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 AngelesJanuary 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.comTABLE 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 ................................ ................................ ................................ ................. 17BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C. Motion and Application of AMERICAN AIRLINES, IN C. 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 scar c e national resource among more S tates 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
. A s American’s President Scott Kirby testified in this pr oceeding , 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 a nd 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 airlin e 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
. A s 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 D epartment 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, w ith 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. Del ta’s (re)application 2 requests 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 f or Detroit and again when Delta asked to move the Detroit service to Seattle. 3 For this
reason , Delta ’s commitment to p rovide 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 U pon 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, n one of which have complain ed 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 abo ut 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 Se rvice , ” 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, succes sfully 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 t hese Asian services , which began decades ago, were s uccessful 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 result s 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/fro m 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

— Seattle

Haneda. 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 Ex s . 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 In terest 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 T here 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 restrict ive airports in Asia and one where the Department is forced to allocate U.S
. - carrier access to maximize the public benefits
. T he 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 t he 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 nonstop s to Narita on A ll Nippon Airways Co., Ltd. (“ANA”) and Delta. 12 In fact, Seattle will still be one of only six continental U.S. gateways with two
carrier 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 Ex s . 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 th is 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 metal

neutrality 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 ac tions 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. M etal 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 Ex s . AA

- R

- 112 to
- 113. 14 The metal

- neutrality provision s 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 Delta

Virgin 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 g o 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 custo mers 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 ser vice, 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 a lso 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 ro ute’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 struct ure 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 bene ficiaries 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 2 014

- 12

- 9 at 6. 18 Answer Ex s . AA

- R

- 203 to

- 205
. 19 Answer Ex s . AA

- R

- 20 6 to

- 20 7
.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 , w hich 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 Hawaiian 21 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 Ex s . 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 add itional 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 m ake 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 Ja panese - originating cannot make it, one questions how Hawaiian realistically could. In addition, i n many ways, those 14 years were the good (or best) years for Japanese tourists because of the high value and purchasing power of the y en versus the U.S. Dolla r . But, times have changed and so has the y en - d ollar exchange rate. For years, the y en had incredible purchasing power vis

- à

- vis the d ollar. In 2013, however , the y en fell relative to the d ollar , 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 d ollar appreciated almost another 15 percent versus the y en. 26 This trend is likely to continue as Japanes e economic g rowth remains sluggish and the dollar continues to appreciate, driving the y en to lows versus the d o llar 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 , a t 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 Vi sitor 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 JAL ways 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 resolut ion 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, whic h 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 ’ Propo sals 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 De partment also placed great weight on achi eving 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 allian ces 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 acces s 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 re gions 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 Sta tes, 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 w est c oast gatew ay, 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 1 6 states. 37

 American’s Los Angeles

- Haneda service will serve almost 10 times as many uniq ue connecting markets as H awaiian’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
g enerate 87 percent m ore O&D p assengers t han Hawaiian’s Kona c onnecting
m arkets
. 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 t ons
— 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 (3 65 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 one world 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
. Re spectfull y 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 SERVIC E I, Abigail Donovan, certify that, on January 12, 2015, I ca us ed 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@co oley.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 (P ort of Seattle) dan.weiss@united.com ( United) steve.m orrissey@united.com ( United) gmurphy@crowell.com ( United) sseiden@crowell.com ( United) i nfo@airlineinfo.com (AirlineInfo.com)

_________________________________ Abigail Donovan2 #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 43 #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 44 #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 45 #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 46 

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

## NARRATIVE TO SE RIES 100 REBUTTAL EXHIBIT S

Delta ’s a pplication 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 D ocket. With respect to Delta’s arguments concerning the substance and merits of the issues involved in this proceeding , it i s clear that Delta’s most current application for Seattle

- Haneda service is a far cry from the substantial effort that Delta unde rtook 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 : “I s Delta really com mitted to making Seattle

- Haneda work for the long

- term? ”
American’s 100 Series R ebuttal E xhibits focus on the inconsistencies and inaccuracies in Delta’s (re)application for Seattle

Haneda service. From a questionable service commitment to Seattle , to l ow 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 an d Haneda d uring w inter 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 dec ision 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 Seattle

Haneda service has performed so poorly . However, Exhibit AA

- R

- 102 shows that, with one sm all 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 avai lab le
. 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 betwe en 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 f actor 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 perform ed exceeding well
.Delta’s Seattle

- Haneda service not only experience s 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 show s as you unfold it, Seattle

- Haneda has the lowest load factor of all of Delta’s current intercontinental flight s . Exhib its 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 ve rsus 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 benefit s . In this case, American proposes to launch its own Los Angeles

- Haneda service with an a ircraf t 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 E xhibits 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 opportu nities 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 show s what the slot holdings at Haneda are by carrier and by allianc e . The comparison is not relevant , be cause slots at Haneda are not freely transferable be t ween carriers as shown in Exhibit AA

