BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Motion and Application of

AMERICAN AIRLINES, INC.

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

Services Allocation Proceeding

 Docket DOT-OST-2010-0018

MOTION AND 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

Thompson Hine LLP

1919 M Street, NW

Suite 700

Washington, DC 20036-1600

(202) 263.4189

charles.hunnicutt@thompsonhine.com

patricia.snyder@thompsonhine.com

October 2, 2014
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Motion and Application of

AMERICAN AIRLINES, INC.

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

Services Allocation Proceeding

Docket DOT-OST-2010-0018

MOTION AND APPLICATION OF AMERICAN AIRLINES, INC.

American Airlines, Inc. (“American”) respectfully requests the Department to grant this motion to 

withdraw one daily U.S.-Haneda frequency from Delta Air Lines (“Delta”)1, and to reallocate that 

frequency to American. Delta just announced that it is reducing its Haneda service for the upcoming 

winter season. American would use that frequency between Los Angeles and Haneda year-round, service 

that would be substantially superior to Delta’s near-dormant Seattle-Haneda service. American 

vigorously opposes any use of these valuable Haneda rights on a seasonal basis, and we stand ready to use 

them fully on a year-round basis. The Department should not allow Delta to squander these valuable 

frequencies, which the United States worked hard to obtain, and for which there is unmet demand.

News reports indicate that Delta intends to operate only a limited winter season service in the 

Seattle-Haneda market.

2

 This is consistent with Delta’s most recent filing in the Official Airline Guide

(“OAG”), which contains proof of Delta’s planned underutilization of its Seattle-Haneda service, as 

shown in the following table:

 

1 Although the Haneda route rights are sometimes referred to as slots, they do not give carriers a right to a specific time 

of operation, as an airport slot would. In substance, they are a right to operate a daily service, usually referred to as frequencies, 

and we adopt that terminology here.

2

 J. Gillie, Delta cancels its Seattle-Tokyo Haneda Flight for the Winter, THENEWSTRIBUNE.COM, Sept. 26, 2014,

http://www.thenewstribune.com/2014/09/26/3400761_delta-cancels-its-seattle-tokyo.html?rh=1.(“[Delta] is canceling non-stop 

service for much of the fall, winter and early spring on its Sea-Tac-to-Tokyo Haneda flight.”). See also, B. Drum, Delta to 

suspend the Seattle/Tacoma-Tokyo Haneda Route for the Winter, WORLD AIRLINE NEWS.COM, Sept. 21, 2014, 

http://worldairlinenews.com/2014/09/21/delta-to-suspend-the-seattletacoma-tokyo-haneda-route-for-the-winter/.
Motion and Application

Of American Airlines, Inc.

Page 2 of 7

DELTA’S PUBLISHED HANEDA OPERATING SCHEDULE FOR WINTER 2014-15

Source: Exhibit AA-1, using OAG schedules (viewed 9/29/2014).

Week Scheduled Weekly Flights 

Between Seattle and Haneda

October 5, 2014 0

October 12, 2014 0

October 19, 2014 0

October 26, 2014 0

November 2, 201 0

November 9, 2014 0

November 16, 2014 7

November 23, 2014 0

November 30, 2014 0

December 6, 2014 0

December 13, 2014 0

December 20, 2014 0

December 27, 2014 0

January 4, 2015 0

January 11, 2015 0

January 18, 2015 0

January 25, 2015 0

February 1, 2015 0

February 8, 2015 2

February 15, 2015 5

February 22, 2015 0

March 1, 2015 0

March 8, 2015 0

March 15, 2015 0

March 22, 2015 0

March 29, 2015 3

TOTAL 17
Motion and Application

Of American Airlines, Inc.

Page 3 of 7

As the Department is aware, the frequency is subject to the condition that it will become dormant 

and revert automatically to the Department if it is not used for a period of 90 days. The table above 

shows that Delta plans to operate a daily service for one week every 90 days – just enough to keep the 

frequency from going dormant and reverting to the Department for reallocation. Out of 182 possible 

operating days, Delta plans to operate on only 17 days – less than 10 percent of the total days. This 

limited service provides no consumer benefits.

