43,200 37,500

Winter Jan 80,700 80 180 43,200 37,500

Feb 80,700 80 180 43,200 37,500

Mar 80,700 80 180 42,300 38,400

Spring Apr 80,700 80 180 42,300 38,400

May 80,700 80 180 42,300 38,400

Jun 80,700 80 180 42,300 38,400

Summer Jul 80,700 80 180 42,300 38,400

Aug 80,700 80 180 42,300 38,400

Sep 80,700 80 180 43,200 37,500

Fall Oct 80,700 80 180 43,200 37,500

Nov 80,700 80 180 43,200 37,500

Annual Average 80,700 80 180 42,750 37,950

Per Flight

80% Passenger Load Factor

B757-223 Seats US LAX Dec 49,200 80 150 36,096 13,104

188 Winter Jan 49,200 80 150 36,096 13,104

Feb 49,200 80 150 36,096 13,104

Mar 49,200 80 150 35,344 13,856

Spring Apr 49,200 80 150 35,344 13,856

May 49,200 80 150 35,344 13,856

Jun 49,200 80 150 35,344 13,856

Summer Jul 49,200 80 150 35,344 13,856

Aug 49,200 80 150 35,344 13,856

Sep 49,200 80 150 36,096 13,104

Fall Oct 49,200 80 150 36,096 13,104

Nov 49,200 80 150 36,096 13,104

Annual Average 49,200 80 150 35,720 13,480
100

#LetAAFlyHaneda

Cargo Capacity for Flights Connecting to American’s

LAX-HND Service at 80% Load Factor

Source: American Airlines

DOT Docket OST-2010-0018

Exhibit AA-504

Page 4 of 5

Per Flight

80% Passenger Load Factor

Equipment Seats Orig Dest Season Month Payload lbs

Pax 

Demand 

(%LF)

Equivalent 

Pax Count

Pax & Bags 

Payload-lbs

Cargo 

Capability 

Based on Pax

Demand

MD80 140 US LAX Dec 36,900 80 112 26,880 10,020

Winter Jan 36,900 80 112 26,880 10,020

Feb 36,900 80 112 26,880 10,020

Mar 36,900 80 112 26,320 10,580

Spring Apr 36,900 80 112 26,320 10,580

May 36,900 80 112 26,320 10,580

Jun 36,900 80 112 26,320 10,580

Summer Jul 36,900 80 112 26,320 10,580

Aug 36,900 80 112 26,320 10,580

Sep 36,900 80 112 26,880 10,020

Fall Oct 36,900 80 112 26,880 10,020

Nov 36,900 80 112 26,880 10,020

Annual Average 36,900 80 112 26,600 10,300

Per Flight

80% Passenger Load Factor

 

737-823 Seats US LAX Dec 39,700 80 128 30,720 8,980

160 Winter Jan 39,700 80 128 30,720 8,980

Feb 39,700 80 128 30,720 8,980

Mar 39,700 80 128 30,080 9,620

Spring Apr 39,700 80 128 30,080 9,620

May 39,700 80 128 30,080 9,620

Jun 39,700 80 128 30,080 9,620

Summer Jul 39,700 80 128 30,080 9,620

Aug 39,700 80 128 30,080 9,620

Sep 39,700 80 128 30,720 8,980

Fall Oct 39,700 80 128 30,720 8,980

Nov 39,700 80 128 30,720 8,980

Annual Average 39,700 80 128 30,400 9,300
101

#LetAAFlyHaneda

Cargo Capacity for Flights Connecting to American’s

LAX-HND Service at 80% Load Factor

Source: American Airlines

DOT Docket OST-2010-0018

Exhibit AA-504

Page 5 of 5

Per Flight

80% Passenger Load Factor

 

Equipment Seats Orig Dest Season Month Payload lbs

Pax Demand 

(%LF)

Equivalent 

Pax Count

Pax & Bags 

Payload-lbs

Cargo Capability 

Based on Pax

Demand

E140 44 US LAX Dec 10,756 80 35 7,744 3,012

Winter Jan 10,756 80 35 7,744 3,012

Feb 10,756 80 35 7,744 3,012

Mar 10,756 80 35 7,744 3,012

Spring Apr 10,756 80 35 7,744 3,012

May 10,756 80 35 7,744 3,012

Jun 10,756 80 35 7,744 3,012

Summer Jul 10,756 80 35 7,744 3,012

Aug 10,756 80 35 7,744 3,012

Sep 10,756 80 35 7,744 3,012

Fall Oct 10,756 80 35 7,744 3,012

Nov 10,756 80 35 7,744 3,012

Annual 10,756 80 35 7,744 3,012

Average

Equipment Seats Orig Dest Season Month Payload lbs

Pax Demand 

(%LF)

