BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D. C. 

----------------------------------------: 

2010 U.S. – HANEDA COMBINATION SERVICES : DOT-OST-2010- 

ALLOCATION PROCEEDING : 0018 

----------------------------------------: 

 

REPLY OF AMERICAN AIRLINES, INC. 

Communications with respect to this document should be sent 

to: 

VIRASB VAHIDI WILLIAM K. RIS, JR. 

Senior Vice President - Senior Vice PresidentMarketing and Planning Government Affairs 

and Chief Commercial Officer American Airlines,Inc. 

American Airlines, Inc. 1101 17th Street, N.W. 

P.O. Box 619616, MD 5634 Washington, D.C. 20036 

DFW Airport, Texas 75261 

 FRANCIS C. HEIL 

ROBERT A. WIRICK Senior Attorney 

Managing Director, Regulatory American Airlines,Inc. 

and International Affairs 1101 17th Street, N.W. 

American Airlines, Inc. Washington, D.C. 20036 

P.O. Box 619616, MD 5635 (202) 496-5642 

DFW Airport, Texas 75261 francis.heil@aa.com 

(817) 963-0394 

robert.wirick@aa.com 

 

 

 

 

September 13, 2012 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D. C. 

----------------------------------------: 

2010 U.S. – HANEDA COMBINATION SERVICES : DOT-OST-2010- 

ALLOCATION PROCEEDING : 0018 

----------------------------------------: 

 

REPLY OF AMERICAN AIRLINES, INC. 

 American Airlines, Inc., under the Department’s 

Order 2012-8-20 of August 17, 2012, hereby replies to the 

answers submitted on September 6, 2012 by Delta Air Lines, 

Inc., United Air Lines, Inc., and Hawaiian Airlines, Inc., 

concerning U.S.-Haneda service authority. 

 American seeks one daily U.S.-Haneda slot pair to 

operate year-round scheduled foreign air transportation of 

persons, property, and mail between Los Angeles, California 

and Tokyo (Haneda), Japan. In doing so, American proposes 

to operate 247-seat B777 aircraft to Haneda. 

 Los Angeles is the number one U.S. Mainland O&D 

market to Tokyo, with two times more local passengers than 

San Francisco and six times more than Seattle (Exhibit AA111). Global alliance competition between Los Angeles and 

Haneda is limited to Star (with service operated by ANA and 
marketed by United and US Airways) and SkyTeam (with 

service operated by Delta). Among the aligned U.S. 

carriers, American has the least number of total 

frequencies between the United States and Japan (Exhibit 

AA-RA-101). To maximize alliance competition in the 

largest Mainland-Tokyo market that would result in the 

greatest benefit to the traveling public, American and Los 

Angeles should be selected in this proceeding. 

 American has a strong identity and presence in the 

U.S.-Japan market, and is well positioned to serve the LAXHND route. American has served Japan since 1988, and has 

extensive sales and marketing relationships in both 

countries. 

 Selection of American will provide convenient online roundtrip connections from its hub at Los Angeles to 

