BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Motions and Application of 

AMERICAN AIRLINES, INC. 

HAW AllAN AIRLINES, INC. 

In the matter of 2010 U.S.-Haneda Combination 

Services Allocation Proceeding 

) 

) 

) 

) 

) Docket DOT -OST -2010-0018 

) 

) 

) 

CONSOLIDATED ANSWER OF THE PORT OF SEATTLE 

Communications with respect to this document should be addressed to: 

Mark Reis 

Managing Director 

Seattle - Tacoma International Airport 

Kazue Ishiwata 

Senior Manager Air Service Development 

Seattle-Tacoma International Airport 

Port of Seattle 

P.O. Box 68727 

Seattle, WA 98168 

(206) 787-4698 (tel) 

(206) 439-7782(fax) 

ishiwata.k@portseattle.org 

January 12, 2015 

Isabel R. Safora 

Deputy General Counsel 

Port of Seattle 

Legal Department 

P. 0. Box 1209 

Seattle, WA 98111 

(206) 787-3216 (tel) 

(206) 787-3205 (fax) 

safora.i@portseattle.org 
Consolidated Answer of the Port of Seattle 

DOT -OST -2010-0018 

BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Motions and Application of 

AMERICAN AIRLINES, INC. 

HAW AllAN AIRLINES, INC. 

In the matter of 2010 U.S.-Haneda Combination 

Services Allocation Proceeding 

) 

) 

) 

) 

) Docket DOT-OST-2010-0018 

) 

) 

) 

CONSOLIDATED ANSWER OF THE PORT OF SEATTLE 

The Port of Seattle, the owner-operator of Seattle-Tacoma International Airport, 

("Seattle") respectfully responds in strong support of a decision by the Department 

allowing Delta Air Lines ("Delta") to retain Seattle-Haneda service, thereby maintaining 

significant public benefit through geographic diversity. Reallocating the slots would give 

priority to the size of the market and result in a perpetual grant of scarce slots to 

redundant markets, contrary to the Department's long-standing objective of increasing 

inter-gateway competition in limited entry markets. Delta's recently established Seattle 

hub, combined with its Seattle-Haneda slots, provides gateway parity in the U.S.-Haneda 

marketplace and the only non-stop or one-stop service to Haneda from a previously 

unserved geographic region with a strong economy and focus on international trade. 
Consolidated Answer of the Port of Seattle 

DOT-OST-2010-0018 

I. Delta's SEA-HND Slot Pair Provide the Only Haneda Gateway in the Pacific 

Northwest Region. 

Delta's Seattle-Haneda slot pair offers the only direct connection from the Pacific 

Northwest region to Asia with minimum circuity for travelers connecting through 

Seattle. 1 While other carriers' proposals may include the Pacific Northwest as a 

connecting market, residents in the vast region of Washington, Alaska, Oregon, Montana 

and Idaho will not choose to travel to the southern gateways only to circuitously travel 

back north to Haneda. Once convenient access to Haneda is lost, the Pacific Northwest 

traveling public will likely choose Seattle-Narita or Vancouver-Haneda over the southern 

gateways, eliminating the benefits the Pacific Northwest region receives from the 

October 25,2010, Memorandum ofUnderstanding between the United States and Japan? 

The importance of retaining the Delta-Haneda slots to serve Washington State and 

the Pacific Northwest is well expressed in Washington State Governor Jay Inslee's letter 

to Secretary Foxx.3 Revoking Delta's Seattle-Haneda slots and awarding to American or 

Hawaiian will result in duplicative service to California and Hawaii, states that already 

enjoy the largest allocation ofU.S.-Haneda slots and will eliminate the competitive 

benefit to the region's travelers.4 Loss of the Seattle service will also greatly 

inconvenience Pacific Northwest travelers, since Delta has already sold Seattle-Haneda 

flights beginning March, 2015 and beyond. 

1 Exhibit SEA-102: Circuity map of West Coast gateways 2 Exhibit SEA-l 03: Inconvenience of southern gateway 3 Exhibit SEA-101: Letter from the Governor of the State of Washington 4 Exhibit SEA-104: Current and proposed U.S.-Haneda services 

2 
Consolidated Answer of the Port of Seattle 

DOT-OST-2010-0018 

II. Seattle is the Fastest Growing West Coast Airport and Should Not Lose 

Haneda Service for Perpetuity. 

