BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

 DELTA AIR LINES, INC. 

 

2010 U.S.-Haneda Combination Services 

Allocation Proceeding 

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Docket DOT-OST-2010-0018 

ANSWER OF DELTA AIR LINES, INC. 

Communications with respect to this document should be addressed to: 

 

Glen Hauenstein 

Executive Vice President – Network Planning 

 & Revenue Management 

Robert J. Cortelyou 

Senior Vice President – Network Planning 

Andreas Renner 

Director – International Network Planning 

DELTA AIR LINES, INC. 

1030 Delta Boulevard 

Atlanta, Georgia 30320 

Andrea Fischer Newman 

Senior Vice President – Government Affairs 

DELTA AIR LINES, INC. 

1212 New York Avenue, N.W. 

Washington, D.C. 20005 

Alexander Van der Bellen 

Managing Director – Government Affairs 

 & Associate General Counsel 

Jeff Morgan 

Regional Director – Government Affairs 

DELTA AIR LINES, INC. 

1212 New York Avenue, N.W. 

Washington, D.C. 20005 

(202) 842-4184 

sascha.vanderbellen@delta.com

March 1, 2010 
 

BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

 DELTA AIR LINES, INC. 

 

2010 U.S.-Haneda Combination Services 

Allocation Proceeding 

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Docket DOT-OST-2010-0018 

ANSWER OF DELTA AIR LINES, INC. 

I. Introduction 

Delta has submitted U.S.-Haneda service proposals from Seattle, Detroit, Los 

Angeles and Honolulu that will maximize consumer benefits and competition for the traveling 

public. Each of these gateways will provide significant service benefits and promote 

effective 3-way alliance competition between Delta and the Star (United/Continental/ANA) 

and oneworld (American/JAL) alliance carriers. Delta’s proposals will create a third 

competitor in hundreds of U.S.-Haneda city-pair markets and are backed by a strong service 

commitment with 403-seat B747-400 and 298-seat A330-300 aircraft – delivering the 

greatest capacity and greatest benefits of any applicant at the critical but tightly constrained 

Haneda airport. We believe that the selection of Delta for service at Seattle, Detroit, Los 

Angeles and Honolulu will maximize consumer benefits by promoting broad-based alliance 

competition to the Star and oneworld carriers which already have a major presence at 

Haneda by virtue of the large hubs and extensive slot holdings maintained by JAL and ANA. 

The reopening of Tokyo’s downtown Haneda airport to international service is one of 

the most important aspects of implementing the new open skies agreement with Japan. 
Answer of Delta 

Page 2 

Although bilateral limitations on U.S.-Japan service would be lifted, restrictions on airport 

slots, particularly at Haneda, will limit carriers’ ability to implement new competitive service 

at this critical airport. 

The proposed antitrust immunized alliances between American/JAL and 

United/Continental/ANA have a significant bearing on the disposition of this case. Japan 

has indicated that it will not sign the open skies agreement until a favorable outcome is 

reached in the pending ATI cases.1

 It is Delta’s understanding that new Haneda 

opportunities are also part of the open skies package. Under their immunized joint venture 

arrangements, American and JAL, and United/Continental ANA propose to operate as 

single, merged entities. According to the principles of “metal neutrality” and “indifference” to 

operating carrier advanced by the joint venture applicants themselves, service by American, 

United, or Continental -- or its Japanese partner -- is exactly the same from a service and 

competition standpoint. 

The public interest would be well served by an allocation that maximizes interalliance competition. Haneda service will be in very high demand because of its 

convenience to Tokyo passengers relative to Narita. Haneda is located just 15 minutes from 

downtown Tokyo, whereas Narita is over an hour by car, bus, or train and located 45 miles 

outside the city. Service at Narita is unlikely to constrain prices at Haneda because of its 

remote location. Just at the Department correctly concluded that Heathrow and Gatwick are 

separate relevant markets at London, so are Haneda and Narita at Tokyo. 

Given the significant access restrictions that will persist at Haneda, Delta believes 

that consumers will benefit from maximizing the impact of independent competitors against 

the incumbent alliance carriers operating at Haneda. Oneworld members American and 

JAL, once granted ATI, will not be independent competitors; nor will Star members United, 

 

1 See, December 11, 2009 letter from JCAB Deputy Director-General Keiji Takiguchi to 

Deputy Assistant Secretary for Transportation Affairs, John Byerly. 
Answer of Delta 

Page 3 

Continental and ANA be independent competitors once they are granted ATI. Therefore, 

any grant of slots to American or United/Continental takes away slots that could be used by 

Delta to provide independent price and service competition on hundreds of additional U.S.-

Haneda O&D itineraries. 

For this reason, we believe that service, competition, and the public interest would be 

well served by Delta’s proposals, which represent the best and only effective competition to 

the Star and oneworld alliances operating at Haneda. This is consistent with the approach 

the Department has taken in the past, and most recently confirmed in the American/British 

Airways show cause order, in refusing slot eligibility to affiliated carriers or joint venture 

partners at the slot constrained Heathrow Airport. 

Delta recognizes that a request for all four of the available slot pairs at Haneda may 

appear extraordinary. However, in order to provide consumers the benefit of an effective 

third competitor in the U.S.-Haneda market, taking into account the presence benefits both 

Star and oneworld will enjoy as incumbent hub operators at Haneda, Delta would need to be 

able to enter the Haneda market on the scale reflected in its service proposals to ensure 

competitive balance among the three alliances.2

 But because Delta lacks a Japanese 

alliance partner and because there will be no buy-sell mechanism to acquire additional slots, 

an allocation from DOT in this proceeding is the only way for Delta to acquire the slots it will 

need to compete at Haneda. 

 

2 While Delta has submitted the strongest and most effective proposal for Honolulu-Haneda 

service utilizing 403-seat B747 aircraft, Delta recognizes the Department’s policy in 

promoting new entry and would not object to Hawaiian receiving an award for one set of slot 

pairs for Honolulu-Haneda. As discussed below, this will enable Hawaiian to realize 

substantially all of benefits of its entire service proposal. Should the Department decide to 

grant Hawaiian a pair of slots, Delta requests backup authority at Honolulu, together with the 

grant of its remaining proposals. 
Answer of Delta 

Page 4 

II. American, United and Continental Should Be Treated as Haneda 

Incumbents In Light of the Slots That Will be Granted By Japan to Their 

Japanese Joint Venture Partners 

 The Department has in analogous circumstances treated alliance partners as 

incumbents, not new entrants, when awarding limited slot opportunities and managing 

alliance-related slot divestitures. This reflects the Department’s fundamental public interest 

policy of promoting competition and maximizing consumer benefits. 

The Department considers “affiliated carriers” together with their partners for slot 

allocation purposes at restricted airports: “an air carrier that operates under the same 

designator code, or enters into a codeshare agreement, with another air carrier shall not 

qualify [for new entrant slots] . . .” 49 U.S.C. 41714 (k). The Department recently affirmed 

this policy and its application to global alliance partners operating at slot restricted airports: 

“Airlines are not eligible [Heathrow slot] recipients if they are members of the oneworld 

global alliance, affiliates of the applicants, or airlines in which the airlines have a substantial 

financial interest.” Oneworld Show Cause Order at 26. This same policy and precedent 

should disqualify from consideration in this proceeding U.S. carriers that have entered into 

joint venture alliance with the Haneda incumbents. The alliance competitive considerations 

are especially important in this case given the extensive presence already enjoyed by the 

Haneda incumbents at this restricted airport, and that there is no market opportunity for 

unaligned carriers, such as Delta, to acquire the slots.3

 

3

 Equitable considerations also favor an award to Delta. Prior to 1978, Delta’s legacy Tokyo 

hub was based at Haneda. Delta was compelled to give up all of its slots, and relocated all 

of its facilities at great cost and expense to Narita when Haneda was declared a domesticonly airport. Now Delta is faced with the prospect of competing for international passengers 

at Haneda against carriers that have built large hubs in a protected operating environment – 

and stand ready to extend their reach and penetration into the U.S. market from Haneda 

with the assistance of immunized U.S. carrier partners. Even if Delta were to receive an 

award of all four Haneda opportunities, it would still be at a competitive disadvantage to Star 

and oneworld at Haneda. 
Answer of Delta 

Page 5 

Here, the U.S members of Star and oneworld should be treated as incumbents for 

the same policy reasons. American/JAL and United/Continental/ANA have applied for 

antitrust immunity in order to form metal-neutral joint ventures covering all of their U.S.-

Japan services. Although those applications have not yet been granted, Japan has 

indicated that it will not sign the open skies agreement until it is satisfied with the outcome of 

the antitrust immunity proceedings.4

 Delta understand that the Haneda opportunities at 

issue here are part of the same open skies package. Following the grant of antitrust 

immunity, the Star and oneworld alliances will each have the benefit of 2 U.S.-Haneda slot 

pairs, together with the important presence benefits of incumbent hubs. In these 

circumstances, the Star and oneworld carriers should not be granted additional slots in this 

proceeding when doing so would restrict the introduction of competitive service by Delta. 

