January 2, 2015

BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Motion and Application of

AMERICAN AIRLINES, INC.

Motion of 

HAWAIIAN AIRLINES, INC.

in the matter of 2010 U.S.-Haneda 

Combination Services Allocation Proceeding

Docket DOT-OST-2010-0018

ANSWER OF AMERICAN AIRLINES, INC.

TO PETITION FOR RECONSIDERATION

Howard Kass 

Vice President – Regulatory Affairs

Robert A. Wirick

Managing Director, Regulatory and 

International Affairs

Abigail Donovan

Director, Congressional and Federal Affairs

American Airlines, Inc.

1101 17th Street, N.W.

Washington, DC 20036

(202) 326-5153

howard.kass@aa.com

robert.wirick@aa.com

abigail.donovan@aa.com

Charles A. Hunnicutt

Patricia N. Snyder

Thompson Hine LLP

1919 M Street, NW

Suite 700

Washington, DC 20036-1600

(202) 263-4189

charles.hunnicutt@thompsonhine.com

patricia.snyder@thompsonhine.com
January 2, 2015

BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Motion and Application of

AMERICAN AIRLINES, INC.

Motion of 

HAWAIIAN AIRLINES, INC.

in the matter of 2010 U.S.-Haneda 

Combination Services Allocation Proceeding

Docket DOT-OST-2010-0018

ANSWER OF AMERICAN AIRLINES, INC.

TO PETITION FOR RECONSIDERATION

American Airlines, Inc. (“American”) fully supports the Department’s decision in 

Order 2014-12-9 to conduct a fresh examination of the best use of the U.S.-Haneda slot 

pair currently being used on a Seattle-Haneda route by Delta Air Lines (“Delta”). 

American will show in that examination that the Department should reallocate the slot 

pair to American to serve the Los Angeles-Haneda market, which has strong, unsatisfied 

demand and requires an additional market participant.

This proceeding involves the scarcest resource the Department has been forced to 

allocate in recent years. The U.S.-Japan agreement allows for only four daily slot pairs 

between the United States and Haneda, a highly desirable market. The Department, the 

public, and the airline community have a particularly acute interest in ensuring that those 

four opportunities are put to their highest and best use. As the Department recognized in 
Answer of American Airlines, Inc.

To Petition for Reconsideration

Page 2 of 15

Order 2014-12-9: “[t]he principal objective in this proceeding will be to maximize public 

benefits with this scarce resource.”1

Currently, Delta is using this scarce resource to operate 17 flights between 

October 2014 and March 2015, whereas it could have operated 182 flights during that 

time. With this degree of underuse, the Department has not just the right, but also the 

obligation, to review its decision to allocate one slot pair to Delta for use at Seattle. 

In its petition for reconsideration of Order 2014-12-9, Delta resists this review. 

Delta knows that the Department’s examination will show that it has squandered the 

valuable U.S.-Haneda slot pair, and that it has failed to provide the service on which the 

award of that slot pair was predicated.

Delta has another pressing incentive to resist this review: each day of delay 

allows Delta to continue to preclude competitive entry into the U.S.-Haneda market, 

where Delta holds two of the four valuable slot pairs. The Department should reject 

Delta’s petition and focus on the pleadings called for under the Carrier Selection Process 

of Order 2014-12-9. American will provide compelling evidence that its year-round 

daily Los Angeles-Haneda service will offer greater public benefits than Delta’s 

occasional Seattle-Haneda service.

This will be the fourth carrier-selection proceeding to allocate U.S.-Haneda slot 

pairs. Delta has competed for slot pairs in all but one. Delta has never before questioned 

the Department’s power to allocate or reallocate slot pairs. Instead, it did what it has 

 

1

 Order 2014-12-9 at 5. The Haneda slot pairs are an extremely scarce resource, in large part, because Delta 

made them so by resisting additional liberalization during the U.S.-Japan negotiations unless it could move its 

substantial Narita operations to Haneda. Its strident opposition to liberalization made an agreement impossible, thus 

preventing a liberalization of access to Haneda for U.S. airlines.
Answer of American Airlines, Inc.