Seattle is the fastest growing large hub airport in the country, with a passenger 

increase of7.5% between 2013 and 2014.5 Since the year 2000, the number ofpassengers 

going through Seattle grew 32% while Los Angeles ("LAX") saw a growth of only 3%, 

indicating some level of market saturation.6 Long-haul international services have been 

especially strong, with the growth of intercontinental passengers reaching over 110% in 

the last 1 0 years. 7 

Similarly, the City of Seattle is the fastest growing city in the United States with 

one of the nation's strongest economies.8 Contrary to data indicating the LAX market is 

under-served and under-utilized, the Seattle region is the most under-served in long-haul 

international service capacity in relation to the regional gross domestic product ("GDP").9 

Stripping away the valuable Haneda slots from Seattle's strong and growing market and 

reallocating them to states that already enjoy multiple Haneda service would be contrary 

to the public interest. 

III. The Case for a Seattle-Haneda Slot Pair is Stronger Today With Delta's 

Recently Established Seattle Hub. 

Since the launch of the Seattle-Haneda flight in 2013, Delta has built Seattle into 

a West Coast hub. From August 2013 to August 2015, Delta will have increased its 

domestic seats in Seattle by 91% and its daily departures from 47 to 120, 85 of which will 

5 Exhibit SEA-I 06: Passenger growth at top 25 U.S. Airports 6 Exhibit SEA-105: Indexed passenger growth at West Coast airports 7 Exhibit SEA-107: Intercontinental passenger growth at SEA 8 Exhibits SEA-108 through SEA-110: Seattle's economic and population growth 9 Exhibit SEA-Ill: Seattle is underserved: intercontinental seats per GOP 

3 
Consolidated Answer of the Port of Seattle 

DOT -OST -2010-0018 

connect to Delta's Haneda flight. 10 Delta's continued expansion in Seattle will clearly 

result in increased passenger demand for the Seattle-Haneda service. 

IV. The Department's 2013 public interest findings in awarding the SEA-HND 

frequency to Delta are even more compelling today and there is no cause to revisit 

those findings. 

In granting Delta's motion to move its Detroit-Haneda slot pair to Seattle (Order 

2013-2-4), the Department made final its tentative findings of public interest set forth in 

Order 2012-11-12. Those findings remain compelling today: 

• " ... Delta's proposal would best serve the public interest by providing the first 

nonstop Haneda service on a significant mainland U.S-Tokyo route that currently 

lacks any such service, thereby establishing a new U.S. gateway to Haneda." 

• " ... Delta's proposed service would further serve the public interest by providing 

a number of western cities with a first one-stop connecting opportunity to 

Haneda." 

• " ... [O]ther cities that now enjoy one-stop connections over more southerly 

gateways would gain the option of service over a less circuitous northwest 

gateway." 

• "Allowing Delta to move from Detroit to Seattle would also advance one ofthe 

prime objectives we sought to achieve ... , namely, seeking with our limited 

number of Haneda opportunities to address a diversity of public interest goals." 

• " ... [B]rings first-time Haneda service and first U.S.-flag Haneda service to the 

sixth-largest 0 & D market, while also promoting the geographic diversity of the 

10 Exhibit SEA-112: Delta destinations added in 2013 and 2014 from SEA 

4 
Consolidated Answer of the Port of Seattle 

DOT -OST -2010-0018 

U.S.-Haneda gateways, ... consistent with our established approach for the award 

of limited Haneda slot opportunities that would serve the public interest." 

• " . . . Los Angeles already has two daily nonstop flights to Haneda. Delta serves 

Los Angeles-Haneda with its own flights, and United offers Los Angeles-Haneda 

service through its code share with ANA. Given the very limited opportunities for 

U.S. carrier service to Haneda, we tentatively do not find American's arguments 

persuasive for adding more Haneda service at Los Angeles while other significant 

U.S.-Tokyo gateways have no access to Haneda." 