 The Star and oneworld applicants do not need an allocation of Haneda slots from the 

Department to provide the service benefits claimed in their applications. American, United 

and Continental will have to access Haneda through the “metal neutral” joint ventures with 

their Japanese partners for which they are seeking antitrust immunity. While the 

Department has sometimes discounted the effectiveness of arms-length codeshare 

arrangements as a substitute for own-metal service, the same cannot be said of integrated 

joint ventures – which the applicants and the Department consider as the competitive 

equivalent of a merger. Indeed, to conclude otherwise would deny the very benefits that 

 

4 Delta appreciates the Department’s desire to allocate the Haneda opportunities in advance 

of the ATI decisions, so that the selected applicants can have as much time as possible to 

plan and implement their services. Delta believes the most expeditious determination can 

be made by considering the ATI applicants as single competitive entities, as they would be 

under open skies. Alternatively, the Department could consolidate this proceeding and the 

ATI alliance cases for contemporaneous consideration. 
Answer of Delta 

Page 6 

American, United and Continental have advanced in support of their antitrust immunity 

applications. 

The Star carriers say that: 

“The Pacific JV will foster ‘metal neutrality’ – a commercial 

environment in which joint venture partners share common 

economic incentives to promote the interests of their 

alliance over their individual corporate interests. By 

pooling resources to improve the overall service offering 

and sharing the resulting gains and losses, the Joint 

Applicants will harmonize their joint network and become 

indifferent as to which partner collects the revenue and 

operates the aircraft on a given itinerary.” 

Joint Application of ANA, Continental and United at 12, December 23, 2009, OST-2009-

0350 

 The same integrative joint venture benefits are echoed by oneworld alliance partners, 

American and JAL: 

“The Joint Applicants seek approval for a highly-integrated, 

revenue-sharing joint venture that will strengthen their 

alliance by eliminating each carrier’s economic incentive to 

maximize its own revenue. Only the closer cooperation 

made possible through a joint venture based on metal 

neutrality – or indifference as to which airline actually 

carries a customer – will maximize the consumer benefits 

that immunized alliances make possible. This is because 

metal neutrality removes each carrier’s incentive to act 

opportunistically in ways that inure to its own short-term 

financial advantage, to the detriment of the efficiencies and 

consumer benefits that could otherwise be delivered by the 

alliance. Accordingly, the Joint Applicants are seeking 

approval for a highly integrated joint venture with revenue 

sharing that creates metal neutrality. By providing for the 

broad sharing of revenue on a metal neutral foundation, 

the JBA will ensure that American and JAL act for the 

benefit of – and are compensated for their contribution to – 

the alliance as a whole.” 

Joint Application of American and JAL at 7, February 12, 2010, OST-2010-0034 
Answer of Delta 

Page 7 

Given the entry constraints that will continue to exist at Haneda, and the large 

presence already enjoyed by JAL and ANA which operate hubs there, the grant of additional 

slots to the U.S. members of oneworld and Star would be contrary to competition and the 

public interest. Joint venture alliance can and do produce important consumer benefits – 

particularly when there is both de jure and de facto open entry. Here, however, taking into 

account the limitations that will continue to affect competitive access at Haneda and 

considering that American, United and Continental have entered into proposed joint venture 

agreements with Japanese partners, it would be contrary to the public interest to allow these 

carriers to “double dip” at Haneda – to receive access through their joint venture alliances, 

and to receive further individual slot allocations – at the expense of Delta which would bring 

additional price and service competition to the Haneda market. 

 It is important to note that declining to award additional Haneda slots to American, 

United and Continental on top of their alliance partner holdings does not foreclose any of the 

potential benefits of their service proposals. Los Angeles, San Francisco and New York can 

and likely will receive Haneda service from Star and/or oneworld regardless of the outcome 

of this proceeding. As explained above in the applicants’ own words, a core principle of joint 

venture alliances is to achieve metal neutrality and indifference as to the operating carrier. 

Thus, the gateways proposed by American, United, and Continental can still enjoy service 

by the Star and oneworld joint venture alliances. In contrast, none of Delta’s gateway cities 

(or the beyond-gateway cities that are connected to them) can receive any service by Delta 

or SkyTeam absent an award in this proceeding, because Delta has no joint venture partner 

with Haneda slots and no other means to obtain them. 

The applications presented in this case tell only half the story with respect to Star 

and oneworld plans for U.S.-Haneda service. Given the closely inter-related issues affecting 

antitrust immunity and the effectiveness of open skies and these Haneda opportunities, it is 
Answer of Delta 

Page 8 

important to take into account likely use and impact of the U.S.-Haneda slots brought to the 

table by the Japanese partners of Star and oneworld. The proposed gateway choices put 

forward by American, United and Continental would be factored into the joint route planning 

decision of the Star and oneworld alliances when they implement Haneda service-- 

• United, Continental and ANA state that: “Under the Pacific JV Agreement, the 

Joint Applicants will jointly manage capacity, planning, scheduling, pricing, 

revenue management, sales and marketing of the carriers’ U.S.-Asia 

services.” Star ATI Application at 12 (OST-2009-0350). 

• American and JAL state that: “Approval and immunization of the 

American/JAL alliance agreement will enable close integration of the two 

carriers’ activities . . . This coordination will include the following: [pricing, 

yield management, and schedules.] The Joint Applicants will jointly plan their 

respective schedules . . .” oneworld ATI Application at 10 (OST-2010-0034). 

Star and oneworld already enjoy the benefit of strong and established Haneda hubs 

which will grow in strength and influence on U.S.-Tokyo service with antitrust immunity 

under open skies. Therefore, in allocating the limited Haneda slots available in this 

proceeding, the Star and oneworld carriers should not receive further slot allocations at the 

expense of Delta’s proposal which will provide important independent price and service 

options to consumers. 

III. Delta’s Haneda Service Proposal Will Maximize Haneda Service and 

Competitive Benefits for the Traveling Public. 

The reopening of Haneda airport will have a profound effect on service and 

competition in the U.S.-Japan and U.S.-Tokyo market. Haneda is highly preferred by Tokyo 

passengers, because it is only minutes from downtown. Narita, by comparison is an hour 

and a half and located 45 miles outside the city. Existing U.S.-Tokyo service at the far-
Answer of Delta 

Page 9 

distant Narita airport will not effectively discipline pricing for U.S.-Haneda services operated 

by the Star and oneworld carriers. There is therefore a danger that Haneda’s strong appeal 

combined with the very limited slots available for U.S.-Haneda service will expose 

passengers to higher prices in many O&D markets due to limited competition. Delta’s full 

package of Haneda service proposals offers the best opportunity to introduce effective 

competition for the incumbent Haneda carriers. 

In allocating the scarce Haneda opportunities in this case, we believe that 

competition and the public interest would be maximized by promoting independent pricing 

and 3-way alliance competition in as many U.S.-Haneda O&D markets as possible. Delta’s 

proposed gateways provide important nonstop service benefits in their own right – and 

extend the benefits of competitive service to scores of additional online cities served by 

Delta behind its gateways. By contrast, a grant of slots to American or United/Continental – 

coming as they necessarily would at the expense of Delta’s service proposals -- would be 

additive to the routes already available to them under the umbrella of immunized 

cooperation with JAL and ANA, and would result in increased concentration and less 

competition on hundreds of U.S.-Haneda O&D markets. 

Delta proposes a balanced package of Haneda services, which are designed to 

maximize service and competitive benefits for the traveling public. Seattle and Detroit work 

in tandem to provide comprehensive network coverage of the Western and Eastern halves 

of the United States, respectively. Delta would also provide important competitive discipline 

at Los Angeles and Honolulu, which are large local markets that are likely to receive (or 

already are receiving) Haneda service by Japanese carriers. 

A. Delta’s Seattle Proposal Will Establish a Key Tokyo Haneda Gateway in 

the Pacific Northwest with Important Network and Competition Benefits. 

Seattle-Haneda service is a top priority for Delta. The growth and development of 

international service at Seattle is a key element of Delta’s west coast strategy. Seattle-
Answer of Delta 

Page 10 

Tokyo is a large local market with nearly 80,000 annual Tokyo O&D passengers.5

 Seattle is 

also well situated to serve as a West Coast hub gateway. Delta’s partnership with Alaska 

Airlines, together with Delta’s own-metal services, will enable Delta to provide nonstop-tononstop Haneda service for 55 U.S. cities. DL-ANS-204. 

The grant of slots to Delta for Seattle-Haneda service will dramatically enhance 

competitive service options for west coast passengers to Tokyo, which would otherwise face 

a Star and oneworld duopoly. The west coast is particularly attractive for Haneda service in 

light of the continued restrictions on schedules and operations. Furthermore, in addition to 

the U.S. and Japanese services that would be authorized under the 2009 MOU, Japan and 

Canada have already reached agreement that provides for expanded Haneda opportunities 

for Japanese and Canadian carriers at airports including Vancouver. Seattle and Vancouver 

compete aggressively for traffic in the Pacific Northwest, and Delta would be able to 

compete for western passengers by offering service to Tokyo’s preferred airport from Seattle. 