1. U.S. Airlines Returned to Haneda Despite Delta’s Obstructionism.

The Department worked long and hard to restore U.S.-carrier access to Haneda, after more than three 

decades of absence. Throughout the course of the multi-round negotiations to gain Haneda access for 

U.S. carriers, Delta saw the U.S. Government’s (“USG”) goal as a threat to its Narita hub. Delta opposed 

any U.S. compromise on open skies unless it would deliver complete flexibility to move Delta’s entire 

portfolio from Narita to Haneda. Although it was clear that such a position would derail the U.S.-Japan 

talks, Delta garnered powerful political support for its position and brought enormous pressure on USG 

negotiators. Today, Delta continues to oppose efforts that would introduce new service to Haneda unless 

Delta’s objective of moving its entire Narita hub to Haneda is ensured in any new agreement.

Despite Delta’s opposition during the open skies negotiations, the USG was successful in 

securing four daily frequencies (or slot pairs) for U.S. carriers to serve Haneda. Six U.S. airlines 

competed for those four opportunities.

3

 

Nevertheless, the Department entrusted half of its hard-won access to Haneda to Delta in the 2010 

U.S.-Haneda frequency case.4 There, Delta argued that it would serve more U.S. cities than the gateways 

 

3 Order to Show Cause, Order 2010-5-7, 2010 U.S.-Haneda Combination Services Allocation Proceeding, Docket DOTOST-2010-0018 (served May 7, 2010).

4

Final Order, Order 2010-7-2, 2010 U.S.-Haneda Combination Services Allocation Proceeding, Docket DOT-OST2010-0018 (served July 6, 2010).
Motion and Application

Of American Airlines, Inc.

Page 4 of 7

on the U.S. East Coast could.5 Delta also claimed it could provide better service than the other applicants 

because “Detroit boasts a large local market to Tokyo with 33,000 annual O&D passengers.”6 Delta 

argued that it would make the most efficient use of the Haneda frequencies by using a Boeing 747-400 

with a 403-seat capacity at Detroit.7

Then, in 2012, having over-promised the Department of the consumer benefits it would deliver 

with a daily Detroit-Haneda service, Delta was forced to return and ask for a second chance, this time at 

Seattle. At the time, American and others voiced concerns that Seattle was the smallest market proposed 

in the proceeding and questioned the viability of the service. But Delta promised the Department 

significant competition and transportation benefits. Delta claimed that Seattle–Haneda was a “unique 

new product in a new time channel that will drive increased demand” for Delta flights.8 The Department 

once again placed its confidence in Delta and allowed the gateway to be moved from Detroit to Seattle.

9

Delta has again failed in its promises by operating only a seasonal service in the Seattle-Haneda 

market.

10 Seattle is an ideally located West Coast gateway to Japan and a city of growing importance to 

Delta. If Delta still cannot make Haneda work, Delta’s frequency should be reallocated. Delta should 

not be given a third bite at the apple.

Unlike Delta, when American decided to terminate its JFK-Haneda service, American did not 

hoard the frequency by providing just enough flights within the 90-day dormancy period to stave off 

automatic reversion to the Department. Instead, American notified the Department of its withdrawal, 

allowing reallocation.

 

5 Answer of Delta Air Lines, Inc., 2010 U.S.-Haneda Combination Services Allocation Proceeding, Docket DOT-OST2010-0018 at 17 (March 1, 2010). 

6

Id. at 11.

7

Id. 

8 Consolidated Reply of Delta Air Lines, Inc. at 14, 2010 U.S.-Haneda Combination Services Allocation Proceeding, 

Docket DOT-OST-2010-0018 (Sept. 13, 2012).

9

Final Order, Order 2013-2-4, 2010 U.S.-Haneda Combination Services Allocation Proceeding, Docket DOT-OST2010-0018 (served Feb. 5, 2013).

10 Exhibit AA-1 (showing Delta’s underutilization). 
Motion and Application

Of American Airlines, Inc.

Page 5 of 7

American is today proposing a credible, well-considered service plan that responds to the demand 

in the market, unlike Delta, which is essentially deserting Seattle. We urge the Department to seize this 

opportunity to restore the public benefits for which it negotiated.

