1

ANSWER/REBUTTAL EXHIBITS OF AMERICAN AIRLINES

2010 U.S.-HANEDA COMBINATION SERVICES ALLOCATION PROCEEDING 

(HANEDA 2014)

Docket DOT-OST-2010-0018

January 12, 2015

Tokyo Haneda

Los Angeles
January 12, 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

CONSOLIDATED ANSWER OF AMERICAN AIRLINES, INC.

TO APPLICATIONS OF

DELTA AIR LINES, INC. AND HAWAIIAN AIRLINES, INC.

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

Jason D. Tutrone

Thompson Hine LLP

1919 M Street, NW

Suite 700

Washington, DC 20036-1600

(202) 263-4189

charles.hunnicutt@thompsonhine.com

patricia.snyder@thompsonhine.com

jason.tutrone@thompsonhine.com
TABLE OF CONTENTS

I. Seattle-Haneda for Delta Has Not Worked and Delta’s Proposed Fix Is 

Not Going to Make It Work ......................................................................................2

A. Delta’s Public Interest Claims About Why It Should Retain Its Haneda 

Slot Allocation Benefit Delta’s Interests Only .....................................................6

1. Seattle Will Continue to Enjoy Twice-Daily Tokyo Service ........................6

2. Delta’s Attempts to Portray Itself As “Disadvantaged” in the U.S.-

Japan Market Are Laughable and Factually Inaccurate ................................7

II. American’s Los Angeles-Haneda Service Will Produce Public Benefits 

Superior to Hawaiian’s Kona-Haneda Service........................................................9

III. American’s Proposal Will Best Serve the Public Interest and Is 

Substantially Superior to the Other Applicants’ Proposals.................................14

IV. Conclusion.................................................................................................................17
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

CONSOLIDATED ANSWER OF AMERICAN AIRLINES, INC.

TO APPLICATIONS OF

DELTA AIR LINES, INC. AND HAWAIIAN AIRLINES, INC.

American Airlines, Inc. (“American”) hereby submits its consolidated answer to 

the applications of Delta Air Lines, Inc. (“Delta”) and Hawaiian Airlines, Inc. 

(“Hawaiian”) in the above-captioned proceeding. 

American has proposed a solid, credible Los Angeles-Haneda service that will put 

the Haneda slot pair to its highest and best use to the benefit of U.S. consumers and 

shippers by:

 benefiting more U.S. O&D passengers than other applicants;

 offering better passenger service and more cargo capacity than other 

applicants;

 addressing the unmet demand at Los Angeles, the largest U.S.-Tokyo market 

in the continental United States and the largest one in this proceeding;

 distributing the public benefits of this scarce national resource among more 

States than the other applicants; and

 promoting competition—among carriers, gateways and alliances.
Consolidated Answer of American Airlines, Inc.

To Applications of Delta and Hawaiian

Page 2 of 17

In order to achieve these benefits, American asked the Department to review 

Delta’s use of the slot pair. As American’s President Scott Kirby testified in this 

proceeding, a strong Tokyo service is a key part of American’s Asia strategy and, to 

“have a meaningful presence in Tokyo, service to Haneda is a necessity.”

1

Part I of this answer addresses Delta’s application, Part II addresses Hawaiian’s 

application, and Part III explains why American’s proposal is substantially superior.

I. Seattle-Haneda for Delta Has Not Worked and Delta’s Proposed Fix Is Not 

Going to Make It Work

As an initial matter, American recognizes that Seattle is a dynamic city with a 

strong airline market. Indeed, American operates 30 daily flights at Seattle and in the 

past has operated service between Tokyo and Seattle. However, it is clear that, for 

whatever reason, the Seattle market is not responding well to Delta’s Seattle-Haneda 

service. As we show below, the reasons Delta attributes for the route’s poor performance 

do not withstand even cursory scrutiny. 

In normal market conditions, there would be no reason for Department 

involvement. Delta would be free to take market risk and support the service for as long 

as it wanted. However, Haneda is not at this time an open market. Flight and slot 

availability is extremely limited, with only four daily flights available for U.S. carriers

within certain limited curfew hours. As long as Haneda remains restricted, the public 

interest requires that this scarce national resource be fully used and that the Haneda slot 

 

1 American Application Ex. AA-T-1 at 2. The company is entirely committed to 

making this Haneda service work for the benefit of U.S. consumers.
Consolidated Answer of American Airlines, Inc.

To Applications of Delta and Hawaiian

Page 3 of 17

pair be allocated to the highest and best use. That highest and best use in this case is 

American’s Los Angeles-Haneda service.

Delta’s (re)application2requests that the Department affirm its 2012 allocation of 

Haneda slots to Delta to operate Seattle-Haneda service, an allocation premised on 

Delta’s commitment to operate that service daily, year-round. Delta now (again) 

promises to operate Seattle-Haneda on a daily, year-round basis. The Department is left

to assess the veracity of a carrier that has failed to honor its many commitments. Delta’s 

statements are the same statements it previously made in seeking a Haneda allocation for 

Detroit and again when Delta asked to move the Detroit service to Seattle.3 For this 

reason, Delta’s commitment to provide daily year-round service is no more ironclad than 

its previous daily year-round service commitments for this slot pair, which it has 

repeatedly broken.

Even Delta seems to agree that its Seattle-Haneda service has not performed well. 

Delta says as much by describing the primary problem (in its view) and the proposed 

solutions (again, in its view) for improving its service. Delta’s position can be reduced to 

three points:

1) We need our own aircraft (“metal”) because the incentives of Alaska Airlines, 

Inc. (“Alaska”) as a domestic competitor are not aligned with Delta’s;

2) As we have added our own metal, we have had “astounding” results; and

 

2 Delta’s Petition for Reconsideration should be promptly denied. The 

Department’s Instituting Order is lawful as demonstrated by the January 2, 2015, 

Answers of American and Hawaiian. 

3 Answer Ex. AA-R-101.
Consolidated Answer of American Airlines, Inc.

To Applications of Delta and Hawaiian

Page 4 of 17

3) Seattle-Haneda will work now that we have our own metal.4

Upon examination of the facts, Delta’s excuses and solutions simply fall flat. As 

noted above, Seattle is a great community with much to offer. Yet, Delta squarely points 

the finger of blame to Seattle’s hometown carrier, Alaska, for the Haneda service’s poor 

performance. As is well known, Alaska is widely regarded as a first-rate airline with 

first-rate service. It code shares with many airlines, both domestic and international

carriers, none of which have complained as Delta has done here. Indeed, American, also 

a substantial code-share partner of Alaska, has had and continues to have a great 

experience working with Alaska. American has experienced none of the alleged Alaska 

failings about which Delta now complains. 

Even if Alaska were the problem, and it most certainly is not, Delta’s complaints 

about Alaska obfuscates the real issues. Of the 61 markets that Delta claims it will 

connect to its “New Own-Metal Enhanced Seattle-Haneda Service,” 41 of those 

markets—or slightly more than two-thirds—have had and will continue to have 

“supplemental codeshare service on Alaska Airlines.”5 Of the remaining 20 markets, not 

counting existing Delta hubs, all of those markets except for Jackson Hole, Wyoming,

overlap with Alaska.6 

Contrary to Delta’s argument that it needs its own aircraft to mount a successful 

Seattle-Haneda service is the unassailable fact that Delta, today, successfully operates 

 

4 Delta Application 2-3.

5 Delta Application 5, Ex. DL-401

6 Answer Ex. AA-R-102.
Consolidated Answer of American Airlines, Inc.

To Applications of Delta and Hawaiian

Page 5 of 17

transpacific services between Seattle and Beijing, Hong Kong, Seoul, Shanghai, and 

Tokyo-Narita (in addition to transatlantic services to Amsterdam, London, and Paris).

7

 

The build-up of these Asian services, which began decades ago, were successful before 

Delta’s introduction of new own-metal domestic services, and all of these services 

operate year-round with exceedingly high load factors. Thus, even without a build-up of 

own-metal domestic services, Delta has experienced excellent results between Seattle and

the other Asia markets, including of course, exceptional results between Seattle and 

Tokyo-Narita.

Notwithstanding Delta’s assertion, the problem is not Seattle as a hub, or which 

carrier’s metal operates the connecting service to/from Seattle. And, the problem cannot 

be explained away as a Haneda problem, because all other current U.S. services to 

Haneda, including Delta’s Los Angeles-Haneda service, have performed with strong load 

factors year-round.8 The problem is indeed limited to one and only one route—SeattleHaneda.9

 In short, for whatever reason, the empirical evidence compels a finding that the 

Seattle market has not responded well to nonstop Haneda service.10 

 

7 Answer Ex. AA-R-105.

8 Answer Exs. AA-R-103 to -104.

9 Answer Ex. AA-R-108, -126.

10 Answer Ex. AA-R-107.
Consolidated Answer of American Airlines, Inc.

To Applications of Delta and Hawaiian

Page 6 of 17

Unfortunately, Delta’s proposed solutions are the wrong solutions for the wrong 

problem. As American’s Answer exhibits demonstrate, Delta’s proposed fixes will not 

and cannot fix the unique problems it has with Seattle-Haneda service.

11

 

A. Delta’s Public Interest Claims About Why It Should Retain Its 

Haneda Slot Allocation Benefit Delta’s Interests Only

Delta’s other arguments about why it should retain the Seattle-Haneda service 

should be no more appealing to the Department. 

1. Seattle Will Continue to Enjoy Twice-Daily Tokyo Service

There is no disputing Seattle’s geographic location as a well-positioned gateway 

to Asia. One need only look to Delta’s own success in developing several Asia routes. 

However, as noted earlier, Haneda is one of the most restrictive airports in Asia and one 

where the Department is forced to allocate U.S.-carrier access to maximize the public 

benefits. The Department should not experiment again based on promises from a carrier 

(for a third time) about a gateway (for a second time). It is a difficult decision, 

admittedly, but the Department should take heart that, even if the slot pair currently used 

for Seattle-Haneda service is reallocated, Seattle will still retain competitive Tokyo 

service with two daily nonstops to Narita on All Nippon Airways Co., Ltd. (“ANA”) and 

Delta.12 In fact, Seattle will still be one of only six continental U.S. gateways with twocarrier service to Tokyo—a benefit that super hubs like Atlanta, Dallas/Fort Worth, 

Detroit, and Houston do not enjoy.

 

11 Answer Exs. AA-R-107 to -108, -126.

12 Answer Exs. AA-R-124 to -125.
Consolidated Answer of American Airlines, Inc.

To Applications of Delta and Hawaiian

Page 7 of 17

2. Delta’s Attempts to Portray Itself As “Disadvantaged” in the 

U.S.-Japan Market Are Laughable and Factually Inaccurate

Since 2010, when U.S. carrier access to Haneda first became available, Delta has 

complained in the Haneda carrier-selection cases, at the bilateral negotiation table, and to 

Congress about its disadvantaged position relative to the immunized alliances of 

American and Japan Airlines Co. Ltd. (“JAL”), on the one hand, and United Airlines, Inc.