Equivalent 

Pax Count

Pax & Bags 

Payload-lbs

Cargo Capability 

Based on Pax

Demand

CRJ70 70 US LAX Dec 18,800 80 56 12,320 6,480

Winter Jan 18,800 80 56 12,320 6,480

Feb 18,800 80 56 12,320 6,480

Mar 18,800 80 56 12,320 6,480

Spring Apr 18,800 80 56 12,320 6,480

May 18,800 80 56 12,320 6,480

Jun 18,800 80 56 12,320 6,480

Summer Jul 18,800 80 56 12,320 6,480

Aug 18,800 80 56 12,320 6,480

Sep 18,800 80 56 12,320 6,480

Fall Oct 18,800 80 56 12,320 6,480

Nov 18,800 80 56 12,320 6,480

Annual 18,800 80 56 12,320 6,480

Average
102

Series 600

Letters of Support


DC Headquarters Office | 1819 L Street, NW, Suite 200 | Washington, DC 20036 | Tel: (202) 223-6840 | Fax: (202) 280-1235

Tokyo Office | 5-2-20 Akasaka, Minato-ku | Tokyo, Japan, 107-6113 | Tel: (03) 5544-4515 | Fax: (03) 5544-4518

http://www.usjapancouncil.org

December 30, 2014

The Honorable Anthony R. Foxx

Secretary of Transportation

U.S. Department of Transportation

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Application of American Airlines in the U.S.-Haneda Combination 

Services Allocation Proceeding, Docket DOT-OST-2010-0018

Dear Secretary Foxx:

On behalf of the U.S.-Japan Council, I am writing to convey our strong and 

enthusiastic support for American Airlines’ application to acquire a slot pair from the 

Department to serve Tokyo’s Haneda Airport (“Haneda”) from Los Angeles International 

Airport (“LAX”). This is a very significant opportunity to enhance the travel, economic 

relationships, and continued ties between Japan and the United States especially the 

Western part of the country.

The U.S.-Japan Council is headquartered in Washington, D.C. with offices in Los 

Angeles and Tokyo. The Council’s mission is to create active people-to-people 

relationships to ensure a strong relationship between the United States and Japan. As a 

leadership organization the Council has Council members throughout the U.S. and Japan 

with the largest number in the Western United States. Since the 2011 disasters in the 

Tohoku region, the Council has administered the TOMODACHI initiative, a public-private 

partnership with the U.S. Embassy in Tokyo. We have raised nearly $40 million from 

Japanese and American companies that has supported over 3,000 young people in crosscultural leadership and exchange programs between the U.S. and Japan and served over 

10,000 young people in programs within each country. With the interest on the part of both 

governments to increase student exchanges, as re-committed by President Obama and 

Prime Minister Abe in their spring 2014 meeting, the ability to increase flights between Los 

Angeles and Haneda is critically important. 

In addition to the Council’s work on TOMODACHI, the Council sponsors 

conferences, symposia, and special events that encourage closer business, government, and 

community ties at all levels. We have worked with members of the Japanese Parliament 

and the U.S. Congress as well as state legislatures to support greater legislative exchanges. 

In November 2015, the Council will hold its Annual Conference in Tokyo Japan, for the first 
DC Headquarters Office | 1819 L Street, NW, Suite 200 | Washington, DC 20036 | Tel: (202) 223-6840 | Fax: (202) 280-1235

Tokyo Office | 5-2-20 Akasaka, Minato-ku | Tokyo, Japan, 107-6113 | Tel: (03) 5544-4515 | Fax: (03) 5544-4518

http://www.usjapancouncil.org

time-ever. We are expecting a large attendance of American leaders, including many 

Japanese American leaders, who want to ensure that the new opportunities for 

collaboration with Japan can be explored and realized. The largest concentration of our 

members are in the Southern California area and we know many travel back and forth to 

Japan and will plan to attend next year’s Conference. 

