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 A NSWER 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@unite d.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 United 1 proposes 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 serv ing 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 ga teway 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 . S electing 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 A nswer of United

Page 2 To maximize the public benefits to the traveling and shipping public available through the use of the se 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 p roposal to operate daily San Francisco
- Haneda flights because:

 United ’s proposal will provide nonstop Tokyo Haneda service i n the second largest West Coast
- Tokyo market .
 In addition to providing enhanced convenience for nonstop passengers i n 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 Wester n 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 convenien c e of Tokyo Haneda service as well as the alternative time
- of

- day flights and extensi ve 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 small er Tokyo market than San Francisco , and Delta offers few online connections at Seattle

– relying almos t exclusively on Alaska
- operated codeshare service .
 Hawaiian’s proposal to serve Kona is inferior to United’s p roposal 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 m ainland 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 Coast
Tokyo gateway without nonstop U.S. carrier access to Haneda.Consolidated A nswer 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 compe ls the award of the available Haneda slots to United . T he 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 support ing 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 deter mination, 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 beh ind 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 la rge gateway market with plentiful online connections has enabled United to institute and sustain U.S.
- Asia services. Exhibits UA
- A
- 113 t o A
- 115 ; and UA
- A
- 126 to A
- 128 . Appropriate emphasis on t hese 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 largerConsolidated A nswer of United

Page 4 than th ose 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 corre ct 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 Toky o 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 o perates 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. Exhibit s UA
- A
- 113 to A
- 115 . Delta’s proposedConsolidated A nswer of United

Page 5 service in the small Seattle
- Tokyo Ha neda 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 pr oposed 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 roundtri p connections to only 28 U.S. points. Exhibit UA
- A
104. Additionally, D elta 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 , t he Department did so by determin ing that “Delta’s pro posal 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 connecti ons (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 t hese factors clearly warrants rejection of Delta’s proposed Seattle

- Haneda service

– with itsConsolidated A nswer 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
- A
104 . Delta’s claims regarding the competitive benefits of its proposed Seattle

- Tokyo Haneda service also do not withstand scrutiny . S electing Delta ’s Seattle
- Tokyo Haneda proposal would further en trench 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 . Exhibit s UA
- A
- 109 to A
- 111 . This would clearly be at odds with the stated intent of the U.S.
- Japan Open Skies agreeme nt 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 Secret ary LaHood Announces U.S.
- Japan Agreement on Open Skies (Dec. 11, 2009). Many of Delta’s p roposed 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 w ould provide Delta with intergateway competition for nonstop West Coast
- Tokyo Haneda traffic and offer travelers the public benefit s of United’s extensive hub network at San Francisco . Exhibit s UA
- A
- 11 0 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/A NA at Los Angeles . ” Application of Delta at 8 .Consolidated A nswer of United

Page 7 B ut Delta already provides daily nonstop Los Angeles
- Tokyo Haneda Service. I n granting antitrust immunity to oneworld and Star in the U.S.
- Japan Alliance Case , the Department achieved both “a balanced competitive inter
- alliance d ynamic 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 perm itted 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 propo ses 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 A nswer 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 ’ applic a tion in that case would be “maintainin g and expanding nonstop service ”

– not reducing it. Id . at 13. B. Hawaiian’s Proposal Would Use These Valuable Haneda Slots to Serve a S mall Japan - Origin Tourist Market W ith No Connections to the U.S. Mainland and Offers Few Benefits to U.S. Consumers Hawaiian propose s to provide nonstop service in the Kona
- Tokyo market that is nearly three times smaller than the San Francisco market. Exhibi t UA
- A
- 116 . Hawaiian’s proposed service at Kona would of fer no connections to the U.S. m ainland whatsoever , offering connecting service only to Honolulu and Maui. See Application of Hawaiian, Exhibit HA
App2012
- 2. This stands in stark contrast to the co mprehensive 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 prov ide 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. E xhibit 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 Duplicate s Delta’s Service at Los Angeles and Its Selection W ould 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 Angeles

Haneda 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. ca rrierConsolidated A nswer 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 H aneda. 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 con sistently “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 t o 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 ro undtrip 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 th e 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 re commencing the New York/JFK
- Tokyo Haneda service for which it was selected in the initial proceeding. See OAG, 2012.Consolidated A nswer 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. S ee 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 d ynamic 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 1Docket 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 1Docket 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 1Docket 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 NaritaDocket 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 SeattleDocket 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 WashingtonDocket 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 WashingtonDocket 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. connectionsDocket 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 392,961Docket 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 4,861,007Docket 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 PopulationDocket 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 proceedingDocket 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

Source: August 2012 OAG, Delta 2012 Tokyo Haneda applicationDocket 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 applicationDocket 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 GatewayDocket 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 GatewayDocket 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 OperationsDocket 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 DestinationsDocket 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 CombinedDocket 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 KonaDocket 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 

### 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 proceedingDocket 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 OAGDocket 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 41,050Docket 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 HawaiiDocket 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 PopulationDocket 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 AngelesDocket DOT - OST - 2010 - 0018

Haneda Service UA - A - 124 Page 1 of 1 

### 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 proceedingDocket 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

Source: August 2012 OAG, American 2012 Tokyo Haneda applicationDocket 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 DestinationsDocket 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 AngelesDocket 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 DestinationsDocket 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 OAGDocket 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