(“United”) and ANA, on the other.

13

 Delta makes this argument by explaining that,

because of the metal-neutrality provisions in those alliance agreements,14 the partner 

airlines should be viewed as one airline vis-à-vis Delta. 

Delta, with its own long history of immunized alliances, is correct that metalneutrality does benefit both consumers and airlines. However, the economic indifference 

created by the metal-neutrality clause does not and cannot account for passenger 

preferences. In many parts of the world where culture, customs, and interpersonal actions 

are very different from culture, customs, and interpersonal actions in the United States, 

passengers from one culture simply feel more comfortable traveling on airlines operated 

by companies that share their culture and customs. Metal neutrality, however 

economically beneficial it may be, simply cannot overcome that social/cultural

preference. That is why, in any antitrust-immunized alliance, airlines from both cultures 

operate flights. And, while not every airline has a partner in every country (e.g., 

 

13 Answer Exs. AA-R-112 to -113.

14 The metal-neutrality provisions create an economic indifference between the 

airlines as to whose metal operates the route because of revenue-sharing agreements. 
Consolidated Answer of American Airlines, Inc.

To Applications of Delta and Hawaiian

Page 8 of 17

American in China, Delta in Japan, United in Australia), where there are two partners, 

both airlines usually operate between the two countries, wherever possible.

Delta knows this very well. In its purchase of 49 percent of Virgin Atlantic 

Airways Ltd. (“Virgin”) and its commercial tie-up (including an antitrust immunized 

relationship resulting in a route swap), Virgin’s CEO recently made clear that the DeltaVirgin Atlantic joint venture benefits from both airlines flying the same route, 

irrespective of metal-neutrality, because of the passenger preference:

There are people who prefer the Virgin Atlantic airplane. 

Having a Virgin Atlantic airplane in the mix to Atlanta will 

help us sell Heathrow to . . . all the various places you go to 

via Atlanta . . . .

It's a lot of new markets that we think having a mix of 

Delta airplanes and Virgin Atlantic airplanes will do better 

than just having all Delta. . . . This combination of offering 

mixed metal in these different markets gives customers the 

ability to choose if they have a preference.15

Thus, Delta’s insistence that American is already in Haneda by virtue of its 

relationship with JAL is not true. Just as Virgin was not operating in the Atlanta or 

Detroit markets before adding the service, American cannot be said to be in Haneda if it 

is not an operating carrier at Haneda, and its absence deprives consumers of a real and 

beneficial travel option.

 

15 Interview: Virgin Atlantic CEO Craig Kreeger and Founder Richard Branson, 

Bus. Travel News, Nov. 11, 2014, http://tinyurl.com/ktk3uyv. See also Dennis Schall, 

Interview: Virgin Atlantic CEO on Going All-In with Delta and the Dreamliner, Skift, 

Oct. 28, 2014, http://tinyurl.com/q7fk25r.
Consolidated Answer of American Airlines, Inc.

To Applications of Delta and Hawaiian

Page 9 of 17

II. American’s Los Angeles-Haneda Service Will Produce Public Benefits 

Superior to Hawaiian’s Kona-Haneda Service

American acknowledges that Hawaiian has done an excellent job of delivering on 

its Honolulu-Haneda commitment.16 The Honolulu-Haneda service has performed as 

promised by Hawaiian, and Hawaiian and its employees should be proud of the route’s 

success. However, Hawaiian’s success in one already-proven market does not translate 

automatically into success in an unproven market—in this case, Kona-Haneda. As the 

Department states in its Instituting Order:

[C]onsideration will be given to the proposal most likely to 

result in service that best meets the needs of the traveling 

and shipping public. The Department will also consider the 

effects of each service proposal on the overall competitive 

environment, including effects on the market structure and 

on competition in the U.S.-Japan market.17

In this case, Kona is simply too small and the public benefits too limited, both in size and 

scope, for the Department to select a Kona-Haneda service over American’s Los 

Angeles-Haneda proposal.18

The beneficiaries of the proposed Hawaiian Kona-Haneda service would be 

almost exclusively Japanese tourists—96 percent according to Hawaiian’s own 

estimate.19 The number of passengers originating travel in Kona is projected to be fewer 

 

16 Answer Ex. AA-R-202.

17 2010 U.S.-Haneda Allocation Services Proceeding, Docket DOT-OST-2010-

0018, Order 2014-12-9 at 6.

18 Answer Exs. AA-R-203 to -205.

19 Answer Exs. AA-R-206 to -207.
Consolidated Answer of American Airlines, Inc.

To Applications of Delta and Hawaiian

Page 10 of 17

than nine per day each way.20 As a result, Japanese travelers, not U.S. travelers, will be 

the overwhelming beneficiaries of any Hawaiian Haneda service to Kona.

Moreover, all of the public benefits of a Hawaiian Kona-Haneda service would 

accrue exclusively to the State of Hawaii, which already enjoys three of the eight 

frequencies available for U.S.-Haneda service. When compared with American’s 

proposed Los Angeles-Haneda service, the level of public benefits offered by Hawaiian’s 

proposed Kona-Haneda service is clearly inferior: 

Comparison of Key Public-Benefit Criteria between American and Hawaiian21

Public Benefit Criteria Hawaiian American

Population of Gateway 

Airport CSA 185,079 18,351,929

Number of U.S. 

Communities Served 2

23 Winter;

30 Summer

Communities’ Population 1.4 million 194.6 million

Communities’ Tokyo O&D

(HND & NRT) 57,301 432,525

Number of States Served 1 Summer; 

1 Winter

15 Summer; 

16 Winter

States’ Population 1.4 million (HI) 38.8 million (CA)

 

20 Answer Ex. AA-R-206.

21 Answer Exs. AA-R-201, -203 to -205; Hawaiian Application Ex. HA-App2015-3; 

MIDT YE Nov. 2014; U.S. Census.
Consolidated Answer of American Airlines, Inc.

To Applications of Delta and Hawaiian

Page 11 of 17

As for local tourism, Hawaiian acknowledges that Los Angeles also attracts a very large 

number of Japanese tourists,22 with nearly 300,000 Japanese visitors in 2013.23 But, in 

addition to inbound tourism, Los Angeles is a leading global city for business and 

commerce with hundreds of Japanese firms located in Los Angeles and throughout 

Southern California. Kona simply cannot meet the level of public benefits that an 

additional Los Angeles-Haneda service brings to the U.S.-Haneda market. 

It should also be noted that the Kona-Tokyo market has had service before. JAL 

started the service in 1996—but never daily as Hawaiian proposed. After 14 years,

numerous attempts to make this service work, an average load factor of only 61.7 

percent, and load factors as low as the mid-30s, JAL finally gave up in October 2010.

24

If a Japanese airline with close connections to the Japanese tour operators in a market that 

is 96 percent Japanese-originating cannot make it, one questions how Hawaiian 

realistically could.

In addition, in many ways, those 14 years were the good (or best) years for 

Japanese tourists because of the high value and purchasing power of the yen versus the 

U.S. Dollar. But, times have changed and so has the yen-dollar exchange rate. For years, 

the yen had incredible purchasing power vis-à-vis the dollar. In 2013, however, the yen 

fell relative to the dollar, and this was reflected in spending by Japanese visitors to 

 

22 See Hawaiian Application 3 n.4.

23 Los Angeles Tourism & Convention Bd., Los Angeles Tourism by Numbers: 

2013 Quick Facts 3 (Aug. 2014), http://www.discoverlosangeles.com/tourism/research.

24 Answer Ex. AA-R-208. JAL intermittently substituted its low-cost subsidiary, 

JALways in this service.
Consolidated Answer of American Airlines, Inc.

To Applications of Delta and Hawaiian

Page 12 of 17

Hawaii, which decreased by over 11 percent from 2012 to 2013.25 Then, just last year, 

the dollar appreciated almost another 15 percent versus the yen.26 This trend is likely to 

continue as Japanese economic growth remains sluggish and the dollar continues to 

appreciate, driving the yen to lows versus the dollar not seen in over ten years.

27

 This 

will, in turn, affect both Japanese travel and spending habits.

While Kona is a scenic, beautiful place to visit, it does not offer all the amenities 

of Honolulu, which has a much broader selection of activities important to Japanese 

visitors, including shopping, dining, and resorts. Japanese travelers might want to spend 

part of their vacation time in Kona, but it is likely that such a visit would involve a short 

time in Kona as an add-on, island hop to a Honolulu “base.” In fact, the average 

Japanese visitor stay in Hawaii is 5.94 nights and, in Honolulu, is 5.49 nights, while Kona 

is considerably less, at 3.85 nights.28 In short, Kona may be part of a Japanese visitor’s 

Hawaiian Islands itinerary, but it is not likely to be their gateway to Hawaii, or the 

destination. Moreover, given limited convenient intra-island airlinks from Kona (to just 

two markets), for most visitors, Honolulu is a far better gateway to see all of Hawaii than 

Kona. 

 

25 Hawaiian Tourism Auth., 2013 Annual Visitor Research Report 43 tbl. 20, 

http://tinyurl.com/kmcjheu (last visited Jan. 12, 2015).

26 Federal Reserve System, Historical Rates for the Japanese Yen; Foreign 

Exchange Rates-H.10, http://www.federalreserve.gov/releases/h10/hist/dat00_ja.htm (last 

visited Jan. 11, 2015).

27 Trading Economics, Japanese Yen: 1972-2015, 

http://www.tradingeconomics.com/japan/currency (last visited Jan. 11, 2015).

28 Hawaiian Tourism Auth., 2013 Annual Visitor Research Report 43 tbl. 20, 

http://tinyurl.com/kmcjheu.
Consolidated Answer of American Airlines, Inc.

To Applications of Delta and Hawaiian

Page 13 of 17

Finally, Hawaiian has not addressed an important challenge that threatens to delay 

start-up for many months:29 the lack of a U.S. Customs and Border Protection (“CBP”) 

Federal Inspection Services (“FIS”) facility at Kona. Kona lost all international 

commercial air service more than five years ago with the 2010 exit of JALways from the 

Kona-Japan market. Today, CBP does not support commercial air service at the 

airport—not even for big charters—except private flights that presumably pay for the 

service on an ad hoc basis. 

Before it could start Kona-Haneda service, Hawaiian would therefore have to 

work with U.S. authorities to develop the necessary facilities, services, and staffing. CBP 

has told Hawaiian and the State and County of Hawaii that it needs to build a new FIS 

facility before it can operate international service. The State and County have asked CBP 

for a five-year exemption from this requirement, but so far, to our knowledge, this 

request has been rejected.30 Hawaiian cannot, of course, operate a Kona-Haneda service 

without CBP/FIS facilities.