American Airlines has been a strong partner with the U.S.-Japan Council from our 

inception and we would strongly encourage support for their application. The nonstop 

flights to Haneda Airport are scarce national resources that should be distributed amongst 

U.S. carriers to obtain the maximum consumer and economic benefits. Yet, today three U.S. 

carriers operate the four daily flights at Haneda, limiting travel options for U.S. consumers 

and shippers who want convenient access to Tokyo. We are convinced that American’s 

proposed daily service from LAX to Haneda will have the effect of increasing the existing 

cultural, educational and leisure tourism, and business ties.

As you may be aware, California and Japan enjoy strong business and cultural ties 

that further underscore the necessity for American Airlines’ service to Haneda. In 2011, 

Japan was the largest source of Foreign Direct Investment into Los Angeles County while

travel demand between the two countries was sustained by the approximately 250,000 

Japanese Americans and 50,000 Japanese nationals living in Southern California. American 

Airlines’ LAX-Haneda flight will not only better connect travelers and businesses, but it 

will help stimulate new business opportunities and create much needed jobs for other 

California companies. 

We strongly believe American Airlines’ application for nonstop service between 

LAX and Haneda will not only have a positive impact on both our constituents and our 

state’s economy, but will best utilize the scarce Haneda slots. Therefore, we urge you to 

approve American Airlines’ proposal to serve Haneda from LAX without further delay. 

Sincerely,

Irene Hirano Inouye

President

Cc: Susan Kurland, Assistant Secretary for Aviation and International Affairs
Henry Y. Ota 

Attorney-at-Law 

12492 Hillside Drive 

Moorpark,CA 93021 

(714) 330-5446 

h.otalaw@gmail.com 

The Honorable Anthony R. Foxx 

Secretary of Transportation 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Re: Application of American Airlines in the U.S.-Haneda Combination Services 

Allocation Proceedin& Docket D0T-0ST-2010<X)18 

Dear Secretary Foxx: 

I am writing this letter to you wearing several hats. I am a leader in the Japanese 

American community here in Los Angeles and I serve as the Vice-Chair of the US-Japan 

Council (350 members) whose Board of Councilors has Secretary Mineta as a Vice Chair. 

The USJC's mission is to engage Japanese Americans in U.S.-Japan relations and this council 

organizes several trips to Japan each year. I am also the Chair of the Japanese American 

Cultural Center (1000 members) based in Los Angeles which is the largest such center in 

the U.S. that brings Japanese culture and arts to our audiences in Los Angeles. I have 

served as the legal advisor to the Japan Business Association of Southern California which 

has over 450 Japanese business members who frequently make the trip to Japan from Los 

Angeles. Finally, from a personal standpoint, I am a frequent traveler to Japan, making 

about 4 trips each year, because my legal practice continues to serve Japanese companies 

and AA has always been my airline of choice. 

It is in this context that I write to express my overwhelming support for American Airlines' 

application to acquire a slot pair from the Department to serve Tokyo's Haneda Airport 

("Haneda") from Los Angeles International Airport ("LAX"). It is clear to me that the Los 

Angeles community and in particular the Japanese American community and the large 

Japanese business community would not just welcome this addition but would be well 

served by this added flight into Haneda. 

I understand that the nonstop flights to Haneda are scarce national resources that 

should be distributed amongst U.S. carriers to obtain the maximum consumer and economic 

benefits. Yet, today only three U.S. carriers operate the four daily flights at Haneda, limiting 
travel options for U.S. consumers and shippers who want convenient access to Tokyo. It is 

clear to me that our community would both benefit greatly from American's proposed daily 

service from LAX to Haneda which will have the effect of strengthening the cultural, tourism, 

and business ties between the greater Los Angeles region and Japan. 

As I am sure that you are aware, California and Japan enjoy strong business and 

cultural ties that further underscore the necessity for American Airlines' service to Haneda. 

Just a month ago, Los Angeles Mayor Eric Garcetti visited Japan to promote increased 

business ties with our Los Angeles business community. It is a fact that In 2011, Japan was 

the largest source of Foreign Direct Investment into Los Angeles County while travel demand 

between the two countries was sustained by the approximately 250,000 Japanese 

Americans and 50,000 Japanese nationals living in Southern California. American Airlines' 

LAX-Haneda flight will not only better connect travelers and businesses, but it will help 

stimulate new business opportunities and create much needed jobs for California 

companies. 