Seattle is a proven and successful gateway to Asia. This summer, Delta will 

commence new nonstop service from Seattle to Beijing and Osaka – building on Delta’s 

existing long-haul international services to Amsterdam and Narita. 

Delta will operate its new Haneda services using large capacity Airbus 330-300 

aircraft outfitted with 298 passenger seats. The proposed schedule to and from Haneda 

dovetails with Delta’s Seattle-Amsterdam flight, making for a particularly efficient aircraft 

rotation despite the Haneda scheduling challenges. Delta’s Haneda service will depart 

Seattle at 7:25pm, arriving Haneda at 10:00pm to coincide with the opening of the Haneda 

nighttime operating window. Eastbound, Delta proposes to depart Haneda at midnight, 

arriving Seattle at 5:10pm. DL-104. 

 

5

 MIDT YE November 2009.
Answer of Delta 

Page 11 

B. Delta’s Detroit Proposal Will Establish the Largest and Most Effective 

Eastern U.S. Gateway for Haneda Passengers. 

Detroit is Delta’s primary Eastern U.S. gateway for service to Asia. Detroit, in 

concert with Seattle, will provide the comprehensive network coverage of the United States 

and help to protect the traveling public from the effects of the increased market power by the 

Star and oneworld immunized alliances operating from Haneda. Delta’s Detroit hub is the 

largest and most effective U.S. airline hub for service to Asia, and will provide nonstop-tononstop Haneda service for 106 U.S. points. DL-112. In addition, Detroit boasts a large 

local market to Tokyo with 33,000 annual O&D passengers.6

 

While the scheduling limitations at Haneda pose challenges for Eastern U.S. service, 

Delta’s service pattern for Detroit addresses those concerns with a westbound departure at 

8:10pm, arriving at the start of the 10pm nighttime operating window. The aircraft will 

overnight at Haneda, and depart eastbound at 7:00 am, arriving Detroit at 5:45am (summer) 

or 5:00am (winter). DL-113. This schedule enables Delta to make full use of Detroit’s 

expansive network, and maximizes connectivity for Eastern U.S. passengers. 

Delta is proposing its largest aircraft – the Boeing 747-400 for Detroit. The 403 seat 

capacity of the 747 will help to maximize the value of the scarce Haneda slots that are 

available to U.S. carriers. 

Another factor favoring the selection of Detroit is its state-of-the art and consumer 

friendly 120-gate terminal facility, which is backed by significant airside capacity. The 

terminal was specifically designed to make international connections easy and efficient. 

There is a Federal Inspection Services (FIS) station located in the center of the mile-long 

terminal building, which is able to process 3,200 passengers an hour. The Express Tram 

monorail station is positioned immediately adjacent to the FIS facility, allowing passengers 

 

6

 MIDT YE November 2009
Answer of Delta 

Page 12 

to reach either end of the terminal building in less than two minutes. The Detroit terminal 

has received numerous accolades for its design, aesthetics, and efficiency, including 

recognition by J.D. Power & Associates, Airports Council International, and Airport Revenue 

News, as being among the most consumer friendly and innovative airports in the United 

States. 

C. Delta’s Los Angeles-Haneda Proposal Will Serve the Largest U.S. Mainland 

Market to Tokyo and Provide Significant Network Benefits. 

Los Angeles is the largest U.S.-Tokyo O&D market. It is very likely to receive 

Haneda service by the Star and oneworld alliances (as decided by their respective alliance 

steering committees). Delta is the only non-aligned U.S. carrier that can provide effective 

independent price competition to Star and oneworld on this important route -- but requires 

an allocation of Haneda slots in order to do so. Delta will use large capacity 747-400 

aircraft for maximizing service, competitive, and public interest benefits. Delta’s Los 

Angeles schedules are provided at Exhibit DL-122. 

With over 400,000 local O&D passengers, Los Angeles generates more than twice 

as many passengers as United’s proposed San Francisco gateway. DL-ANS-506. And, 

although Honolulu generates large numbers of local passenger by virtue of its appeal to 

Japanese leisure passengers, Los Angeles would benefit more than twice as many U.S. 

origin passengers which are particularly relevant to the Department’s public interest 

determination. DL-ANS-505. The are numerous U.S. Fortune 500 companies and 

Japanese multinational corporations located in the greater Los Angeles area – all of which 

stand to benefit from the new nonstop access to Tokyo’s preferred downtown airport. 

Delta will also provide significant network benefits to U.S. cities behind the Los 

Angeles gateway. Delta and its domestic alliance partner, Alaska, provide connecting 

opportunities to 18 interior U.S. cities via Los Angeles. DL-ANS-501. 
Answer of Delta 

Page 13 

D. Delta’s Honolulu-Haneda Proposal Will Maintain U.S. Flag Competitiveness 

for Tokyo Beach Markets. 

 Competition for Tokyo leisure passengers is intense. Japanese carriers are already 

using Haneda charter opportunities to their advantage, and would enjoy the additional 

opportunity for scheduled service to U.S. beach markets if the 2009 MOU is formalized. 

Delta seeks an allocation of seven Haneda slots for daily Haneda-Honolulu service (but 

would accept a backup award if Hawaiian is selected as primary on this route). Once again, 

Delta will use large capacity 747-400 aircraft, thereby maximizing service and competitive 

benefits. 

IV. Delta’s Proposals Are Superior on the Service Merits. 

As stated, the proposals of American, United, and Continental can be fully 

accommodated by services of their joint venture partners. The Star and oneworld alliances 

are, by their own acknowledgment “indifferent” as to the operating carrier – and will fully 

realize the benefits no matter which Star or oneworld member flies the aircraft. However, 

only through an award in this case is Delta able to offer competitive service at its proposed 

gateways. Even putting aside the ATI alliance competitive issues, Delta believes its 

proposals are superior on the merits. 

A. Delta Will Provide the Largest Capacity Aircraft Maximizing U.S.-

Haneda benefits 

The Department has on numerous occasions stated that the size of the aircraft and 

amount of capacity delivered by the applicant is an important selection criteria for 

maximizing public benefits in carrier selection cases. 
Answer of Delta 

Page 14 

Here, by a substantial margin, Delta would deliver more capacity than any other 

applicant: 

As the Department explained in Order 2007-2-10 (2006 China Case), “shortfall of 

available nonstop service options emphasizes the importance of injecting as much nonstop 

capacity into the. . .market as possible when awarding these frequencies.” (Page 5 

emphasis added). The Department went on to select United because it would “provid[e] the 

most capacity in this proceeding with B-747 aircraft . . .” Id. 

The extent of Delta’s capacity advantage varies by market, but in each and every 

case is substantial: 

• At Los Angeles, Delta proposes to fly 403 seat B747-400 aircraft in contrast 

to the 247 seat B777 offered by American. This equates to 63 percent more 

capacity for Delta’s proposal; which, on an annualized basis amounts to over 

100,000 more nonstop seats. DL-ANS-502-504. 
Answer of Delta 

Page 15 

• At Detroit compared to New York/Newark in the Eastern U.S., Delta provides 

63 percent more capacity than American at JFK, and 46 percent more 

capacity than Continental at Newark – or approximately 100,000 incremental 

annual seats. DL-ANS-402-404. 

• In the Pacific Northwest, Delta’s 298 seat A330 is larger than United’s 269 

seat B777 at San Francisco, delivering 11 percent more capacity with over 

20,000 additional annual seats. DL-ANS-302-304. 

• In the Pacific Islands, Delta’s B-747-400 proposal for Honolulu-Haneda 

delivers 57 percent more seats (107,000 annually) than Continental’s 767 

proposal for Guam, and 56 percent more seats (106,000 annually) than 

Hawaiian’s 767 proposal for Honolulu. DL-ANS-602-604; 611-613. 

The Department has previously found such capacity differences to be decisionally 

significant. In rejecting Continental’s Newark-Shanghai proposal in favor of United, the 

Department selected United because it would offer “22 percent more capacity than 

Continental.” Order 2007-1-4 at 17. The importance of maximizing capacity is the same 

regardless of whether the service limitation is imposed by bilateral constraints (as in China), 

or by airport slot constraints and perimeter rules -- such as those that effect service at 

Haneda and Washington National Airport. See, Order 2002-11-10 (selecting Delta for 

DCA-Salt Lake City beyond-perimeter service for reasons including that “Delta would use 

183-seat B-757, a relatively large aircraft.”). 

B. Delta’s Seattle Proposal Will Maximize Competition In the Pacific 

Northwest 

For the reasons explained above, even absent an award to United in this case, San 

Francisco is still likely to receive nonstop Haneda service from ANA -- which is equivalent to 

service by United under their metal neutral joint venture. Thus, all of the benefits of United’s 
Answer of Delta 

Page 16 

proposal can and will be attained without compromising a vital competitive opportunity at 

Haneda. 