 

29 For the purpose of this paragraph, American assumes Hawaiian would be 

prepared to start up earlier than its reservation-of-rights declaration to postpone a start-up 

until the judicial resolution of any court challenge to the Department’s decision. See

Answer Ex. AA-R-210.

30 Answer Ex. AA-R-211. The requests of the State and County of Hawaii to CBP 

and the responses thus far from CBP are not readily available. It would behoove 

Hawaiian, which surely knows the status of these requests, to inform the Department and 

the applicants in this proceeding of the current status.
Consolidated Answer of American Airlines, Inc.

To Applications of Delta and Hawaiian

Page 14 of 17

III. American’s Proposal Will Best Serve the Public Interest and Is Substantially 

Superior to the Other Applicants’ Proposals

Throughout this proceeding, which began in 2010, the Department has placed a 

high priority on using the four slot pairs to improve the competitive structure in the U.S.-

Haneda market, and also in the U.S.-Japan and U.S.-Asia markets.31 In 2010, the 

Department also placed great weight on achieving a geographic distribution of services, 

although time and experience have shown that geographic distribution may not be easily

achieved beyond U.S. west coast gateways in light of the curfews in existence at Haneda. 

Adding American to the U.S.-Haneda market is the best way to achieve the goals 

of enhancing competition and making sure that the rest of the country has access to 

Haneda. American is the largest carrier at Los Angeles. Its network will enable it to 

compete very effectively with Delta at Los Angeles as well as with United at San 

Francisco. It would also improve head-to-head competition with the Star and SkyTeam 

alliances both by increasing the intra- and inter-gateway competition among the alliances 

in the U.S.-Haneda market, and by increasing the overall level of competition in U.S.-

Japan and U.S.-Asia markets.32 Moreover, by offering greater capacity than Delta can, it 

would enable the Department to address the unmet demand for U.S.-Haneda access that 

exists in both passenger and cargo services.33

 

31 2010 U.S.-Haneda Allocation Services Proceeding, Docket DOT-OST-2010-

0018, Order 2014-4-6 at 3; Id. Order 2010-7-2 at 5-8; Id. Order 2010-5-7 at 8-11; Id. 

Order 2010-1-17 at 2.

32 Answer Ex. AA-R-209 (showing competition benefits).

33 American Application Exs. AA-209 to -211.
Consolidated Answer of American Airlines, Inc.

To Applications of Delta and Hawaiian

Page 15 of 17

American’s exhibits demonstrate that its proposed Los Angeles-Haneda service 

would offer a large and broad range of service benefits to U.S. passengers and shippers as 

well as economic benefits to all regions of the United States—benefits substantially 

superior to those that Hawaiian and Delta propose. Among these benefits, which 

American fully describes in its exhibits, are:

 American will serve the largest U.S.-Tokyo market in the continental United 

States, Los Angeles.34 

 American will serve not just the 18.3 million people living in the Greater Los 

Angeles Metropolitan Area,

35 but it will also offer convenient one-stop 

connecting services to millions more people in 25 cities through its west coast 

gateway, Los Angeles, in the summer season, and 32 cities in the winter 

season.

36

 American’s Los Angeles-Haneda service would directly benefit travelers and 

shippers in 16 states.37

 American’s Los Angeles-Haneda service will serve almost 10 times as many 

unique connecting markets as Hawaiian’s proposed Kona-Haneda service and 

more than Delta’s.

38

 Its Los Angeles-Haneda connecting markets will 

 

34 Answer Ex. AA-R-118 to -123; American Application Exs. AA-201 to -202.

35 Answer Ex. AA-R-120.

36 American Application Ex. AA-107.

37 Answer Ex. AA-R-203.

38 Answer Ex. AA-R-203.
Consolidated Answer of American Airlines, Inc.

To Applications of Delta and Hawaiian

Page 16 of 17

generate 87 percent more O&D passengers than Hawaiian’s Kona connecting 

markets.

39

 American’s proposed B777 Los Angeles-Haneda service will provide 37 more 

seats per flight than Delta’s B767 service.

40

 American’s Los Angeles-Haneda service will provide unquestionably superior 

cargo capacity to Delta’s B767 service—over 18.1 metric tons per flight 

versus Delta’s 9.5 metric tons—translating into more than 3.1 million pounds 

of cargo capacity annually.41

 American’s proposed Los Angeles-Haneda service will provide intergateway, 

intragateway, and first-time three-way alliance competition:

o intergateway with United at San Francisco;

o intragateway with Delta at Los Angeles;

o three-way alliance competition with Star (ANA) and SkyTeam (Delta) at 

Los Angeles.

 Finally, American is the only U.S. airline serving Tokyo that is not currently 

authorized to serve Haneda. Allocating this Haneda slot pair to American will 

inject robust, vigorous competition, itself a consumer benefit, but also open an 

entirely new array of travel options for consumers and shippers—an 

undeniable substantial public benefit. As the Department noted in 2010, 

 

39 Answer Ex. AA-R-205.

40 Answer Ex. AA-R-109 to -111; American Application Ex. AA-213; Delta 

Application Ex. DL-103.

41 (365 days)*(18.1mt – 9.5mt)=3,146.3mt.
Consolidated Answer of American Airlines, Inc.

To Applications of Delta and Hawaiian

Page 17 of 17

awarding American U.S.-Haneda service will “enhance alliance competition 

by improving the competitive posture of American and oneworld in the U.S.-

Asia market as compared to the SkyTeam and Star alliances.”42

IV. Conclusion

For the foregoing reasons, the Department should reject the Delta and Hawaiian 

requests for allocation of the Haneda slot pair and select the substantially superior 

American proposal.

Respectfully submitted,

Howard Kass 

Robert A. Wirick

Abigail Donovan

 

42 2010 U.S.-Haneda Allocation Services Proceeding, Docket DOT-OST-2010-

0018, Order 2010-5-7 at 11.
CERTIFICATE OF SERVICE

I, Abigail Donovan, certify that, on January 12, 2015, I caused to be served a copy 

of the foregoing Answer of American Airlines, Inc. to Applications of Delta Air Lines, 

Inc. and Hawaiian Airlines, Inc. 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 (Hawaiian)

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)

info@airlineinfo.com (AirlineInfo.com)

_________________________________

Abigail Donovan
2

#LetAAFlyHaneda

Exhibit 

Number Title

Answer/Rebuttal Exhibits to Delta’s Seattle-Haneda Service

AA-R-100 Narrative to 100 Series Exhibits

AA-R-101 Delta Has Repeatedly Made Promises to the Department and to the Public and Has Repeatedly Failed to 

Deliver on Those Promises

AA-R-102 Delta’s Alleged Service Build-Up at Seattle Is Not a Build-Up of New Services, But, Rather, a Duplication and 

Almost Total Overlap of Pre-Existing Alaska Services on Which Delta Code-Shared

AA-R-103 Despite Delta’s Build-Up of Its Own Seattle Hub, Which Added Only One New Service (Jackson Hole), Its 

Seattle-Haneda Load Factor (When it Operates) Is the Lowest of Any U.S. Carrier Serving Haneda

AA-R-104 Despite Delta’s Build-Up of Its Own Seattle Hub, Which Added Only One New Service (Jackson Hole), Its 

Seattle-Haneda Load Factor (When it Operates) Is the Lowest of Any Carrier Serving Haneda

AA-R-105 The Load Factors of All of Delta’s Other Long Haul International Services at Seattle Are Substantially Higher 

than Its Seattle-Haneda Route . . .without Delta’s Own Service Build-Up Benefit . . . And Tokyo-Narita Has the 

Highest Load Factor

AA-R-106 If Delta’s Build-Up at Seattle Were as Successful as It Claims, Why Did Delta Abandon the Seattle-Haneda 

Market Starting This Winter When Its Seattle Hub Was Increasing by 50%?

AA-R-107 For Whatever Reason, Seattle Has Demonstrably Not Responded Well to Delta’s Haneda Service

AA-R-108 . . . And Delta’s Seattle-Haneda Load Factor Is the Lowest, By Far, of All of the International Routes Delta 

Operates (excluding Transborder) and 20% Lower Than the Load Factor of the Next Lowest Route’s Load 

Factor

Answer/Rebuttal Exhibits of American Airlines

DOT Docket OST-2010-0018

Table of Contents

Page 1 of 4
3

#LetAAFlyHaneda

Exhibit 

Number Title

AA-R-109 Delta’s B767 Aircraft Are the Smallest of Any Airline Operating U.S.-Haneda Service

AA-R-110 In Terms of Seats Offered, Delta’s B767 Does Not Maximize the Public Benefit – American’s B777 Would

AA-R-111 American’s B777 Aircraft Would Provide the Equivalent of 125 Additional Delta B767 Flights Annually

AA-R-112 Delta’s Strained Attempt to Portray Itself as Disadvantaged in Japan Is Ironic and Fanciful

AA-R-113 Delta’s Strained Attempt to Sell Itself as Disadvantaged in Japan vis-à-vis American Is Fanciful – If Anything It 

is American That is Disadvantaged

AA-R-114 Delta’s Strained Attempt to Portray Itself as Disadvantaged in Japan vis-à-via the oneworld Alliance Is Ironic 

and Fanciful

AA-R-115 Delta’s Reliance on Overall Haneda Slot Pair Holdings Ignores the Facts

AA-R-116 “Disadvantaged Delta” Is Not “Locked Out” of Haneda. To the Contrary, It Has Had the Opportunity to Utilize 

Two Haneda Slot Pairs at, Now, Three Gateways – Triple the Opportunities Made Available to Any Other U.S. 

Airline

AA-R-117 “Disadvantaged Delta” Suffers No Disadvantage at Haneda Versus Other U.S. Airlines. Indeed, It Is American 

Which Is Both Disadvantaged and Locked Out

AA-R-118 Los Angeles Has Over 3.2 Times the GDP of the Seattle Area

AA-R-119 Los Angeles Outranks Seattle by a Wide Margin on the Critical Factors for Air Service Success

Answer/Rebuttal Exhibits of American Airlines

DOT Docket OST-2010-0018

Table of Contents

Page 2 of 4
4

#LetAAFlyHaneda

Exhibit 

Number Title

AA-R-120 Los Angeles Has Over Four Times the Population of the Seattle Area

AA-R-121 California Has 5.5 Times the Population of Washington State

AA-R-122 Los Angeles Has Nearly Four Times the Japanese-American Population of Seattle

AA-R-123 California Has Over Seven Times the Japanese-American Population of Washington

AA-R-124 Even Without Haneda Service, Seattle Is Over-Served Relative to Los Angeles, Even With American’s Los 

Angeles-Haneda Service

AA-R-125 Seattle Enjoys, and Will Continue to Enjoy, Double Daily Service to Tokyo

AA-R-126 Why Is Delta Consistently Holding on to This Haneda Slot Pair When Delta Has Cancelled Routes with 

Substantially Higher Load Factors?