We strongly believe you should support the American Airlines' application for nonstop 

service between LAX and Haneda because it will not only have a positive impact on both our 

Japanese American community, the Japanese business community and our state's 

economy, but will best utilize the scarce Haneda slots. Therefore, we urge you to approve 

American Airlines' proposal to serve Haneda from LAX without further delay. 

Sincerely, 

Vice-Chair, U.S.-Japan Council 

Chair, Japanese American Cultural Center 

Cc: Susan Kurland, Assistant Secretary for Aviation and International Affairs 


December 30, 2014

The Honorable Anthony R. Foxx

Secretary of Transportation

United States Department of Transportation

1200 New Jersey Avenue, SE

Washington, DC 20590

Subject: Application of American Airlines in the U.S.-Haneda Combination Services 

Allocation Proceeding, Docket DOT-OST-2010-0018

Dear Secretary Foxx:

I am the founder, chairman and chief collaboration officer of IW Group, a minority-owned and 

operated company with offices in Los Angeles, New York and San Francisco. Our firm 

specializes in marketing and advertising to Asian-American consumers, the fastest growing 

segment of the United States population. We employ more than 60 full-time professionals and 

will celebrate our 25th anniversary next year.

Our company’s growth and development is heavily dependent on having accessible, affordable 

and regular service to global and domestic markets, including Japan. Since we rely so heavily on 

having service to and from Los Angeles International Airport (LAX), we were thrilled to learn 

that American Airlines has applied to secure a slot-pair from the U.S. Department of 

Transportation to serve Tokyo International Airport/Haneda Airport (HND) from LAX.

It is very, very difficult for a small, but growing company to secure nonstop service to HND. I 

feel very strongly that businesses and consumers should have better access to this airport since 

it is often more convenient to fly there than the larger Narita International Airport. It is my 

understanding that only three airline companies currently operate daily service at HND, which 

does not provide enough options for growing companies such as ours. Having additional 

service and access to HND will increase options and positively impact international trade, 

tourism, educational and cultural ties and much more. 

As you and your colleagues may already know, Los Angeles and Southern California are home to 

the largest number of Japanese and Japanese-American companies in the country. Direct 

foreign investment in Los Angeles County by the Japanese has created thousands of jobs and 

has fueled our economy for a number of years. In order for the greater Los Angeles area to 
Hon. Anthony R. Foxx

Page 2

remain competitive in an increasingly competitive global world, we must have regular and 

convenient access to airports such as HND

Two years ago, I co-founded a national Asian/Pacific-Islander American Chamber of Commerce 

to address the needs, interests and aspirations of entrepreneurs, business owners and 

corporate leaders of Asian Americans, Native Hawaiians and Pacific Islanders. Our organization 

strongly believes that future economic development between the U.S. and Asia requires 

transportation access to all major Asian markets, including Tokyo. In 2015-16, we are planning 

at least one trade mission to Japan. Having additional access to HND will help us in promoting 

this trade mission to our members and governmental partners.

Since airline slots at HND rarely become available, we strongly urge swift and decisive action by 

you and the U.S. Department of Transportation to approve American Airlines’ proposal to serve 

Haneda Airport from Los Angeles International Airport.

I would appreciate a response to this letter. I also request being kept informed on the progress 

of American Airlines’ proposal.

Very truly yours,

Bill Imada

Chairman and Chief Collaboration Officer

IW Group, Inc.

cc: Hon. Susan Kurland, Assistant Secretary for Aviation and International Affairs

Hon. Jay Rockefeller, Chairman, Commerce, Science and Transportation Committee, U.S. 

Senate

Ms. Sach Takayasu, President and CEO, Asian/Pacific Islander American Chamber of 

Commerce and Entrepreneurship (ACE)

Mr. Jimmy Ferguon, Chairman, ACE

December 30, 2014

The Honorable Anthony R. Foxx

Secretary of Transportation

U.S. Department of Transportation

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Application of American Airlines in the U.S.-Haneda Combination Services Allocation 

Proceeding, Docket DOT-OST-2010-0018 

Dear Secretary Foxx:

I represent Kintetsu International Express Travel Consultants Company that provides travel related 

services located in NEW YORK, NEW JERSEY, CHICAGO, LOS ANGELES and SAN JOSE. We employ 69

workers to provide our product/service and the service proposed by American Airlines will contribute to 

continued growth of our business/customer base. It is in this context that we write to express our

enthusiastic support for American Airlines’ application to acquire a slot pair from the Department to serve 

Tokyo’s Haneda Airport (“Haneda”) from Los Angeles International Airport (“LAX”). 