Like San Francisco, Delta’s Seattle gateway would provide comprehensive network 

benefits to West Coast passengers. But, unlike a Star award for San Francisco, an award to 

Delta will inject a third alliance that will offer independent price competition West CoastHaneda passengers. Seattle and the Pacific Northwest face a Star/oneworld Haneda 

duopoly that is projected both from U.S. gateways as well as from nearby Vancouver, 

Canada which is eligible for Haneda service under the Japan-Canada agreement by 

United’s current and future immunized Star partners, Air Canada and ANA (or JAL). By 

authorizing a pair of slots for Delta service at Seattle, the Department will promote healthy 3-

way alliance competition to combat the inherent advantages already enjoyed by the 

Japanese incumbents at Haneda. 

Seattle is home to major international corporations with important interests in Tokyo 

including Microsoft, Boeing, and Starbucks. In order to better serve its customers – and to 

maintain the competitiveness of its Seattle gateway for passengers up and down the west 

coast, Delta requires access to Haneda, the highly preferred downtown airport. Delta will 

rely on network feed provided by Alaska Airlines, Seattle’s hometown hub carrier. Thus, not 

only will an award benefit Delta, it will also further the interests of one of the country’s 

smaller and highly efficient low cost carriers. 

C. Delta’s Detroit Hub Gateway Maximizes Competition for 

Eastern U.S. Customers. 

Delta requires an allocation of Haneda slots in order to offer competitive service for 

the Eastern United Sates from Detroit. Neither American nor Continental require an 

allocation of slots to participate in the New York/Newark-Haneda market, because their 

Japanese partners have slots available to provide New York service. 
Answer of Delta 

Page 17 

Under their immunized joint ventures American and Continental are “indifferent” as to 

which carrier operates the aircraft. An award to American or Continental at the expense of 

Delta’s Detroit proposal would reduce Eastern U.S.-Haneda competition from three carriers 

to two – creating a competitive monopoly (or at best a duopoly) affecting over 900,000 

passengers in more than 100 U.S. cities that would enjoy convenient and competitive 

service by a third independent pricer from Detroit. DL-ANS-406, 414, 415. 

American can muster well timed connections for only a handful of Eastern U.S. cities. 

DL-ANS-408, 409. Continental’s Newark hub fares slightly better than American -- but is 

completely eclipsed by Delta’s Detroit hub, which would offer service to more 60 additional 

cities, benefitting 2.5 times more potential Eastern U.S.-Tokyo passenger than Continental. 

DL-ANS-414, 415. 

American’s attempt to claim credit for beyond-Haneda connections by its immunized 

alliance partner is not a relevant consideration because JAL can use the “established 

Haneda presence” noted by American under the joint venture – delivering exactly the same 

benefits as American – but without depriving an independent competitor the ability to offer 

service.7

 

C. Delta’s Los Angeles Proposal Will Maximize Competition in the Largest 

U.S.-Tokyo Market. 

Delta and American have each proposed nonstop Los Angles-Haneda service. 

However, the proposals are vastly different in terms of the service and competitive benefits 

they will create. Los Angeles is the largest mainland U.S.-Japan O&D market, and it is 

 

7

 American goes on to speculate that its connecting schedules might improve “as the 

Haneda window is expanded.” (Page 6). This is no reason to award American more slots. 

The Haneda operating window was established through artful bilateral compromise. Should 

the Haneda window be expanded through additional bilateral consultations, the Department 

may need to examine what additional remedies and conditions would be necessary to 

maintain fair and equal competitive conditions at the airport. 
Answer of Delta 

Page 18 

situated in the west coast region that is particularly attractive for Haneda service due to the 

schedule and perimeter rule constraints imposed by JCAB. Given these attributes, Los 

Angeles is likely to receive nonstop Haneda service from JAL or ANA, or both. The 

immunized alliance steering committees will be able to make joint route planning decisions 

based on the Haneda slots allocated to JAL and ANA. Los Angeles-Haneda service by JAL 

gives American fully effective commercial access through its immunized joint venture – but 

leaves unfulfilled the Department’s critical public interest objective of maximizing service and 

competition for the traveling public. 

By contrast, the selection of Delta for service at Los Angles would create a third 

competitive option to the entrenched oneworld and Star alliance carriers that are firmly 

ensconced at Haneda. In light of the strong existing presence by JAL and ANA at Haneda, 

Delta submits that the public interest is better served by allocating Los Angeles-Haneda 

slots to a third alliance carrier without a Japanese partner that can provide meaningful 

competition -- rather than further exacerbating the Haneda advantages already enjoyed by 

the Star and oneworld alliance carriers. 

As noted above, Delta will operate much larger 747 aircraft, providing 63 percent 

more capacity or more than 100,000 more annual seats than American. DL-ANS-502-504. 

In addition, Delta’s substantial network at Los Angeles will extend Haneda service benefit to 

interior U.S. points, further bolstering service with the Star and oneworld alliance carriers. 

Delta, together with its domestic alliance partner Alaska Airlines, will provide nonstop-tononstop service via Los Angeles for 18 U.S. points. DL-ANS-501. 
Answer of Delta 

Page 19 

D. Delta’s Honolulu-Haneda Service Provides the Greatest Benefits for 

the Pacific Islands. 

1. Hawaiian at Honolulu. 

Delta’s 403-seat B747 proposal would maximize service benefits on the HonoluluHaneda route, delivering 56 percent more seats (106,000 annually) than Hawaiian’s B767 

proposal. DL-ANS-602-604. This will maximize U.S. flag competition with the Japanese 

flag incumbents, who are already serving Honolulu on a charter basis from Haneda. 

Nonetheless, Delta is mindful of the high priority the Department places on new entry. 

Hawaiian Airlines, like Delta, lacks a Japanese alliance partner, and absent an award in this 

case Hawaiian would be limited to offering charter service at Haneda. In these 

circumstances, Delta would have no objection to Hawaiian receiving one slot pair for 

Honolulu-Haneda scheduled service, with Delta receiving backup authority on the route. 

All of the benefits of Hawaiian’s service proposal can and will be realized with a 

single slot pair. There is no utility to a second “wingtip” flight using smallest aircraft at issue 

in this case. Hawaiian acknowledges it has larger capacity A330 aircraft on order and that it 

could upgauge to if the response to its service is positive. Providing Hawaiian a single slot 

pair will incentivize Hawaiian to use larger and more efficient aircraft – as well as preserving 

scarce slots that are critically needed at key mainland gateways to combat the expanding 

Haneda presence of the Star and oneworld alliance carriers. There are 600 Haneda charter 

opportunities that can be used by Hawaiian to augment service on the route, without 

expending a second pair of critically scarce scheduled service slots that can be used to 

provide new service at an additional U.S. gateway. DL-ANS-608. 

With only four slot pairs available, Honolulu should not receive more than a single 

slot pair – since any further allocation would come at the expense of Delta’s large and 

important mainland gateway that will benefit U.S. passengers. While Honolulu-Tokyo is an 

important route, passengers are 94% Japan-originating. DL-ANS-601. Service at Delta’s 
Answer of Delta 

Page 20 

mainland gateways of Seattle, Detroit, and Los Angeles will benefit a much larger 

percentage of U.S. origin passengers which are more important than Japanese leisure traffic 

in the Department’s public interest analysis. 

While Hawaiian attempts to claim credit for a number of U.S. west coast gateways on 

a connecting basis via Honolulu, in reality Hawaiian’s service via the South Pacific would be 

highly circuitous, inconvenient, and ineffective for west cost passengers. DL-ANS-605, 606, 

607. As illustrated by the following table, Delta’s Seattle and Los Angeles proposals 

provide far more convenient and effective routings for West Coast Passengers: 

Given the need for effective Haneda competition from the mainland U.S. to combat 

the Star and oneworld alliances, at most a single pair should be allocated for Hawaiian 

service at Honolulu. As acknowledged by Hawaiian, it has competed successfully for many 

years as a charter carrier in the U.S.-Japan market (and could do so at Haneda). An 

allocation of a single pair Haneda slots will enable Hawaiian to try its hand at scheduled 

operations for competing in the Japanese leisure market, while preserving maximum 

competitive opportunities for U.S. travelers and shippers at key mainland gateways. 
Answer of Delta 

Page 21 

2. Continental at Guam 

Guam is another Japan-original leisure market that is currently eligible for Haneda 

charters and is eligible to receive more such service under the new agreement. Delta and 

Continental both serve Guam on a scheduled basis from Narita. There is no justification for 

giving Continental a competitive advantage from the preferred airport at Delta’s expense – 

especially when Continental will reap the benefits of a major Haneda presence from its 

partner, ANA. 

V. Conclusion. 

For the foregoing reasons, Delta requests the allocation of slot pairs to provide new 

daily Haneda service from Seattle, Detroit and Los Angeles, with either primary or backup 

authority for Honolulu. 

