BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

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

:

In the Matter of :

:

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

SERVICE ALLOCATION PROCEEDING :

:

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

CONSOLIDATED ANSWER OF

UNITED AIR LINES, INC.

Communications with respect to this document should be sent to:

Hershel I. Kamen

Senior Vice President-Alliances,

 Regulatory and Policy

Daniel A. Weiss

Managing Director-International

 Affairs and Regulatory

UNITED AIR LINES, INC.

77 West Wacker Drive-HDQIZ

10th Floor HDQIZ

Chicago, IL 60601

(312) 997-7573

hershel.kamen@united.com

dan.weiss@united.com

Steve Morrissey

Managing Director-Regulatory

 Affairs and Policy

UNITED AIR LINES, INC.

1225 New York Avenue, NW

Suite 1100-DCAIZ

Washington, DC 20005

(202) 521-4400

steve.morrissey@united.com

September 6, 2012

Thomas Newton Bolling

Vice President and Deputy General Counsel

Jonathan T. Linde

Managing Director and Senior Counsel-

 Regulatory

UNITED AIR LINES, INC.

77 West Wacker Drive

16th Floor HDQLD

Chicago, IL 60601

(312) 997-8068

thomas.bolling@united.com

jonathan.linde@united.com

Lorraine B. Halloway

Gerald F. Murphy

Steven J. Seiden

CROWELL & MORING LLP

1001 Pennsylvania Avenue, N.W.

Washington, DC 20004-2595

(202) 624-2500

lhalloway@crowell.com

gmurphy@crowell.com

sseiden@crowell.com

Counsel for

United Air Lines, Inc.
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

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

:

In the Matter of :

:

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

SERVICE ALLOCATION PROCEEDING :

:

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

CONSOLIDATED ANSWER OF

UNITED AIR LINES, INC.

I. INTRODUCTION

United1proposes to provide new entrant Tokyo Haneda service at its San Francisco hub 

gateway – serving the second largest West Coast-Tokyo market. Meanwhile Delta, which has 

underutilized these scarce, valuable Haneda slots, seeks to control all U.S. carrier-operated 

service from the West Coast by serving a second West Coast gateway with far fewer passengers 

and online connecting opportunities than United at San Francisco; Hawaiian proposes to serve 

another island gateway that would offer scant benefits to U.S. consumers and virtually no 

connecting opportunities; and American proposes to serve a gateway that already receives 

nonstop U.S. carrier Haneda service. United is the only applicant in this proceeding that is not

currently permitted to serve Haneda with its own aircraft and crews and is thus the only applicant

that can bring new competition to Tokyo Haneda. Selecting United over these Haneda 

incumbents will both maximize public benefits and establish competitive parity for U.S. carriers 

at Tokyo Haneda. 

 

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

Page 2

To maximize the public benefits to the traveling and shipping public available through

the use of these valuable Tokyo Haneda slots while at the same time enhancing the overall 

competitive environment in the U.S.-Japan market, the Department should select United’s 

proposal to operate daily San Francisco-Haneda flights because:

 United’s proposal will provide nonstop Tokyo Haneda service in the second largest 

West Coast-Tokyo market.

 In addition to providing enhanced convenience for nonstop passengers in one of the 

largest U.S.-Tokyo markets, United will provide convenient connecting service 

between Tokyo Haneda and points served behind its San Francisco hub.

 Only United’s proposal will introduce new U.S. carrier service and a large hub 

network for Tokyo Haneda passengers throughout the Western U.S.

 United is the only U.S. carrier serving Japan that is not permitted to operate at Tokyo 

Haneda with its own aircraft and crews, and awarding the available slots to United

will correct this imbalance and establish competitive parity among U.S. carriers at 

Haneda.

 United has committed to continuing its service between San Francisco and Tokyo 

Narita to offer passengers the convenience of Tokyo Haneda service as well as the 

alternative time-of-day flights and extensive connections at Tokyo Narita.

None of the proposals by other airlines – all of which already have access to Tokyo 

Haneda – should be selected over United’s proposal to offer San Francisco-Haneda service.

 Delta’s proposal to serve Seattle is inferior to United’s proposal because it would 

leave Delta as the only U.S. carrier serving Haneda from the West Coast and forfeit 

the competitive benefits of a new entrant at Tokyo Haneda, Seattle is a far smaller

Tokyo market than San Francisco, and Delta offers few online connections at Seattle

– relying almost exclusively on Alaska-operated codeshare service.

 Hawaiian’s proposal to serve Kona is inferior to United’s proposal because it will 

offer few benefits to U.S. consumers, Kona is a much smaller Tokyo market than San 

Francisco, and Hawaiian offers no nonstop connections between Kona and the 

mainland United States.

 American’s proposal to offer Los Angeles-Tokyo Haneda service duplicates Delta’s 

existing service at Los Angeles, and would leave the second largest West CoastTokyo gateway without nonstop U.S. carrier access to Haneda.
Consolidated Answer of United

Page 3

United answers the applications of Delta, Hawaiian and American as follows and urges 

the Department to grant its application to provide San Francisco-Tokyo Haneda service.

II. UNITED’S PROPOSAL OFFERS FAR MORE PUBLIC BENEFITS THAN THE 

OTHER PROPOSALS

United’s proposal to provide nonstop San Francisco-Tokyo Haneda service offers far 

more public benefits than the other proposals and Department precedent compels the award of 

the available Haneda slots to United. The Department should select the largest U.S.-Tokyo 

market to maximize the number of passengers who will benefit from the introduction of nonstop 

Tokyo Haneda service at the gateway supporting the largest traffic volume to meet its “principal 

objective” in allocating slots to “maximize the public benefits. . .that will likely result in service 

that best meets the needs of the traveling and shipping public.” Order 2012-8-20 at 3. To make 

this determination, the Department should also consider the hub strength and connecting 

networks of the applicants’ U.S. gateways in addition to large volumes of local Tokyo traffic. 