The nonstop flights to Haneda are scarce national resources that should be distributed amongst 

U.S. carriers to obtain the maximum consumer and economic benefits. Yet, today three U.S. carriers 

operate the four daily flights at Haneda, limiting travel options for U.S. consumers and shippers who want 

convenient access to Tokyo. We are convinced that American’s proposed daily service from LAX to Haneda 

will have the effect of increasing the existing cultural, tourism, and business ties.

As you may be aware, California and Japan enjoy strong business and cultural ties that further 

underscore the necessity for American Airlines’ service to Haneda. In 2011, Japan was the largest source 

of Foreign Direct Investment into Los Angeles County while travel demand between the two countries was 

sustained by the approximately 250,000 Japanese Americans and 50,000 Japanese nationals living in 

Southern California. American Airlines’ LAX-Haneda flight will not only better connect travelers and 

businesses, but it will help stimulate new business opportunities and create much needed jobs for other 

California companies. 

We strongly believe American Airlines’ application for nonstop service between LAX and Haneda will

not only have a positive impact on both our clients and our state’s economy, but will best utilize the scarce 

Haneda slots. Therefore, we urge you to approve American Airlines’ proposal to serve Haneda from LAX

without further delay. 

Sincerely,

Koji Hamada, President

Kintetsu International Express

Travel Consultants Company

Cc: Susan Kurland, Assistant Secretary for Aviation and International Affairs
December 29, 2014

The Honorable Anthony R. Foxx

Secretary of Transportation

U.S. Department of Transportation

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Application of American Airlines in the U.S.-Haneda Combination Services Allocation Proceeding, Docket 

DOT-OST-2010-0018 

Dear Secretary Foxx:

We write to encourage you to approve American Airlines’ proposal to serve Haneda from LAX without further 

delay.

I am the CEO of The Pacific Bridge Companies, an international wealth management firm helping to connect 

financial advisors from banking, insurance, investment, tax, and the law, and from different geographical 

locations between Asia and the United States. We employ and independently contract over 400 

practitioners between Japan and the United States alone to deliver to our vision -- to help financial advisors 

help their clients wherever in the world their lives may lead. We believe that the American Airlines proposal

will contribute to continued growth of our business relationships and overall customer base. It is because of 

this that I write to express our holding company’s enthusiastic support for American Airlines’ application to 

acquire a slot pair from the Department to serve Tokyo’s Haneda Airport (“Haneda”) from Los Angeles 

International Airport (“LAX”). 

We understand the nonstop flights to Haneda to be scarce national resources. Today only three U.S. carriers 

operate daily flights at Haneda, limiting travel options for U.S. consumers and shippers who want convenient 

access to Tokyo while failing to maximize the potential economic benefit to those involved within the region. 

We further believe that American’s proposed daily service from LAX to Haneda may help increase existing 

cultural exchange, tourism, and business ties, underscoring the necessity for American Airlines’ service to 

Haneda. In 2011, Japan was the largest source of Foreign Direct Investment into Los Angeles County while 

much of that travel demand between the two countries was sustained by the approximately 250,000 

Japanese Americans and 50,000 Japanese nationals living in Southern California. American Airlines’ LAXHaneda flight will not only better connect travelers and businesses, but promises to help stimulate new 

business opportunities and create much needed jobs for other California companies. 

With all of this at hand, we urge you to expeditiously approve American Airlines’ application for nonstop

service between LAX and Haneda.

With sincere hope,

Stephen Kagawa

cc: Susan Kurland, Assistant Secretary for Aviation and International Affairs


 

Bob Graziano

Chairman

Kathryn Schloessman

President

 

 

December 20, 2014

The Honorable Anthony R. Foxx

Secretary of Transportation

U.S. Department of Transportation

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Application for American Airlines in the U.S.-Haneda Combination Services Allocation 

Proceeding, Docket DOT-OST-2010-0018

Dear Secretary Foxx:

I represent Los Angeles Sports & Entertainment Commission (LASEC) that partners with the City of Los 

Angeles the Los Angeles Tourism and Convention Board, to help bring major sporting and entertainment 

events to Los Angeles, like the NBA All-Star Weekend, the GRAMMY Awards, the College Football Playoffs

and many more. These events have a significant economic impact on the local economy and continue to 

spotlight Los Angeles as the Entertainment Capital of the World. 