 Respectfully submitted,

_________________________________ 

Alexander Van der Bellen 

Managing Director, Government Affairs 

 & Associate General Counsel 

DELTA AIR LINES, INC. 
ANS-100 Series

Delta’s Proposals Provide Effe

Competition to the Star and One

Incumbent Alliances at Hane
Haneda is the Preferred Airport Serving the Metro Tokyo 

Area – Services at Narita are at a Serious Competitive Disadvantage

• Haneda is the busiest airport in Japan and 4th busiest in the world

• Haneda is located in downtown Tokyo; Narita is 45+ miles away from ce

Source: Google Maps. Map copyright Google.

• Narita to Tokyo (Ma

46 miles

• Haneda to Tokyo (M

13 miles 46 miles

13 miles

A

C
Star

46%

Oneworld

38%

Other

16%

Star

50%

Other

10%

Star and Oneworld Have a Significant Presence at Haneda

Source: February 2010 schedules (APGdat)

Haneda Departures Haneda Seat
An Allocation of Haneda Slots to Delta is Necessary

to Enable Inter-Alliance Competition

2 2

0

012

Star (UA, CO, NH, US) Oneworld (AA, JL) SkyTeam 

U.S.-Japan Haneda Daily Slot Pairs
American, United, and Continental Will Have Haneda

Access Through Their Metal Neutral Joint Ventures With JAL and ANA

“The Pacific JV will foster ‘metal neutrality’ – a commercial environment in which join

share common economic incentives to promote the interests of their alliance over th

corporate interests. By pooling resources to improve the overall service offering and 

resulting gains and losses, the Joint Applicants will harmonize their joint network an

indifferent as to which partner collects the revenue and operates the aircraft on a giv- Joint Application of ANA, Continental and United at 12, December 23, 2009, OST-200

“The Joint Applicants seek approval for a highly-integrated, revenue-sharing joint ve

strengthen their alliance by eliminating each carrier’s economic incentive to maximizrevenue. Only the closer cooperation made possible through a joint venture based o

– or indifference as to which airline actually carries a customer – will maximize the c

that immunized alliances make possible. This is because metal neutrality removes ea

incentive to act opportunistically in ways that inure to its own short-term financial addetriment of the efficiencies and consumer benefits that could otherwise be delivereAccordingly, the Joint Applicants are seeking approval for a highly integrated joint v

revenue sharing that creates metal neutrality. By providing for the broad sharing of 

metal neutral foundation, the JBA will ensure that American and JAL act for the benecompensated for their contribution to – the alliance as a whole.”- Joint Application of American and JAL at 7, February 12, 2010, OST-2010-0034

Delta Has No Japanese Carrier Partner -- and Therefore No Han

Absent An Allocation of Haneda Slots By the Departm
ANS-200 Series

Selection of Delta’s Haneda Pro

Will Maximize Public Benef
Delta’s Proposals Will Bring the Greatest Capacity

to the U.S.-Haneda Market

294,190 294,190 294,190

217,540

201,480 196,370 188,340 186,880 180

0

50,000

100,000150,000200,000250,000300,000350,000

Delta DTW

747-400

Delta LAX

747-400

Delta HNL

747-400

Delta SEA

A330-300

Continental

EWR 777-

200

 United

SFO 777-

200

Hawaiian

HNL 767-

300

Continental

GUM 767-

400

Am

LA

Annual Seats

Sources: Exhibits DL-115, DL-124, DL-133, DL-106, CO-114, UA-2, HA-App-3, CO-115, AA-104, and AA-102

Seats Per Flight: 403 403 403 298 276 269 258 256 
Delta’s Detroit and Seattle Gateways Will Serve the Most 

Nonstop-to-Nonstop U.S. Points to Haneda

90

50

40

19

11 10

9

4

0

20406080

100120

Delta DTW Delta SEA Continental

EWR

United SFO American

LAX

American

JFK

Delta LAX Hawa

HN

Nonstop-to-Nonstop U.S. Points(Within 10% Circuity)

Note: Includes U.S. points with no more than 10% circuity to Haneda via U.S. gateway and included in applicant’s connecting sch

Sources: Exhibits DL-108-111, DL-117-120, DL-126-129, UA-3, UA-6, CO-122-123, CO-124-125, AA-107-110, AA 111-114, HA-
Delta’s Detroit and Seattle Connecting Traffic Bases to 

Haneda Are Larger Than Any Other Applicant’s

1,434,020

886,662

602,505

369,208

267,001 245,029

169,325 128,

0

200,000400,000600,000800,000

1,000,0001,200,0001,400,0001,600,000

Delta SEA Delta DTW United 

SFO

Continental

EWR

American

LAX

Delta LAX American

JFK

Hono

HN

Base Passengers in U.S. – Tokyo Connecting Markets(Within 10% Circuity)

Note: Includes U.S. points with no more than 10% circuity to Haneda via U.S. gateway and included in applicant’s connecting sch

Sources: Exhibits DL-108-111, DL-117-120, DL-126-129, UA-3, UA-6, CO-122-123, CO-124-125, AA-107-110, AA 111-114, HA-
Delta’s Seattle and Detroit Gateways Will Serve the Largest 

Combined Local and Connecting U.S. – Tokyo Traffic Base Among U.S. Mainland Gateways

1,511,348

918,938

807,854

721,033 668,783 646,811

0

200,000400,000600,000800,000

1,000,0001,200,0001,400,0001,600,000

Delta SEA Delta DTW United SFO Continental

EWR

American LAX Delta LAX 

Local and Connecting Base Passengers in U.S. – Tokyo Markets(Within 10% Circuity)

Note: Includes U.S. points with no more than 10% circuity to Haneda via U.S. gateway and included in applicant’s connecting sch

Proposed U.S. gateway demand included (includes JFK, EWR, and LGA for CO EWR and AA JFK proposals).Sources: Exhibits DL-108-111, DL-117-120, DL-126-129, UA-3, UA-6, CO-122-123, CO-124-125, AA-107-110, AA 111-114, HA-
BUR BUR

SBA SBA

STS

OAK

SFO

SJC SJC

ONT ONT ONT

LAX LAX

SNA SNA

ALW

YKM PSC PSC PSC PSC PUW

EAT EAT EAT GEG FCA FCA

FAT FAT FAT

PDX

EUG

To ANC, FAI, JNU, SIT, KTN To ANC, FAI, JNU, SIT, KTN To ANC, FAI, JNU, SIT, KTN To ANC, FAI, JNU, SIT, KTN To ANC, FAI, JNU, SIT, KTN To ANC, FAI, JNU, SIT, KTN

ATL ATL ATL

BIL BIL BIL

BLI BLI BLI

BOI BOI BOI 

BZN BZN

CVG

DEN

DFW

DTW

GTF GTF GTF GTF GTF GTF GTF

HLN

LAS LAS

LGB LGB LGB

LWS LWS

MEM

MFR MFR MFR

MSO

MSP MSP MSP MSP

ORD ORD

PHX PHX

PSP PSP

RDD RDD

RDM

RNO RNO RNO

SAN SAN

SLC

SMF SMF SMF

Seattle is an Ideal West Coast Gateway to HanedaDelta Will Provide Nonstop-to-Nonstop Haneda Service for 55 U.S. Points 

Haneda

Note: Includes service operated by Alaska/HorizonSource: Exhibits DL-108-111

SEA
To SJU To SJU To SJ

To SJ

LGA LGA

JFK JFK

HPN HPN

EWR

SWF SWF SWF

SBN SBN

FWA FWA MDW ORD ORD

DAY DAY

RIC RIC

CHO

AVP AVP

SCE SCE ABE ABE

ITHITH

SYR SYR

ELM

ALB ALB

MHT MHT MHT

BTV

ROC

BUF BUF BUF BUF BUF BUF

LAN LAN

MBS MBS

PLN PLN

MQT MQT MQT

GRB GRB CWA

MKE MKE

MSN MSN

GRR GRR

IND IND

CAK CAK

EVV EVV

SDF SDF SDF

DCA DCA

IAD

TPA TPA

MSY MSY MSY MSY IAH IAH

SAT SAT SAT

AUS AUS

DFW

TUL TUL TUL

OKC OKC

MCI MCI MCI

STL STL STL

CMI CMI CMI

BMI BMI BMI

PIA

MLI MLI MLI

CID CID

DSM

OMA OMA

RST RST RST

MSP MSP

DLH DLH

RSW

MIA MIA

APN APN

ATL ATL ATL

ATW

AVL AVL AVL

AZO

BDL BDL BDL BDL BDL BDL BDL BGM

BHM

BNA BNA

BOS BOS

BWI BWI BWI

CAE

CHS CHS CHS CHS

CLE CLE

CLT CLT CLT

CMH CMH

CRW

CVG

ERI ERI ERI ERI

FLL FLL FLL

FNT FNT FNT

GSO

GSP GSP

HSV

JAX JAX

LEX LEX

LSE LSE

MCO

MDT MDT MDT

MEM MYR MYR

ORF ORF ORF

PBI PBI PBI PBI

PIT PIT PHL PHL PHL PITPIT

PVD PVD

PW

RDU RDU RDU RDU

ROA ROA

SAV

TOL TOL TOL TOL TOL TOL TOL

TRI TRI TRI TRI

TVC TVC

TYS TYS

Delta’s Detroit Hub is the Largest and Most EffectiveGateway to Haneda for the Eastern United StatesDelta Will Provide Nonstop-to-Nonstop Haneda Service for 106 U.S. Points 

