# 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 th is 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, 2010United Will Offer Roundtrip Online ConnectionsUnited Will Offer Roundtrip Online ConnectionsTo Haneda From 27 Airports Via San FranciscoTo Haneda From 27 Airports Via San FranciscoSources: MIDT, CY2009.U.S. to Tokyo (HND/NRT).OAG, November 2010 (as adjusted to reflect planned retiming of 6 connectionspredicated on receipt of a Haneda slot award).Each of these round-trip connections meetsthe following criteria:year-round, connectionwindow less than 4 hours, and connection flights operated by United/United Express.Docket DOT-OST-2010-0018Exhibit UA-R-1Page 1 of 1YEGLAXYVRYYJSEAPDXEUGBOIYYCSLCRNOACVRDDCICSMFSFOMODMRYFATLASSBPSBABURSNASANPHXDENORDUnited Connections To SFO-HND Will Serve 175,566 (or 31% of)U.S.-Originating Tokyo O&D PassengersUnited’s SFO-HND Service Will Offer More NonHND Service Will Offer More Non–Stop Plus SingleStop Plus Single–Connect Service To Haneda Than Any Other West Coast Gateway PropConnect Service To Haneda Than Any Other West Coast Gateway ProposalSources: 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’srelevant 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 byUnited/United Express for United, American/American Eagle for American, and Delta/Delta Connection for Delta.SFO=SFO,SJC,OAK. LAX=LAX,SNA,BUR,ONT.Docket DOT-OST-2010-0018Exhibit UA-R-2Page 1 of 1050,000100,000150,000200,000250,000SFOLAXLAXSEAConnectingLocal

Annual PassengersAnnual U.S. To Tokyo O&D Passengers (U.S. Point Of Origin)23,47751,700175,56683,68283,68283,9114,532227,266167,59388,21423,477The San FranciscoThe San Francisco–Tokyo Local Market IsMore Than Twice AsTokyo Local Market IsMore Than Twice AsLarge As SeattleLarge As Seattle–Tokyo And More Than Four Times Larger Than DetroitTokyo And More Than Four Times Larger Than Detroit–TokyoSource: MIDT, CY2009. U.S. to Tokyo (HND/NRT).SFO=SFO,SJC,OAK.51,70023,47711,950010,00020,00030,00040,00050,00060,000SFOSEADTW

Annual PassengersDocket DOT-OST-2010-0018Exhibit UA-R-3Page 1 of 1Annual U.S. To Tokyo O&D Passengers (U.S. Point Of Origin)27810051015202530SFOLAXLAXSEA

