BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Motion of 

DELTA AIR LINES, INC. 

In the matter of 2010 U.S.-Haneda Combination 

Services Allocation Proceeding

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Docket DOT-OST-2010-0018 

CONSOLIDATED ANSWER OF DELTA AIR LINES, INC.

Communications with respect to this document should be addressed to:

Glen Hauenstein

Executive Vice President – Network Planning

 & Revenue Management

Robert J. Cortelyou

Senior Vice President – Network Planning

Andreas Renner

Director – International Network Planning

DELTA AIR LINES, INC.

1030 Delta Boulevard

Atlanta, Georgia 30320

Andrea Fischer Newman

Senior Vice President – Government Affairs

DELTA AIR LINES, INC. 

1212 New York Avenue, N.W. 

Washington, D.C. 20005

Alexander Van der Bellen

Managing Director – Government Affairs

 & Associate General Counsel

DELTA AIR LINES, INC. 

1212 New York Avenue, N.W. 

Washington, D.C. 20005

(202) 842-4184

sascha.vanderbellen@delta.com

September 6, 2012
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Motion of 

DELTA AIR LINES, INC. 

In the matter of 2010 U.S.-Haneda Combination 

Services Allocation Proceeding

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Docket DOT-OST-2010-0018 

CONSOLIDTED ANSWER OF DELTA AIR LINES, INC.

Delta has requested permission to use its previously allocated slots to provide 

Seattle with its first and only nonstop Haneda service. Three carriers have filed competing 

applications: United seeks to provide a second daily service on the San Francisco-Haneda 

route; American would provide a third daily flight on the Los Angeles-Haneda route; and 

Hawaiian Airlines seeks a second pair of Haneda slots to provide additional service to 

Hawaii (which currently has three Haneda flights). As we show below, Delta’s SeattleHaneda proposal will provide superior public benefits, unmatched by any of the competing 

applicants. 

I. Executive Summary

Seattle is the largest U.S.-Tokyo O&D gateway that does not have nonstop service 

to Haneda. It is the also the largest west coast business center without Haneda service, 

placing Seattle and the Pacific Northwest region at a disadvantage to the existing west coast 

gateways of San Francisco and Los Angeles. Delta’s proposal will create the following 

public benefits:

• Seattle will be established as a new gateway, providing 114,000 annual 

Tokyo passengers with new nonstop access to Haneda.1

 New intergateway 

 1 See, DL-201 (MIDT data adjusted to account for direct sales). 
Delta Answer

Page 2

competition will be created with San Francisco and Los Angeles which both 

have one or more Haneda flights.

• 32 cities will receive round-trip connections, and an additional 10 cities will 

receive one-way connecting service to Haneda via Seattle. Seattle’s 

geographic location provides the largest catchment area and best network 

coverage of the United States. 

• The Pacific Northwest region will gain its first convenient access to Haneda 

because the existing west coast gateways are too far south and 

unreasonably circuitous. 

• The Delta/Alaska domestic marketing alliance will allow Alaska Airlines to 

bring its Seattle network into play, improving service and competition for U.S.-

Haneda passengers. Alaska and its employees will benefit from the 

additional traffic flowing across their system. 

Delta’s request to improve the utilization of its Haneda slots by moving them from 

Detroit to Seattle is clearly in the public interest. Delta’s request is also consistent with 

market-based principles that are fundamental to U.S. open skies policy. Delta recognizes 

that the Haneda bilateral compromise creates a unique limited entry situation within the 

Japan open skies agreement. The Department’s current distribution of Haneda slots 

promotes rough parity between the alliances with Delta having two slot pairs, Star two slot 

pairs, and oneworld three slot pairs. However, while Delta is limited to the Haneda 

gateways selected in the 2010 route case, Star and oneworld have commercial discretion to 

select their own Haneda gateways and redeploy the Haneda slots operated by ANA and 

JAL under their metal neutral joint venture alliances. This flexibility, combined with the

dominant incumbent hubs operated by ANA and JAL at Haneda, creates significant 

advantages for Star and oneworld. 