Haneda

Source: Exhibits DL-117-120

DTW
ATL ATL

CVG

DTW

IND

LAS

MEM

MSP

PRC

RNO

SAN SAN

SLC SLC SLC SLC

T

RDD RDD RDD RDD

MMH

Delta Los Angeles-Haneda Service Would Provide Strong Competition at Star Alliance’s LAX Hub Delta Will Provide Nonstop-to-Nonstop Haneda Service for 18 U.S. Points 

Haneda

Note: Includes service operated by Alaska/HorizonSource: Exhibits DL-126-129

LAX
HND HND

Delta’s Honolulu-Haneda Service Will Maintain U.S.Flag Competitiveness for Tokyo Leisure Passengers

Honolulu is Already Served by Japanese Charter Flights from 
ANS-300 Series

Delta’s Seattle Proposal W

Maximize Competition in th

Pacific Northwest
SEA SEA

ALW

PUW

GEG GEG GEG

PSC PSC PSC

ONT ONT ONT

LAX LAX LAX

SNA SNA SNA PSP PSP PSP

BUR BUR BUR

SAN SAN SAN

SBA SBA SBA

SFO SFO SFO

STS STS STS

ATL ATL ATL

BIL BIL BILBIL

BLI BLI BLI BLI

BOI BOI BOI BOI 

BZN BZN BZN

CVG CVG CVG

DEN DEN DEN

DFW

DTW

EAT EAT EAT

EUG EUG EUG

FAT FAT FAT

FCA FCA FCA

GTF GTF GTF

HLN HLN HLN

LAS LAS LAS

LGB LGB LGB

LWS LWS LWS

MCO MCO MCO

MEM MEM

MFR MFR MFR

MSO MSO MSO

MSP MSP MSP

OAK OAK OAK

ORD ORD ORD

PDX PDX PDX

PHX PHX PHX

RDD RDD RDD

RDM RDM

RNO RNO RNO

SJC SJC SJC

SLC SLC SLC SMF SMF SMF

YKM YKM

Seattle’s Pacific Northwest Location Enables Non-Circuituous Connections to HanedaFrom Across the Entire Continental U.S. 

10% C

10% Circuity

DL U.S. Behind Points Served 50

Note: Includes service operated by Alaska/HorizonSource: Exhibits DL-108-111
Delta’s Seattle Service Would Offer 29 More Seats

Per Flight Than United’s San Francisco Proposal

298

269

250255260265270275280285290295300305

United (SFO) Delta (SEA)

Sources: Exhibits DL-106 and UA-2

Seats Per Flight

+11%

0
Delta’s Seattle Service Would Offer 29 More Seats

Per Flight Than United’s San Francisco Proposal

Delta’s Airbus A330-300

298 Seats

United’s 777-200

269 Seats

Sources: Exhibits DL-106 and UA-2
Delta’s Seattle Service Would Offer Over 20,000 More 

Annual Nonstop Seats to/from Haneda Than United’s San Francisco Proposal

196,370

217,540

180,000190,000200,000210,000220,000

United (SFO) Delta (SEA)

Sources: Exhibits DL-106 and UA-2 

Annual Seats

+11%

0
SFO SFO SFO SFO

SNA SNA SNA

BUR BUR BUR

ACV ACV ACV

BOI BOI BOI BOI

CIC CIC CICCIC

DEN DEN DEN

FAT FAT FAT

LAS LAS LAS

LAX LAX LAX

MOD MOD MOD

MRY MRY MRY

PHX PHX PHX

RDD RDD RDD

RNO RNO RNO

SAN SAN SAN

SBA SBA SBA

SBP SBP SBP

SLC SLC SLC SMF SMF SMF

United’s San Francisco Hub Serves Far Fewer Points in aSmaller Catchment Area Than Delta’s Seattle Gateway

SEA 1

Sources: Exhibits DL-108-111, UA-3, and UA-6 

10% Circuity

UA U.S. Behind Points Served 19DL U.S. Behind Points Served 50% DL Greater 163%
Seattle’s Primary Catchment Traffic Base to Tokyo is 

87% Larger Than San Francisco’s

807,854

1,511,348

0

200,000400,000600,000800,000

1,000,0001,200,0001,400,0001,600,000

UA SFO Tokyo

Base

DL SEA Tokyo

Base

Local and Connecting U.S. – Tokyo Traffic Base(Within 10% circuity)

Note: Includes U.S. points with no more than 10% circuity to Haneda via U.S. gateway and included in applicant’s connecting sch

U.S. gateway demand included.Sources: MIDT CY 2009; Exhibits DL-108-111, UA-3, and UA-6 (for one-way connections)

+87%
Seattle’s Primary Catchment Connecting Traffic Base 

to Tokyo is More Than Double San Francisco’s

602,505

1,434,020

0

200,000400,000600,000800,000

1,000,0001,200,0001,400,0001,600,000

UA SFO Tokyo

Base

DL SEA Tokyo

Base

U.S. – Tokyo Connecting Traffic Base(Within 10% circuity)

Note: Includes U.S. points with no more than 10% circuity to Haneda via U.S. gateway and included in applicant’s connecting sch

Sources: MIDT CY 2009; Exhibits DL-108-111, UA-3, and UA-6 (for one-way connections)

+138%
Delta’s Seattle Service Will Serve 90% More 

Nonstop-to-Nonstop U.S. Points to Haneda as United’s San Francisco Proposal

29

55

0

102030405060

United (SFO) Delta (SEA)

Nonstop-to-Nonstop U.S. Points to Haneda(No Circuity Limitation) Delta will serve 26 more total points tha

Note: Includes U.S. points included in applicant’s connecting schedule exhibits.Sources: Exhibits DL-108-111, UA-3, and UA-6 (for one-way connections)

+90%
Delta’s Seattle Service Will Offer 31 More

Nonstop-to-Nonstop U.S. Points to Haneda Than United’s San Francisco Proposal Within 10% Circuity

19

50

0

102030405060

United (SFO) Delta (SEA)

Nonstop-to-Nonstop U.S. Points to Haneda(Within 10% Circuity) Delta will serve 31 more points than 

Note: Includes U.S. points with no more than 10% circuity to Haneda via U.S. gateway and included in applicant’s connecting sch

Sources: Exhibits DL-108-111, UA-3, and UA-6 (for one-way connections)

+163%
Delta’s Seattle Gateway is Under Competitive Threat by 

the Nearby Vancouver Gateway, Which is Eligible for HanedaService by Multiple Star ATI Partners (Air Canada and ANA),as Well as Oneworld (JAL)

Tokyo Tokyo
SFO SFO SFO SFO

SEA SEA

Passengers Throughout the West Coast Can Conveniently Travel via Seattle – But Pacific Northwest Passengers Would Be Inconvenienced Under United’s San Francisco Proposal

Note: Mileage is statute mileage.Source: Exhibits DL 110-111, UA-1, and UA-3

Delta United

SFO SEA

Via SEA Via SFO

Two Segment Miles 5,468 5,824Circuity (%) 6% 22%Circuity (Miles Roundtrip) 644 2,068 
ANS-400 Series

Delta’s Detroit Hub Gatewa

Maximizes Competition fo

Eastern U.S. Customers
FNT FNT FNT

DTW

MBS MBS MBS

CAK CAK CAK

CLE CLE CLE

MDW

MSN MSN MSN

ORD ORD ORD

GRR GRR GRR

ITITIT

IT

ELEL

SDF SDF SDF

EVV EVV EVV

PIA PIA PIAPIA

ATWGRB GRB GRB

MDT MDT MDT

SCE SCE SCE

IAD IAD IADIAD

ROC ROC ROC

APN APN APN

ATL ATL ATL

AVL AVL AVL

AZO AZO AZO

BHM BHM

BMI BMI BMI

BNA BNA BNA

BUF BUF BUF

CAE CAE CAE

CCC

CHCHCH

CLT CLT CLT

CMH CMH CMH CMI CMI CMI

CRW

CVG CVG CVG

DAY DAY DAY 

ERI ERI ERI ERI

FWA FWA FWA

GSO GSO GSO

GSP GSP GSP

HSV HSV HSV

IND IND INDIND

JAX JAX JAX

LAN LAN LAN

LEX LEX LEX

MCO MCO MCO

MEM MEM

MKE MKE MKE

MLI MLI MLI

MSY MSY MSY

PIT PIT PITPIT 

PLN PLN PLN

ROA ROA ROA

RSW

SAV SAV SAV

SBN SBN SBN

STL STL STL

TOL TOL TOL

TPA TPA TPA

TRI TRI TRI TRI

TVC TVC TVC

TYS TYS TYS

Delta’s Primary Catchment Area From DetroitProvides Comprehensive and CompetitiveHaneda Service for the Entire Eastern U.S.

