BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, DC 

 

In the Matter of ) 

 ) 

2010 U.S.-Haneda Combination ) Docket DOT-OST-2010-0018 

Services Allocation Proceeding ) 

 ) 

CONSOLIDATED REPLY 

OF 

UNITED AIR LINES, INC.

 Communications with respect to this document should be addressed to: 

JULIE OETTINGER 

Managing Director – International 

& Regulatory Affairs 

UNITED AIR LINES, INC. 

1025 Connecticut Avenue, NW 

Suite 1210 

Washington, DC 20036 

BRUCE H. RABINOVITZ 

DAVID HEFFERNAN 

NEIL J. KING 

WILMER CUTLER PICKERING 

 HALE AND DORR LLP 

1875 Pennsylvania Avenue, NW 

Washington, DC 20006 

(202) 663-6000 (Phone) 

(202) 663-6363 (Fax) 

bruce.rabinovitz@wilmerhale.com 

david.heffernan@wilmerhale.com 

neil.king@wilmerhale.com 

Counsel for 

UNITED AIR LINES, INC. 

DATED: March 8, 2010 









































United Will Offer Roundtrip Online Connec

United Will Offer Roundtrip Online Connec

To Haneda From 27 Air To Haneda From 27 Airports Via San Fran

ports Via San Fran

Sources: MIDT, CY2009. U.S. to Tokyo (HND/NRT).OAG, November 2010 (as adjusted to reflect planned retiming of 6 connections predicated on receipt of a Haneda slot award).Each of these round-trip connections meets the following criteria: year-round, connection window less than 4 hours, and connection flights operated by United/United Express. 

YEG

LAX

YVR

YYJ

SEA

PDX

EUG

BOI

YYC

SLC

RNO

ACV

RDD

CIC

SMF

SFO MOD

MRY

FAT

SBP LAS

SBA

BUR

SNA

SAN PHX

DEN

ORD

United Connections To SFO-HND Will Serve 175,566 (or 31% of) U.S.-Origin
United’s SFO-HND Service Will Offer More Non HND Service Will Offer More Non–Sto

Sto

Connect Service To Haneda Than An Connect Service To Haneda Than Any Other West Coas

y Other West Coas

Sources: MIDT, CY2009. U.S. to Tokyo (HND/NRT).Passenger totals are derived from summing industry U.S. to Tokyo O&D passengers for each applicant’s relevant local and connecting U.S. airports. Each of these round-trip connections meets the followingcriteria: year-round, connection window less than 4 hours, and connection flights operated by United/United Express for United, American/American Eagle for American, and Delta/Delta Connection for Delta.SFO=SFO,SJC,OAK. LAX=LAX,SNA,BUR,ONT.

0

50,000

100,000150,000200,000250,000

SFO LAX LAX 

Annual Passengers

Annual U.S. To Tokyo O&D Passengers (U.S. Point Of Origin)

51,700

175,566

83,682 83,682

83,911

4,532

227,266

167,593

88,214
The San Francisco The San Francisco–Tokyo Local Market Is Tokyo Local Market Is More T

More T

Large As Seattle Large As Seattle–Tokyo And More Than Four Ti Tokyo And More Than Four Times Large

mes Large

Source: MIDT, CY2009. U.S. to Tokyo (HND/NRT).SFO=SFO,SJC,OAK.

51,700

23,477

0

10,00020,00030,00040,00050,00060,000

SFO SEA D

Annual Passengers

Annual U.S. To Tokyo O&D Passengers (U.S. Point Of Origin)
27

8

1

05

1015202530

SFO LAX LAX 

# Of Connecting Airports

Roundtrip Online Connecting Airports

United’s San Francisco Service Will s San Francisco Service Will Offer More Ro

Offer More Ro

Connecting Airports To Haneda Than Connecting Airports To Haneda Than Any Other West Coa

Any Other West Coa

Sources: Exhibits UA-3, AA-111, AA-112, AA-113, AA-114, DL-108, DL-109, DL-110, DL-111, DL-126, DL-127, DL-128, DL-129. Each of these round-trip connections meets the following criteria: year-round, connection window less than 4 hours, and connection flights operated by United/United Express for United, American/American Eagle for American, and Delta/Delta Connection fo
United’s SFO-HND Proposal Would Benefit More U

HND Proposal Would Benefit More U

Passengers Than Any Of The Othe Passengers Than Any Of The Other West Coast Gat

r West Coast Gat

Sources: Exhibits UA-3, AA-111, AA-112, AA-113, AA-114, DL-108, DL-109, DL-110, DL-111, DL-126, DL-127, DL-128, DL-129. MIDT, CY2009. U.S. to Tokyo (HND/NRT). Passenger totals are derived from summing industry U.S. to Tokyo O&D passengers for each applicant’s relevant connecting U.S. airports.Local market demand defined as: SFO=SFO,SJC,OAK. NYC=EWR,JFK,LGA. LAX=LAX,SNA,BUR,ONT.*One of the four airports is operated by American’s codeshare partner. **Both of the airports are operated by Delta’s codeshare partner.