The Department can improve market-based competition at Haneda – and generate 

important new nonstop and network service benefits – by allowing Delta the flexibility to 

operate from its preferred U.S. mainland gateway at Seattle. It is both reasonable and 

commercially necessary for Delta to make network adjustments to improve under-performing 

flights. While Delta respects the regulatory requirement for this comparative selection 
Delta Answer

Page 3

proceeding, it would not be in the public interest for the Department to strip Delta of the 

Haneda slots it needs to compete with the U.S.-Japan immunized alliances. The loss of a 

slot pair would marginalize Delta in the U.S.-Haneda marketplace, leaving Delta with just a 

single daily flight to compete against the multiple daily transpacific flights and large Haneda 

hubs operated by Star and oneworld. This would increase market dominance by the U.S.-

Japan ATI alliances, and undermine Delta’s ability to compete in the U.S.-Tokyo and U.S.-

Japan marketplace. The following points highlight the key deficiencies of the competing 

Star and oneworld alliance proposals:

United

• United operates a metal neutral joint venture with ANA, the largest hub 

operator at Haneda. A further award to United/Star would undermine alliance 

competition with Star and oneworld each having three Haneda flights to 

Delta’s one.

• San Francisco already has nonstop Haneda service (on JAL), and United and 

ANA have discretion under their metal-neutral joint venture to add a second 

daily flight if that is the best use of the slot pair for the alliance. San 

Francisco should not receive a second Haneda flight at the expense of 

Seattle’s first nonstop service.

• United will rationalize San Francisco-Narita service, canceling out the 

benefits of its proposed Haneda flight. United admits that it intends to 

operate “at least one daily Tokyo Narita flight” – whereas United currently 

operates two daily Tokyo Narita flights for seven months of the year. (UA app 

at n.4) By contrast, Delta’s daily full year-round Seattle-Narita service will be 

maintained and the new Haneda flight will produce true incremental benefits.

American

• Los Angeles already has two daily nonstop Haneda flights, and American/JAL 

have the option to add a third under their metal-neutral Joint Venture.

• An award to American would create a less competitive distribution of Haneda 

slots, with oneworld holding four opportunities, Star two, and Delta one.

• American has already rationalized its JFK-Narita flight (with American flying 

JFK-Haneda and JAL flying JFK-Narita). American is currently reducing Los 

Angeles-Narita from daily to 5 weekly. Should American receive additional 

Haneda slots, the Department can expect American to fully rationalize its Los 

Angeles-Narita flight, as it did at JFK, thereby canceling out the benefits of its 

Haneda proposal. 
Delta Answer

Page 4

Hawaiian Airlines is also an applicant for Haneda slots. Hawaiian proposes to 

reestablish nonstop service between Tokyo and Kona, Hawaii. This route was previously 

operated by JAL for fourteen years -- from June 1996 to October 2010. Hawaiian does not 

need an award of Haneda slots to reestablish Tokyo-Kona service. The United States 

secured an open skies agreement with Japan, with the limited exception of Haneda. The 

open skies agreement includes Tokyo Narita, which is far and away the largest Japanese 

gateway to Hawaii. Yet, Hawaiian fails to offer any competitive service from Tokyo Narita, 

preferring instead to concentrate on protected limited entry routes and niche markets. If 

Hawaiian wants to offer Tokyo-Kona service, it is free to do so at Narita. Hawaiian does not 

need a further allocation of limited entry Haneda slots to provide this service. Delta’s 

service proposal is superior to Hawaiian’s because:

• Seattle and the Pacific Northwest have no nonstop service to Haneda, 

whereas Hawaii has three daily Haneda flights.

• Seattle nonstop service will benefit 114,000 nonstop Tokyo O&D passengers 

vs. 80,000 at Kona.

• Seattle service will benefit U.S. travelers while Kona service will benefit 

Japanese tourists.

• Kona does not have functional CBP/FIS facilities, and there can be no 

certainty that these facilities will be available at Kona in the near future, if at 

all.

• Delta’s proposal will preserve and enhance competition among the U.S.-

Japan network competitors at Haneda; Hawaiian’s proposal would consume 

Haneda limited entry authority for a niche market that can readily be served 

using open skies rights.
Delta Answer

Page 5

II. Delta’s Seattle-Haneda Service Proposal Will Maximize Public Benefits. 

A. Delta’s Proposal Will Preserve 3-Way Alliance Competition at Haneda and 

Enhance the Competitive Market Structure. 