Answer/Rebuttal Exhibits to Hawaiian Airlines’ Proposed Kona-Haneda Service

AA-R-200 Narrative to 200 Series Exhibits

AA-R-201 American’s Proposed Los Angeles-Haneda Service Offers Substantially Superior Public Benefits to Hawaiian’s 

Proposed Kona-Haneda Service

AA-R-202 Hawaiian Has Done a Commendable Job of Fully Utilizing Its Allocated Haneda Slot Pair

AA-R-203 Hawaiian’s Proposed Kona Service Benefits Only One U.S. State and 2 U.S. Communities; American’s 

Proposed LAX Service Benefits 15 States and 23 U.S. Communities in the Summer and 16 States and 30 

Communities in the Winter

AA-R-204 The Public Benefits Substantially Favor American’s 15/16 States Over Hawaiian’s One State

AA-R-205 American’s Proposed Los Angeles-Haneda Service Will Benefit Almost Double the O&D Passengers of 

Hawaiian’s Proposed Kona-Haneda Service

Answer/Rebuttal Exhibits of American Airlines

DOT Docket OST-2010-0018

Table of Contents

Page 3 of 4
5

#LetAAFlyHaneda

Exhibit 

Number Title

AA-R-206 Kona Is Almost Exclusively an All-Japanese Originating Market Benefitting Less Than 9 U.S. PDEWS

AA-R-207 Hawaiian’s Proposed Kona-HND Service Provides Practically No Benefits to the U.S. Traveling Public

AA-R-208 Nonstop Kona-Tokyo Service Has Been Tried Before... and Failed

AA-R-209 American’s Los Angeles-Haneda Service Provides Substantially More Competition Benefits Than Hawaiian’s 

Kona-Haneda Service

AA-R-210 Hawaiian’s Soft and Changing Start-Up Date Commitment Could, Literally, Be Years Away

AA-R-211 Kona: A No Fly Zone

Letters of Support

Answer/Rebuttal Exhibits of American Airlines

DOT Docket OST-2010-0018

Table of Contents

Page 4 of 4
6

Answer/Rebuttal Exhibits to 

Delta’s Seattle-Haneda Service
NARRATIVE TO SERIES 100 REBUTTAL EXHIBITS

Delta’s application in this proceeding is initially focused on its presumptive legal challenge to the Department’s perfectly 

lawful decision to review the highest and best use of the unused/underutilized slot pair currently allocated to Delta for Seattle-Haneda. 

American’s full support of the Department’s legal position can be found in American’s January 2, 2015 filing in this Docket. 

With respect to Delta’s arguments concerning the substance and merits of the issues involved in this proceeding, it is clear that 

Delta’s most current application for Seattle-Haneda service is a far cry from the substantial effort that Delta undertook to, first, receive 

its initial Detroit-Haneda allocation or even its efforts to persuade the Department to allow it to shift its unsuccessful Detroit service to 

Seattle. Based on the application effort alone, one can fairly ask: “Is Delta really committed to making Seattle-Haneda work for the 

long-term?”

American’s 100 Series Rebuttal Exhibits focus on the inconsistencies and inaccuracies in Delta’s (re)application for SeattleHaneda service. From a questionable service commitment to Seattle, to low historical load factors on the Seattle-Haneda route, to the 

smallest aircraft operating in the U.S.-Haneda market, Delta’s application pales in comparison to the application of American for Los 

Angeles-Haneda service.

Starting with AA-R-101, American reviews the seven promises that Delta has made to the Department in past Haneda cases. 

As the Department is aware, this proceeding arose in part, because of Delta’s virtual cessation of service between Seattle and Haneda 

during winter 2014-15. In fact, since this Proceeding began on December 15 through the final submissions on January 20, Delta will 

not have operated a single Seattle-Haneda flight (and that will continue through February 13, by which time, hopefully, a decision in 

this case will be rendered). 
In its application, Delta points to the lack of Delta’s own aircraft in markets behind/beyond Seattle as a reason the SeattleHaneda service has performed so poorly. However, Exhibit AA-R-102 shows that, with one small exception (involving a market with 

less than one PPDEW), almost all of the markets where Delta is adding its own aircraft are markets where Delta had an existing (and 

longstanding) codeshare relationships with Alaska, Seattle’s hometown carrier. Yet, despite Delta’s build-up of its own services,

which Delta labels as “astonishing,” Exhibit AA-R-103 illustrates how Delta’s Seattle-Haneda service, when it does operate, has the 

lowest load factor of any U.S. carrier’s Haneda service for which data is available. Looking at the load factors of all U.S.-Haneda 

services, Exhibit AA-R-104 demonstrates that Delta’s Seattle-Haneda load factor is over 22 load factor points below the service with 

the next lowest load factor.

Notwithstanding, Delta’s half-hearted assertion that its Seattle-Haneda service is harmed by its reliance on Alaska service for 

traffic flows, Delta’s other international services at Seattle which rely upon those same Alaska traffic flows are quite successful, with 

load factors averaging between 78 and 88 percent on a year-round basis. Most telling is Exhibit AA-R-105 that shows that the Seattle 

Asian route with the highest load factor is Tokyo-Narita, again without the benefit (or need) of Delta’s own metal.

Exhibits AA-R-106-108 demonstrate that:

 despite Delta adding more of its own domestic feed aircraft to Seattle (overlapping with Alaska); 

 despite Delta having abundant feed from Alaska; 

 despite overall Seattle-Tokyo traffic increasing; 

 despite stable U.S.-Haneda traffic ; and,

 despite Delta’s troubles with the Seattle-Haneda route,

all of its other Seattle-Asia routes have performed exceeding well.
Delta’s Seattle-Haneda service not only experiences the lowest load factor of all of Seattle’s Asia routes and of all the U.S.-

Haneda routes, but, as Exhibit AA-R-108 so graphically shows as you unfold it, Seattle-Haneda has the lowest load factor of all of 

Delta’s current intercontinental flights.

Exhibits AA-R-109-111 focus on Delta’s aircraft proposal – B767 – which is the smallest aircraft proposed in this case and one 

of the smallest aircraft in Delta’s fleet that can fly nonstop to Haneda. AA-R-110 is a comparison of American’s proposed aircraft 

versus Delta’s. The issue of capacity has always been an important decisional criterion used by the Department in route case 

proceedings as a measure of public benefits. In this case, American proposes to launch its own Los Angeles-Haneda service with an 

aircraft with 36 more seats than Delta, which is shown on Exhibit AA-R-110. Over the course of one year, Exhibit AA-R-111 shows 

that American’s larger capacity equates to an additional 125 B767 flights over what Delta would operate (assuming, of course, it lived 

up to its most recent “daily, year-round” service commitment).

In Exhibits AA-R-112-114, Delta tries (to again) convince the Department that it is a “Japan have-not,” disadvantaged against 

the American/JAL and United/ANA alliances. Yet, the reality is much different. With more routes, destinations and flights to/from 

Tokyo, Delta is hardly a “Japan have-not.” Exhibits AA-R-116 and 117 amplify the fact that Delta is actually a “Japan have and had 

have for decades,” with more opportunities to serve Haneda and more slots at Haneda than any other U.S. carrier. As part of its effort 

to distract the Department from its underperforming Seattle-Haneda service, Delta again shows what the slot holdings at Haneda are 

by carrier and by alliance. The comparison is not relevant, because slots at Haneda are not freely transferable between carriers as 

shown in Exhibit AA-R-115. What is relevant is that Delta is a leading holder of Haneda slots that are eligible for U.S. service and it 

is the largest airline in the U.S.-Japan market – larger than United, JAL or ANA, and about the same size as JAL and American 

combined.
Exhibits AA-R-118-123 show the demographic comparison between Los Angeles and Seattle. Through every statistical 

measurement including population, regional gross domestic product, O&D passengers to Tokyo and residents of Japanese ancestry, 

Los Angeles is superior. These exhibits are important because they demonstrate that, even with existing levels of Los Angeles-Tokyo 

air service, the Los Angeles region is still underserved as shown specifically in Exhibits AA-R-124-125.

Finally, Exhibit AA-R-126 shows all the cancelled intercontinental routes by Delta in recent years, and that all of these 34 

routes except one had load factors higher than Delta has experienced on the Seattle-Haneda route. Based on this conduct of cancelling 

by Delta, it is fair to ask the motivation behind Delta continuing to operate this route and whether its motivation is to keep the route 

out of the hands of other airlines like American, whose proposal is substantially superior to Delta’s and could put this scarce resource 

to a much higher and better use. 
7

#LetAAFlyHaneda

Delta Has Repeatedly Made Promises to the Department and to

the Public and Has Repeatedly Failed to Deliver on Those Promises

Delta’s Promise

Delta’s Delivery

on that Promise

1) Detroit Promise #1: B747 service

2) Detroit Promise #2: Daily year-round service

3) Los Angeles Promise #1: B747 service

4) Seattle Promise #1: A330-300 service

5) Seattle Promise #2: B767 service with 225 seats

6) Seattle Promise #3: Daily service

7) Seattle Promise #4: Year-round service















DOT Docket OST-2010-0018

Exhibit AA-R-101

Page 1 of 1

Delta’s Seven Failed Promises

In Rebuttal to Exhibit DL-101 and DL-102
8

#LetAAFlyHaneda

Delta’s Alleged Service Build-Up at Seattle Is Not a Build-Up of

New Services, But, Rather, a Duplication and Almost Total Overlap of

Pre-Existing Alaska Services on Which Delta Code-Shared

“New Services” Added 

by Delta’s “Build Up”

Date

Added

Previous/Pre-Existing 

Delta Code Share on 

Alaska?

Anchorage June '13 Yes

Las Vegas June '13 Yes

San Diego June '13 Yes

San Jose June '13 Yes

Jackson Hole Dec '13 No

Los Angeles Apr '14 Yes

San Francisco Apr '14 Yes

Ketchikan May '14 Yes

Fairbanks June '14 Yes

Juneau June '14 Yes

Portland Aug '14 Yes

Spokane Nov '14 Yes

Bozeman Dec '14 Yes

Maui Dec '14 Yes

Palm Springs Dec '14 Yes

Phoenix Dec '14 Yes

Tucson Dec '14 Yes

Sacramento May '15 Yes

Sitka May '15 Yes

Boise May '15 Yes

Denver June '15 Yes

Source: OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-R-102

Page 1 of 1

The Only New Delta Market – Jackson Hole – Has a TYO PPDEW 

of 0.8 and a Haneda PPDEW of 0.1.