• " .. . the State of Hawaii now enjoys three of the eight total U.S.-Haneda routeopportunities available to U.S. and Japanese carriers." Consistent with our 

ongoing goal of using our limited Haneda rights to address a variety of public 

interest objectives, including the objective of geographically diverse gateways, we 

tentatively find that the public interest would be better served by opening Haneda 

nonstop access to a new region of the country, the Pacific Northwest, than by 

allocating a fourth Haneda route to Hawaii." 

V. The Public Interest Would Not be Served by Reallocating Delta's SeattleHaneda Slots. 

Delta's Seattle-Haneda service provides vital competition to the ATI alliances 

with Japanese carriers and increases the geographic options for travelers in the Pacific 

Northwest region. Delta's Seattle-Haneda service is less than 2 years old. The familiarity 

of Seattle travelers with this route is not yet optimal. Seattle is working closely and in 

5 
Consolidated Answer of the Port of Seattle 

DOT -OST -2010-0018 

unique ways with Delta sales and marketing to improve and further develop this valuable 

route for the region. 11 

Neither American nor Hawaiian disputes that Delta is operating its SeattleHaneda slots in full compliance with the Department's dormancy conditions. As such, it 

would be unlawful and unwise to summarily withdraw slots from Seattle and reallocate 

them to another gateway. 

As the airport owner and a regional economic catalyst, the Port of Seattle 

respectfully requests the Department to preserve and maximize the benefits to the public 

by maintaining Delta's Haneda frequencies in Seattle. 

Respectfully submitted, 

PORT OF SEATTLE 

By: 

Deputy General Counsel 

~ DATED: January 12,2015 

11 Exhibit SEA-113: SEA is actively promoting HND 

6 
Consolidated Answer of the Port of Seattle 

DOT-OST-2010-0018 

CERTIFICATE OF SERVICE 

I hereby certify that one copy of the foregoing Consolidated Answer of the Port of 

Seattle regarding Docket DOT OST 2010 0018 and the Port of Seattle was served this 

12th day of January, 2015, on all parties identified on the attached service list via 

electronic mail. 

howard.kass@aa.com 

abigail.donovan@aa.com 

robert. wirick@aa.com 

charles.hunnicutt@thompsonhine.com 

patricia.snyder@thompsonhine.com 

jhill@cooley.com 

perkmann@cooley.com 

bberlin@cooley.com 

dan. weiss@united.com 

thomas. bolling@united.com 

steve.morrissey@united.com 

gmurphy@crowell.com 

sseiden@crowell.com 

Mike.Donatelli@alpa.org 

dino.atsalis@alpa.org 

Doug.Ralph@alpa.org 

sascha.vanderbellen@delta.com 

chris. walker@delta.com 

paul. gretch@dot. gov 

brian.hedberg@dot.gov 

brett.kruger@dot. gov 

todd.homan@dot.gov 

peter. irvine@dot. gov 

englets@state. gov 

cristinasa@state. gov 

eugene alford@ita.doc.gov 

info@airlineinfo.com 

ejames@jamhoti.com 

seth. waxman@wilmerhale.com 

john.allen@faa.gov 

Robert.Lamansky@hawaiianaire.com 

glindsey@lawa.org 

7 
Motions and Application of Docket DOT-OST-2010-0018

AMERICAN AIRLINES, INC.

HAWAIIAN AIRLINES, INC.

In the matter of 2010 U.S.-Haneda

Combination Services Allocation Proceeding

Exhibits

Port of Seattle

Consolidated Answer of the Port of Seattle
Index of Exhibits 

Exhibit SEA-101: 

Exhibit SEA-102: 

Exhibit SEA-103: 

Exhibit SEA-104: 

Exhibit SEA-105: 

Exhibit SEA-106: 

Exhibit SEA-107: 

Exhibit SEA-108: 

Exhibit SEA-109: 

Exhibit SEA-110: 

Exhibit SEA-111: 

Exhibit SEA-112:

Exhibit SEA-113:

Letter from the Governor of the State of Washington 

Circuity map of West Coast gateways 

Inconvenience of southern gateways 

Current and proposed U.S.-Haneda services 

Indexed passenger growth at West Coast airports

Passenger growth at top 25 U.S. Airports

Intercontinental passenger growth at SEA 

Seattle is the nation’s fastest-growing city 

Seattle has a low unemployment and robust housing market 

Seattle has a strong global economy 

Seattle is underserved: intercontinental seats per GDP

Delta destinations added in 2013 and 2014 from SEA 

SEA is actively promoting HND
The Honorable Anthony Foxx 

U.S. Department ofTransportation 

1200 New Jersey Avenue SE 

Washington, DC 20520 

Dear Secretary Foxx: 

I am writing to urge the Department to keep the only direct flight from Seattle to Haneda Airport 

in Tokyo, Japan. 