When it first allocated the Haneda slots at issue, the Department did not weigh the 

impact that the pending United and American ATI applications would have U.S.-Haneda and 

U.S.-Tokyo service and competition. (Order to Show Cause, 2010-5-7, page 8; Final Order 

2010-7-2, page 6). However, now that United and American have been granted antitrust 

immunity with their Japanese partners, DOT has properly indicated that in considering 

Delta’s request to move its Haneda slots from Detroit to Seattle, DOT intends to consider the 

“overall competitive environment” and “market structure.” Order 2012-8-20, page 3. 

Permitting Delta to serve the Seattle gateway in competition with San Francisco and Los 

Angeles will satisfy the DOT’s competition and market structure objectives. 

The two immunized U.S.-Japanese alliances have inherent advantages over Delta, 

which does not have a Japan alliance partner. As a SkyTeam member and major U.S.-

Japan competitor, Delta is the only carrier capable of offering a competitive alternative to the 

west coast Haneda services of American/JAL at San Francisco and United/ANA at Los 

Angeles. The DOT has consistently sought to promote inter-alliance competition.2

 By 

approving Delta’s request, the Department will ensure that the two large immunized 

alliances are not allowed to eliminate competition in the U.S.-Haneda and U.S.-Japan 

markets. 

 2 See Order 2009-7-10, page 17 (“We also examined the changes in inter-alliance 

competition.... The ability of the ‘non-hub’ alliance members to compete at [a hub of 

another alliance] can benefit both business and leisure passengers.”); Order 2010-2-8, page 

28 (“[E]nhanced inter-alliance competition is beneficial for consumers across many 

markets....”)
Delta Answer

Page 6

B. Delta’s Seattle-Haneda Proposal Will Create Important Service Benefits for 

the Traveling Public

Seattle is the largest U.S.-Tokyo O&D market without Haneda service. DL-A-101. In 

addition, the Seattle gateway competes with San Francisco and Los Angeles for U.S.-Tokyo 

traffic and is disadvantaged in not being able to offer service to Haneda. DL-A-207, 407.

Delta, together with its partner, Alaska Airlines, will be able to offer convenient 

nonstop-to-nonstop Haneda service at Seattle from 42 points in the United States –

extending the benefits of Haneda service to the Pacific Northwest region and throughout the 

United Sates. DL-A-102, 103, 206, 406. Delta has built a successful international gateway 

at Seattle and will succeed in the Haneda market as it has in other international markets. 

Seattle’s demographic and business metrics support the establishment of Haneda service at 

the Seattle gateway. Seattle ranks near the top of 50 U.S. metropolitan areas in categories 

such as exports, growth, and household income. And, in 2011, two-way trade between the 

State of Washington and Japan surpassed $24 billion. (Answer of Seattle, p. 2). Yet, unlike 

the other major west coast business centers of San Francisco and Los Angeles, Seattle 

does not have any service to Tokyo’s preferred downtown airport. 

DOT can best achieve the public interest objectives it seeks to attain in this 

proceeding by allowing Delta to offer Haneda service at the Seattle gateway. This will 

enable Delta to better compete on the west coast with the services of the immunized 

alliance carriers. 

III. Delta’s Haneda Proposal is Superior to Those of United, Hawaiian and 

American.

A. United’s Proposal Would Undermine Alliance Competition and Produce 

Fewer Benefits than Delta’s. 

United’s proposal to provide a second daily flight at San Francisco should not be 

selected at the expense of Delta’s proposal to provide Seattle and the Pacific Northwest 
Delta Answer

Page 7

region with their first and only Haneda flight. United’s proposal would undermine 

competition in the U.S.-Haneda and U.S.-Tokyo marketplace by taking Haneda slots from 

Delta, the only effective network competitor to Star and oneworld, and concentrating them in 

the hands of Star -- the largest immunized U.S.-Japan competitor with the biggest Haneda 

hub. DL-A-105, 106, 201.