2. American Would Make Better Use Of The Haneda Frequency.

American has designed a realistic, achievable service proposal that would take advantage, to the 

extent possible, of connecting banks of flights within the United States,11 but would focus on some of the 

characteristics that make the U.S.-Haneda market different from the U.S.-Narita market. American’s 

entry into the Los Angeles-Haneda market furthers the Department’s goals by improving the competitive 

structure of the U.S.-Haneda market.

American proposes to begin service between Los Angeles and Haneda on January 15, 2015, using

a 247-seat B-777 aircraft.

12

 American will offer daily service, which will better meet demand than 

Delta’s seasonal offering and will fully use these valuable operating rights.

13 Further, since Los Angeles 

is a hub for American, its service will provide connections to other U.S. destinations. 

American’s proposal also responds to U.S-Haneda market characteristics that reflect the severely 

restricted operating hours at Haneda. First, American will focus its service specifically at Tokyo O&D 

passengers in the Los Angeles region, with a convenient late afternoon Los Angeles departure and an 

early evening arrival back in Los Angeles. 

Second, American has chosen a U.S. West Coast gateway, Los Angeles, instead of an interior 

U.S. gateway like Chicago or Dallas/Ft. Worth. It is clear that Haneda curfew restrictions make service to 

interior U.S. gateways infeasible at this time. American discontinued its New York-Haneda service due 

to unsustainable losses, the result of unattractive schedules forced by the curfew. Delta also tried to 

operate from an interior U.S. point with no success. Indeed, in the most recent Haneda frequency 

 

11 Exhibit AA-2 (American’s service proposal).

12 Exhibit AA-2 (American’s service proposal).

13 Exhibits AA-2 (American’s service proposal).
Motion and Application

Of American Airlines, Inc.

Page 6 of 7

allocation proceeding, the only applicants were for San Francisco and Kona. As long as the curfew is in 

place, the schedules that result make viable service from interior U.S. points unattractive to consumers 

and airlines.

14

Finally, American’s re-entry into the market will achieve the goals the Department had hoped to 

achieve in the 2010 allocation by improving the competitive structure of the U.S.-Tokyo market.

15 Not 

only will American’s service compete head-to-head with Los Angeles-Haneda incumbents Delta and All 

Nippon Airways, but it will also enhance overall competition to the U.S.-Tokyo market, as Los Angeles is 

the largest continental U.S. gateway to Tokyo. The demand in the Los Angeles-Tokyo market is robust 

enough that six carriers today operate Los Angeles-Narita flights. A new U.S. entrant into Haneda will 

provide important competition in the Tokyo market.

In sum, American’s proposal will achieve a convenient and well-timed Los Angeles-Haneda 

schedule for consumers travelling to or through the largest West Coast U.S.-Tokyo market. The proposal 

will also inject new competition into the Los Angeles-Tokyo market; thereby ensuring consumers have a 

variety of options when travelling to Tokyo. Finally, it will further the Department’s goals of fostering 

competition and maximizing public benefits from limited-entry route rights.

3. Delta’s Poor Service Is Thwarting the Department’s Goals; Reallocation to 

American would Further Them.

Delta’s efforts to hold onto its frequency allocation are thwarting the Department’s goal of 

making the most effective use of its hard-won Haneda rights. The Department’s long-standing policy is 

that it is in the public interest to redeploy dormant limited-entry rights as soon as possible,16 and Delta’s 

 

14 American recognizes that there may be a need for modifying the Haneda operating restrictions. American looks 

forward to working with the Department to do so upon its entry into the Haneda market. 

15

 Final Order, Order 2010-7-2 at 6, 2010 U.S.-Haneda Combination Services Allocation Proceeding, Docket DOT-OST2010-0018 (served July 6, 2010)

16 Order 2008-10-20, 2008 U.S.-Brazil Combination Frequency Allocation Proceeding, Docket DOT-OST-2008-0307 

(served Oct. 21, 2008) (“As we have stated many times before, it has been the Department’s longstanding policy not to permit 

valuable operating rights to remain unused for an extended period of time, particularly when another carrier has firm plans to use 

them, and the carrier holding authority does not.”); see also, Certificate Duration in Limited Entry Markets, Final Rule, 51 Fed. 