To Petition for Reconsideration

Page 3 of 15

always done and what every other carrier has always done: it competed in the carrierselection proceeding.

That same process is precisely what the Department is undertaking here. No 

changes or precedent-breaking actions. Simply, the same carrier-selection process and 

long-standing evidentiary requirements, all of which are well known to Delta. As in all 

such cases, this proceeding will afford Delta three rounds of pleadings to present its case 

as to the public benefits of the Seattle-Haneda service.

Delta nevertheless objects to even the idea of reviewing the best use of the U.S.-

Haneda slot pair. Delta asserts that the Department categorically lacks authority to 

determine whether the public interest is being served; that the Department should not and 

cannot hold a carrier selection case to consider other options; and, that the Department 

has no right to reallocate the slot pair it is currently operating.

Delta’s contentions are legally incorrect, are contrary to the public interest, and 

depart from the course of conduct under which Delta has participated in other such 

proceedings. The Department should deny Delta’s Petition and develop a fresh record for 

determining which carrier will “maximize public benefits with this scarce resource.”2 

American is confident that, with a complete and current record, the Department will 

recognize that reallocation of the slot pair that Delta is currently operating is required to 

fulfill this public interest objective.

 

2 Order 2014-12-9 at 5.
Answer of American Airlines, Inc.

To Petition for Reconsideration

Page 4 of 15

1. The Department Has Inherent Power to Review Prior Decisions.

“The power to reconsider is inherent in the power to decide.”3 Delta does not 

acknowledge this obvious point, but in fact, the Department has from time to time 

exercised its lawful authority to review prior decisions. According to the U.S. Supreme 

Court in CAB v. Delta,4a case upon which Delta relies heavily, that authority applies 

even to effective, permanent certificates. There, the former Civil Aeronautics Board 

(“CAB”) had selected Delta to serve a route, but later withdrew the certificate, even 

though Delta was using the authority. The Supreme Court overturned the CAB’s action, 

but only because the CAB did not adhere to statutorily specified procedures. The Court 

repeatedly emphasized the CAB’s general authority to reconsider its prior decision, so 

long as the carrier is given notice and a hearing.

5

 The Department has done exactly that 

here, giving Delta notice of its examination and an opportunity to show why the current 

allocation of the U.S.-Haneda slot pair is in the public interest. CAB v. Delta thus fully 

supports the Department instituting this proceeding. 

Certainly, nothing in CAB v. Delta supports Delta’s contention that the 

Department cannot review the allocation merely because Delta is “in compliance with” 

 

3 Albertson v. Federal Communications Comm’n., 182 F.2d 397, 399 (D.C.Cir. 1950) (holding that the FCC 

could reconsider a prior decision, so long as it granted petitioner notice and a fair opportunity to be heard).

4

Civil Aeronautics Board v. Delta Air Lines, Inc., 367 U.S. 316 at 329 (1961) (the CAB could reconsider an 

earlier decision, but “it must proceed in the manner authorized by statute”). Hereafter, the case is referred to as “CAB 

v. Delta.”

5

See CAB v. Delta, 367 U.S. at 328 n.11 (“Congress has shown no intent to preclude reconsideration, either 

judicial or administrative, after notice and hearing”); id. at 329 (“In the first place, it bears repetition that we are not

deciding that the Board is barred from reconsidering its initial decision. All we hold is that, if the Board wishes to do 

so, it must proceed in the manner authorized by statute. Thus, for example, the Board may reconsider an effective 

certificate at any time if it affords the certificated carrier notice and hearing prior to decision . . . .”).
Answer of American Airlines, Inc.