Indeed, the “ability to flow traffic over the primary route to and from points behind the U.S. 

gateway. . .figured significantly in carrier selection because it bears on both the economic 

viability of a carrier’s proposal and the benefits it might bring to passengers outside of the 

primary market.” 51 Fed. Reg. 43180 at 43187 (Dec. 1, 1986) (establishing procedures and 

criteria for selecting carriers for limited entry markets). The combination of a large gateway 

market with plentiful online connections has enabled United to institute and sustain U.S.-Asia 

services. Exhibits UA-A-113 to A-115; and UA-A-126 to A-128. Appropriate emphasis on 

these two factors will also ensure the long term success of the selected Tokyo Haneda service. 

United proposes to serve a large nonstop market that lacks U.S. carrier service, and properly 

timed Tokyo Haneda flights from United’s San Francisco hub would provide competitive new 

entrant service to approximately 1.8 million Americans – reaching a catchment area far larger 
Consolidated Answer of United

Page 4

than those offered by the Delta and Hawaiian proposals. Exhibits UA-A-104 and UA-A-117.

United at San Francisco will also provide more roundtrip connections than American can provide 

at Los Angeles. Exhibit UA-A-123.

San Francisco is the second largest West Coast-Tokyo market (Exhibit UA-A-100), and 

United’s San Francisco hub is the largest and most comprehensive hub both on the West Coast 

and at which Haneda service is being proposed in this proceeding. Exhibit UA-A-129 and 

UA-A-130. San Francisco is also the largest U.S.-Tokyo gateway without nonstop U.S. carrier 

access to Haneda, and United is the only U.S. carrier serving Japan that is not permitted to 

operate there. Exhibit UA-A-108. Awarding the available Tokyo Haneda slots to United will 

correct this imbalance by providing competitive parity among U.S. carriers at Haneda. In 

addition, United’s extensive hub at San Francisco will offer convenient online connecting service 

for passengers traveling between points throughout North America and Tokyo Haneda.

III. UNITED’S PROPOSAL SHOULD BE SELECTED OVER THE AMERICAN, 

DELTA AND HAWAIIAN PROPOSALS

United’s proposal for San Francisco-Tokyo Haneda service should be selected since it 

will serve the public interest far better than the proposals offered by the other applicants in this 

proceeding. 

A. Delta’s Proposal to Serve Seattle Despite its Small Size and Minimal Online 

Connecting Opportunities Would Leave Delta as the Only U.S. Carrier Serving 

Haneda from the West Coast

The San Francisco-Tokyo market is nearly three times larger than the Seattle-Tokyo 

market. Exhibit UA-A-100. In sharp contrast to Delta’s non-hub at Seattle, United at its San 

Francisco hub not only operates more than nine times the number of weekly departures and 

seven times the number of destinations, but also supports more than twice the number of weekly 

Asian departures and Asian destinations. Exhibits UA-A-113 to A-115. Delta’s proposed 
Consolidated Answer of United

Page 5

service in the small Seattle-Tokyo Haneda market would offer virtually no online connections on 

Delta flights other than those serving its own hubs. Moreover, Delta’s Atlanta, Detroit and 

Minneapolis/St. Paul hubs (at which Delta would offer online connections to its proposed 

Seattle-Haneda service) already have nonstop service to Delta’s Tokyo Narita hub, in addition to 

Delta’s existing service to Tokyo Haneda from Los Angeles. See Application of Delta at 6-7 and 

Exhibit DL-401, et seq. The roundtrip connections Delta purports to offer to its proposed 

Seattle-Tokyo Haneda service would also largely constitute self-diversion from Delta’s existing 

Los Angeles-Haneda service in any event. Exhibit UA-A-112.

Delta’s claim that “[t]ogether, Delta and its domestic codeshare partner, Alaska Airlines, 

will provide nonstop-to-nonstop connections to 42 U.S. cities” (Application of Delta at 4) is 

misleading. First, “Delta” (including services marketed by Delta but offered by an entirely 

different airline), would provide roundtrip connections to only 28 U.S. points. Exhibit UA-A104. Additionally, Delta would only provide online connecting service to Haneda in four of 

those 28 markets – only 14% – relying on Alaska-operated service for the other 86%. 

Application of Delta at 4. When it selected Delta’s Los Angeles-Tokyo Haneda proposal in the 

initial Haneda slot allocation proceeding despite Delta’s reliance on Alaska/Horizon codeshare 

service, the Department did so by determining that “Delta’s proposal at Los Angeles would 

maximize public benefits by providing service in the largest west coast and mainland U.S.-

Tokyo market” and finding that the Alaska/Horizon codeshare services, which accounted for 

only 10 of Delta’s 18 (or 56%) purported connections (Application of Delta dated Feb. 26, 2010 

in this docket, Exhibits DL-126-129), would “augment the large Los Angeles-Tokyo local traffic 

base.” Order 2010-5-7 at 9. Here, Alaska codeshare service is Delta’s proposal. Consideration 

of these factors clearly warrants rejection of Delta’s proposed Seattle-Haneda service – with its 
Consolidated Answer of United

Page 6

virtually complete reliance on codeshare flights for connecting service (well beyond that of 

Delta’s Los Angeles proposal) – in a market that is nearly five times smaller than the Los 

Angeles-Tokyo Market and three times smaller than the San-Francisco-Tokyo market. Exhibit 

UA-A-100. Any benefits of Delta’s proposal pale in comparison to the 31 convenient roundtrip 

online connections United would provide with its San Francisco-Haneda service. Exhibit UA-A104. 