its other hubs at Chicago, DFW, and Miami, and 22 other 

U.S. cities including San Francisco, San Jose, Seattle, 

Portland, Anchorage, Las Vegas, San Diego, Santa Barbara, 

Fresno, Denver, Houston, Boston, New York (JFK), and 

Washington (IAD). In addition, American’s immunized 

cooperative relationship with Japan Airlines will provide 

connecting opportunities beyond Haneda to more than two 

dozen cities in Japan as well as to Shanghai, Beijing, 

Bangkok, Hong Kong, Seoul, Singapore and Taiwan. 
1. DELTA 

Delta’s failure in succeeding with service from its 

large hub at Detroit should not be rewarded with a second 

chance opportunity. Doing so is not in the public interest 

especially where, as here, Delta pins its second chance 

hope on service to and from a non-hub airport, Seattle, 

where it operates to only six Mainland cities and must rely 

heavily on codeshare connecting service from its partners 

Alaska and Horizon to achieve its roundtrip connections as 

shown in Exhibit DL-A-406. Furthermore, Delta proposes use 

of the smallest aircraft from the smallest Mainland-Tokyo 

market of all the applicants1. Contrary to Delta’s 

assertion that Seattle is the largest U.S.-Tokyo O&D 

gateway that does not have service to Haneda, it ranks 

tenth in the U.S.-Haneda market without nonstop service 

(Exhibit AA-RA-102). In addition, Seattle-Haneda bookings 

were a mere .25% of all U.S.-Haneda O&D bookings. American 

plans to reduce its Los Angeles–Narita operation to five 

weekly flights in January 2013 for one month only. Daily 

service in the market resumes on February 14. To that end, 

 

1 Delta has proposed the smallest aircraft (225-seat B767) among the applicants (see Exhibit AA-R-105). 

The Department used aircraft size as a carrier selection factor in the initial decision in this docket. See 

Order 2010-5-7, p.10 (citing Delta’s significant capacity advantage). Delta, as the applicant proposing the 

least amount of capacity, should not be favored.
American is committed to operating daily Los Angeles-Haneda 

nonstop service as stated in our service proposal. 

Delta also states that American ignores its ATI 

Partnership with JAL and the metal-neutral benefits claimed 

to justify immunity (See Delta’s Exhibit DL-A-402). To the 

contrary, in implementing immunity with JAL, American’s 

goal is to position itself for long-term success in the 

U.S.-Japan and U.S.-Asia markets against Delta and United. 

For the benefit of its customers, shareholders, pilots, 

flight attendants, mechanics, and all other employees, 

American will continue to seek route opportunities to Japan 

and to operate transpacific flights in the context of the 

metal-neutral joint venture. American’s application for 

Los Angeles-Haneda is consistent with that approach. 

Finally, Delta’s suggestion that any of JAL’s, and indeed, 

ANA’s current Haneda frequencies can be reallocated should 

be rejected. JAL and ANA also had to undergo an extensive 

selection process in Japan and have made commitments to 

serve the current market city pairs. 

2. UNITED 

United and its Star Alliance partners (ANA and 

Singapore Airlines) command the largest presence in the 

U.S.-Japan nonstop market. United alone operates 9 daily 
frequencies to Tokyo from 8 gateways (Newark, Honolulu, 

Washington (Dulles), Houston, Los Angeles, Seattle and San 

Francisco) compared to American’s 5 daily operations from 

only 4 gateways (Chicago, Dallas/Fort Worth, Los Angeles 

and New York). Star operates 210 weekly nonstop 

frequencies between the U.S. and Japan, while oneworld 

operates 118 (Exhibit AA-R-108). Los Angeles is the 

largest U.S. Mainland gateway to Tokyo, and twice the size 

of San Francisco (Exhibit AA-111). In the interest of 

competitive balance among the three global alliances, and 

to best serve the public interest in the largest U.S. 

Mainland O&D market to Tokyo, American’s application for 

Los Angeles-Haneda authority should be favored over 

United’s application for a San Francisco-Haneda award. 

3. Hawaiian Airlines 

 Hawaiian’s application is the weakest among the 

contenders and clearly should be disfavored as contrary to 

the public interest. Only eight U.S.-Haneda opportunities 

are available under the U.S.-Japan air transport agreement 

and three of the eight are already being used to serve 

Hawaii (HA, JAL, and ANA each operates to Haneda from 

Honolulu)(Exhibit AA-R-111). If Hawaiian were to prevail 

here, 50 percent of all Haneda opportunities (four of 

eight) and 50 percent of U.S. carrier Haneda opportunities 
(two of four) would be used at a Hawaii gateway (Exhibit 

AA-R-112). Destinations in Hawaii account for 36 percent 

of passenger bookings in the U.S.-Tokyo market (Exhibit AAR-113), which is less than the 37.5% Haneda slot share now 

enjoyed by Hawaii. Awarding half of these valuable U.S.-

Haneda opportunities for service to Hawaii would clearly be 

contrary to the public interest. 