To Petition for Reconsideration

Page 5 of 15

the dormancy condition by operating a few flights every 90 days.6 Delta’s position 

would effectively eviscerate any public interest standard so long as technical dormancy 

conditions are met, and the Department could not even consider whether the existing 

allocation remains in the public interest. Delta unsurprisingly cites no regulatory or 

judicial precedent even suggesting that a dormancy condition (or any other condition) can 

take precedence over the public interest of the United States.

Delta next claims that it should enjoy the “security of route” described by the 

Supreme Court in CAB v. Delta, no matter how poorly it uses the valuable Haneda slot 

pair.7 Delta reads the Court’s decision as extending the “security of route” to the CAB’s 

ability to withdraw the certificate in question in that case. As noted above, however, 

Delta simply misreads the case: the Court unambiguously reaffirmed the CAB’s 

authority to withdraw the certificate with notice and hearing. See supra note 5. In other 

words, even if “security of route” is relevant to the substantive question of whether a 

certificate is withdrawn, it is not remotely relevant to the procedural question of how to 

withdraw a certificate, which simply requires proper notice and fair hearing. This case, 

of course, does not even involve a certificate, but the Department is providing notice and 

hearing, which is all that matters at this stage.

Delta’s next argument is that, because the Department sometimes explicitly

reserves the right to amend, modify, or revoke a frequency/slot pair or an exemption, it 

 

6 Delta’s Petition at 2. The dormancy condition operates to withdraw slot pairs without further process, 

enabling the Department to “authorize new services quickly should those services not materialize.” Order 96-2-17 at 

13 (U.S.-Russia).

7 Delta’s Petition at 6, citing CAB v. Delta Air Lines, 367 U.S. at 324.
Answer of American Airlines, Inc.

To Petition for Reconsideration

Page 6 of 15

can only exercise that authority where it has made that express reservation. This is 

patently wrong for two reasons.

First, because the Department inherently has the power to revoke,8it is 

unnecessary to reserve that legal power explicitly. The redundant explicit language that 

the Department often uses is a belt-and-suspenders approach to remind parties that their 

authorizations are subject to revocation.

Second, the dormancy condition by its plain terms does not preclude the 

Department from reviewing the allocation to determine whether it remains in the public 

interest. In relevant part, the condition reads:

The slot pair allocation will remain in effect indefinitely . . . provided 

further that the slot pair will become dormant and will revert automatically

to the Department if it is not used for a period of 90 days (once 

inaugurated).9

That language thus simply puts Delta on notice that failure to fulfill the allocation

conditions will result in the “automatic[. . . ]” revocation without any due process 

safeguards, such as notice and an opportunity to be heard. “Automatic” means 

“beginning when specific conditions are fulfilled, without the need for a decision or 

action.”10 The Department’s use of the term “automatically” signals that the reversion 

 

8

The Department has used that power to revoke exemption authority especially where changed circumstances 

exist. See, e.g., Application of Exec Express II, Inc., Order 98-11-8 at 3 n.9 (issued Nov. 10, 1998) (unlike certificate 

authority, exemption authority may be revoked at any time without notice where circumstances warrant). See, also, 

Application of Covia Partnership For An Exemption, Order 94-8-5 at 14 (Aug. 3, 1994). There, the Department said:

[W]e may reexamine the wisdom of an exemption after we grant it. If persons affected by the exemption 

believe that experience has shown that the exemption should be revoked or modified, it is appropriate for 

them to ask us to reexamine the exemption, particularly when their request for reexamination is based on an 

unforeseen use of the exemption.

9 Order 2013-2-4 at 6, condition 3 (emphasis added).

10 Encarta Dictionary (English: North America). Accord: Merriam Webster on-line: “having a self-acting or 

self-regulating mechanism.” 
Answer of American Airlines, Inc.

To Petition for Reconsideration

Page 7 of 15

will take place without further Department action. The provision thus does nothing to 

limit the Department’s authority to take further action to enforce and promote the public 

interest, with the usual procedural safeguards.