Reg. 43181 (Dec. 1, 1986).
Motion and Application

Of American Airlines, Inc.

Page 7 of 7

Seattle-Haneda service will be effectively dormant for the coming winter season.17 The Department 

should withdraw the allocation and reallocate it to American for its proposed daily, year-round service.

American will provide substantially superior service to Delta’s winter operating season plan. In 

its policy statement on authority in limited-entry markets, the Department gave as an example of 

substantially superior service “a proposal to provide daily service in a market receiving three weekly 

flights.”18 Since Delta would effectively offer no service in the Seattle-Haneda market, American’s 

proposal to provide year-round daily service more than meets that test. American’s service also furthers

the Department’s goals of ensuring that carriers meet market demand and yield consumer benefits, 

whereas Delta’s service is unresponsive and has no public benefits. 

5. Conclusion

American urges the Department to end Delta’s squandering of valuable frequencies. We 

respectfully suggest that the Department could do so now by granting American’s motion to withdraw the 

valuable Haneda frequencies from Delta forthwith – and give consumers an opportunity to benefit from 

the proposal that American presents here to bring better service to the market and make more effective 

use of the U.S.-Haneda frequencies.

19

Respectfully submitted,

Howard Kass 

Robert A. Wirick

Abigail Donovan

 

17

 Exhibit AA-1 (showing Delta’s underutilization). 

18 Certificate Duration in Limited Entry Markets, Final Rule, 51 Fed. Reg. 43181, 43184 (Dec. 1, 1986).

19 American also seeks such other and further relief as the Department may decide.
CERTIFICATE OF SERVICE

I, Abigail Donovan, certify that, on October 2, 2014, I caused to be served a copy of the 

foregoing Answer of American Airlines, Inc. by email upon those addressees listed below:

EngleTS@state.gov (Department of State)

paul.gretch@dot.gov (Department of Transportation)

brian.hedberg@dot.gov (Department of Transportation)

brett.kruger@dot.gov (Department of Transportation)

sascha.vanderbellen@delta.com (Delta)

chris.walker@delta.com (Delta)

jhill@cooley.com (Hawaiian)

dan.weiss@united.com (United)

thomas.bolling@united.com (United)

glindsey@lawa.org (Los Angeles World Airports)

___________________________

Abigail Donovan
Exhibit AA-1

Page 1 of 7

Delta Is Underutilizing Its Valuable Haneda Frequency Allocation

Winter 2014/2015 Schedule

Source: OAG (viewed 9/29/2014)

Month

Total Number of 

DL Operated Flights 

(SEA-HND Nonstop)

October 2014 0

November 2014 7

December 2014 0

January 2015 0

February 2015 7

March 2015 3

TOTAL 17
Exhibit AA-1

Page 2 of 7

Number of Delta Seattle – Haneda Operations in October: 0

Month Date Day of Week DL Operating 

SEA-HND Nonstop

October

1 Wednesday No

2 Thursday No

3 Friday No

4 Saturday No

5 Sunday No

6 Monday No

7 Tuesday No

8 Wednesday No

9 Thursday No

10 Friday No

11 Saturday No

12 Sunday No

13 Monday No

14 Tuesday No

15 Wednesday No

16 Thursday No

17 Friday No

18 Saturday No

19 Sunday No

20 Monday No

21 Tuesday No

22 Wednesday No

23 Thursday No

24 Friday No

25 Saturday No

26 Sunday No

27 Monday No

28 Tuesday No

29 Wednesday No

30 Thursday No

31 Friday No
Exhibit AA-1

Page 3 of 7

Number of Delta Seattle – Haneda Operations in November: Only 7

Month Date Day of Week DL Operating 

SEA-HND Nonstop

November

1 Saturday No

2 Sunday No

3 Monday No

4 Tuesday No

5 Wednesday No

6 Thursday No

7 Friday No

8 Saturday No

9 Sunday No

10 Monday No

11 Tuesday No

12 Wednesday No

13 Thursday No

14 Friday No

15 Saturday No

16 Sunday Yes

17 Monday Yes

18 Tuesday Yes

19 Wednesday Yes

20 Thursday Yes

21 Friday Yes

22 Saturday Yes

23 Sunday No

24 Monday No

25 Tuesday No

26 Wednesday No

27 Thursday No

28 Friday No

29 Saturday No

30 Sunday No
Exhibit AA-1

Page 4 of 7

 