Delta’s claims regarding the competitive benefits of its proposed Seattle-Tokyo Haneda 

service also do not withstand scrutiny. Selecting Delta’s Seattle-Tokyo Haneda proposal would

further entrench Delta’s dominant position by allowing it to serve Tokyo Haneda via two West 

Coast gateways to the exclusion of any other U.S. carriers. Exhibits UA-A-109 to A-111. This 

would clearly be at odds with the stated intent of the U.S.-Japan Open Skies agreement to 

“ensure fair competition regarding the new opportunities at Tokyo’s close-in Haneda airport.” 

Press Release, U.S. Dept. of Transp., U.S. Transportation Secretary LaHood Announces U.S.-

Japan Agreement on Open Skies (Dec. 11, 2009). Many of Delta’s proposed Tokyo Haneda 

connections at Seattle would duplicate the connections already provided by Delta at Los 

Angeles. Exhibit UA-A-112. By contrast, United’s proposed San Francisco-Tokyo Haneda 

service would provide Delta with intergateway competition for nonstop West Coast-Tokyo 

Haneda traffic and offer travelers the public benefits of United’s extensive hub network at San 

Francisco. Exhibits UA-A-110 and UA-A-111. 

Delta’s assertions with respect to interalliance competition are similarly without merit. 

Here, Delta contends that its Seattle-Tokyo Haneda service is essential because “Delta is the only 

carrier capable of offering a competitive alternative to the west coast Haneda services of 

American/JAL at San Francisco and United/ANA at Los Angeles.” Application of Delta at 8. 
Consolidated Answer of United

Page 7

But Delta already provides daily nonstop Los Angeles-Tokyo Haneda Service. In granting 

antitrust immunity to oneworld and Star in the U.S.-Japan Alliance Case, the Department 

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

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

discipline versus SkyTeam.” Order 2010-10-4 at 7. Unless United’s San Francisco-Haneda 

proposal is selected, United would remain the only U.S. carrier serving Japan not permitted to 

operate at Haneda and Star would continue to be the only global alliance whose U.S. carrier 

member is unable to do so. Exhibit UA-A-108. 

Lastly, Delta attacks United’s legitimate interest in serving Haneda with its own aircraft

and crews by distorting the concept of metal neutrality in an attempt to deflect attention from 

SkyTeam/Delta’s competitive strength in the U.S.-Japan market. See Application of Delta at 8-

9. In rejecting the argument that the immunized joint ventures at issue in the U.S.-Japan 

Alliance Case would cause U.S. carriers to lose flying, the Department was unequivocal: “we 

believe that American, Continental, and United, like their partners, have every incentive to 

increase capacity if possible, which could provide for more opportunities for pilots and other 

labor groups.” Order 2010-10-4; see also, e.g., Order 2009-4-5 at 19. And United in this 

proceeding proposes to do just what DOT has found to be decisive – which is to offer 

competitive new entrant service at Tokyo Haneda for its customers, clients, communities and 

coworkers.

2 Delta’s suggestion that Star/ANA could simply move its Haneda slots (currently 

being used for Los Angeles-Haneda service that competes with Delta’s service) to serve San 

Francisco is self-serving and ignores the valuable consumer benefits that this existing service 

 

2 Delta’s questioning of United’s commitment to “metal neutrality” with its 

Japanese carrier partner simply because United is an applicant in this proceeding is nonsensical. 

American is also in an immunized joint venture with a Japanese partner; and American currently 

enjoys access to Tokyo Haneda. United is simply asking for equal treatment.
Consolidated Answer of United

Page 8

provides in its own right. See Order 2010-10-4 at 10. In any case, the Department concluded 

that one of the many public benefits of granting the Star carriers’ application in that case would 

be “maintaining and expanding nonstop service” – not reducing it. Id. at 13.

B. Hawaiian’s Proposal Would Use These Valuable Haneda Slots to Serve a Small

Japan-Origin Tourist Market With No Connections to the U.S. Mainland and 

Offers Few Benefits to U.S. Consumers

Hawaiian proposes to provide nonstop service in the Kona-Tokyo market that is nearly 

three times smaller than the San Francisco market. Exhibit UA-A-116. Hawaiian’s proposed 

service at Kona would offer no connections to the U.S. mainland whatsoever, offering 

connecting service only to Honolulu and Maui. See Application of Hawaiian, Exhibit HAApp2012-2. This stands in stark contrast to the comprehensive network benefits offered by

United at San Francisco. Exhibit UA-A-126. Putting aside that Hawaiian is seeking a second 

pair of U.S.-Tokyo Haneda slots while United is still not permitted to operate at Haneda, 

Hawaiian has yet to provide service from Kona or any point in the open-entry Hawaii-Tokyo 

Narita market. Exhibit UA-A-119. Moreover, with the Kona-Tokyo market consisting of 97% 

Japan point of sale passengers, Hawaiian’s proposed service will benefit virtually no U.S. 

consumers. Exhibit UA-A-117. It is also unclear that Kona International Airport has sufficient 

CBP/FIS facilities to accommodate Hawaiian’s proposed Kona-Tokyo Haneda service. See 

Application of Hawaiian at n. 2.

C. American’s Proposal Duplicates Delta’s Service at Los Angeles and Its Selection 

Would Leave the Second Largest West Coast-Tokyo Gateway Without U.S. 

