1 

## BEFORE THE DEPARTMENT OF TRANSPORTATION

**WASHINGTON, D.C.**

2014/2015 U.S.

- Haneda

Frequency Allocation

Docket DOT

- OST

- 2010

- 0018

In Response to Order 2014

- 12

- 9

SUPPLEMENTAL	COMMENTS OF LOS	ANGELES	WORLD	AIRPORTS,	OPERATOR

OF	LOS	ANGELES	INTERNATIONAL	AIRPORT, IN	SUPPORT	OF AMERICAN

AIRLINES LAX

– TOKYO	HANEDA	PROPOSAL

Communications	with	respect	to	this	document	should	be addressed	to:

Ms.	Gina	Marie	Lindsey

Executive	Director

Los	Angeles	World	Airports

One	World	Way

Los	Angeles,	CA	90045

glindsey@lawa.org

Mr.	Samson	Mengistu

Deputy	Director,	Administration

Los	Angeles	World Airports

One	World	Way

Los	Angeles,	CA	90045

smengistu@lawa.org

January	5,	20152 Los	Angeles	World	Airports (“ LAWA ”)	supports	the	application	of American Airl ines

(AA’s) to operate seven (7) weekly nonstop frequenc ies starting	 January	 15, 2015

from Los	Angeles	International	Airport (“ LAX ”)	to Tokyo

- Haneda ( “ HND ” )

. LAWA	is

a	City	of	Los	Angeles	Department	that	owns	and	operates	a	system	of	three	airports

including	LAX,	LA/Ontario	International	Airport	and	Van	Nuys	Airport. LAX	has the

largest	U.S.	passenger	market	demand to /from Tokyo

- Haneda in	the contiguous U.S.

an d	 the	 first nonstop flight	 serving	 oneworld	 passengers	 from	 LAX will	 offer

enhanced	 service	 to	 a	 signific ant	 number	 of travelers	 and	 further	 shipping

opportunities

. Nine	s upporting	points	are	outline d below	and	provided	 to	 the U

. S

.

D epartment	of T ranspor tation for serious	consider ation	of AA’s	proposed	HND

- LAX

service.

1.0	LAX	is	the largest U.S. gateway	to	Asia

LAX	is	 the sixth	 (6 th )	busiest passenger airport	in	 the	world 1 and	 the international

gateway	 serving the g reater	 Los	 Angeles region ,	 the	 second (2 nd ) most	 populated

U.S. market with	over	18	million	residents 2

. LAX	is also the top gateway	to	Asia,	with

more	nonstop service

-- flights	and	markets

-- to	As ia	than	any	other	U.S.	airport	and

in	the	last	four	years,	capacity	increases	have	been	met	by strong demand.

2.0 LAX	is	Haneda’s	largest	O&D	market	in	the	contiguous U

. S

.

Tokyo

- Haneda	 is	 the	 fourth	 (4 th )	 busiest	 passenger	 airport	 serving the	 most

populated	city	in	the	world.	Los	Angeles	ranks	as	HND’s	largest	O&D	market	in	the

1 Airport	Council	International	(ACI)	world	rankings	2013

2 U.S.	Census, Los	Angeles,	Orange,	Ventura,	San	Bernardino	and	Riverside	counties3 contiguous	 U.S.	 with almost	 117,750	 annual	 passengers	 or	 161	 passengers	 daily

each	way	(PDEW),	up	over	6	percent	since	2011. {Exhibit	1} Since	gaining	nonstop

service	by	ANA	(member	of	Star	Alliance)	and	Delta	(member	of	Skyteam)	to	HND,

the	 LAX	 market	 has	 responded	 well	 with	 average	 load	 factors	 increasing from

69.2%	in	2011 to	81.7%	in	2014	(YEJun2014	latest	data	available). {Exhibit	2}

3 .0 Of	the	original	U.S.	carrier	route	allocations	to	Haneda,	only	service	at	LAX

has	succeeded	from	the	contiguous	U.S.