Delta also misconstrues the term “indefinitely” as used in the same condition. In 

its view, Delta remains entitled to keep the slot pair forever, so long as it “complies with” 

the dormancy condition. But “indefinite” does not mean “forever.” Just the opposite: as 

the Department has already determined, “indefinite” in the context of frequency 

allocations (in this case, slot allocation) means that the allocation continues in effect until 

it reverts automatically or the Department takes an action to change the status of the slot 

pair.11 The term thus confirms, rather than abrogates, the Department’s inherent 

authority to take appropriate actions needed to protect the public interest.

Exercising that authority, the Department has previously reviewed exemption 

authorities, even when they were being operated, to determine whether they were in the 

public interest. In the 2007/2008 U.S.-Colombia frequency allocation proceeding, the 

Department did just that.12 Although American had allowed the frequencies to become 

dormant, it had firm plans to use the frequencies and had actually (re)started service. The 

Department nonetheless decided to reexamine the frequency allocation. Ultimately, the 

Department withdrew American’s slots and awarded them to other carriers.13

 

11 Application of American Airlines (Dallas/Ft. Worth-Buenos Aires Combination Frequencies), Order 2003-8-4 

at 6 n. 9 (stating that American’s award would be “indefinite” rather than permanent “since the authority could in fact 

be lost, whether by operation of the conditions themselves or by subsequent action of the Department”).

12 2007/2008 U.S.-Colombia Combination Frequency Allocation Proceeding, Order 2008-5-27 (2008) 

(hereafter “U.S.-Colombia).

13 Id., at 15, ordering paragraph 2 (“We reallocate seven of American’s currently allocated U.S.-Colombia 

scheduled combination frequencies as described in this order”).
Answer of American Airlines, Inc.

To Petition for Reconsideration

Page 8 of 15

Finally, Delta contends that, by imposing an express dormancy condition on the 

slot pair, the Department cannot rely on its implied right to reconsider its decision. 

According to Delta, by expressly imposing the dormancy condition as a ground for 

revocation, the Department necessarily excluded all other grounds, including the public 

interest.14 As noted above, however, the dormancy condition by its terms only specifies 

the basis for automatic revocation — it says nothing about other, non-automatic grounds 

for revocation. Further, the authority Delta cites — the D.C. Circuit’s National Mining 

decision — is irrelevant to this case. National Mining holds only that an agency could 

not rely on its general statutory authority to undermine a specific congressional directive. 

It has nothing to do with the construction of the Department’s own order specifying the 

grounds for automatic revocation, against the backdrop of its well-settled, general 

authority to revoke for public interest reasons with notice and hearing. Nothing in Order 

2013-2-4 states, or remotely suggests, the Department’s intent to abandon its statutory 

responsibility to safeguard, protect, and ensure the public interest, in favor of wooden 

adherence to a technical dormancy condition. Moreover, the more recent Order 2014-12-

9 carefully reviewed the pleadings and explained the basis for the Department’s legally 

sound decision to institute a carrier-selection proceeding.

As the Supreme Court said, reconsideration involves the balancing of two 

opposing policies: “the desirability of finality” and “the public interest in reaching . . . 

the right result.”15 In the present case, the Department has reasonably determined that 

 

14 Delta’s Petition at 4, citing National Mining Ass’n v. U.S. Dept. of Interior, 105 F.3d 691, 694 (D.C. Cir. 

1997).

15 CAB v. Delta Air Lines, Inc., 367 U.S. 316, 321 (1961).
Answer of American Airlines, Inc.

To Petition for Reconsideration

Page 9 of 15

balancing those two policies requires a review of the existing allocation. The Department 

awarded Delta this slot pair nearly two years ago, relying upon a record that closed in 

November 2012.16 Delta promised daily year-round service, but it has not delivered on 

that promise.17

The Department is correct as a matter of law and policy to re-examine market 

conditions and reconsider how the public interest is best served. Indeed, as we show 

below, not only is the Department correct, but its responsibility to safeguard the public 

interest requires this fresh examination, especially when a scarce resource is involved.