I understand that the Department recently received a request to reallocate Seattle's service to 

Haneda to another U.S. city (Docket-DOT-OST-2010-0018). I strongly oppose moving 

Washington State's only direct flight to Haneda to another city which already has the valuable 

Haneda service. 

Japan is a top trading partner to Washington State and our third-largest export market, behind 

only China and our neighbor Canada. Tokyo is Seattle's top international destination. We have 

a long and fruitful relationship with Japan, their residents, businesses and communities, including sister ports and sister cities. Having service directly between Sea-Tac Airport and 

Haneda serves our longstanding relationship and connection. 

We benefit from companies in Seattle creating jobs and trade in several industries including 

aerospace, technology, retail and e-commerce, as well as a number of travel-related businesses. 

Our air cargo and ocean cargo are dominated by Asian markets, with many of our agricultural, 

aerospace and technology companies doing extensive business with Japan. Domestic and 

international travel will continue to increase to Seattle because of our diverse corporate base, 

strong economy, favorable geography and focus on international trade. 

Our flight to Haneda will continue to benefit from the increased flying to Seattle and is critical to 

our efforts to support trade between Washington State and Asia. Delta has moved its Asian hub 

to Sea-Tac, more than doubling its employment in our region to nearly 3,000. Since 2013, 

Delta's flights from Sea-Tac Airport also doubled to nearly 100 peak-day departures. 

In 2013, the Department rightly believed that the best use of this slot was Seattle because it 

would provide the first nonstop Haneda service on a significant mainland U.S.-Tokyo route that 

currently lacked service and would provide a number of western cities with their first one-stop 

P.O. Box 40002 • Olympia, Washington 98504-0002 • (360) 902-4111 • www.governor.wa.gov 

Seattle offers the least circuitous route 

to Haneda for the majority of the U.S. 

DOT-OST-2010-0018 

Exhibit SEA-102

- • Seattle is the closest gateway to Haneda 

San Francisco is a closer gateway than Seatt le 

• Los Angeles is a closer gateway than Seattle 

SEATILE-TACOMA INTERNATIONAL AIRPORT 

Port-- of Seattle-
Loss of a Seattle Gateway would deprive the 

Pacific Northwest of a low-circuity connection to Haneda 

SEA-HND

Nonstop 4,803 miles

LAX-HND 

Nonstop 5,487 miles

LAX-HND

via SEA 5,757 miles

SEA-HND 

via LAX 6,441 miles 

DOT-OST-2010-0018 

Exhibit SEA-103
Non-Seattle Proposals are duplicative, 

especially with Japanese Immunized Partnerships 

Dotted lines indicate contested/proposed services 

DOT-OST-2010-0018 

Exhibit SEA-104
Source: Airports Council International 

Seattle’s growth is stronger and more stable 

compared to other West Coast Airports 

SEA: 31%

LAX: 3%

PDX: 16%

SFO: 14%

YVR: 20%

-30%

-20%

-10%

0%

10%

20%

30%

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 YE

Nov

2014

Change in passengers from 2000

DOT-OST-2010-0018 

Exhibit SEA-105
SEA is the fastest growing large 

airport in the U.S.