In Rebuttal to Exhibit DL-202 and DL-401
9

#LetAAFlyHaneda

Despite Delta’s Build-Up of Its Own Seattle Hub, Which Added

Only One New Service (Jackson Hole), Its Seattle-Haneda Load Factor 

(When it Operates) Is the Lowest of Any U.S. Carrier Serving Haneda

DOT Docket OST-2010-0018

Exhibit AA-R-103

Page 1 of 1

Note: United currently operating SFO-HND service but no publicly available information because of the recent inauguration of that service

Source: U.S. DOT T100, OAG flight schedules

Load Factor for all U.S. Carrier–Haneda Flights for Oct 2013 – Jun 2014

51.1

77.4 81.2

Delta SEA Delta LAX Hawaiian HNL

In Rebuttal to Exhibit DL-401 and Delta Application at page 2
10

#LetAAFlyHaneda

Despite Delta’s Build-Up of Its Own Seattle Hub, Which Added Only

One New Service (Jackson Hole), Its Seattle-Haneda Load Factor

(When it Operates) Is the Lowest of Any Carrier Serving Haneda

DOT Docket OST-2010-0018

Exhibit AA-R-104

Page 1 of 1

86.7 84.3 84.0

81.2

77.4

73.6

51.1

0

10

20

30

40

50

60

70

80

90

100

Load Factor %

Note: United currently operating SFO-HND service but no publicly available information because of the recent inauguration of that service

Source: U.S. DOT T100, OAG flight schedules

ANA

HNL-HND

JAL

HNL-HND

ANA

LAX-HND

HA

HNL-HND

DL

LAX-HND

JAL

SFO-HND

DL

SEA-HND

October 2013 – June 2014

In Rebuttal to Delta Application at Page 2 and 3
11

#LetAAFlyHaneda

The Load Factors of All of Delta’s Other Long Haul International Services

at Seattle Are Substantially Higher than Its Seattle-Haneda Route . . .without Delta’s

Own Service Build-Up Benefit . . . And Tokyo-Narita Has the Highest Load Factor

DOT Docket OST-2010-0018

Exhibit AA-R-105

Page 1 of 1

Latest 24 Months October 2013-June 2014

Delta SEA Long-Haul Load Factors:

87.9% 87.1% 86.1%

82.9% 81.0% 79.7% 78.1%

69.0%

56.5%

Amsterdam

Tokyo-NRT Seoul-ICN Paris Hong Kong Tokyo-HND

Beijing Shanghai

Inaugurated 

June 2014

Inaugurated 

June 2013

Inaugurated 

June 2014

Inaugurated 

June 2013

88.4% 84.4% 86.1%

82.0% 78.8%

76.4% 78.1%

69.0%

51.1%

In Rebuttal to Delta Application at Page 2 and 3

London-LHR

Inaugurated 

March 2014

Amsterdam

Tokyo-NRT Seoul-ICN Paris Hong Kong Tokyo-HND

Beijing Shanghai

Inaugurated 

June 2014

Inaugurated 

June 2013

Inaugurated 

June 2014

Inaugurated 

June 2013

London-LHR

Inaugurated 

March 2014

Source: U.S. DOT T100, OAG flight schedules
12

#LetAAFlyHaneda

If Delta’s Build-Up at Seattle Were as Successful as It Claims,

Why Did Delta Abandon the Seattle-Haneda Market Starting This Winter

When Its Seattle Hub Was Increasing by 50%?

9 9 9 9 10

15 15 16

14 14 14

21 20 20 20 21

23

29

17

19 20

31

29

22

0

7

0 0

7

3

0

5

10

15

20

25

30

35

Jan-14 Feb-14 Mar-14 Apr-14 May-14 Jun-14 Jul-14 Aug-14 Sep-14 Oct-14 Nov-14 Dec-14 Jan-15 Feb-15 Mar-15

Delta Own-Metal Domestic Markets

Monthly Delta Flights to Haneda

DOT Docket OST-2010-0018

Exhibit AA-R-106

Page 1 of 1

Note: OAG Flight Schedules

50% increase in Delta’s own service 

at Seattle 

Almost no service to Haneda

In Rebuttal to Delta Application at Page 2 and 3
13

#LetAAFlyHaneda

For Whatever Reason, Seattle Has Demonstrably

Not Responded Well to Delta’s Haneda Service

It Is Not Because of a Lack of Connections -- They are Abundant

Destination Marketing Carrier Operating Carrier Destination Marketing Carrier Operating Carrier

ALW DL AS MCI DL AS

ANC DL AS MCO DL AS

ATL DL AS MFR DL AS

BIL DL AS MSO DL AS

BLI DL AS MSP DL AS

BOI DL AS OGG DL AS

BOS DL AS ONT DL AS

BUR DL AS ORD DL AS

BZN DL AS PDX DL AS

DCA DL AS PHL DL AS

DEN DL AS PHX DL AS

DFW DL AS PSC DL AS

EAT DL AS RDM DL AS

EUG DL AS RNO DL AS

EWR DL AS SAN DL AS

FAI DL AS SFO DL AS

FCA DL AS SJC DL AS

GEG DL AS SLC DL AS

GTF DL AS SMF DL AS

HNL DL AS SNA DL AS

IAH DL AS STL DL AS

JNU DL AS STS DL AS

KOA DL AS TUS DL AS

KTN DL AS YEG DL AS

LAS DL AS YKM DL AS

LAX DL AS YLW DL AS

LGB DL AS YVR DL AS

LIH DL AS YYC DL AS

LWS DL AS YYJ DL AS

Alaska, the Favored Airline and Pride and Joy of Seattleites,

Provided Delta Abundant Connections to Feed Haneda Service

Source: OAG Schedules, March 2014

DOT Docket OST-2010-0018

Exhibit AA-R-107

Page 1 of 4

In Rebuttal to Exhibit DL-401
14

#LetAAFlyHaneda

For Whatever Reason, Seattle Has Demonstrably

Not Responded Well to Delta’s Haneda Service

0

2,000

4,000

6,000

8,000

10,000

12,000

Jul

2013

Aug

2013

Sep

2013

Oct

2013

Nov

2013

Dec

2013

Jan

2014

Feb

2014

Mar

2014

Apr

2014

May

2014

Jun

2014

Onboard Passengers by Month, 

July 2013-June 2014

0

10

20

30

40

50

60

70

80

90

100

Jul

2013

Aug

2013

Sep

2013

Oct

2013

Nov

2013

Dec

2013

Jan

2014

Feb

2014

Mar

2014

Apr

2014

May

2014

Jun

2014

Load Factor by Month, 

July 2013-June 2014

DL SEA-HND DL SEA-NRT NH SEA-NRT

It is Not Because Seattle-Tokyo Traffic Has Declined -- It Hasn’t

Note: July and August are peak months. Passenger numbers reflect the peak travel months..

Source: US DOT, T100

DOT Docket OST-2010-0018

Exhibit AA-R-107

Page 2 of 4

In Rebuttal to Delta Application at Page 2 and 4
15

#LetAAFlyHaneda

For Whatever Reason, Seattle Has Demonstrably

Not Responded Well to Delta’s Haneda Service

It Is Not Because the U.S. Market Similarly Responded

Poorly to Haneda Service -- It Hasn’t

Load Factors of U.S.-Haneda Services

Even Delta’s Detroit-HND and American’s JFK-HND Services Experienced

Higher Load Factors than Delta’s SEA-HND Service

0

10

20

30

40

50

60

70

80

90

100

DL-DTW HA-HNL AA-JFK DL-LAX DL-SEA

Source: US DOT, T100

DOT Docket OST-2010-0018

Exhibit AA-R-107

Page 3 of 4

In Rebuttal to Delta Application at Page 2 and 4
16

#LetAAFlyHaneda

For Whatever Reason, Seattle Has Demonstrably

Not Responded Well to Delta’s Haneda Service

It Is Not Because, Contrary to Delta’s Argument, Delta Did Not Have Its Own Metal 

Connecting Services -- All Other Delta International Services at Seattle Experienced 

High Load Factors Without Delta’s Own Metal

Latest 12 Months

88.2% 87.4% 86.1% 84.2% 82.5% 79.2% 78.1%

69.0%

56.6%

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

80.0%

90.0%

100.0%

Tokyo

Narita

Amsterdam Seoul

Incheon

Beijing Paris Shangahi Hong Kong London Tokyo

Haneda

Inaugurated June 2014

Inaugurated June 2013

Inaugurated 

June 2014

Inaugurated 

March 2014

Source: US DOT, T100

DOT Docket OST-2010-0018

Exhibit AA-R-107

Page 4 of 4

In Rebuttal to Delta Application at Page 2 and 4

Inaugurated 

June 2013
17
18

#LetAAFlyHaneda

Delta’s B767 Aircraft Are the Smallest of Any Airline Operating

U.S.-Haneda Service

DOT Docket OST-2010-0018

Exhibit AA-R-109

Page 1 of 1

Seats % Greater Than DL SEA-HND

777

HNL

JAL

389

332

HNL

Hawaiian

294

773

SFO

JAL

283

777

SFO

United

269

777

LAX

ANA

222

76W

SEA

Delta

211

76W

LAX

Delta

208

777

LAX 

American 

(reconfigured)

260

777

LAX 

American

(current)

247

84.4% 39.3% 34.1% 27.5% 23.2% 17.1% 5.2% 0% -1.4%

In Rebuttal to Exhibits DL-101, DL-102 and DL-103
19

#LetAAFlyHaneda

In Terms of Seats Offered, Delta’s B767 Does Not 

Maximize the Public Benefit – American’s B777 Would

DOT Docket OST-2010-0018

Exhibit AA-R-110

Page 1 of 1

American Airlines 777-200

247 Seats Initially

Delta Air Lines 767-300

211 Seats

American Airlines 777-200

260 Seats Retrofitted

Seats Offered per Flight 247 260 211

Per Flight Difference 36 49 --

Annual Seats 180,310 189,800 154,030

Annual Difference 26,280 35,770 --

% Greater than Delta 17.1% 23.2% --

In Rebuttal to Exhibits DL-101, DL-102 and DL-103
20

#LetAAFlyHaneda

American’s B777 Aircraft Would Provide the Equivalent of

125 Additional Delta B767 Flights Annually

DOT Docket OST-2010-0018

Exhibit AA-R-111

Page 1 of 1

125 Additional B767-Equivalent Flights and 26,280 Additional Seats

(170 Additional B767 Equipment Flights and 35,770 Seats Once American’s Reconfigured 

B777 Introduced onto Route)

In Rebuttal to Exhibits DL-101, DL-102 and DL-103
21

#LetAAFlyHaneda

HKG

NRT

BKK

MNL

HNL

SIN

DTW

GUM

SPN

PDX

TPE

PVG HND

ROR

JFK

LAX

MSP

SEA

ATL

Delta’s Strained Attempt to Portray Itself as Disadvantaged 

in Japan Is Ironic and Fanciful

“Disadvantaged Delta” Has, of Course, the Largest 3rd/4th and 5th Freedom Network in Japan of 