2. Delta Has Severely Cut Back Or Eliminated Its Seattle-Haneda Service and 

the Department Is Right to Hold a Carrier-Selection Proceeding.

Delta attempts to hide its squandering of the Seattle-Haneda slot pair with an 

unfounded claim that the Department cannot re-examine its own decisions unless it does 

so for all decisions in similar circumstances. Delta then asserts without explanation that 

circumstances in a 2008 U.S.-Brazil case are similar to those in this proceeding.18

Neither proposition is true. Delta cites multiple judicial decisions for the 

proposition that an agency acts arbitrarily and capriciously if it does not “treat similar 

cases in a similar manner” or if the agency reverses its position without adequately 

distinguishing the facts.19 But the whole point of the fresh examination is to assess the 

particular facts of this case. As Delta well knows, carrier-selection proceedings are 

highly fact-dependent and do not involve similar circumstances. Each proceeding 

 

16 Order 2013-2-4, issued Feb. 5, 2013.

17 See, Exhibit AA-1 of our Oct 2, 2014 Motion & Application in this docket.

18 Delta’s Petition at 4-5.

19 Delta’s Petition at 5.
Answer of American Airlines, Inc.

To Petition for Reconsideration

Page 10 of 15

reflects different bilateral regimes as well as dynamic economic circumstances. Each 

proceeding stands on its own. The Department considers numerous factors in deciding 

each case. The basic facts already established in this case illustrate the point: Delta’s 

own conduct necessitated the need to re-examine the strategically important U.S.-Haneda 

market.

Delta errs badly in analogizing this case to a 2008 case in which the Department 

had allocated 105 weekly U.S.-Brazil frequencies to various points in Brazil among four 

U.S. carriers.20 Delta does not and cannot show that the legal, political, economic, and 

even diplomatic dynamics of the U.S.-Haneda slot pair situation equate to the complex 

bilateral relationship that governs U.S.-Brazil frequencies.

Indeed, the differences between the facts surrounding Brazil and Haneda could 

not be starker. In the Brazil matter, United Airlines, Inc. (“United”) held unused, fully 

unrestricted frequencies obtained through a route transfer and had no firm plans for those 

frequencies. No other carriers expressed an interest in using those frequencies either and 

there was no reason to hold a carrier-selection proceeding. But when other carriers 

expressed interest, United did not object to reallocation and did not seek to prevent entry 

by another carrier.

21

 That situation is worlds apart from the current situation, where Delta 

is not using the frequencies effectively, yet is resisting the Department’s effort to assess 

the public interest and consider competitive options. 

 

20 Delta’s Petition at 5, citing 2008 U.S.-Brazil Combination Frequency Allocation Proceeding, Order 2008-10-

20.

21 Order 2008-10-20 at 3 (noting that United had neither answered the applications nor challenged the 

applicants’ allegations regarding its nonuse of the frequencies).
Answer of American Airlines, Inc.

To Petition for Reconsideration

Page 11 of 15

The complex Brazil frequency regime also contrasts sharply with the basic U.S.-

Japan arrangement: the U.S.-Japan bilateral in this situation gives the United States four 

daily round-trip slot pairs for one airport in Japan — Haneda. Haneda slot pairs are a 

highly valuable, highly desirable, and highly sought after scarce resource. By contrast, 

the 2008 Brazil case involved more than one hundred frequencies with different sets of 

operating rights attached to different frequencies.

Delta also complains that, because the Department took “no action for three and a 

half years” to revoke United’s Brazil frequencies, it is unfair to reallocate the underused 

slot pair Delta is using to operate Seattle-Haneda service.22 In fact, the Department is 

merely treating Delta’s effective abandonment of the slot pairs the same way it treated 

United’s unused frequencies. When American and Delta applied for the unused Brazil 

frequencies, United did not object and the Department reallocated the frequencies within 

three months.23 The Department took action as soon as other carriers applied for the 

frequencies. It is doing the same thing here. 