Rank

Airport 

Size Rank 

(2013)

Airport YOY Growth 

(YTD Oct)*

1 14 SEA 7.5%

2 3 LAX 6.3%

3 6 JFK 5.7%

4 7 SFO 5.2%

5 4 DFW 5.1%

6 19 BOS 4.7%

7 2 ORD 4.4%

8 16 MSP 4.2%

9 11 PHX 4.1%

10 21 FLL 3.7%

11 25 MDW 3.5%

12 12 IAH 3.3%

13 8 CLT 2.5%

Source: Airport statistics, BTS

*Data for ATL and DTW are through Sept only

Rank

Airport 

Size Rank 

(2013)

Airport YOY Growth 

(YTD Oct)*

14 9 LAS 2.5%

15 5 DEN 2.4%

16 15 MCO 2.1%

17 1 ATL 1.6%

18 18 PHL 1.2%

19 13 EWR 1.0%

20 24 DCA 1.0%

21 20 LGA 0.8%

22 10 MIA 0.6%

23 17 DTW 0.5%

24 22 BWI -0.8%

25 23 IAD -1.7%

DOT-OST-2010-0018

Exhibit SEA-106
Passenger growth 

at SEA airport from 

2004

Growth especially strong 

in intercontinental markets 

Source: Port of Seattle 

7% 9% 12%

16% 19% 16% 17%

21% 21%

13% 27% 29% 18% 19%

25%

36%

26%

44%

59%

80%

104%

110%

0%

20%

40%

60%

80%

100%

120%

2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 YE

6/2014

North America Intercontinental

DOT-OST-2010-0018 

Exhibit SEA-107
Seattle’s population continues to increase

Source: Seattle Times 

DOT-OST-2010-0018 

Exhibit SEA-108

(;IIA~'(:II.OF5tl0"''~ 

Hljh,66.._, .S6,• 1f 

... " ... ~...,..,. ... ([~e Seattle <!rimes 

wiNNER oF NINE PuLnzEa PRizEs G sEATILfTIMEs.coM 

$1.00 

_,__k>eol:r __ ,_ l. ............ ......,.,.,._~ .. ~· ..... 

Seattle the fastest-growing big city in U.S. 

Census Bureau says Seattle grew by 2.8 percent -

highest rate among the 50 most-populous U.S. cities 

;;.~~ 

l..asl )~. St~~ gtt'W b«u 

tb.alt: a:ty Otbd" ll'lljot Amttl(all 

city, a«''rdi!lg co popuLation 

r:srek:W:<ITbutWyby 

tbe CU~SUS Buru~a. 

rrom Jtily 1,20121oJWy 1. 

201), Setnlt 8f"'b)' 2..8 pd"· 

ce:o1- me ru~ 1'1~ lmOtl& 

(be SO mMt·popuklus U.S. 

a~~r:s. Seattle added aally 

18,000 IC~dttitt in lbc ()()C•)'nf 

pmocl btmgmg itt popubboa 

to aboat6S'2,000. 

Aus!m. Tc:tu h.:ld led the 

UDgkoyur BfOV.'III ntc llmocti 

die: bii£C$1 citiel fOJ che prC'Vl+ 

ous two yean . 

...... , 

to tJw: 2011 to 2012 C(OSIH 

cUu, S<Wiegrcu.·by'2.1 pes-- «::ll, wbicll rx.ktd oDiy Di:Dih. 

Aho in me latest popci.Ui.oo 

ts~ima~ S<attk kJf)(r~ 

.Bo6tonto b«OD:Jr ill( tlltioo ·, 

21Sl bigg~t city. S<-U1k is 

.... ,!!lit~ s.trW.nt ~SUO« of 

rtrurllioa to ~ t~ 20 citi« tor 

lbt fim tittlc sirltt 1960. 1'be n.ew d.u.t •w tbat an bot 

tout of lilt ttUjor otJr:s uperi· 

enttd ltOWlh Jut yt:tt. Otuot~., at lbt oppos.itc md or 

tbt spteetnul'l, bad 1bt blU«t 

popubbOU lou - I 4 ptrtau. 

1bt othtf Cllld: v.illl tltpb\~ 

g:rowtb W~e Cle\>tla!ld, Mttr~· 

¢Us. TtM.. and Bal.tuoort.. 

WIUI's tM ruson f« 

Sf'.l:llk'$ ltiCCUStd popllltttotl 

Tbt ~ C~ llutnu Ofl'tf$ 1'10 

iDtdJ)ftUM:.'l Of itt M- ~ bU. 