Carrier Service to Haneda

While Los Angeles is the largest West Coast-Tokyo market, American’s Los AngelesHaneda proposal would duplicate Delta’s existing service at Los Angeles and would leave San 

Francisco, the second largest West Coast-Tokyo market, without any nonstop U.S. carrier 
Consolidated Answer of United

Page 9

service. Exhibit UA-A-125. Under similar circumstances, the Department “selected Continental 

to introduce Newark-Beijing service to address the biggest service deficiency in the U.S.-China 

market at that time – the lack of any U.S. carrier nonstop service to China from New York, 

which represented the largest U.S.-China [O&D] market in that proceeding.” Order 2007-2-10 at 

5 (emphasis added). The Los Angeles-Tokyo market already has nearly twice the amount of 

service compared to San Francisco – even without American operating at Haneda. See OAG, 

August 2012. Not only has the Department looked unfavorably on duplicative service proposals 

in limited-entry route proceedings (see, e.g., Orders 2009-3-14 (U.S.-Brazil), 2007-2-10 (U.S.-

China), and 2007-9-25 (U.S.-China), but it has consistently “stated in. . .carrier selection 

proceedings that, when rights for U.S. carriers become available in restrictive markets, one of 

[the Department’s] primary goals has been to enhance competition by creating opportunities for 

new entrant carriers to gain market access.” Order 2009-3-14 at 7-8 (citing Orders 2008-3-4 and 

2007-9-25).

American’s Los Angeles proposal offers less connectivity than United’s San Francisco 

proposal, with 23 roundtrip connecting flights for American at Los Angeles and 31 roundtrip 

connecting flights for United at San Francisco. United at San Francisco also provides service to 

more than twice the number of destinations and offers two times the number of weekly 

departures than American at Los Angeles, including three times the number of Asian weekly 

departures and three times the number of Asian destinations.3 Exhibits UA-A-126 and 

 

3 American has also not yet determined what schedule changes, if any, would result 

from its proposed Los Angeles-Tokyo Haneda service. See Application of American at 9. It is

thus worth noting that, unlike United’s plans to continue operating at least one daily San 

Francisco-Tokyo Narita flight year-round if awarded the requested Tokyo Haneda slots, 

American completely discontinued its New York/JFK-Tokyo Narita service in 2012 shortly after 

recommencing the New York/JFK-Tokyo Haneda service for which it was selected in the initial 

proceeding. See OAG, 2012.
Consolidated Answer of United

Page 10

UA-A-128. The San Francisco-Tokyo market also has a larger share of U.S. point of sale 

passengers than the Los Angeles-Tokyo market. See MIDT YE July 2012.

American’s claim that selection of its proposed Los Angeles-Haneda service is necessary 

to correct a “competitive imbalance among the three global alliances” because that route is 

served by SkyTeam and Star but not oneworld (Application of American at 6) ignores the fact 

that Star is the only immunized global alliance whose U.S. carrier partner still remains locked 

out of Haneda. Following its initial award of one slot pair to American to provide New 

York/JFK-Haneda service (see Order 2010-7-2), the Department concluded that its grants of 

immunity to oneworld and Star in the U.S.-Japan Alliance Case would result in “three 

immunized alliance competitors with comparable market shares” and “a balanced competitive 

interalliance dynamic in the U.S.-Japan market.” Order 2010-10-4 at 7. Indeed, selecting 

United’s San Francisco-Haneda proposal is the only way to truly address the imbalance in 

interalliance competition that exists with respect to U.S.-Japan services.4 

 

4 United’s proposed San Francisco-Tokyo Haneda service will also enable Star to 

compete directly with the nonstop service in that market provided by American’s oneworld

partner, JAL.