With respect to Haneda, the Department granted 50 percent of the slot pairs (and 

67 percent of the U.S. mainland slot pairs) to Delta. It then permitted Delta to move its 

failed Detroit-Haneda service to Seattle after a carrier-selection proceeding,24 based on 

Delta’s new “Seattle Promises.” Thus, the Department has already excused Delta once 

from an ill-advised market selection that Delta made through its “Detroit Promises,” 

which Delta also could not fulfill. Delta knows that the Department would not move the 

 

22 Delta’s Petition at 5, citing Order 2008-10-20, 2008 U.S. Brazil Combination Frequency Allocation 

Proceeding (Oct. 21, 2008).

23 Order 2008-11-21.

24 Order 2012-8-20.
Answer of American Airlines, Inc.

To Petition for Reconsideration

Page 12 of 15

authority yet again without another carrier-selection proceeding; and that such a 

proceeding would expose Delta’s failure to fulfill its “Seattle Promises” and its 

abandonment of the route for six months. Delta accordingly seeks to dispense with any 

public interest inquiry whatsoever and tries to hide behind technical dormancy rules to 

exclude any other carrier that might be able put the Haneda slot pair to far better 

competitive and public benefit use.25

3. If Delta Has Firm Plans to Fully Use the Seattle-Haneda Slot Pair, It Should 

Prove It in the Carrier Selection Proceeding.

Delta contends that the Department cannot review allocation of the U.S.-Haneda 

slot pair because Delta has “firm plans” to use the Seattle-Haneda slot pair. That 

assertion is irrelevant to its petition for reconsideration. The contention — yet another 

Seattle Promise — is premature: the place for Delta to make its case that its plans are 

firm and credible and that Delta can be relied on will be in the evidentiary phase of this 

proceeding. 

No doubt because Delta lacks confidence as to what the record will actually show 

about its “firm plans,” it insists that, by simply asserting its “firm plans,” it has insulated 

itself altogether from review of the Haneda slot pair. Putting aside the credibility of 

Delta’s “firm plans,” Delta knows that simply saying it does not make it so. Delta 

actively participated in the U.S.-Colombia case discussed above in which American not 

only had firm plans to use the frequencies, but actually started using the frequencies 

 

25 Delta points to market seasonality to explain its underutilization of the Seattle authority. Such a defense is 

not credible. Tokyo is not regarded as a seasonal market. All U.S. and Japanese airlines operating between Narita and 

the United States operate year-round service. And, tellingly, Delta’s own Seattle-Narita service operates year-round.
Answer of American Airlines, Inc.

To Petition for Reconsideration

Page 13 of 15

during the pendency of the case, and the Department nonetheless withdrew them.26 That 

case presented reconsideration issues nearly identical to those raised by Delta, and the 

Department overruled American’s objections.

Delta also claims that the Department is treating Delta differently from the 

carriers in two other U.S.-Brazil frequency cases (different from the 2008 case discussed 

above) where carriers asserted firm plans to use frequencies. Delta is wrong. The 2005 

case Delta cites actually proves the opposite point: the order actually did reallocate five 

of United’s unused frequencies to Delta, despite United’s asserted firm plans to use 

them.27 Delta says the order refused “to confiscate and reallocate to American” the five 

frequencies,28 but what matters is that the order did reallocate them—only to Delta, not 

American.

In the second case, the Department did refuse to reallocate United’s U.S.-Brazil 

frequencies where United had firm plans to use the frequencies in question.29 Delta will 

have every opportunity for yet a second time to show that it has firm plans to make 

effective use of the U.S.-Haneda slot pair at issue here.