10% Circ

10% Circuity

DL U.S. Behind Points Served 90

Source: Exhibits DL-117-120
Delta’s Detroit Service Would Offer 156 More Seats

Per Flight Than American’s New York Proposal

247

403

0

50

100150200250300350400450

American (JFK) Delta (DTW)

Sources: Exhibits DL-115 and AA-102

Seats Per Flight

+63%
Delta’s Detroit Service Would Offer 156 More Seats

Per Flight Than American’s New York Proposal

Delta’s Boeing 747-400

403 Seats

American’s 777-200

247 Seats

Sources: Exhibits DL-115 and AA-115 
Delta’s Detroit Service Would Offer More Than 100,000 

More Annual Nonstop Seats to/from Haneda ThanAmerican’s New York Proposal

180,310

294,190

0

50,000

100,000150,000200,000250,000300,000

American (JFK) Delta (DTW)

Sources: Exhibits DL-115 and AA-104 

Annual Seats

+63%
MCO MCO MCO

PIT PIT PITPIT

TPA TPA TPA

American’s JFK Gateway Serves Far Fewer Points in aSignificantly Smaller Catchment Area Than Delta’sDetroit Hub

JFK 10% Circuity

Source: Exhibits AA-107-110 and DL-117-120

10% Circuity

AA U.S. Behind Points Served 10DL U.S. Behind Points Served 90% DL Greater 800%

DTW 10% Circuity
Detroit’s Primary Catchment Traffic Base to Tokyo is 

76% Larger Than American’s at JFK

521,150

918,938

0

100,000200,000300,000400,000500,000600,000700,000800,000900,000

1,000,000

AA JFK-Tokyo

Base

DL DTWTokyo Base

Local and Connecting U.S. – Tokyo Traffic Base(Within 10% circuity)

Note: Includes U.S. points with no more than 10% circuity to Haneda via U.S. gateway and included in applicant’s connecting sch

U.S. gateway demand included (EWR, LGA, and JFK for AA). Sources: MIDT CY 2009; Exhibits AA-107-110 and DL-117-120

+76%
Detroit’s Primary Catchment Connecting Traffic Base 

to Tokyo is Five Times the Size of American’s at JFK

169,325

886,662

0

100,000200,000300,000400,000500,000600,000700,000800,000900,000

1,000,000

AA JFK Tokyo

Base

DL DTW Tokyo

Base

U.S. – Tokyo Connecting Traffic Base(Within 10% circuity)

Note: Includes U.S. points with no more than 10% circuity to Haneda via U.S. gateway and included in applicant’s connecting sch

Sources: MIDT CY 2009; Exhibits AA-107-110 and DL-117-120

+424%
Delta’s Detroit Service Will Serve 91 More 

Nonstop-to-Nonstop U.S. Points to HanedaThan American’s JFK Proposal

15

106

0

20406080

100120

American (JFK) Delta (DTW)

Nonstop-to-Nonstop U.S. Points to Haneda(No Circuity Limitation) Delta will serve 91 more total points tha

Note: Includes U.S. points included in applicant’s connecting schedule exhibits.Sources: Exhibits AA-107-110 and DL-117-120

+607%
Delta’s Detroit Service Will Serve 80 More

Nonstop-to-Nonstop U.S. Points to Haneda Than American’s JFK Proposal Within 10% Circuity

10

90

0

102030405060708090

100

American (JFK) Delta (DTW)

Nonstop-to-Nonstop U.S. Points to Haneda(Within 10% Circuity) Delta will serve 80 more points than 

Note: Includes U.S. points with no more than 10% circuity to Haneda via U.S. gateway and included in applicant’s connecting sch

Sources: Exhibits AA-107-110 and DL-117-120

+800%
Delta’s Detroit Service Would Offer 127 More Seats

Per Flight Than Continental’s Newark Proposal

276

403

0

50

100150200250300350400450

Continental

(EWR)

Delta (DTW)

Sources: Exhibits DL-115 and CO-114 (CO capacity reflects removal of 9 seats from B777 as explained in note on CO-114) 

Seats Per Flight

+46%
Delta’s Detroit Service Would Offer 127 More Seats

Per Flight Than Continental’s Newark Proposal

Delta’s Boeing 747-400

403 Seats Continental’s 777-200

276 Seats

Sources: Exhibits DL-115 and CO-118 
Delta’s Detroit Service Would Offer Nearly 100,000 More 

Annual Nonstop Seats to/from Haneda Than Continental’s Newark Proposal

201,480

294,190

0

50,000

100,000150,000200,000250,000300,000

Continental

(EWR)

Delta (DTW)

Sources: Exhibits DL-115 and CO-114 (CO capacity reflects removal of 9 seats from B777 as explained in note on CO-114) 

Annual Seats

+46%
IAD IAD IADIAD 

GSO GSO GSO

ATL ATL ATL

AVL AVL AVL

BUF BUF BUF

CHCHCH

CLE CLE CLE

CLT CLT CLT

CMH CMH CMH

JAX JAX JAX

MCO MCO MCO

PIT PIT PITPIT 

RORORO

RSW

SAV SAV SAV

TPA TPA TPA

TYS TYS TYS

Continental’s Newark Hub Serves Far Fewer Points in aSignificantly Smaller Catchment Area Than Delta’sDetroit Hub

EWR 10% Circuity

DTW 10% Circuity

Sources: Exhibits DL-117-120 and CO-122-123

10% Circuity

CO U.S. Behind Points Served 40DL U.S. Behind Points Served 90% DL Greater 125%
Detroit’s Primary Catchment Connecting Traffic Base 

to Tokyo is Nearly 2.5 Times As Large As Newark’s

369,208

886,662

0

100,000200,000300,000400,000500,000600,000700,000800,000900,000

1,000,000

CO EWR

Tokyo Base

DL DTW Tokyo

Base

U.S. – Tokyo Connecting Traffic Base(Within 10% circuity)

Note: Includes U.S. points with no more than 10% circuity to Haneda via U.S. gateway and included in applicant’s connecting sch

Sources: MIDT CY 2009; Exhibits DL-117-120 and CO-122-123

+140%
Delta’s Detroit Service Will Serve 130% More 

Nonstop-to-Nonstop U.S. Points to Hanedaas Continental’s Newark Proposal

46

106

0

20406080

100120

Continental

(EWR)

Delta (DTW)

Nonstop-to-Nonstop U.S. Points to Haneda(No Circuity Limitation) Delta will serve 60 more total points tha

Note: Includes U.S. points included in applicant’s connecting schedule exhibits.Sources: Exhibits DL-117-120 and CO-122-123

+130%
Delta’s Detroit Service Will Offer More Than Twice As Many

Nonstop-to-Nonstop U.S. Points to Haneda As Continental’s Newark Proposal Within 10% Circuity

40

90

0

102030405060708090

100

Continental

(EWR)

Delta (DTW)

Nonstop-to-Nonstop U.S. Points to Haneda(Within 10% Circuity) Delta will serve 50 more points than 

Note: Includes U.S. points with no more than 10% circuity to Haneda via U.S. gateway and included in applicant’s connecting sch

Sources: Exhibits DL-117-120 and CO-122-123

+125%
Delta’s Detroit Hub is a More Effective Transpacific Gateway

Than Continental at Newark and American at JFKDetroit Has More Transpacific Seats Than All of the CompetingEastern U.S. Gateways

Source: July 2010 schedules (APGdat)

19,790

15,848

3,45

0

5,000

10,00015,00020,00025,000

Delta DTW Continental EWR America

Transpacific Weekly Seats

(Both Directions)
ANS-500 Series

Delta’s Los Angeles Propos

Will Maximize Competition 

the Largest Mainland U.S.-Tokyo 
ATL ATL

CVG

DTW

IND

LAS

MEM

MSP

PRC

RNO

SAN SAN

SLC SLC SLC SLC

T

RDD RDD RDD RDD

MMH

Delta Los Angeles-Haneda Service Would Provide Strong Competition at Star Alliance’s LAX Hub Delta Will Provide Nonstop-to-Nonstop Haneda Service for 18 U.S. Points 

Haneda

Note: Includes service operated by Alaska/HorizonSources: Exhibits DL-126-129; MIDT CY 2009.