Docket DOT-OST-2010-0018

Haneda Service

Before The

Department Of Transportation

2012 U.S. – Tokyo Haneda Combination Services Allocation 

Proceeding Docket DOT-OST-2010-0018

Nonstop San Francisco – Tokyo Haneda

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

Haneda Service

Index of Exhibits

Page 1 of 3

United Index Of Answer Exhibits

Exhibit

Number Tokyo - Haneda Service 

Number

Of Pages

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

Tokyo Market

1

UA-A-101 The San Francisco - Tokyo Market Is Nearly Three Times 

Larger Than The Seattle - Tokyo Market

1

UA-A-102 The California - Tokyo Market Is Nearly Nine Times 

Larger Than The Washington - Tokyo Market

1

UA-A-103 The Northern California - Tokyo Market Is Nearly Three 

Times Larger Than The Washington - Tokyo Market

1

UA-A-104 United’s San Francisco - Tokyo Haneda Proposal Will 

Reach More Consumers Than Delta At Seattle Even With 

Delta’s Codesharing On Alaska Airlines

1

UA-A-105 The San Francisco Metropolitan Area’s Asian Population 

Is Four Times Larger Than Seattle’s Asian Population

1

UA-A-106 California’s Asian Population Is Ten Times Larger Than 

Washington’s Asian Population

1

UA-A-107 Northern California’s Asian Population Is Nearly Five 

Times Larger Than Washington’s Asian Population

1

UA-A-108 Delta Already Operates Tokyo Haneda Service While 

United Is Not Permitted To Do So

1

UA-A-109 Delta Already Operates Between The West Coast And 

Tokyo Haneda

1

UA-A-110 United Proposes To Provide First Time U.S. Carrier 

Nonstop Competition On The West Coast

1

UA-A-111 United Proposes To Provide First Time U.S. Carrier 

Connecting Service And/Or Competitive Connecting 

Service Between Tokyo Haneda And Smaller Western 

Communities

1

UA-A-112 Delta’s Proposal To Provide Connections To/From Tokyo 

Haneda Via Seattle Would Duplicate Delta’s Connections 

To/From Tokyo Haneda Already Provided At Los Angeles

1
Docket DOT-OST-2010-0018

Haneda Service

Index of Exhibits

Page 2 of 3

United Index Of Answer Exhibits

Exhibit

Number Tokyo - Haneda Service 

Number

Of Pages

UA-A-113 United’s San Francisco Hub Is Larger Than Delta And 

Alaska’s Seattle Operations Combined

1

UA-A-114 United Continues To Grow Its Asian Operations At San 

Francisco, Which Are Twice As Large As Delta’s Asian 

Operations At Seattle

1

UA-A-115 United’s San Francisco Hub Domestic Operations Are 

Larger Than Delta And Alaska’s Seattle Domestic 

Operations Combined

1

UA-A-116 The San Francisco - Tokyo Market Is Nearly Three Times 

Larger Than The Kona - Tokyo Market

1

UA-A-117 Hawaiian’s Proposal Will Benefit Almost No U.S. 