4. Delta Wrongly Accuses the Department of Refusing to Consider Alternative 

Options. 

Delta’s final argument is that the Department refused to consider options other 

than reallocating the Haneda slot pairs. But of course alternative options are presumably 

 

26 Order 2008-5-27.

27 Delta’s Petition at 6, citing Order 2005-4-13 at 3 n.5. The footnote records that American had an application 

for five weekly frequencies pending at the time in a different docket but it was never acted on.

28 Delta’s Petition at 6 (emphasis added). In addition, the cited footnote does not seem to contain the quotation 

shown at the top of page 6, although something similar does appear in the text.

29 Order 95-3-52 at 4.
Answer of American Airlines, Inc.

To Petition for Reconsideration

Page 14 of 15

just the kind of factor the Department would consider in its review of the existing 

allocation — they are not a reason to avoid review altogether. 

Order 2014-12-9 itself makes the point clear. Delta contends that the Department 

has ignored its earlier proposal to revise the dormancy condition, which would better 

protect Delta’s “reliance interests” than reallocation of the slot pairs.30 But that order 

states clearly that the Department believes its standard conditions are sufficient, but that 

if any party holds a different view, “it will be free to argue its point on the record.”31

There is certainly no reason for the Department to revise its standard dormancy 

condition in favor of a fair review of the proceeding. The Department has had almost 

twenty years of experience with its standard dormancy condition and it has served all 

parties well, including the traveling public, carriers, and other market participants.

Conclusion

American respectfully urges the Department to deny Delta’s petition for 

reconsideration. The Department in this case is following decades of precedent and 

practice in pursuit of the public interest. The Department is acting reasonably in 

reviewing its decision of nearly two years ago, since Delta is not delivering on the 

promises it made to obtain the authority to use the scarce slot pair in the Seattle-Haneda 

market. American will provide compelling evidence that its proposed Los AngelesHaneda service will provide more U.S. consumers with a competitive service option that 

is substantially superior to Delta’s service, that American will provide greater 

 

30 Delta’s Petition at 6-7.

31 Order 2014-12-9 at 6 n. 20.
Answer of American Airlines, Inc.

To Petition for Reconsideration

Page 15 of 15

competitive benefits, and that American’s service will maximize the public benefits of 

this scarce resource.

Respectfully submitted,

Howard Kass 

Robert A. Wirick

Abigail Donovan
CERTIFICATE OF SERVICE

I, Abigail Donovan, certify that, on January 2, 2015, I caused to be served a copy 

of the foregoing Answer of American Airlines, Inc. to Petition for Reconsideration by 

email upon those addressees listed below:

paul.gretch@dot.gov(DOT)

brian.hedberg@dot.gov(DOT)

brett.kruger@dot.gov(DOT)

todd.homan@dot.gov(DOT)

peter.irvine@dot.gov(DOT)

EngleTS@state.gov(Dep’t of State)

cristinasa@state.gov(Dep’t. of State)

eugene.alford@ita.doc.gov(Dep’t. of 

Commerce)

ejames@jamhoff.com (Allied Pilots 

Association)

seth.waxman@wilmerhale.com (Delta)

sascha.vanderbellen@delta.com(Delta)

chris.walker@delta.com(Delta)

Mike.Donatelli@alpa.org(Delta 

MEC/ALPA)

john.allen@faa.gov (FAA)

jhill@cooley.com(Hawaiian)

Perkmann@cooley.com(Hawaiian)

bberlin@cooley.com(Hawaiian)

Robert.Lamansky@hawaiianair.com(Hawai

ian)

glindsey@lawa.org(Los Angeles World 

Airports)

ishiwata.k@portseattle.org(Port of Seattle)

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

dan.weiss@united.com(United)

steve.Morrissey@united.com(United)

gmurphy@crowell.com(United)

sseiden@crowell.com(United)

iinfo@airlineinfo.com (AirlineInfo.com)

_________________________________

Abigail Donovan