Any U.S. Airline, Which it Enjoys Because of Its Inherited “Incumbency” Status, 60-year Presence 

in Japan and Over 30 Year Head-Start on American

Source: August 2014 schedules

19 segments from Tokyo

679 monthly departures

DOT Docket OST-2010-0018

Exhibit AA-R-112

Page 1 of 2

In Rebuttal to Exhibits DL-205, DL-301, DL-302, DL-303, DL-304 and DL-305
22

#LetAAFlyHaneda

Delta’s Strained Attempt to Portray Itself as Disadvantaged 

in Japan Is Ironic and Fanciful

486

434

375 372

116

0

100

200

300

400

500

600

DL UA JL NH AA

“Disadvantaged Delta” Operates More Flights Between the U.S. and Tokyo Than Any 

Other Carrier – U.S. or Japanese – and Four Times as Many Flights as American

“Disadvantaged Delta” Actually Operates 52 More U.S.-Tokyo Flights than the Next Largest 

Airline . . . and almost exactly the same number as American and JAL Combined

U.S.-Tokyo (NRT+HND) Monthly Flights – August 2014

Source: OAG flight schedules

DOT Docket OST-2010-0018

Exhibit AA-R-112

Page 2 of 2

In Rebuttal to Exhibits DL-205, DL-301, DL-302, DL-303, DL-304 and DL-305
23

#LetAAFlyHaneda

Delta’s Strained Attempt to Sell Itself as Disadvantaged in Japan vis-à-vis 

American Is Fanciful – If Anything It is American That is Disadvantaged

ATL

DTW

LAX

SEA

HNL

JFK

MSP PDX

HND

NRT

ORD

DFW

Delta American

Routes 12 3

Weekly

Flights 117 26

Source: OAG flight schedules,, August 2015 

SPN

GUM

DOT Docket OST-2010-0018

Exhibit AA-R-113

Page 1 of 2

Delta Operates, By Far, More Routes and More Flights

to Tokyo Than American

In Rebuttal to Exhibit DL-205 and Delta Application at Page 4
24

#LetAAFlyHaneda

NRT

DFW

ORD

SFO

HNL

HND

DTW JFK

LAX

MSP PDX

SEA

DEN

EWR

IAD

IAH

ATL

United Delta American

Routes 10 12 3

Weekly

Flights 84 117 26

Delta’s Strained Attempt to Sell Itself as Disadvantaged in Japan vis-à-vis 

American Is Fanciful – If Anything It is American That is Disadvantaged

SPN

GUM

Source: OAG flight schedules,, August 2015 

DOT Docket OST-2010-0018

Exhibit AA-R-113

Page 2 of 2

Delta and United Operate 300% and 233% More Routes and

350% and 223% More Flights, Respectively, to Tokyo Than American

In Rebuttal to Exhibit DL-205 and Delta Application at Page 4
25

#LetAAFlyHaneda

Delta’s Strained Attempt to Portray Itself as Disadvantaged 

in Japan vis-à-vis the oneworld Alliance Is Ironic and Fanciful

Delta/Sky Team

American/

oneworld

“Disadvantaged Delta’s”

Actual Advantage

Flights 6,153 5,718 8.4%

Seats 1,627,866 1,435,560 13.4%

“Disadvantaged Delta” in fact, Suffers No Disadvantage 

vis-a-vis oneworld Alliance in Tokyo. To the contrary is it American/JAL which is 

“disadvantaged” and Delta which is “advantaged”

Source: OAG flight schedules, 12 months ending December 2014

DOT Docket OST-2010-0018

Exhibit AA-R-114

Page 1 of 1

In Rebuttal to Exhibits DL-301, DL-302, DL-303, DL-304 and DL-305
26

#LetAAFlyHaneda

JAL

25.0%

ANA

25.0%

Delta

25.0%

Hawaiian

12.5%

United

12.5%

Delta’s Reliance on Overall Haneda Slot Pair Holdings

Ignores the Facts

Unlike other airports, at Haneda:

• Slots cannot be sold

• Slots cannot be leased

• Night slots cannot be swapped for 

day slots

DOT Docket OST-2010-0018

Exhibit AA-R-115

Page 1 of 1

Source: Delta Application Exhibit DL-302, and OAG flight schedules

Not Relevant

What Is Relevant:

U.S.-Haneda Slot Holdings by Carrier

The Facts

American 0%

In Rebuttal to Exhibit DL-302
27

#LetAAFlyHaneda

“Disadvantaged Delta” Is Not “Locked Out” of Haneda. To the Contrary,

It Has Had the Opportunity to Utilize Two Haneda Slot Pairs at, Now,

Three Gateways – Triple the Opportunities Made Available to Any Other U.S. Airline

Delta: Three Opportunities

“Disadvantaged Delta Says: It Is “effectively locked out of [Haneda].”1

Delta’s Opportunities=3 All Other U.S. Carrier Opportunities=1 each

1 Delta Application, at p. 5 

HND DTW

HND SEA

HND LAX

HND HNL

HND SFO

HND JFK

Delta Is Neither “Disadvantaged” Nor Locked Out of Haneda

Hawaiian, American, and United: 

One Opportunity Each

DOT Docket OST-2010-0018

Exhibit AA-R-116

Page 1 of 1

In Rebuttal to Exhibit DL-301
28

#LetAAFlyHaneda

“Disadvantaged Delta” Suffers No Disadvantage at Haneda

Versus Other U.S. Airlines. Indeed, It Is American Which Is Both 

Disadvantaged and Locked Out

Slot Holdings of U.S. Airlines at Haneda

Delta 2 50%

Hawaiian 1 25%

United 1 25%

American 0 0

DOT Docket OST-2010-0018

Exhibit AA-R-117

Page 1 of 1

In Rebuttal to Exhibit DL-301
29

#LetAAFlyHaneda

Los Angeles Has Over 3.2 Times the GDP of the Seattle Area

Gross Domestic Product of Los Angeles and Seattle

$ Billions, 2013

0 1 2

Source: U.S. Bureau of Economic Analysis, 2013 estimates for Los Angeles-Long Beach-Anaheim, CA and Riverside-San Bernardino-Ontario, CA,

and Seattle-Tacoma-Bellevue, WA and Bellingham, WA

$953.6

$295.1

Los Angeles Seattle

DOT Docket OST-2010-0018

Exhibit AA-R-118

Page 1 of 1

In Rebuttal to Exhibit DL-206
30

#LetAAFlyHaneda

Los Angeles Outranks Seattle by a Wide Margin on the

Critical Factors for Air Service Success

Rank Among Continental U.S. Metropolitan Areas

Los Angeles

Seattle

GDP Population O&D Passengers 

to Tokyo

O&D Passengers 

to Haneda

1 1 2 2

12 14 6 4

Source: MIDT YE November 2014, U.S. BEA, U.S. Census, Delta submission to DOT

DOT Docket OST-2010-0018

Exhibit AA-R-119

Page 1 of 1

In Rebuttal to Exhibits DL-201 and DL-206
31

#LetAAFlyHaneda

Los Angeles Has Over Four Times the Population of the Seattle Area

Population of Los Angeles and Seattle 

(Combined Statistical Areas, 2013)

0 1 2

Source: U.S. Census

18,351,929

4,459,677

Los Angeles Seattle

DOT Docket OST-2010-0018

Exhibit AA-R-120

Page 1 of 1

In Rebuttal to Exhibits DL-201 and DL-205
32

#LetAAFlyHaneda

California Has 5.5 Times the Population of Washington State

38,802,500

7,061,530

California Washington

Population

July 2014 Estimate

Source: U.S. Census

DOT Docket OST-2010-0018

Exhibit AA-R-121

Page 1 of 1

In Rebuttal to Exhibits DL-201 and DL-205
33

#LetAAFlyHaneda

Los Angeles Has Nearly Four Times the Japanese-American

Population of Seattle

33,170

8,538

Los Angeles Seattle

Source: U.S. Census, American Community Survey 2009-2013 estimate, reported Japanese ancestry

Reported Japanese Ancestry by Metro Area

DOT Docket OST-2010-0018

Exhibit AA-R-122

Page 1 of 1

In Rebuttal to Exhibits DL-201 and DL-205
34

#LetAAFlyHaneda

California Has Over Seven Times the Japanese-American

Population of Washington

280,432

38,115

California Washington

Source: U.S. Census, American Community Survey 2009-2013 estimate, reported Japanese ancestry

Reported Japanese Ancestry by State

DOT Docket OST-2010-0018

Exhibit AA-R-123

Page 1 of 1

In Rebuttal to Exhibit DL-301
35

#LetAAFlyHaneda

Even Without Haneda Service, Seattle Is Over-Served Relative

to Los Angeles, Even With American’s Los Angeles-Haneda Service

432,525

93,892

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

450,000

500,000

LAX SEA

Los Angeles O&D Is 3.6X Larger

Than Seattle’s

LAX 3.6X Seattle

Los Angeles only has 2.7X the number of 

Tokyo flights as Seattle

LAX 2.7X Seattle

Continental U.S.-Tokyo Annual Passengers

YE November 2014

SEA

LAX

TYO

Source: MIDT YE November 2014, OAG flight schedules

...yet

DOT Docket OST-2010-0018

Exhibit AA-R-124

Page 1 of 1

In Rebuttal to Exhibits DL-201, DL-202, DL-203, DL-204, and DL-205

Errata to Direct Exhibit AA-212
36

#LetAAFlyHaneda

Seattle Enjoys, and Will Continue to Enjoy, Double Daily Service to Tokyo

Source: OAG flight schedules

SEA

NRT

Daily Year-round

Daily Seats: 473 each way

Annual Seats: 172,522 each way

DOT Docket OST-2010-0018

Exhibit AA-R-125

Page 1 of 1

In Rebuttal to Exhibit DL-205
37

#LetAAFlyHaneda

Why Is Delta Consistently Holding on to This Haneda Slot Pair When

Delta Has Cancelled Routes with Substantially Higher Load Factors?

Delta Cannot Be Holding on to This Haneda Slot Pair for Economic Reasons as It Loses 

Substantial Money at Its Current 51.8% Load Factor, or Even a Load Factor 20% Higher. Delta 

Is Holding on to the Haneda Slot Pair to Keep It Away from Other U.S. Carriers Which Could 

Make Better Use of It – to the Substantial Detriment of the Public and Competition

0

10

20

30

40

50

60

70

80

90

100 Load Factors for SEA-HND and International Routes Canceled by Delta

Note: Routes with more than 100 flights in period

DOT Docket OST-2010-0018

Exhibit AA-R-126

Page 1 of 1

In Rebuttal to Exhibits DL-203 and DL-204
38

Answer/Rebuttal Exhibits to

Hawaiian Airlines’ Proposed Kona-Haneda Service
NARRATIVE TO SERIES 200 REBUTTAL EXHIBITS

The 100 Series of American’s Rebuttal Exhibits demonstrates that Delta’s (re)application for Seattle-Haneda service is flawed. 