Consumers

1

UA-A-118 Hawaiian Already Operates Tokyo Haneda Service While 

United Is Not Permitted To Do So

1

UA-A-119 Hawaiian Has Yet To Serve The Open Entry Hawaii -

Tokyo Narita Market

1

UA-A-120 The San Francisco Metropolitan Area’s Asian Population 

Is 38 Times Larger Than Kona’s Asian Population

1

UA-A-121 California’s Asian Population Is Nine Times Larger Than 

Hawaii’s Asian Population

1

UA-A-122 Northern California’s Asian Population Is Four Times 

Larger Than Hawaii’s Asian Population

1

UA-A-123 United At San Francisco Will Provide Roundtrip 

Connections To Eight More Points Than American At Los 

Angeles

1

UA-A-124 American Already Operates Tokyo Haneda Service While 

United Is Not Permitted To Do So

1

UA-A-125 American’s Los Angeles - Tokyo Haneda Proposal Does 

Not Offer Any Time-Of-Day Coverage Unique To Delta’s 

Current Los Angeles - Tokyo Haneda Service

1
Docket DOT-OST-2010-0018

Haneda Service

Index of Exhibits

Page 3 of 3

United Index Of Answer Exhibits

Exhibit

Number Tokyo - Haneda Service 

Number

Of Pages

UA-A-126 United’s San Francisco Hub Is Larger Than American At 

Los Angeles

1

UA-A-127 United Continues To Grow Its Asian Operations At San 

Francisco, Which Are Three Times Larger Than 

American’s Asian Operations At Los Angeles

1

UA-A-128 United’s San Francisco Hub Domestic Operations Are 

Larger Than American’s Los Angeles Domestic 

Operations

1

UA-A-129 United’s San Francisco Hub Is The Largest Hub On The 

West Coast

1

UA-A-130 United’s San Francisco Hub Is The Largest Gateway 

Competing In This Proceeding

1
Docket DOT-OST-2010-0018

Haneda Service

UA-A-100

Page 1 of 1

San Francisco Is The Second Largest West Coast - Tokyo Market 

Source: MIDT YE July 2012

Note: Tokyo = Tokyo Haneda + Tokyo Narita

West Coast Tokyo

Point Passengers

Los Angeles 493,366

San Francisco 230,918

Seattle 85,386

San Diego 37,078

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

Haneda Service

UA-A-101

Page 1 of 1

The San Francisco - Tokyo Market Is Nearly Three Times Larger Than 

The Seattle - Tokyo Market

Gateway U.S. – Tokyo 

Passengers

San Francisco 

Larger

San Francisco 230,918 2.7 Times

Seattle 85,386

U.S. – Tokyo Passengers

Source: MIDT YE July 2012

Note: Tokyo = Tokyo Haneda + Tokyo Narita

230,918

85,386

0

50,000

100,000

150,000

200,000

250,000

San Francisco Seattle
Docket DOT-OST-2010-0018

Haneda Service

UA-A-102

Page 1 of 1

The California - Tokyo Market Is Nearly Nine Times Larger Than The 

Washington - Tokyo Market

U.S. – Tokyo Passengers

State U.S. – Tokyo 

Passengers

California 

Larger

California 777,484 8.8 Times

Washington 88,022

Source: MIDT YE July 2012

Note: Tokyo = Tokyo Haneda + Tokyo Narita

777,484

88,022

0

100,000

200,000

300,000

400,000

500,000

600,000

700,000

800,000

900,000

California Washington
Docket DOT-OST-2010-0018

Haneda Service

UA-A-103

Page 1 of 1

The Northern California - Tokyo Market Is Nearly Three Times Larger 

Than The Washington - Tokyo Market

U.S. – Tokyo Passengers

State U.S. – Tokyo 

Passengers

Northern 

California Larger

Northern 

California

242,050 2.7 Times

Washington 88,022

Source: MIDT YE July 2012

Note: Tokyo = Tokyo Haneda + Tokyo Narita

242,050

88,022

0

50,000

100,000

150,000

200,000

250,000

300,000

Northern California Washington
Docket DOT-OST-2010-0018

Haneda Service

UA-A-104

Page 1 of 1

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

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

Alaska Airlines

Source: MIDT YE July 2012, Tokyo Haneda applications

Note: Roundtrip U.S. connections

Point Market Size Point Market Size

San Francisco 230,918 Seattle 85,386

Boise 3,803

Boston 66,459 Atlanta 40,347

Burbank 123 Detroit 43,529

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

Chico 121 Salt Lake City 19,598

Cleveland 7,292

Dallas/Ft. Worth 43,902

Denver 18,630 Anchorage 4,262

Eugene 1,069 Bellingham 103

Eureka 91 Boise 3,803

Fresno 1,224 Bozeman 963

Houston 42,380 Burbank 123

Las Vegas 97,448 Juneau 126

Los Angeles 493,366 Kalispell 150

Medford 420 Ketchikan 56

Modesto 65 Las Vegas 97,448

Monterey 721 Los Angeles 493,366

New York / JFK & Liberty 378,278 Medford 420

Ontario 304 Missoula 297

Orange County 1,282 Oakland 451

Phoenix 21,153 Orange County 1,282

Portland 35,610 Pasco 764

Redding 366 Phoenix 21,153

Redmond 383 Portland 35,610

Reno 1,851 Pullman 99

Sacramento 3,597 Sacramento 3,597

San Diego 37,078 San Diego 37,078

San Luis Obispo 262 San Francisco 230,918

Santa Barbara 1,067 San Jose 4,420

Seattle 85,386 Spokane 1,455

Washington / Dulles 89,294 Walla Walla 51

Delta Only Catchment Area 213,125

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

Delta Online Connections

Connections Operated By Alaska

United's Proposed Catchment Area Delta's Proposed Catchment Area
Docket DOT-OST-2010-0018

Haneda Service

UA-A-105

Page 1 of 1

The San Francisco Metropolitan Area’s Asian Population Is Four Times 

Larger Than Seattle’s Asian Population

Source: U.S. Census Data 2010

Note: San Francisco metropolitan area includes: San Francisco, Oakland, Fremont, San 

Jose, Sunnyvale and Santa Clara

Gateway Asian 

Population

San Francisco 

Larger

San Francisco 1,577,790 4.0 Times

Seattle 392,961

Metropolitan Area Asian Population

1,577,790

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

1,600,000

1,800,000

San Francisco Seattle

392,961
Docket DOT-OST-2010-0018

Haneda Service

UA-A-106

Page 1 of 1

California’s Asian Population Is Ten Times Larger Than Washington’s 

Asian Population

Asian Population

State Asian 

Population

California

Larger 

California 4,861,007 10.1 Times

Washington 481,067

Source: U.S. Census Data 2010

0

1,000,000

2,000,000

3,000,000

4,000,000

5,000,000

6,000,000

California Washington

481,067

4,861,007
Docket DOT-OST-2010-0018

Haneda Service

UA-A-107

Page 1 of 1

Northern California’s Asian Population Is Nearly Five Times Larger Than 

Washington’s Asian Population

State Asian 

Population

Northern 

California

Larger

Northern 

California 

2,246,518 4.7 Times

Washington 481,067

Source: U.S. Census Data 2010

0

500,000

1,000,000

1,500,000

2,000,000

2,500,000

Northern California Washington

2,246,518

481,067

Asian Population
Docket DOT-OST-2010-0018

Haneda Service

UA-A-108

Page 1 of 1

Delta Already Operates Tokyo Haneda Service While United Is Not 

Permitted To Do So

Source: August 2012 OAG

1/ Seven weekly frequencies currently allocated to Delta are at issue in this proceeding

U.S. Carrier Operating To/From Japan? Operating To/From Tokyo Haneda? Weekly Tokyo Haneda Frequencies

American Yes Yes 7

Delta Yes Yes 14 1/

Hawaiian Yes Yes 7

United Yes NO 0
Docket DOT-OST-2010-0018

Haneda Service

UA-A-109

Page 1 of 1

Delta Already Operates Between The West Coast And Tokyo - Haneda

Los Angeles

Seattle

Delta Proposed West Coast - Tokyo Haneda Service

Delta Current West Coast - Tokyo Haneda Service

DL Current DL Proposed DL Total Other U.S. Carriers

7 at Los Angeles 7 at Seattle 14 0

Delta West Coast - Tokyo Haneda Weekly Frequency Plan

Source: August 2012 OAG, Delta 2012 Tokyo Haneda application
Docket DOT-OST-2010-0018

Haneda Service

UA-A-110

Page 1 of 1

United Proposes To Provide First Time U.S. Carrier Nonstop 

Competition On The West Coast 

Los Angeles

San Francisco

United Proposed West Coast Tokyo Haneda Service

Delta Current West Coast Tokyo Haneda Service

Source: August 2012 OAG, United 2012 Tokyo Haneda application

DL Current UA Proposed

7 at Los Angeles 7 at San Francisco

United West Coast - Tokyo Haneda Weekly Frequency Plan
Docket DOT-OST-2010-0018

Haneda Service

UA-A-111

Page 1 of 1

United Proposes To Provide First Time U.S. Carrier Connecting Service 

And/Or Competitive Connecting Service Between Tokyo Haneda And 

Smaller Western Communities

Source: United 2012 Tokyo Haneda application

Note: Roundtrip U.S. connections

San Francisco

Fresno

Monterey

Eureka

Eugene Boise

Modesto

Reno

San Luis Obispo

Santa Barbara

Sacramento

Redding

Chico

Medford

Redmond

United Proposed Connecting Tokyo Haneda Service

Proposed Tokyo Haneda Gateway
Docket DOT-OST-2010-0018

Haneda Service

UA-A-112

Page 1 of 1

Delta’s Proposal To Provide Connections To/From Tokyo Haneda Via 

Seattle Would Duplicate Delta’s Connections To/From Tokyo Haneda 

Already Provided At Los Angeles

Source: August 2012 OAG, Delta 2010 and 2012 Tokyo Haneda applications

Note: Roundtrip U.S. connections 

Los Angeles

Atlanta

Detroit

Phoenix

San Diego

Points Delta Claims To Connect To/From Tokyo Haneda Via Seattle

That Are Already Served By Delta At Los Angeles

Delta Proposed Tokyo Haneda Connections Via Seattle

Delta Current Tokyo Haneda Connections Via Los Angeles

Seattle

Sacramento

Salt Lake City

San Jose

Portland

Oakland

Las Vegas

San Francisco

Minneapolis

Proposed And Current Tokyo Haneda Gateway
Docket DOT-OST-2010-0018

Haneda Service

UA-A-113

Page 1 of 1

United’s San Francisco Hub Is Larger Than Delta And Alaska’s Seattle 

Operations Combined

Source: August 2012 OAG

Note: Delta and Alaska destination total excludes double counting destinations served by