Number of Delta Seattle – Haneda Operations in December: 0

Month Date Day of Week DL Operating 

SEA-HND Nonstop

December

1 Monday No

2 Tuesday No

3 Wednesday No

4 Thursday No

5 Friday No

6 Saturday No

7 Sunday No

8 Monday No

9 Tuesday No

10 Wednesday No

11 Thursday No

12 Friday No

13 Saturday No

14 Sunday No

15 Monday No

16 Tuesday No

17 Wednesday No

18 Thursday No

19 Friday No

20 Saturday No

21 Sunday No

22 Monday No

23 Tuesday No

24 Wednesday No

25 Thursday No

26 Friday No

27 Saturday No

28 Sunday No

29 Monday No

30 Tuesday No

31 Wednesday No
Exhibit AA-1

Page 5 of 7

Number of Delta Seattle – Haneda Operations in January: 0

Month Date Day of Week DL Operating 

SEA-HND Nonstop

January

1 Thursday No

2 Friday No

3 Saturday No

4 Sunday No

5 Monday No

6 Tuesday No

7 Wednesday No

8 Thursday No

9 Friday No

10 Saturday No

11 Sunday No

12 Monday No

13 Tuesday No

14 Wednesday No

15 Thursday No

16 Friday No

17 Saturday No

18 Sunday No

19 Monday No

20 Tuesday No

21 Wednesday No

22 Thursday No

23 Friday No

24 Saturday No

25 Sunday No

26 Monday No

27 Tuesday No

28 Wednesday No

29 Thursday No

30 Friday No

31 Saturday No
Exhibit AA-1

Page 6 of 7

Number of Delta Seattle – Haneda Operations in February: Only 7

Month Date Day of Week DL Operating 

SEA-HND Nonstop

February

1 Sunday No

2 Monday No

3 Tuesday No

4 Wednesday No

5 Thursday No

6 Friday No

7 Saturday No

8 Sunday No

9 Monday No

10 Tuesday No

11 Wednesday No

12 Thursday No

13 Friday Yes

14 Saturday Yes

15 Sunday Yes

16 Monday Yes

17 Tuesday Yes

18 Wednesday Yes

19 Thursday Yes

20 Friday No

21 Saturday No

22 Sunday No

23 Monday No

24 Tuesday No

25 Wednesday No

26 Thursday No

27 Friday No

28 Saturday No
Exhibit AA-1

Page 7 of 7

Number of Delta Seattle – Haneda Operations in March: Only 3

Month Date Day of Week DL Operating 

SEA-HND Nonstop

March

1 Sunday No

2 Monday No

3 Tuesday No

4 Wednesday No

5 Thursday No

6 Friday No

7 Saturday No

8 Sunday No

9 Monday No

10 Tuesday No

11 Wednesday No

12 Thursday No

13 Friday No

14 Saturday No

15 Sunday No

16 Monday No

17 Tuesday No

18 Wednesday No

19 Thursday No

20 Friday No

21 Saturday No

22 Sunday No

23 Monday No

24 Tuesday No

25 Wednesday No

26 Thursday No

27 Friday No

28 Saturday No

29 Sunday Yes

30 Monday Yes

31 Tuesday Yes
Exhibit AA-2

Page 1 of 2

AMERICAN AIRLINES

Los Angeles – Haneda Nonstop Service

Effective

January 15, 2015

AA 169 Flight 

Number

AA 170

Daily Frequency Daily

B772 Equipment B772

1705 Los 

Angeles 

(LAX)

1825

| ^

| |

| |

v |

2300 Tokyo

Haneda 

(HND)

0130

12:55 Elapsed 

Time

9:55
Exhibit AA-2

Page 2 of 2

AMERICAN AIRLINES

Los Angeles - Haneda 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

AIRCRAFT AVAILABILITY - American will use aircraft 

currently in its fleet.

American operates 47 Boeing 772s (247 seats) 

FUEL AVAILABILITY - American anticipates no difficulty in 

obtaining fuel 

from existing suppliers at Los Angeles and Haneda.