This series of American’s Rebuttal Exhibits similarly demonstrates that, while Hawaiian has had great success operating HonoluluTokyo Haneda, which is a well-established route, that success is totally irrelevant to the prospects for Kona-Tokyo Haneda, which is a 

route that has been tried before (Kona-Tokyo Narita) and did not succeed, as we show in our Reply Exhibits. The Series 200 Rebuttal 

Exhibits also show that, irrespective of whether it would succeed or not, American’s proposed Los Angeles-Haneda route would offer 

substantially superior public benefits to Hawaiian’s proposed Kona-Haneda route.

Exhibit AA-R-201 lists how American’s proposed Los Angeles-Haneda service will benefit more travelers, more U.S. 

communities, and more States than Hawaiian’s Kona-Haneda proposal, and how American’s proposed Los Angeles-Haneda service 

also will provide more intra-gateway, more inter-gateway, and more inter-carrier competition than Hawaiian’s Kona-Haneda service 

proposal.

Exhibit AA-R-202 commends Hawaiian for fully utilizing its Honolulu-Haneda slot pair by providing daily, year-round 

service, unlike Delta’s Seattle-Haneda service. Exhibits AA-R-203 through 207 illustrate, however, that Kona is not Honolulu and

that the Kona market is too small and the public benefits are too limited for the Department to award the valuable slot pair to 

Hawaiian. 

Exhibit AA-R-203 depicts that only a single U.S. state (Hawaii) and two U.S. communities would benefit from Hawaiian’s 

service proposal, while American’s Los Angeles-Haneda service proposal will benefit 15 states and 23 U.S. communities in the 

summer and 16 states and 30 U.S. communities in the winter. Exhibit AA-R-204 further shows that Hawaiian’s service proposal 

would not benefit even one percent of the U.S. population, while American’s service proposal benefits 61 percent of the U.S. 
population. Exhibit AA-R-205 shows that American’s Los Angeles-Haneda proposal will benefit nearly double the O&D passengers 

compared to Hawaiian’s proposed Kona-Haneda service. 

Exhibits AA-R-206 and 207 illustrate that the beneficiaries of Hawaiian’s Kona-Haneda service would be almost exclusively 

Japanese travelers, and not U.S. consumers.

Exhibit AA-R-208 describes how Kona-Tokyo service has been attempted previously by JAL and its low cost subsidiary 

JALways, and how even flying a smaller aircraft than Hawaiian proposed and operating only three to four times a week—less than 

Hawaiian’s daily proposal—JAL could not make a success of the route and ultimately ceased service. 

Exhibit AA-R-209 details the many competitive benefits that American’s Los Angeles-Haneda service proposal provides 

compared to Hawaiian’s Kona-Haneda service proposal. 

Exhibit AA-R-210 raises questions about Hawaiian’s lack of a firm service start date. In three places, Hawaiian addressed the 

start-up date, and each time, it offered a different answer, including one that would not commit Hawaiian to a start-up date that might 

be a couple of years away. There is also a question of whether, in fact, Hawaiian can lawfully operate Kona-Haneda service since 

there are no CBP/FIS facilities up to currently-required standards. While Hawaiian has asked for a five-year exemption to build the 

necessary facilities, that request has been denied thus far (as far as American knows) and it is unlikely to be granted, at least in time to 

permit Hawaiian to use the scarce resource of this Haneda slot pair by a normal start-up date. Exhibit AA-R-211 is a copy of an 

article that sheds some light on this issue. 
39

#LetAAFlyHaneda

American’s Proposed Los Angeles-Haneda Service Offers Substantially

Superior Public Benefits to Hawaiian’s Proposed Kona-Haneda Service

American’s Proposed Los Angeles-Haneda Service Will:

 Benefit more U.S. travelers

 Benefit more U.S. communities

 Benefit more U.S. States

 Provide more intra-gateway, inter-gateway, inter-carrier competition

DOT Docket OST-2010-0018

Exhibit AA-R-201

Page 1 of 1

In Rebuttal to Exhibits HA-App2015-1, HA-App2015-3, HA-App2015-4
40

#LetAAFlyHaneda

Hawaiian Has Done a Commendable Job of Fully Utilizing Its

Allocated Haneda Slot Pair

Nice Job, Hawaiian!

DOT Docket OST-2010-0018

Exhibit AA-R-202

Page 1 of 1

Source: OAG flight schedules

0

5

10

15

20

25

30

35

NovDec

Jan

Feb

Mar

Apr

May

Jun

Jul

Aug

Sept

Oct

NovDec

Jan

Feb

Mar

Apr

May

Jun

Jul

Aug

Sept

Oct

NovDec

Jan

Feb

Mar

Apr

May

Jun

Jul

Aug

Sept

Oct

NovDec

Jan

Feb

Mar

Apr

May

Jun

Jul

Aug

Sept

Oct

NovDec

Jan

Feb

Mar

HA HNL-HND Flights Days of Month

Days of Service

2011 2012 2013 2014 2015

In Rebuttal to Hawaiian Airlines Application at page 5
41

#LetAAFlyHaneda

Hawaiian’s Proposed Kona Service Benefits Only One U.S. State

and 2 U.S. Communities; American’s Proposed LAX Service Benefits 15 States and

23 U.S. Communities in the Summer and 16 States and 30 Communities in the Winter

Hawaiian’s Kona-HND Service American’s LAX-HND Service 

Summer

American’s LAX-HND Service 

Winter

DOT Docket OST-2010-0018

Exhibit AA-R-203

Page 1 of 2

Source: Exhibit HA-App2015-3 and Exhibit AA-107.

1 State

2 Communities

15 States

23 U.S. Communities

(plus 2 Canadian markets)

16 States

30 U.S. Communities

(plus 1 Canadian and 

1 Brazilian market)

In Rebuttal to Exhibits HA-App2015-3
42

#LetAAFlyHaneda

Hawaiian’s Proposed Kona Service Benefits Only One U.S. State and

2 U.S. Communities; American’s Proposed LAX Service Benefits 15 States and

23 U.S. Communities in the Summer and 16 States and 30 Communities in the Winter

Hawaiian’s Kona-HND Service American’s LAX-HND Service 

Summer

American’s LAX-HND Service 

Winter

Hawaii Arizona

California

Florida

Georgia

Illinois

Massachusetts

New York

Nevada

North Carolina

Oregon

Pennsylvania

Tennessee

Texas

Virginia/ Washington DC

Washington

Arizona

California

Florida

Georgia

Illinois

Massachusetts

New York

Nevada

North Carolina

Oregon

Pennsylvania

Tennessee

Texas

Utah

Virginia/ Washington DC

Washington

1 15 16

DOT Docket OST-2010-0018

Exhibit AA-R-203

Page 2 of 2

Source: Exhibit HA-App2015-3 and Exhibit AA-107.

In Rebuttal to Exhibits HA-App2015-3
43

#LetAAFlyHaneda

The Public Benefits Substantially Favor American’s

15/16 States Over Hawaiian’s One State

Population of States Served

State

Population

2014 Estimate State

Population

2014 Estimate

Hawaii 1,419,561 Arizona 6,731,484

California 38,802,500

Colorado 5,355,866

Florida 19,893,297

Georgia 10,097,343

Illinois 12,880,580

Massachusetts 6,745,408

Nevada 2,839,099

New York 19,746,227

North Carolina 9,943,964

Oregon 3,970,239

Pennsylvania 12,787,209

Tennessee 6,549,352

Texas 26,956,958

Utah 2,942,902

Virginia 8,326,289

Total 1,419,561 Total 194,568,717

Percent of U.S.

Population .04% Percent of U.S.

Population 61.0%

DOT Docket OST-2010-0018

Exhibit AA-R-204

Page 1 of 1

Source: U.S. Census

In Rebuttal to Exhibits HA-App2015-3
44

#LetAAFlyHaneda

American’s Proposed Los Angeles-Haneda Service Will 

Benefit Almost Double the O&D Passengers of Hawaiian’s 

Proposed Kona-Haneda Service

U.S. Markets Without Nonstop U.S. – HND Service

Hawaiian O&D American O&D

Kona 24,096 Las Vegas 26,461

Maui 7,202 New York Kennedy 6,679

San Diego 3,122

Orlando 3,016

Boston 2,227

Phoenix 2,086

Houston 1,835

Atlanta 1,707

Chicago O'Hare 1,590

Salt Lake City 1,522

Washington Dulles 1,420

San Jose 1,236

Dallas/Fort Worth 1,121

Miami 979

Denver 898

Philadelphia 490

Austin 383

Sacramento 349

San Antonio 301

Nashville 259

Tampa 244

Charlotte 180

Tucson 162

Reno 114

Eugene 69

Fresno 66

El Paso 58

West Palm Beach 54

Monterey 46

Total Hawaiian 31,298 Total American 58,674 

DOT Docket OST-2010-0018

Exhibit AA-R-205

Page 1 of 2

Note: Based on American's proposed Winter schedule; includes only American's HND-LAX U.S. connecting markets that would connect both ways. 

Annual O&D for American's proposed Summer schedule totals 53,126.

Source: MIDT YE November 2014

In Rebuttal to Exhibits HA-App2015-3
45

Note: Non-U.S. markets excluded for American (none for Hawaiian). #LetAAFlyHaneda

31,298

58,674

Hawaiian American

DOT Docket OST-2010-0018

Exhibit AA-R-205

Page 2 of 2

American’s Proposed Los Angeles-Haneda Service Will 

Benefit Almost Double the O&D Passengers of Hawaiian’s 

Proposed Kona-Haneda Service

In Rebuttal to Exhibits HA-App2015-4
46

#LetAAFlyHaneda

Kona Is Almost Exclusively an All-Japanese Originating Market

Benefitting Less Than 9 U.S. PDEWS

Point of Sale Annual Passengers

(Per Hawaiian)

96%

4%

Japan Other

154,178

6,424

Japan Other

Source: Ex HA-App 2015-4

DOT Docket OST-2010-0018

Exhibit AA-R-206

Page 1 of 1

In Rebuttal to Hawaiian Airlines Application at page 3 and Exhibit HA-App2015-4
47

#LetAAFlyHaneda

Hawaiian’s Proposed Kona-HND Service Provides

Practically No Benefits to the U.S. Traveling Public

DOT Docket OST-2010-0018

Exhibit AA-R-207

Page 1 of 1

Source: Exhibit HA-App2015-4

Hawaiian’s Proposed Kona Service Is 96% Japan-Originating

Benefits to Japanese Traveling Public Benefits to U.S. Traveling Public

In Rebuttal to Hawaiian Airlines Application at page 3 and Exhibits HA-App2015-4 and HA-App2015-5
48

#LetAAFlyHaneda

Nonstop Kona-Tokyo Service Has Been Tried Before... and Failed

DOT Docket OST-2010-0018

Exhibit AA-R-208

Page 1 of 2

Frequency: Attempt to Match Supply with Demand

Never more than 16X monthly (3x/4x weekly)

Still, unacceptably low load factors

Aircraft: Attempt to Downgauge to Profitability

B747 DC10 B767

400+ Seats 237 Seats

Carrier: Attempt to have Lower Cost Airline Operate

JAL June 1996 – September 1999

JALways October 1999 – March 2000

JAL April 2000 – September 2004

JALways October 2004 – October 2010 (when service ceased)