In	 late	 2010, the	 Japanese	 government	 allowed HND limited	 international service

from	 the	U.S.	and	 three	U.S.	carriers	were given auth ori zation	 to	operate including

Hawaiian	 Airlines	 from	Honolulu,	Delta	 from	 LAX	 and	Detroit Metro	 International

Airport	 (DTW) and	 American	 from NYC/ JFK .	 DL	 moved	 its	 DTW	 flight	 to	 Seattle

International	Airport	(SEA) in the	spring	of	2013 and	Amer ican	discon tinued	its	JFK

service in	 November	 2013

, relinquishing	 its	 slots.	 Upon	 USDOT	 approval,	 United

Airlines	 began	 operating	 from	 San	 Francisco	 ( SFO ) in	 October	 2014.	 In	 addition,

both	Ja panese	carriers	provide daily nonstop service	from	HND	to	the	U.S.	includin g

JAL	and	ANA	from	Honolulu ,	JAL	from	SFO and	ANA	from	LAX.

4 .0	 o neworld	 m embers lack U

. S

. carrier	 access	 to	 Haneda	 and n eed	 AA’s

application	to	succeed in	order to	gain a	direct	link to	Haned a

LAWA believes flights from	LAX by American would provide	a	more	effective	use	of

the	HND	slot	pairs. A	daily	nonstop	flight by	American	would enhance	service	levels

in the large local Los	Angeles market by giving travelers	the	option	of	a	third global4 alliance 3 carrier providing nonstop	 access	 to	 Tokyo

- H aneda airport

. American

Airlines	has a strong	market	presence	at LAX with	a nineteen ( 19 )	percent	share	of

total	seat	capacity and	carries	the	largest	share	of	traffic	at	twenty	(20)	percent. In

addition	 to	 the	important	local	market,	 connecting	 passengers a re	 also	 key	 to	 the

success	of	most international	long	haul	flight s .	At	LAX, AA	offers	nonstop	service	to

51	 markets ( including 2	 seasonal destinations ) with	 156	 daily	 departures

, which

will provide travelers considerable	connec ting	opportunities

. {Exhibi t	3}

5.0	American	is	the	only	carrier proposing	to	start	HND service	immediately

American	 Airlines	 has shown its	 belief in	 the	 LAX

- HND market	 quite	 clearly	 by

proposing	that if	awarded HND	authorization

, AA will start	daily	service as	soon	as

possible	after authorization	is permitted using 247 seat	Boeing	777

- 200	aircraft

.

6 .0	 Los	 Angeles	 s ucceeds in	 part because	 it	 has	 the largest	 Japa nese

population in	the	U.S.	and	strong	trade	ties	to	Japan

Los	Angeles	 ha s	 strong	ethnic	 ties	with	Tokyo	as California	is	 home	 to	 the	largest

Japanese

- Am erican	 population	in	 the	US	at almost	 430,000. {Exhibit	 4} California

also	has	important	trade	links	with	Japan,	exporting $12.5	B 4 annually in	2012 ,	more

than	any	other	state	in	the	U.S.

3 Delta	is	a	member	of	Skyteam,	ANA	is	a	member	of Star	Alliance

4 Dept.	of	Commerce,	Asiamattersforamerica.org5 7 .0	Delta	agrees	that	LAX	is a	strong	choice,	proposing LAX as	one	of	its	service

options	for Haneda launch	flights

In	2010,	DL was	awarded service	at	LAX	and also DTW as	both	cities	were	proposed

as	part	of	its	original	application .	Within	a	few	years,	DL was	permitted	to	transfer

its DTW authority to SEA ,	a	much	smaller	market ,	with a	population	of slightly	more

than 3.6	 million.	 SEA	 is Tokyo

- Haneda’s 6 th largest O&D	 market	 in	 the U.S. with

almost	24,000	annual	passengers	or	32 PDEWs ,	rep resenting	20	perce nt	of	the local

LAX market demand

. SEA

- HND service,	which	started	June	2013

, has	experience d a

lower	passenger	response	with	load	factors	averaging	56.6% 5

. Delta carries eleven

(11)	percent	of	the	passengers	and operates fifteen	(15 )	percent of	the seat s at	SEA 6

.

Total	 seat	 and	 traffic	 levels	 at SEA are hal f	 the	 size	 of	 LAX.	 Delta offers 78	 daily

departures	to 32	markets	(including	6	seaso nal	destinations), a	level	approximately

50

- 57% less than	AA	at	LAX. {Exhibit	5}

8 .0 B y	awarding	the	third	U

. S

. carri er	from	the	only	alliance unrepresented	in

the	 HND	 market ,	 oneworld ( AA)

, and	 from	 the	 largest	 O&D	 market	 to /from

Haneda ,	U.S.	economic	benefits	are	maximized

. Supporting	Delta’s	application

concentrates	the	benefits	on	on e	carrier,	one	alliance	and a smaller	market.

