BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________

)

Joint Application of )

)

DELTA AIR LINES, INC. )

 and )

PT GARUDA INDONESIA (PERSERO) TBK ) Docket DOT-OST-2014-0091

)

for an exemption pursuant to )

49 U.S.C. § 40109 and )

for a statement of authorization )

under 14 C.F.R. Part 212 )

___________________________________________)

ANSWER OF AMERICAN AIRLINES, INC.

Communications with respect to this document should be sent to:

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

June 9, 2014
BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________

)

Joint Application of )

)

DELTA AIR LINES, INC. )

 and )

PT GARUDA INDONESIA (PERSERO) TBK ) Docket DOT-OST-2014-0091

)

for an exemption pursuant to ) June 9, 2014

49 U.S.C. § 40109 and )

for a statement of authorization )

under 14 C.F.R. Part 212 )

___________________________________________)

ANSWER OF AMERICAN AIRLINES, INC.

American Airlines, Inc. (“American Airlines”) supports the Delta Airlines, Inc. 

(“Delta”)/ PT Garuda Indonesia (Persero) Tbk. (“Garuda”) codeshare application and 

Delta’s efforts to fully utilize its valuable authority to offer enhanced services to and from 

Tokyo’s Haneda Airport (“Haneda”). Delta’s application demonstrates the strong 

potential for successful trans-Pacific operations at Haneda. Moreover, it demonstrates 

the value of negotiating additional designations with fewer restrictions that would allow

all U.S. carriers to serve Haneda from their respective U.S. gateways.

Background

On May 29, 2014, Delta and Garuda filed a joint application pursuant to 49 

U.S.C. § 40109 for an exemption and a statement of authorization to allow Delta to 

carry Garuda’s “GA*” designator code on Delta flights between Tokyo-Haneda on the 

one hand, and Seattle and Los Angeles on the other.
2

Demand For Haneda Services Is Strong, Yet U.S. Carrier Entry is Limited

American Airlines supports the Delta/Garuda application and applauds Delta’s 

efforts to maximize its valuable limited authority to offer service to and from Haneda. 

U.S. carrier access to Haneda is highly constrained.

1

 It is clearly in the public interest 

for the Department to seize any opportunity to negotiate sufficient additional 

designations without time constraints so that all U.S. carriers have the opportunity to 

access Haneda from their respective gateways. 

Currently, only passengers departing from West Coast gateways have the benefit 

of the limited service opportunities to Haneda. Additional Haneda capacity would allow 

U.S. carriers to provide significantly improved one-stop connecting service, via their 

gateways, for consumers throughout the United States to downtown Tokyo. Increasing 

access to Haneda without time constraints will serve the public interest by enabling U.S. 

carriers to respond to consumer demand as the market dictates. 

Even with significant additional Haneda service from the United States, there is

no doubt that the demand for Narita hub operations will remain strong for O&D 

passengers, and passengers connecting to and from other destinations. Under a more 

balanced Japanese airport policy both airports can flourish. 

 

1 Currently U.S. carriers are afforded only four daily services to/from Haneda during limited hours. Delta 

holds authority to operate daily service from Los Angeles and Seattle, United has San Francisco, and 

Hawaiian has Honolulu. Because of the limited hours, service to the East Coast and the Midwest has 

proven to be commercially unviable.
3

Finally, the lack of U.S.-carrier access to Haneda hampers global competition. 

Haneda is an important Japanese gateway that many non-U.S. carriers are able to offer 

customers as part of their networks. U.S. carriers must have increased opportunities at 

Haneda in order to effectively compete with third-country carriers. Otherwise, the 

valuable capacity at Haneda will be in the hands of non-U.S. carriers, who will become 

entrenched competitors.

For the foregoing reasons, American Airlines supports the Delta/Garuda 

application and urges the Department to grant it forthwith.

Respectfully submitted,

_______________________

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, D.C. 20036

(202) 326-5153 

howard.kass@aa.com

robert.wirick@aa.com

abigail.donovan@aa.com

June 9, 2014
CERTIFICATE OF SERVICE

I certify that, on June 9, 2014, I caused to be served a copy of the foregoing 

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

urskr@state.gov (Department of State)

cristinasa@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)

nana.hr@garuda.indonesia.com (Garuda)

Hoyt.Zia@hawaiianair.com (Hawaiian)

Mark.Arimoto@hawaiianair.com (Hawaiian)

jhill@cooley.com (Hawaiian)

hershel.kamen@united.com (United)

dan.weiss@united.com (United)

thomas.bolling@united.com (United)

karine.faden@united.com (United)

oracio.marquez@united.com (United)

gmurphy@crowell.com (Counsel for United)

info@airlineinfo.com (airlineinfo.com)

_______________________

Howard Kass