Failed Efforts:

Overall Load Factor: 61.69% 

31 Months with Load Factor of 50% or Less

Only 9 Months with Load Factor of 80% or Higher

Results:

Source: U.S. DOT, T100, June 1996-Oct. 2010

In Rebuttal to Hawaiian Airlines Application at page 6
49

#LetAAFlyHaneda

Nonstop Kona-Haneda Service Has Been Tried Before... and Failed

If a Japanese airline, with the backing of and relationships with Japanese 

wholesalers unmatchable by U.S. carriers, could not succeed at this route, even 

with smaller aircraft and less service than Hawaiian proposes, it is highly 

questionable whether Hawaiian could

DOT Docket OST-2010-0018

Exhibit AA-R-208

Page 2 of 2

JAL/JALways

Last Kona-Narita 

Service

Hawaiian Proposed 

Kona-Haneda

Service

% Hawaiian

Greater

Monthly Flights 15-16 30-31 +100%

Daily Seats 237 294 +24%

Annual Seats 88,164 214,620 +143%

In Rebuttal to Hawaiian Airlines Application at page 6
50

#LetAAFlyHaneda

American’s Los Angeles-Haneda Service Provides Substantially

More Competition Benefits Than Hawaiian’s Kona-Haneda Service

Competition Benefit

• Inter-gateway, but only against Japanese airlines 

(and itself)

Competition Benefits

• Intra-gateway competition at LAX with both 

Japanese and U.S. airlines

• Inter-gateway competition with United at SFO

• Inter-alliance competition at LAX with Star (ANA 

service) and Sky Team (Delta service)

DOT Docket OST-2010-0018

Exhibit AA-R-209

Page 1 of 1

In Rebuttal to Hawaiian Airlines Application at page 3
51

#LetAAFlyHaneda

Hawaiian’s Soft and Changing Start-Up Date Commitment

Could, Literally, Be Years Away

• “...on or about June 1, 2015 or approximately 90 days after Hawaiian receives the 

[allocation]...”

Application of Hawaiian, p.5 (emphasis added)

* * * *

• “It would be Hawaiian’s recommendation that the Department specify a date [to start 

service] no earlier than 90 days after issuance of the final order...”

Application of Hawaiian, p. 9 (emphasis added)

* * * *

• “Hawaiian reserves the right to ask for delay of the startup date should any court 

proceeding be instituted to review an award of the frequency to Hawaiian until such 

time as the case is resolved.”

Application of Hawaiian, fn 6, p. 7 (emphasis added)

DOT Docket OST-2010-0018

Exhibit AA-R-210 

Page 1 of 1

Hawaiian Says:

In Rebuttal to Hawaiian Airlines Application at pages 5,7 and 9
52

#LetAAFlyHaneda

Kona: A No Fly Zone

DOT Docket OST-2010-0018

Exhibit AA-R-211

Page 1 of 1

Source: West Hawaii Today, posted January 28, 2014

By Nancy Cook Lauer

West Hawaii Today

State and county officials are working with the federal government to get 

a five-year exemption from meeting security standards at Kona 

International Airport in order to reopen an international inspection facility 

that’s been closed since 2010.

The lack of a U.S. Customs facility is hampering county efforts to lure 

international flights to Kona, reducing the number of Japanese tourists 

flying directly to the Big Island. U.S. Customs and Border Protection 

currently has limited staff, screening general aviation and cruise ship 

arrivals and some cargo shipments to the area.

At issue is the airport’s design, featuring iconic tiki-hut style outdoor 

passenger holding areas that convey a Hawaiian atmosphere, but do little 

to address Customs’ security concerns at the airport.

The airport does not meet Customs’ airport technical design standards 

for passenger processing facilities, said Brian Humphrey, director of field 

operations for Customs San Francisco office, in a Dec. 24 letter to Hawaii 

County Mayor Billy Kenoi.

“Unfortunately, I cannot approve the request for a five-year exemption,” 

Humphrey said in the letter, adding he’s referred the matter to Customs 

headquarters.

“Since the 2010 termination of international commercial arrivals in Kona, 

(Customs and Border Protection) has maintained a small staff to perform 

these limited operations while the majority of the pre-2010 staff has been 

reassigned to other locations at agency expense,” Humphrey said.

A temporary practice of having charter flights reimburse Customs for 

flying agents from Honolulu to Kona to staff the customs gateway there 

was ended by the agency in 2012. Kenoi remains optimistic. He told 

West Hawaii Today on Monday that he met briefly last week with 

Homeland Security Secretary Jeh Johnson, who assigned the topic to an 

assistant secretary. 

He also discussed it with U.S. Rep. Tulsi Gabbard, a Democrat 

representing Hawaii’s 2nd District, who sits on the Homeland Security 

Committee, and other members of the congressional delegation. 

Kenoi was in Washington for the United States Conference of Mayors 

winter meeting.

“We got a little further. We have a contact,” Kenoi said. “We know it’s 

on someone’s desk. It’s in Washington, D.C. The more people we 

can talk to to get it off the desk and start making progress, the better 

off we will be.”

Kenoi praised Gov. Neil Abercrombie and state Department of 

Transportation Deputy Director for Airports Ford Fuchigami for 

working on the issue.

DOT spokeswoman Caroline Sluyter said the state wants the fiveyear extension to give it time to design a facility and new airport 

procedures to meet the federal requirements. The upgrades are 

estimated to cost about $35 million.

“It’s a very important issue for us,” Sluyter said. “We feel there is a 

demand for direct flights coming in from Japan to Kona.”

Tourism officials have previously said the inability to sell direct flights 

to the Big Island can have economic impacts on hotels and 

businesses.

Thanks to continually growing numbers of Japanese arrivals — who 

often plan multi-island itineraries anyway — to the state, Hawaii 

Island is still seeing more tourists from the country than it did last 

year, with about 8 percent more tourists from the country in the first 

half of 2013, compared to the first half of 2012.

But, Big Island Visitors Bureau Executive Director Ross Birch said, 

the number of Japanese visitors staying only on Hawaii Island was 

down 17 percent compared to 2010, the last time Japan Airlines 

brought a direct flight to the island. If those direct flights came back, 

Hawaii Island may get more visitors, but would almost certainly at 

least gain more nights of hotel occupancy by the visitors who came 

here first, rather than Oahu.

In Rebuttal to Hawaiian Airlines Application at pages 5,7 and 9
53

Letters of Support
January 5, 2015

The Honorable Anthony Foxx

United States Department of Transportation

1200 New Jersey Avenue, S.E.

Washington, DC 20590

Dear Secretary Foxx,

I write in support of American Airlines' application for one slot pair to provide service 

between Los Angeles International Airport (LAX) and Tokyo’s Haneda Airport (HND) 

beginning in 2015 (DOT-OST-2010-0018).

The robust ties between Los Angeles and Japan provide an unmatched foundation for 

American Airlines’ proposed service, addressing unmet and growing demand for service 

between LAX and HND. Current LAX-HND flights are already more than 85 percent full. 

I firmly believe that the public interest will be served by approving the application by

American Airlines, which is committed to fully utilizing the reallocated slot pair to 

conduct daily flights between Los Angeles and Haneda. 

The City of Los Angeles and the Southern California region look forward to improved 

access to Tokyo/Haneda. I strongly support opportunities for strengthening services at 

LAX and encourage you to give American Airlines’ application your full consideration.

Sincerely,

ERIC GARCETTI

Mayor
GOVERNOR’S OFFICE OF BUSINESS AND ECONOMIC DEVELOPMENT

STATE OF CALIFORNIA  OFFICE OF GOVERNOR EDMUND G. BROWN JR.

January 10, 2015

The Honorable Anthony Foxx

Secretary of Transportation

U.S. Department of Transportation

1200 New Jersey Avenue, S.E.

Washington, DC 20590

RE: Additional Los Angeles-Haneda Direct Route Slot Pair

Docket DOT-OST-2010-0018

Dear Secretary Foxx:

We are writing this letter in reference to Docket DOT-OST-2010-0018 to convey our strong support for 

the Department of Transportation to allocate an additional slot pair to provide direct service from Los 

Angeles International Airport (LAX) to Tokyo’s Haneda Airport (Haneda).

As you know, the Governments of the United States and Japan signed an aviation agreement in 2010 that 

provided four daily nonstop flights from the United States to Haneda, Tokyo’s downtown airport. These 

nonstop flights to Haneda are scarce assets that should be distributed among U.S. carriers to obtain the 

maximum consumer and economic benefits.

California and Japan’s strong business and cultural ties along with the fact that Los Angeles is the largest 

continental U.S. gateway to Tokyo underscore the need for expanded service to Haneda from LAX. In 

2011, Japan was the largest source of foreign direct investment into Los Angeles County, and travel 

demand between the United States and Japan was supported by the approximately 250,000 Japanese 

Americans and 50,000 Japanese nationals living in Southern California. An additional LAX-Haneda slot 

pair will not only better connect travelers and businesses, but it will also help stimulate new business 

opportunities and create jobs for California companies.

We strongly believe that the expansion of nonstop service between LAX and Haneda will not only have a 

positive impact on both our state’s economy and thus the U.S. economy, but will provide the maximum 

utilization of the scarce Haneda slots. We encourage you to approve an additional slot pair for the direct 

LAX–Haneda route.

Sincerely,

Kish Rajan

Director

cc: Susan Kurland, Assistant Secretary for Aviation and International Affairs

(916) 322-0694  Business.ca.gov  1325 J Street, 18th Floor, Sacramento, California 95814



January 9, 2015

Anthony R. Foxx

Secretary of Transportation

1200 New Jersey Avenue SE

Washington, DC 20590

RE: American Airlines’ Los Angeles-Haneda Application, Docket DOT-OST-2010-0018

Dear Secretary Foxx:

I write in support of American Airlines’ application to acquire a slot pair to serve Tokyo’s 

Haneda Airport (Haneda) from Los Angeles. 

As Councilmember for Los Angeles’s 14th District, I represent Little Tokyo, a growing 

neighborhood in Downtown, which is also the regional center for Japanese-American culture 

and community. Little Tokyo is one of only three remaining historic Japantowns in California. As 

such it is a major destination for locals and international travelers alike.

With approximately 250,000 Japanese Americans and 50,000 Japanese nationals living in 

Southern California, travel demand is substantial. Additional Los Angeles service to Haneda 

would better connect travelers, families and businesses and promote greater cultural and 

economic exchange between California and Japan.

For these reasons, I urge you to give full consideration to American’s application.

Should you need further information or wish to discuss this further, please do not hesitate to 

contact my Policy Director Martin Schlageter at 213-473-7014, martin.schlageter@lacity.org.

Sincerely,

Councilman Jose Huizar

District 14, Los Angeles