4. CONCLUSION 

 For the foregoing reasons, the Department should 

promptly conclude this proceeding by selecting American to 

operate nonstop service between Los Angeles and Haneda. 

Los Angeles is the largest Mainland gateway to Tokyo and is 

without nonstop service to Haneda by oneworld. Selection 

of American will benefit U.S. Japan passengers, allows 

American to achieve a stronger competitive position for 

itself in the U.S.-Japan market and remedy the competitive 

imbalance among global alliances. 

 Respectfully submitted, 

______________________

Francis C. Heil 

Senior Attorney 

American Airlines, Inc. 

September 13, 2012 
AMONG THE ALLIGNED U.S. CARRIERS, AMERICAN HAS THE 

LEAST NUMBER OF FREQUENCIES BETWEEN U.S. - JAPAN 

Source: OAG August 2012

DOT-OST-2010-0018

Exhibit AA-RA-101

Page 1 of 1

U.S. CARRIER JAPAN TOKYO

AA 35 35

DL 172 124

HA 21 21

UA 139 84

WEEKLY FREQUENCIES
SEATTLE RANKS TENTH IN THE U.S. – HANEDA MARKET 

WITHOUT NONSTOP SERVICE

DOT-OST-2010-0018

Exhibit AA-RA-102

Page 1 of 1

Source: YE July 2012MIDT Unadjusted Bookings

* Have nonstop service

CITY TOTAL SHARE (%)

Honolulu (HNL)* 344,916 50.8

Los Angeles (LAX)* 115,687 17.0

San Francisco (SFO)* 73,824 10.9

New York (NYC)* 38,131 5.6

Las Vegas (LAS) 20,690 3.0

Kona (KOA) 18,832 2.8

Orlando (MCO) 7,023 1.0

Maui (OGG) 5,413 0.8

San Diego (SAN) 4,624 0.7

Detroit (DTW) * 4,465 0.7

Boston (BOS) 3,294 0.5

Phoenix (PHX) 2,735 0.4

Miami (MIA) 2,070 0.3

Atlanta (ATL) 2,030 0.3

Seattle (SEA) 1,680 0.25

Chicago (ORD) 1,649 0.2

OTHERS 31,690 4.7

TOTAL 678,753 100.0

BOOKINGS
CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing document by email 

on the following persons:

sascha.vanderbellen@delta.com jhill@dlalaw.com

scott.mcclain@delta.com steve.morrissey@united.com

sametta.c.barnett@delta.com mgoldman@sgbdc.com

dan.weiss@united.com rsilverberg@sgbdc.com

rbkeiner@crowell.com dhainbach@ggh-airlaw.com

esahr@eckertseamons.com rpommer@atlasair.com

russell.bailey@alpa.org dmrosenthal@jamhoff.com

jonathan.linde@united.com dpdean@jamhoff.com

bob.kneisley@wnco.com dkirstein@yklaw.com

robert.land@jetblue.com jyoung@yklaw.com

msinick@ssd.com william.stallings@usdoj.gov

cdonley@ssd.com dwight.moore@ustranscom.mil

gbleopard@fedex.com john.allen@faa.gov

cefelts@fedex.com urskr@state.gov

kevin.montgomery@polaraircargo.com gmurphy@crowell.com

nssparks@fedex.com cjsimpson@zsrlaw.com

lhalloway@crowell.com benjamin.slocum@usairways.com

efaberman@wileyrein.com howard.kass@usairways.com

mroller@rollerbauer.com anita.mosner@hklaw.com

jennifer.nowak@hklaw.com

 

 

 ________________________________ 

 Francis C. Heil 

September 13, 2012