AA’ s	proposed	service	to	Tokyo

- Haneda	will	provide	the	best	service	benefit	to	the

U.S.	 traveling public.	 Including	 a	 oneworld	 service	 option	 at	 LAX, the	 largest

passenger market to/fro m	 Haneda	 in	 the	 contiguous	 U.S.,	 will	 provide	 the U.S.

traveling	 public	 with	 a	 flight	 choice	 by	 all	 three	 global	 alliances.	 In	 addition, Los

5 US	DOT,	T100	International,	YEJun2014	(most	recent	data	available)

6 Port	of	Seattle	Traffic	Statistics;	Worldwide	Flight	Schedules	CY20146 Angel es	would experience	strong economic	benefit	from	an	additional	daily	flight	at

Tokyo

- Haneda. According	 to	 an	 economic	 impact	 analysis	 performed	 for LA ,	 e ach

new non

- stop	transoceanic route introduced	at LAX provides $623	million	annually

and	supports	3,120	direct	and	indirect	jobs. 7

9.0	 Hawaii an Airlines has	 indicated	 its	 interest	 to	 apply	 for	 slot	 pair s in	 the

near	term

, however a	second	allocation	to	Hawaii would serve	Japan’s	interest

while	 sacrificing the	 broader	U.S.	 interest	 best	 served	 by	 o neworld from	 the

contiguous U.S.

The	 largest	 Japanese	 visitor	 market	 to	 the	 U.S.	 is	 Hawaii 8 and	 the	 majority	 of

passenger	demand is from	inbound tourists. P assenger	demand for	LAX

- HND	is	over

30 percent	originating	U.S. traffic versus	HNL	at	less	than	20	percent 9

. It	is	clear	the

benefits	 of	 nonstop	 HND	 service	 would	 be best	 provided	 to	 more	 of	 the U.S.

traveling	 public at	 LAX. For	 all	 the	 reasons	 outlined	 above,	 Los	 Angeles World

Airports	 supports	American	Airlines	proposal	 for	nonstop	 service	in	 the LAX

- HND

market	and	believes	LAX provides	the	best	use	for	the	slot	pair	at	Haneda

- Tokyo.

_______________________________________ Ms.	Gina	Marie Lindsey

Executive	Director

Los	Angeles	World	Airports

7 Economic	impact	of	international	service	at	LAX,	200 7	LAEDC,	HR&A,	SH&E	analysis

8 Dept

. of	Commerce ,	2013	Market	Profile:	Japan	Report

9 MIDT Passenger	bookings,	Sabre,	12	months	ended	Oct.	20147 Certificate	of	Service

I	 certify	 that	 I	 have	 this	 date	 served	 this	 document	 on	 the	 following	 by	 sending	 a

copy	electronically	in	accordance	with	the	Department’s	rules	of	practice.

paul.gretch@dot.gov (DOT)

brian.hedberg@dot.gov (DOT)

brett.kruger@dot.gov (DOT)

todd.homan@dot.gov (DOT)

peter.irvine@dot.gov (DOT)

john.allen@faa.gov (FAA)

EngleTS@state.gov (Dept. o f State)

cristinasa@state.gov (Dept. o f State)

eugene.alford@ita.doc.gov (Dept. o f Commerce)

ejames@jamhoff.com (Allied Pilots Association)

seth.waxman@wilmerhale.com (Delta)

sascha.vanderbellen@delta.com (Delta)

chris.walker@delta.com (Delta)

Mike.Donatelli@alpa.org (Delta M EC/ALPA)

jhill@cooley.com (Hawaiian)

Perkmann@cooley.com (Hawaiian)

bberlin@cooley.com (Hawaiian)

Robert.Lamansky@hawaiianair.com (Hawaiian)

howard.kass@aa.com (American)

francis.heil@aa.com (American)

abigail.donovan@aa.com (American)

robert.wirick@aa.com (American)

charles.hunnicutt@thompsonhine.com

patricia.snyder@thompsonhine.com

ishiwata.k@portseattle.org (Port o f Seattle)

safora.i@portseattle.org (Port o f Seattle)

dan.weiss@united.com (United)

steve.Morrissey@united.com (United)

gmurphy@crowell.com (United)

sseiden@crowell.com (United)

info@airlineinfo.com (AirlineInfo.com)8 Exhibit	1

Exhibit	2

Average	Load	Factors	LAX

- HND

Source:	USDOT,	T1009 Exhibit	3

E xhibit	410 Exhibit	5