both Delta and Alaska

Total Weekly Frequencies

Total Destinations

239 

2,259 

1,997 

- 

500 

1,000 

1,500 

2,000 

2,500 

United @ SFO Delta and Alaska @ SEA

12 

84 

75

- 

10 

20 

30 

40 

50 

60 

70 

80 

90 

United @ SFO Delta and Alaska @ SEA

63

1,758

Delta Operations

Alaska Operations

Delta Operations

Alaska Operations
Docket DOT-OST-2010-0018

Haneda Service

UA-A-114

Page 1 of 1

United Continues To Grow Its Asian Operations At San Francisco, 

Which Are Twice As Large As Delta’s Asian Operations At Seattle

Source: August 2012 OAG

6 

3 

- 

1 

2 

3 

4 

5 

6 

7 

United @ SFO Delta @ SEA

49 

21 

- 

10 

20 

30 

40 

50 

60 

United @ SFO Delta @ SEA

Asian Weekly Frequencies

Asian Destinations
Docket DOT-OST-2010-0018

Haneda Service

UA-A-115

Page 1 of 1

Source: August 2012 OAG

Note: Domestic = U.S. and Canada. Delta and Alaska destination total excludes double 

counting destinations served by both Delta and Alaska

Domestic Weekly Frequencies

Domestic Destinations

7 

70 70 

- 

10 

20 

30 

40 

50 

60 

70 

80 

United @ SFO Delta and Alaska @ SEA

198 

2,131 

1,956 

- 

500 

1,000 

1,500 

2,000 

2,500 

United @ SFO Delta and Alaska @ SEA

63

1,758

Delta Operations

Alaska Operations

Delta Operations

Alaska Operations

United’s San Francisco Hub Domestic Operations Are Larger Than Delta 

And Alaska’s Seattle Domestic Operations Combined
Docket DOT-OST-2010-0018

Haneda Service

UA-A-116

Page 1 of 1

The San Francisco - Tokyo Market Is Nearly Three Times Larger Than 

The Kona - Tokyo Market

Gateway U.S. – Tokyo 

Passengers

San Francisco 

Larger

San Francisco 230,918 2.6 Times

Kona 89,530

U.S. – Tokyo Passengers

Source: MIDT YE July 2012

Note: Tokyo = Tokyo Haneda + Tokyo Narita

230,918

89,530

0

50,000

100,000

150,000

200,000

250,000

San Francisco Kona
Docket DOT-OST-2010-0018

Haneda Service

UA-A-117

Page 1 of 1

Hawaiian’s Proposal Will Benefit Almost No U.S. Consumers

Source: MIDT YE July 2012, point of sale comparison

Note: Tokyo = Tokyo Haneda + Tokyo Narita

Kona – Tokyo Passengers By Point Of Sale

Number Of U.S. Consumers

To Benefit From Hawaiian’s

Proposal 

1,482

19,388

89,530 68,659

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

80,000

90,000

100,000

Total 

Customers

Sold in Japan Sold in Other 

Countries

Sold in the U.S.
Docket DOT-OST-2010-0018

Haneda Service

UA-A-118

Page 1 of 1

U.S. Carrier Operating To/From Japan? Operating To/From Tokyo Haneda? Weekly Tokyo Haneda Frequencies

American Yes Yes 7

Delta Yes Yes 14 1/

Hawaiian Yes Yes 7

United Yes NO 0

Hawaiian Already Operates Tokyo Haneda Service While United Is Not 

Permitted To Do So

Source: August 2012 OAG

1/ Seven weekly frequencies currently allocated to Delta are at issue in this proceeding
Docket DOT-OST-2010-0018

Haneda Service

UA-A-119

Page 1 of 1

Hawaiian Has Yet To Serve The Open Entry Hawaii - Tokyo Narita Market

Source: August 2012 OAG

U.S. Carrier Operating To/From Japan? Operating To/From Tokyo Narita Operating To/From Tokyo Haneda

American Yes Yes Yes

Delta Yes Yes Yes

Hawaiian Yes NO Yes

United Yes Yes NO
Docket DOT-OST-2010-0018

Haneda Service

UA-A-120

Page 1 of 1

The San Francisco Metropolitan Area’s Asian Population Is 38 Times 

Larger Than Kona’s Asian Population

Source: U.S. Census Data 2010

Note: San Francisco metro area includes: San Francisco, Oakland, Fremont, San Jose, 

Sunnyvale and Santa Clara.

