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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,	2015
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Los	Angeles	World	Airports (“LAWA”)	supports	the	application	of	American Airlines	

(AA’s)	to	operate	 seven	(7)	weekly	nonstop	frequencies	 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.	

and	 the	 first	 nonstop	 flight	 serving	 oneworld	 passengers	 from	 LAX will	 offer	

enhanced	 service	 to	 a	 significant	 number	 of	 travelers	 and	 further	 shipping	

opportunities.	 Nine	supporting	points	are	outlined below	and	provided	 to	 the U.S.		

Department	of	Transportation for serious	consideration	of AA’s	proposed	HND-LAX	

service.

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

LAX	is	 the	sixth	 (6th)	busiest	passenger	airport	in	 the	world1 and	 the	international	

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

U.S.	market with	over	18	million	residents2.	LAX	is also	the	top	gateway	to	Asia,	with	

more	nonstop	service	-- flights	and	markets	-- to	Asia	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	 (4th)	 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	counties
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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	authorization	 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	American	discontinued	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	Japanese	carriers	provide	daily	nonstop	service	from	HND	to	the	U.S.	including	

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

4.0	 oneworld	 members lack U.S. carrier	 access	 to	 Haneda	 and need	 AA’s	

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

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	global	
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alliance 3 carrier providing nonstop	 access	 to	 Tokyo-Haneda 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 are	 also	 key	 to	 the	

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

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

will provide	travelers considerable	connecting	opportunities.	{Exhibit	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	 succeeds in	 part because	 it	 has	 the	 largest	 Japanese	

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

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

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

also	has	important	trade	links	with	Japan,	exporting	$12.5	B4 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.org
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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	 6th largest O&D	 market	 in	 the	 U.S.	 with	

almost	24,000	annual	passengers	or	32	PDEWs,	representing	20	percent	of	the	local	

LAX	market demand.		SEA-HND service,	which	started	June	2013, has	experienced 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	seats at	SEA6.	

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

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

50-57%	less than	AA	at	LAX. {Exhibit	5}

8.0 By	awarding	the	third	U.S. carrier	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	one	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/from	 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	CY2014
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Angeles	would	experience	strong economic	benefit	from	an	additional	daily	flight	at	

Tokyo-Haneda.	According	 to	 an	 economic	 impact	 analysis	 performed	 for	 LA,	 each	

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

and	supports	3,120	direct	and	indirect	jobs.7

9.0	 Hawaiian Airlines	has	 indicated	 its	 interest	 to	 apply	 for	 slot	 pairs 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	 oneworld from	 the	

contiguous U.S.

The	 largest	 Japanese	 visitor	 market	 to	 the	 U.S.	 is	 Hawaii8 and	 the	 majority	 of	

passenger	demand	is from	inbound tourists.	Passenger	demand	for	LAX-HND	is	over	

30 percent	originating	U.S.	traffic	versus	HNL	at	less	than	20	percent9.	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,	2007	LAEDC,	HR&A,	SH&E	analysis

8 Dept. of	Commerce,	2013	Market	Profile:	Japan	Report

9 MIDT	Passenger	bookings,	Sabre,	12	months	ended	Oct.	2014
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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. of State) 

cristinasa@state.gov (Dept. of State) 

eugene.alford@ita.doc.gov (Dept. of 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 MEC/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 of Seattle) 

safora.i@portseattle.org (Port of Seattle)

dan.weiss@united.com (United)

steve.Morrissey@united.com (United)

gmurphy@crowell.com (United)

sseiden@crowell.com (United)

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

Exhibit	2

Average	Load	Factors	LAX- HND

Source:	USDOT,	T100
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Exhibit	3

Exhibit	4	
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Exhibit	5