Even After Applying 10% Circuity Filters, United’s SFO-HND Proposal Still Captures Nearly 

SFO LAX 

Applicant's Priority 1st 2nd Connecting Airports Claimed (U.S. Plus Int'l) 27 25 Minus Non Year-Round Connection Airports 0 (3) Minus Airports Claimed As One-Way Connections Only 0 (10) Minus Airports With Connection Window > 4 Hours In One Or Both Directions 0 (3) Minus Airports With Circuity >10% (8) (4)* Minus Remaining Airports Operated By Codeshare Partners 00Remaining Connection Airports Operated By Applicant's Metal 19 5 Connecting Market Demand (U.S. Point Of Origin Passengers) 114,062 32,027 Local Market Demand (U.S. Point Of Origin Passengers) 51,700 83,682 Total Market Demand Coverage (U.S. Point Of Origin Passengers) 165,762 115,709 % of Total U.S. - TYO Market 29% 21% 
United’s SFO-HND Proposal Would Benefit More U

HND Proposal Would Benefit More U

Passengers Than The First Passengers Than The First-Priority Proposals Of Ot

Priority Proposals Of O

Sources: Exhibits UA-3, CO-122, CO-123, AA-107, AA-108, AA-109, AA-110, HA-App-2, DL-108, DL-109, DL-110, DL-111.MIDT, CY2009. U.S. to Tokyo (HND/NRT). Passenger totals are derived from summing industry U.S. to Tokyo O&D passengers for each applicant’s relevant connecting U.S. airports.Local market demand defined as: SFO=SFO,SJC,OAK. NYC=EWR,JFK,LGA. LAX=LAX,SNA,BUR,ONT.*Continental provided winter 2010 connections only. **Both of the airports are operated by Delta’s codeshare partner.

Even After Applying 10% Circuity Filters, United’s SFO-HND Proposal Still Captures Nearly 

SFO EWR 

Connecting Airports Claimed (U.S. Plus Int'l) 27 74 Minus Non Year-Round Connection Airports 0 -* Minus Airports Claimed As One-Way Connections Only 0 (27) Minus Airports With Connection Window > 4 Hours In One Or Both Directions 0 (9) Minus Airports With Circuity >10% (8) (7) Minus Airports Operated By Codeshare Partners 00Remaining Connection Airports Operated By Applicant's Metal 19 31 Connecting Market Demand (U.S. Point Of Origin Passengers) 114,062 63,063 Local Market Demand (U.S. Point Of Origin Passengers) 51,700 67,877 Total Market Demand Coverage (U.S. Point Of Origin Passengers) 165,762 130,940 8% of Total U.S. - TYO Market 29% 23% 
Delta's History Of Asia Servi Delta's History Of Asia Services At Seattle Sug

ces At Seattle Sug

A Seattle A Seattle–Haneda Service Award Would Be A P

Haneda Service Award Would Be A P

Source: OAG, January 1994 – March 2010. Weekly frequencies to Asia (DOT WAC codes between 700-799).Note: Delta and Northwest weekly frequencies are combined during entire time period.*Delta plans to resume Seattle-Osaka service this summer. (DL App. at 3; DL Ans. at 10).

Delta Has Discontinued 3 Out Of 4 Nonstop Routes From S

NRT

HKG

KIX

SEL

Route Discontinued Route In-Service

Service History:

Route Start Date Discontin

Seattle (SEA) - Seoul (SEL) Pre-1994 Mar 9Seattle (SEA) - Hong Kong (HKG) Nov 94 Aug 9

Seattle (SEA) - Osaka (KIX) Feb 95 Sep 0Seattle (SEA) - Narita (NRT) Pre-1994 -
Delta's Asia Service Failures at Delta's Asia Service Failures at Portland Suggest Portland Suggest 

Another Pacific Northwest Non Another Pacific Northwest Non

-Hub, Also Would Be a Poor C

Hub, Also Would Be a Poor C

Source: OAG, January 1994 – March 2010. Weekly frequencies to Asia (DOT WAC codes between 700-799).Note: Delta and Northwest weekly frequencies are combined during entire time period.*Delta discontinued the route in March 2001. Northwest entered the route in June 2004, which became a Delta route as of February 2010.

Since 1994, Delta Has Discontinued All But One Of Its Nonstop Route

NRT

TPE

NGO FUK

SEL

Route Discontinued Route In-Service

Service History:

Route Start Date Discontin

Portland (PDX) - Taipei (TPE) Pre-1994 Nov 9Portland (PDX) - Seoul (SEL) Pre-1994 Jan 9Portland (PDX) - Fukuoka (FUK) Nov 98 Sep 9Portland (PDX) - Nagoya (NGO) Pre-1994 Mar 0Portland (PDX) - Narita (NRT) Pre-1994 Mar 0
6,523

2,881

0

1,0002,0003,0004,0005,0006,0007,000

SFO HNL

United’s SFO Proposal Will Stimulate 126% M

s SFO Proposal Will Stimulate 126% M

U.S.–Originating Passengers Than Hawaiian Originating Passengers Than Hawaiian’s H

s H

Passengers

Sources: Exhibits HA-A-604, HA-A-802. MIDT, CY2009. SFO and HNL to/from Tokyo (HND/NRT).*Stimulation rate applied as calculated by Hawaiian in Exhibit HA-A-802. 

Stimulated Passengers (U.S. Point Of Origin)

Ap

Tokyo 

Nondire

Passe

Points 

Nondire

Passe

Point 

U.S. Po

As Per

Total No

O&D P

Stimul

Stim

Passe

Point 

SFO 

Th