Gateway Asian 

Population

San Francisco 

Larger

San Francisco 1,577,790 38.4 Times

Kona / Hawaii 

County

41,050

Metropolitan Area Asian Population

1,577,790

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

1,600,000

1,800,000

San Francisco Kona / Hawaii County

41,050
Docket DOT-OST-2010-0018

Haneda Service

UA-A-121

Page 1 of 1

California’s Asian Population Is Nine Times Larger Than Hawaii’s Asian 

Population

State Asian 

Population

California 

Larger

California 4,861,007 9.3 Times

Hawaii 525,078

Source: U.S. Census Data 2010

Asian Population

4,861,007

525,078

0

1,000,000

2,000,000

3,000,000

4,000,000

5,000,000

6,000,000

California Hawaii
Docket DOT-OST-2010-0018

Haneda Service

UA-A-122

Page 1 of 1

Northern California’s Asian Population Is Four Times Larger Than 

Hawaii’s Asian Population

State Asian 

Population

Northern 

California 

Larger

Northern 

California

2,246,518 4.3 Times

Hawaii 525,078

Source: U.S. Census Data 2010

0

500,000

1,000,000

1,500,000

2,000,000

2,500,000

Northern California Hawaii 

2,246,518

525,078

Asian Population
Docket DOT-OST-2010-0018

Haneda Service

UA-A-123

Page 1 of 1

Source: Tokyo Haneda applications

Note: Roundtrip U.S. connections

United At San Francisco Will Provide Roundtrip Connections To Eight 

More Points Than American At Los Angeles

United's Proposed Catchment Area American's Proposed Catchment Area

Boise Albuquerque

Boston Anchorage

Burbank Boston

Chicago Chicago

Chico Dallas/Ft. Worth

Cleveland Denver

Dallas/Ft. Worth Fresno

Denver Houston

Eugene Las Vegas

Eureka Miami

Fresno Monterey

Houston Nashville

Las Vegas New York / JFK

Los Angeles Orlando

Medford Phoenix

Modesto Portland

Monterey Sacramento

New York / JFK & Liberty San Diego

Ontario San Francisco

Orange County San Jose

Phoenix Santa Barbara

Portland Seattle

Redding Washington / Dulles

Redmond

Reno

Sacramento

San Diego

San Luis Obispo

Santa Barbara

Seattle

Washington / Dulles

Total = 31 Total = 23
Docket DOT-OST-2010-0018

Haneda Service

UA-A-124

Page 1 of 1

U.S. Carrier Operating To/From Japan? Operating To/From Tokyo Haneda? Weekly Tokyo Haneda Frequencies

American Yes Yes 7

Delta Yes Yes 14 1/

Hawaiian Yes Yes 7

United Yes NO 0

American Already Operates Tokyo Haneda Service While United Is Not 

Permitted To Do So

Source: August 2012 OAG

1/ Seven weekly frequencies currently allocated to Delta are at issue in this proceeding
Docket DOT-OST-2010-0018

Haneda Service

UA-A-125

Page 1 of 1

American’s Los Angeles - Tokyo Haneda Proposal Does Not Offer Any 

Time-Of-Day Coverage Unique To Delta’s Current Los Angeles - Tokyo 

Haneda Service

Delta Current American Proposed American Proposed Delta Current

DL# 635 AA# 127 Flight Number AA# 128 DL #636

Daily Daily Frequency Daily Daily

A330 B777 Equipment B777 A330

1:10am 1:25am Los Angeles 6:20pm 6:55pm

4:55am 5:00am Tokyo Haneda 12:05am 12:30am

Source: August 2012 OAG, American 2012 Tokyo Haneda application
Docket DOT-OST-2010-0018

Haneda Service

UA-A-126

Page 1 of 1

United’s San Francisco Hub Is Larger Than American At Los Angeles

Source: August 2012 OAG

84 

41 

- 

10 

20 

30 

40 

50 

60 

70 

80 

90 

United @ SFO American @ LAX

2,259 

1,054 

- 

500 

1,000 

1,500 

2,000 

2,500 

United @ SFO American @ LAX

Total Weekly Frequencies

Total Destinations
Docket DOT-OST-2010-0018

Haneda Service

UA-A-127

Page 1 of 1

Source: August 2012 OAG

6 

2 

- 

1 

2 

3 

4 

5 

6 

7 

United @ SFO American @ LAX

49 

14 

- 

10 

20 

30 

40 

50 

60 

United @ SFO American @ LAX

Asian Weekly Frequencies

Asian Destinations

United Continues To Grow Its Asian Operations At San Francisco, Which 

Are Three Times Larger Than American’s Asian Operations At Los 

Angeles
Docket DOT-OST-2010-0018

Haneda Service

UA-A-128

Page 1 of 1

United’s San Francisco Hub Domestic Operations Are Larger Than 

American’s Los Angeles Domestic Operations

Source: August 2012 OAG

Note: Domestic = U.S. and Canada

70 

37 

- 

10 

20 

30 

40 

50 

60 

70 

80 

United @ SFO American @ LAX

2,131 

1,023 

- 

500 

1,000 

1,500 

2,000 

2,500 

United @ SFO American @ LAX

Domestic Weekly Frequencies

Domestic Destinations
Docket DOT-OST-2010-0018

Haneda Service

UA-A-129

Page 1 of 1

United’s San Francisco Hub Is The Largest Hub On The West Coast

Source: August 2012 OAG

Hub - Carrier Weekly Departs

SFO - UA 2,259

SEA - AS 1,758

LAX - UA 1,464

ANC - AS 809

PDX - AS 703

Top 5 West Coast Hubs
Docket DOT-OST-2010-0018

Haneda Service

UA-A-130

Page 1 of 1

United’s San Francisco Hub Is The Largest Gateway Competing In This 

Proceeding

Source: August 2012 OAG

239

(DL)

2,259

1,758

(AS)

1,054

149

0

500

1,000

1,500

2,000

2,500

UA @ SFO DL and AS @ SEA AA @ LAX HA @ KOA

1,997

Total Weekly Frequencies