LAX

The Los Angeles local market and 

Delta’s 18 connecting U.S. points 

via LAX account for 1 million 

Tokyo passengers annually.
Delta’s Los Angeles Service Would Offer 156 More Seats

Per Flight Than American’s Los Angeles Proposal

247

403

0

50

100150200250300350400450

American (LAX) Delta (LAX)

Sources: Exhibits DL-124 and AA-104 

Seats Per Flight

+63%
Delta’s Los Angeles Service Would Offer 156 More Seats

Per Flight Than American’s Los Angeles Proposal

Delta’s Boeing 747-400

403 Seats

American’s 777-200

247 Seats

Sources: Exhibits DL-124 and AA-115
Delta’s Los Angeles Service Would Offer More Than 100,000 

More Annual Nonstop Seats to/from Haneda Than American’s Los Angeles Proposal

180,310

294,190

0

50,000

100,000150,000200,000250,000300,000

American

(LAX)

Delta (LAX)

Sources: Exhibits DL-124 and AA-104 

Annual Seats

+63%
The Los Angeles-Tokyo Local Market Has Twice As Many

U.S.-Originating Passengers as the Honolulu-TokyoLocal Market

60,961

125,617

0

20,00040,00060,00080,000

100,000120,000140,000

Honolulu Los Angeles

Source: MIDY CY 2009

U.S. Point-of-SaleU.S.-Tokyo O&D Passengers

+106%
Los Angeles is the Largest Mainland U.S.-Tokyo Market

and is Nearly Twice the Size of the San Francisco-TokyoLocal Market

205,349

401,782

0

50,000

100,000150,000200,000250,000300,000350,000400,000450,000

San Francisco

(United)

Los Angeles

(Delta)

Source: MIDY CY 2009

U.S.-Tokyo O&D Passengers

+96%
ANS-600 Series

Delta’s Honolulu-Haneda Ser

Provides the Greatest Benef

for the Pacific Islands
6.3%

93.7%

Honolulu-Tokyo Passengers Are Overwhelmingly Non-U.S. Point of Sale

Source: MIDT CY 2009

Honolulu-Tokyo Passengers

U.S. Point of Sale

Non-U.S. Point 
Delta’s Honolulu Service Would Offer 145 More Seats

Per Flight Than Hawaiian’s Honolulu Proposal

258

403

0

50

100150200250300350400450

Hawaiian (HNL) Delta (HNL)

Sources: Exhibits DL-133 and HA-App-3 (HA capacity reflects 6 seats blocked for crew as explained in note on HA-App-3)

Seats Per Flight

+56%
Delta’s Honolulu Service Would Offer 145 More Seats

Per Flight Than Hawaiian’s Honolulu Proposal

Delta’s Boeing 747-400

403 Seats

Hawaiian’s

767-300

258 Seats

Sources: Exhibits DL-133 and HA-App-3
Delta’s Honolulu Service Would Offer 106,000 More 

Annual Nonstop Seats to/from Haneda ThanHawaiian’s Honolulu Proposal

188,340

294,190

0

50,000

100,000150,000200,000250,000300,000

Hawaiian (HNL) Delta (HNL)

Sources: Exhibits DL-133 and HA-App-3 (HA capacity reflects 6 seats blocked for crew as explained in note on HA-App-3)

Annual Seats

+56%
HNL HNL

HND HND

Honolulu is an Ineffective Gateway to Haneda for theContinental U.S.

Note: Mileage is statute mileage.Source: Exhibits DL-104 and HA-App-1-2 

Delta SEA-HND

Miles: 4,790

Circuity: 0%

Roundtrip Elapsed Time Summer: 19:45

Roundtrip Elapsed Time Winter: 19:50

Hawaiian SEA-HNL-HND

Miles: 6,521

Circuity: 36%

Roundtrip Elapsed Time Summer: 44:05

Roundtrip Elapsed Time Winter: 35:00
HNL HNL

HND HND 

Honolulu is an Ineffective Gateway to Haneda for theContinental U.S.

Note: Mileage is statute mileage.Source: Exhibits DL-122 and HA-App-1-2 

Delta LAX-HND

Miles: 5,474

Circuity: 0%

Roundtrip Elapsed Time Summer: 22:00

Roundtrip Elapsed Time Winter: 22:35

Hawaiian LAX-HNL-HND

Miles: 6,397

Circuity: 17%

Roundtrip Elapsed Time Summer: 42:15

Roundtrip Elapsed Time Winter: 34:50
Honolulu is an Ineffective Gateway to Haneda for the

Continental U.S.

*LAX elapsed times for DL based on DL’s nonstop LAX-HND proposal.Note: Best roundtrip elapsed time shown for each applicant based on applicant’s schedule exhibits.Source: Exhibits DL-104, DL-122, DL-108-111, DL-126-129 and HA-App-2 

Hawaiian’s Proposed Continental U.S. Connecting Points Are 

Conveniently Served by Delta’s Seattle and Los Angeles Pr

U.S. Point DL via SEA HA via HNL DL via SEA HA via HNL DL via SE

LAS 2% 19% 28:05 35:05 27:57 

LAX* Nonstop 17% 22:00 42:15 22:35 

OAK 6% 21% 27:55 one-way only 30:34 

PDX 2% 33% 23:50 35:00 24:50 PHX 2% 17% 29:47 37:49 29:54 SAN 5% 16% 30:13 one-way only 29:02 

SEA Nonstop 36% 19:45 44:05 19:50 

SFO 6% 21% 29:04 one-way only 27:42 

SJC 6% 21% 29:00 one-way only 29:47 

SMF 5% 23% 27:45 one-way only 29:29 

Summer

Roundtrip Elapsed Time

W

Circuity Roundtrip 
Hawaiian Competes Today in Japan via Charters and

Has 600 Annual Haneda Opportunities Available

- Hawaiian Haneda Ap

- 2009 U.S.-Japan MOU, A
Hawaiian’s “Wingtip” Flights Fail to Maximize

Public Benefits

188,340

214,620

150,000170,000190,000210,000230,000250,000

Hawaiian 767-

300 Proposal

Hawaiian A330

Proposal

Source: HA-App-3

Annual Seats

+14%

• Hawaiian could increase HNL-HND capacity by 14% by 

larger A330 aircraft

• No new connecting benefits are realized from two fligh

exactly the same time channel

0
0.9%

99.1%

Guam-Tokyo Passengers Are Overwhelmingly Non-U.S. Point of Sale

Source: MIDT CY 2009

Guam-Tokyo Passengers

U.S. Point of Sale

Non-U.S. Point of S
Delta’s Honolulu Service Would Offer 147 More Seats

Per Flight Than Continental Micronesia’s Guam Proposal

256

403

0

50

100150200250300350400450

Continental

Micronesia

(GUM)

Delta (HNL)

Sources: Exhibits DL-133 and CO-115 

Seats Per Flight

+57%
Delta’s Honolulu Service Would Offer 147 More Seats

Per Flight Than Continental Micronesia’s Guam Proposal

Delta’s Boeing 747-400

403 Seats

Continental Micronesia’s 

764-400

256 Seats

Sources: Exhibits DL-133 and CO-119
Delta’s Honolulu Service Would Offer 107,000 More 

Annual Nonstop Seats to/from Haneda ThanContinental Micronesia’s Guam Proposal

186,880

294,190

0

50,000

100,000150,000200,000250,000300,000

Continental

Micronesia

(GUM)

Delta (HNL)

Sources: Exhibits DL-133 and CO-115 

Annual Seats

+57%
Based on U.S. Point-of-Sale Bookings, the Guam

Local Market is Substantially Smaller Than the LocalMarkets of Delta’s Proposed Continental U.S. Gateways

125,617

39,030

16,434

0

20,00040,00060,00080,000

100,000120,000140,000

Los Angeles Seattle Detroit 

U.S. Point-of-SaleU.S.-Tokyo O&D Passengers

Source: MIDT CY 2009 (U.S. point-of-sale only)
GUM GUM

NRT NRT

Continental and Delta Each Serve Guam from Narita

Delta’s Narita-Guam Flights Would Be Placed at a Se

Competitive Disadvantage if Only Continental Was Allo

Serve Guam From Tokyo’s Preferred Airport
CERTIFICATE OF SERVICE 

A copy of the foregoing document has been served this 1st day of March, 2010, upon 

the following persons via email: 

carl.nelson@aa.com 

dan.weiss@coair.com 

hershel.kamen@coair.com 

rbkeiner@crowell.com 

mrosia@crowell.com 

gmurphy@crowell.com 

jeffrey.manley@united.com 

julie.oettinger@united.com 

howard.kass@usairways.com 

benjamin.slocum@usairways.com 

jhill@dowlohnes.com 

ldeavers@dowlohnes.com 

perkmann@dowlohnes.com 

dmendersbee@zsrlaw.com 

todd.homan@dot.gov 

paul.gretch@dot.gov 

keith.glatz@dot.gov 

esta.rosenberg@dot.gov 

byerlyjr@state.gov 

eugene_alford@ita.doc.gov 

joe.cambron@wcaa.us 

Ishiwata.K@portseattle.org 

Safora.I@portseattle.org 

mike.orr@airlineinfo.com