\uttly lbt dty·s btallll)' 

«.oacnu:y is U:Spo11Siblt for 

attrucma I'IW'IY atw tts1tko1S • 

Accouhng to Scanle's- Office 

of EcoDOCUc Dc\'Ciopmeut. tlK 

aty added outl)' 15,000 IXW 

jobs bclwem 2012 l:!ld 201). 

Suttk did:! ' t jusr wrpan 

othn big U.S. citinia ZOI), 

FOf tbe so:ood c;oa5C'(uti\'C 

)'UJ. Seattle outpa«d its StJb.. 

tuin - a.od tbe oew C:CI)Sill 

<bt.~ sbou•tb.is trc:Dd i.s ~le · 

atio.a: 

Seattle tops list of fast11rowlng cities ~attlt had dw fa-stt\.1 rate of growth among the SO moit·poc~Utou'i U.S. cities from 2012 to 201). 

AA'«:10U lOll lr::.. .... O."d·rt.Ak tafY,VrH 

(/U~ L M11•114Y l, JOl)J 

()t(!w,r · 

1-l<X 

r

r!) 

Am:tln _,. 

·0~ ( 

SEATILE·TACOMA INTERNATIONAL AIRPORT 

Port-- of Seattle· 
Seattle has a strong economy and an affluent population 

The Seattle region has one of the lowest unemployment rates in the country: 

Seattle’s median home price has officially topped its 2007 peak, at $543,500 (vs. 

national top 20 markets at 18% below the peak) 

Source: U.S. Bureau of Labor Statistics; Seattle Times 

6.2%

5.6%

4.7%

4.0%

4.5%

5.0%

5.5%

6.0%

6.5%

7.0%

7.5%

8.0%

J

2013

F M A M J J A S O N D J

2014

F M A M J J

Unemployment Rate

United States

Washington State

Seattle (metro)

DOT-OST-2010-0018 

Exhibit SEA-109
Seattle companies are diversified and industry-leaders 

Washington State is home to many of the world’s most successful and 

recognizable companies: 

Companies whose Global or U.S.headquarters are in Seattle metro area 

DOT-OST-2010-0018 

Exhibit SEA-110
The Seattle market still 

remains underserved 

12.4

10.0

5.5

0

2

4

6

8

10

12

14

SFO LAX SEA

Annual Intercontinental Seats 

per Million Dollars of GDP

 GDP for metropolitan areas in CY 2013 

Intercontinental seats for YE June 2014 

 Source: Diio Mi Schedules, US Census Data, Stats Canada 

DOT-OST-2010-0018 

Exhibit SEA-111
New Seattle destinations on Delta announced/inaugurated in 2013 and 2014 

Cities previously unserved from Seattle in bold 

• Anchorage (ANC)

• Boise (BOI)

• Bozeman (BZN)

• Calgary (YYC)

• Denver (DEN)

• Fairbanks (FAI)

• Hong Kong (HKG)

• Jackson Hole (JAC)

• Juneau (JNU)

• Kahului (Maui) (OGG)

• Ketchikan (KTN)

• Las Vegas (LAS)

• London (LHR)

• Los Angeles (LAX)

• Los Cabos (SJD)

• Palm Springs (PSP)

• Phoenix (PHX)

• Portland (PDX)

• Puerto Vallarta (PVR)

• Sacramento (SMF)

• San Diego (SAN)

• San Francisco (SFO)

• San Jose (SJC)

• Seoul (ICN)

• Shanghai (PVG)

• Sitka (SIT)

• Spokane (GEG)

• Tokyo-Haneda (HND)

• Tucson (TUS)

• Vancouver (YVR)

Delta has increased capacity and 

added new, unserved markets 

Includes services announced in 2014 to begin in 2015. 

Source: Delta Air Lines. 

DOT-OST-2010-0018 

Exhibit SEA-112
SEA is actively working with Delta to 

promote the Haneda flight 

DOT-OST-2010-0018 

Exhibit SEA-113

SEA is actively working with 

Delta to specifically promote 

the Haneda flight through 

co-branded advertisements 

and other projects. 

Passengers continue to 

book SEA-HND for flights 

beyond March 29, 2015, and 

allowing these flights to 

proceed as scheduled is in 

the greatest public interest.