- R

- 115. What is relevant is that Delta is a leading holder of Haneda slots tha t are eligible for U.S. service and it is the large st 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 inclu ding 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, E xhibit AA

- R

- 126 shows all the cancelled intercontinental routes by Delta in recent years, and that all of these 34 routes except one ha d 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 kee p the route out o f 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 - 1028 #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 - 4019 #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 tha t 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 210 #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 100Load Factor %

Note: United currently operating SFO
- HND service but no publicly available information because of the recent inauguration of tha t 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 311 #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 Paris Hong Kong Tokyo - HND Seoul
- ICN Tokyo - NRT 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 Paris Hong Kong Tokyo - HND Seoul
- ICN Tokyo - NRT 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 schedules12 #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 313 #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 - 40114 #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 415 #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 416 #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 20131718 #LetAAFlyHaneda 

# D elta’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 H awaiian 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 - 10319 #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 - 10320 #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 - 10321 #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 - 30522 #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 - 30523 #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 424 #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 425 #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 f act, 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”

S ource : 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 - 30526 #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 - 30227 #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 

### DTW HND

SEA HND

LAX HND HNL HND

SFO HND JFK HND



## 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 - 30128 #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 - 30129 #LetAAFlyHaneda 

# Los Angeles Has Over 3.2 Times the GDP of the Seattle Area Gross Domestic Product of Los Angeles and Seattle $ Billions, 2013


# 1 0 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 - 20630 #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 Population GDP O&D Passengers to Tokyo O&D Passengers to Haneda 

# 2 2 

# 1 1

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 - 20631 #LetAAFlyHaneda 

# Los Angeles Has Over Four Times the Population of the Seattle Area
Population of Los Angeles and Seattle (Combined Statistical Areas, 2013) 

# 1 0 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 - 20532 #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 - 20533 #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 - 20534 #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 - 30135 #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 - 21236 #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 - 20537 #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 - 20438 

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

## NARRATIVE TO SERIES 200 REBUTTAL EXHIBITS

The 100 Series of American’s Rebuttal Exhibits demonstrate s that Delta’s (re)application for Seattle

- Haneda service is flawed
. This s eries of American’s Rebuttal Exhibits similarly de monstrates that , while Hawaiian has had great success operating Honolulu

Tokyo 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

- Hane da 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 com mends Hawaiian for fully utilizing its Honolulu

- Haneda slot pair by providing daily, year

- round service, unlike Delta ’s Seattle

- Haneda service . Exhibit s AA

- R

- 203 through 207 illustrate , however, that Kona is not Honolulu and that the Kona market is too sm all 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 ser vice proposal will benefit 15 s tates and 23 U.S. co mmunities in the summer and 16 s tates and 30 U.S. communities in the winter. Exhibit AA

- R

- 204 further shows that Hawaiian’s service proposal would not benefit even one per cent 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 Kon a - 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 o f 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 den ied 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. S tates  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 - 440 #LetAAFlyHaneda 

# Hawaiian Has Done a Commendable Job of Fully Utilizing I ts 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 35NovDecJanFebMarAprMayJunJulAugSeptOctNovDecJanFebMarAprMayJunJulAugSeptOctNovDecJanFebMarAprMayJunJulAugSeptOctNovDecJanFebMarAprMayJunJulAugSeptOctNovDecJanFebMar
HA HNL-HND Flights Days of MonthDays of Service

2013 2014 2015 2012 2011 

### In Rebuttal to Hawaiian Airlines Application at page 541 #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 - 342 #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 - 343 #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 - 344 #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 - 345 #LetAAFlyHaneda Note : Non - U.S. markets excluded for American (none for Hawaiian). 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 - 446 #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 - 447 #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 - 548 #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 649 #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 650 #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 351 #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 952 #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 five year 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 953 

# Letters of SupportJanuary 5, 2015

The Honorable Anthony Foxx United States Department of Transportat ion 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 ( H ND ) beginning in 2015 (DOT
- OST
- 2010 - 0018)

. The robust ties between Los Angeles and Japan provide an u nmatched foundation for American Airline s ’ proposed service, addressing unmet and growing demand for servi ce between LAX and HND . C urrent LAX - H ND 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 A ngeles and Haneda. The City of Los Angeles and the Southern California region look forward to improved a ccess 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 MayorGOVERNOR’S OFFICE OF BUSINESS AND ECONOMIC DEVELOP MENT 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 Hane da 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 To kyo 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 J apanese 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 Califor nia 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  B usiness.ca.gov  1325 J Street , 18 th Floor , Sacramento, California 95814January 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 14 th District, I repre sent Little Tokyo, a growing neighborhood in Downtow n, 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 local s and international travelers alike
. With approximately 250,000 Japanese Americans and 50,000 Japanese nationals living in Southern California , t ravel demand is substantial
. Additional Los Angeles service to Haneda would better connect travelers , familie s 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,

Cou ncilman Jose Huizar District 14, Los Angeles