# Of Connecting AirportsDocket DOT-OST-2010-0018Exhibit UA-R-4Page 1 of 1Roundtrip Online Connecting AirportsUnited’s San Francisco Service WillOffer More Roundtrip Onlines San Francisco Service WillOffer More Roundtrip OnlineConnecting Airports To Haneda ThanAny Other West Coast GatewayConnecting Airports To Haneda ThanAny Other West Coast GatewayProposalProposalSources: 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 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.United’s SFO-HND Proposal Would Benefit More U.S.HND Proposal Would Benefit More U.S.-OriginatingOriginatingPassengers Than Any Of The Other West Coast Gateway ProposalsPassengers Than Any Of The Other West Coast Gateway ProposalsDocket DOT-OST-2010-0018Exhibit UA-R-5Page 1 of 1Sources: 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 foreach 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-HNDProposal Still Captures Nearly 30% Of U.S. – Tokyo PassengersSFO LAX LAX SEAApplicant's Priority1st2nd3rd1stConnecting Airports Claimed (U.S. Plus Int'l)27252060Minus Non Year-Round Connection Airports0(3) (1) (5)Minus Airports Claimed As One-Way Connections Only0(10) (10) (20)Minus Airports With Connection Window > 4 Hours In One Or Both Directions0(3) (8) (15)Minus Airports With Circuity >10%(8)(4)*0(2)**Minus Remaining Airports Operated By Codeshare Partners000(18)Remaining Connection Airports Operated By Applicant's Metal19510Connecting Market Demand (U.S. Point Of Origin Passengers)114,062 32,027 4,5320Local Market Demand (U.S. Point Of Origin Passengers)51,700 83,682 83,682 23,477Total Market Demand Coverage (U.S. Point Of Origin Passengers)165,762 115,709 88,214 23,477% of Total U.S. - TYO Market29% 21% 16% 4%United’s SFO-HND Proposal Would Benefit More U.S.HND Proposal Would Benefit More U.S.-OriginatingOriginatingPassengers Than The FirstPassengers Than The First-Priority Proposals Of Other ApplicantsPriority Proposals Of Other ApplicantsDocket DOT-OST-2010-0018Exhibit UA-R-6Page 1 of 1Sources: 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 foreach 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-HNDProposal Still Captures Nearly 30% Of U.S. – Tokyo PassengersSFO EWR JFK HNL SEAConnecting Airports Claimed (U.S. Plus Int'l)2774411660Minus Non Year-Round Connection Airports0 -*(8)0(5)Minus Airports Claimed As One-Way Connections Only0(27) (22)0(20)Minus Airports With Connection Window > 4 Hours In One Or Both Directions0(9) (3) (12) (15)Minus Airports With Circuity >10%(8)(7)(1)0(2)**Minus Airports Operated By Codeshare Partners0000(18)Remaining Connection Airports Operated By Applicant's Metal1931740Connecting Market Demand (U.S. Point Of Origin Passengers)114,062 63,063 20,965 2,803 0Local Market Demand (U.S. Point Of Origin Passengers)51,700 67,877 67,877 40,457 23,477Total Market Demand Coverage (U.S. Point Of Origin Passengers)165,762 130,940 88,842 43,260 23,477% of Total U.S. - TYO Market29% 23% 16% 8% 4%Delta's History Of Asia Services At Seattle Suggests ThatDelta's History Of Asia Services At Seattle Suggests ThatA SeattleA Seattle–Haneda Service Award Would Be A Poor ChoiceHaneda Service Award Would Be A Poor ChoiceDocket DOT-OST-2010-0018Exhibit UA-R-7Page 1 of 1Source: OAG, January 1994 – March 2010. Weekly frequencies to Asia (DOT WAC codesbetween 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 Discontinued3 Out Of 4 Nonstop Routes From Seattle To AsiaNRTSEAHKGKIXSELRoute DiscontinuedRoute In-ServiceService History:RouteStart Date DiscontinuedSeattle (SEA) - Seoul (SEL) Pre-1994 Mar 94Seattle (SEA) - Hong Kong (HKG)Nov 94 Aug 97Seattle (SEA) - Osaka (KIX) Feb 95 Sep 01*Seattle (SEA) - Narita (NRT) Pre-1994 -Delta's Asia Service Failures atPortland SuggestThat Seattle,Delta's Asia Service Failures atPortland SuggestThat Seattle,Another Pacific Northwest NonAnother Pacific Northwest Non-Hub, Also Would Be a Poor Choice For HND ServiceHub, Also Would Be a Poor Choice For HND ServiceDocket DOT-OST-2010-0018Exhibit UA-R-8Page 1 of 1Source: OAG, January 1994 – March 2010. Weekly frequencies to Asia (DOT WAC codesbetween 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 NonstopRoutes From Portland To AsiaNRTPDXTPENGOFUKSELRoute DiscontinuedRoute In-ServiceService History:RouteStart Date DiscontinuedPortland (PDX) - Taipei (TPE) Pre-1994 Nov 95Portland (PDX) - Seoul (SEL) Pre-1994 Jan 99Portland (PDX) - Fukuoka (FUK) Nov 98 Sep 99Portland (PDX) - Nagoya (NGO) Pre-1994 Mar 01Portland (PDX) - Narita (NRT) Pre-1994 Mar 01*6,5232,88101,0002,0003,0004,0005,0006,0007,000SFOHNLUnited’s SFO Proposal Will Stimulate 126% More News SFO Proposal Will Stimulate 126% More NewU.S.–Originating Passengers Than HawaiianOriginating Passengers Than Hawaiian’s HNL Proposals HNL Proposal

PassengersDocket DOT-OST-2010-0018Exhibit UA-R-9Page 1 of 1Sources: 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)ApplicantTokyo To/FromSan Francisco(SFO)Honolulu(HNL)Nondirectional O&DPassengers (AllPoints Of Origin)217,638 773,607Nondirectional O&DPassengers (U.S.Point Of Origin)90,596 62,635U.S. Point Of OriginAs Percentage OfTotal NondirectionalO&D Passengers42%8%Stimulation Rate*7.2% 4.6%StimulatedPassengers (U.S.Point Of Origin)6,523 2,881SFO % HigherThan HNL126%-