The service proposed by American Airlines will contribute to continued growth of our business/customer 

base, as well as our many global sponsors and board members. It is in this context that we write to express 

our enthusiastic support for American Airlines’ application to acquire a slot pair from the Department to 

serve Tokyo’s Haneda Airport (“Haneda”) from Los Angeles International Airport (“LAX”). 

The nonstop flights to Haneda are scarce national resources that should be distributed amongst U.S. 

carriers to obtain the maximum consumer and economic benefits. Yet, today three U.S. carriers operate 

the four daily flights at Haneda, limiting travel options for U.S. consumers and shippers who want 

convenient access to Tokyo. We are convinced that American’s proposed daily service from LAX to 

Haneda will have the effect of increasing the existing cultural, tourism, and business ties.

As you may be aware, California and Japan enjoy strong business and cultural ties that further underscore 

the necessity for American Airlines’ service to Haneda. In 2011, Japan was the largest source of Foreign 

Direct Investment into Los Angeles County while travel demand between the two countries was sustained 

by the approximately 250,000 Japanese Americans and 50,000 Japanese nationals living in Southern 

California. American Airlines’ LAX-Haneda flight will not only better connect travelers and businesses, but 

it will help stimulate new business opportunities and create much needed jobs for other California 

companies. 

333 South Hope Street, 18th Floor • Los Angeles, CA 90071 • 213/236-2361 • www.lasec.net• www.facebook.com/lasports

Official Marketing Partners of the Los Angeles Sports & Entertainment Commission
We strongly believe American Airlines’ application for nonstop service between LAX and Haneda will not 

only have a positive impact on both our constituents and our state’s economy, but will best utilize the 

scarce Haneda slots. Therefore, we urge you to approve American Airlines’ proposal to serve Haneda 

from LAX without further delay. 

Sincerely,

Kathryn S. Schloessman

President

cc: Susan Kurland, Assistant Secretary for Aviation and International Affairs


Lim, Ruger & Kim, LLP

1055 West Seventh Street, Suite 2800

Los Angeles, California 90017-2554

Tel: (213) 955-9500

Fax: (213) 955-9511

www.limruger.com

Sandy Sakamoto

Email: sandy.sakamoto@limruger.com 

{00965222.DOCX} Los Angeles | San Francisco

December 30, 2014

The Honorable Anthony R. Foxx

Secretary of Transportation

U.S. Department of Transportation

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Application of American Airlines in the U.S.-Haneda Combination 

Services Allocation Proceeding, Docket DOT-OST-2010-0018

Dear Secretary Foxx:

As an attorney with a firm that does business with Asia and an active member of 

the Japanese American community in Los Angeles I write to support American Airlines’ 

application to acquire a slot pair from the Department to serve Tokyo’s Haneda Airport

(“Haneda”) from Los Angeles International Airport (“LAX”). 

The nonstop flights to Haneda are scarce national resources that should be 

distributed amongst U.S. carriers to obtain the maximum consumer and economic 

benefits. Yet, today three U.S. carriers operate the four daily flights at Haneda, limiting

travel options for U.S. consumers and shippers who want convenient access to Tokyo. 

We are convinced that American’s proposed daily service from LAX to Haneda will 

have the effect of increasing the existing cultural, tourism, and business ties.

As you may be aware, California and Japan enjoy strong business and cultural 

ties that further underscore the necessity for American Airlines’ service to Haneda. In 

2011, Japan was the largest source of Foreign Direct Investment into Los Angeles

County while travel demand between the two countries was sustained by the 

approximately 250,000 Japanese Americans and 50,000 Japanese nationals living in 

Southern California. American Airlines’ LAX-Haneda flight will not only better 

connect travelers and businesses, but it will help stimulate new business opportunities 

and create much needed jobs for other California companies. 

We strongly believe American Airlines’ application for nonstop service between 

LAX and Haneda will not only have a positive impact on both our constituents and our 
The Honorable Anthony R. Foxx

Secretary of Transportation

U.S. Department of Transportation

December 30, 2014

Page 2 of 2

{00965222.DOCX}

state’s economy, but will best utilize the scarce Haneda slots. Therefore, we urge you to 

approve American Airlines’ proposal to serve Haneda from LAX without further delay. 

Sincerely,

LIM, RUGER & KIM, LLP

Sandy L. Sakamoto

cc: Susan Kurland, Assistant Secretary for Aviation and International Affairs