Star currently holds 2 U.S.-Haneda slot pairs (placing Star on par with 

Delta/SkyTeam). DL-A-201. However, unlike Delta, Star has the ability to select and 

change the Haneda gateways operated by ANA under the metal-neutral joint venture with 

United. If Star wanted to add a San Francisco-Haneda flight, United and ANA can jointly 

plan and implement that service today with no need for regulatory relief from DOT. DL-A203. Delta can only offer beneficial new competitive service at Seattle if DOT grants Delta’s 

motion. 

United’s application is disingenuous. United ignores the fact that it has a major 

antitrust immunized alliance with All Nippon Airways (ANA) covering the U.S.-Haneda, U.S.-

Japan, and U.S.-Asia marketplace. In fact, in 47 pages of text and exhibits, ANA is 

mentioned only once at footnote 8, where United concedes the existence of a codeshare 

relationship, but gives no hint as to the comprehensive nature of its joint venture. 

United’s forgotten ATI partnership with ANA is central to the Department’s 

consideration of this case – and to maximizing U.S.-Haneda service and competitive 

benefits. The U.S.-Japan antitrust immunized alliances are a defining characteristic of the 

U.S.-Haneda and U.S.-Japan marketplace. Throughout the antitrust immunity proceeding, 

United vigorously argued that antitrust immunity was necessary for United and ANA to 

achieve “metal neutral” benefits and efficiencies, including joint route planning, revenue 
Delta Answer

Page 8

sharing, and a single integrated network covering all of their U.S.-Japan service. See, 

Application of ANA/United/Continental (December 23, 2009, Docket OST-2009-350).

As urged by United and ANA, the Department found these benefit to be significant. 

DOT agreed to approve U.S.-Japan immunized alliances on the basis of the substantial 

benefits that Star would be able to achieve through “a truly metal neutral network” --

In the current environment, the two sets of parties are unable to cooperate on fares, 

route coordination, and other business plans on a network-wide basis because of the 

risk of a legal challenge. As such, the carriers are currently unable to implement 

many of the provisions that would deliver the most significant consumer benefits: 

joint pricing, joint scheduling, and network coordination. . . . Absent the ability to 

share revenues and establish a truly metal-neutral network, the alliances would also 

lack the commercial incentive to fully integrate their networks."

Japan ATI Show Cause Order 2010-10-4 at 15 (emphasis added). 

In its current application, United has abandoned all claims of benefit (or even 

recognition of) its metal neutral Joint Venture with ANA. United asserts that it should be 

authorized to serve Haneda “with its own U.S. aircraft and crews.” (p.1) United goes on to 

claim that its service would “provide increased competition in the U.S.-Japan market by 

adding a fourth U.S. carrier at Tokyo Haneda, [and] by introducing new carrier competition

for behind hub points . . .” (pp. 3-4) United’s “new carrier” competition claims in this case 

cannot be reconciled with fully integrated network and metal neutral joint venture claims it 

made in the ATI case. United cannot be a “new competitor” at Haneda because it has 

already been effectively merged with ANA for purposes of U.S.-Japan service and 

competition. As correctly stated by the Department when it approved the United/ANA 

immunized alliance: "The intended commercial effects of the ATI Applicants’ respective joint 

business agreements are similar to those resulting from a merger." Japan ATI Order 2010-

10-4 at 5. 
Delta Answer

Page 9

United cannot have it both ways. Either United and ANA are competitively merged 

and commercially integrated members of the Star ATI alliance or United and ANA have 

failed to realize the claimed benefits of their ATI alliance and should no longer be entitled to 

the benefit of antitrust immunity. The Department’s grant of immunity enables United (and 

American) to have access to Haneda through the metal-neutral transpacific services and 

hub operations of their Japanese partners. Delta’s only ability to compete at Haneda is 

though its two direct flights. 

United’s application should be denied on the basis of alliance and competition 

considerations alone. However, United’s San Francisco proposal is also inferior from the 

standpoint of service benefits: 

First, San Francisco enjoys Haneda service today, whereas Seattle is the largest 

U.S.-Tokyo gateway without nonstop service to Haneda. DL-A-207. In carrier selection 

cases, the Department has long emphasized the importance of “provid[ing] consumers with 

the special convenience of nonstop service in a market that does not receive it.” Order 98-

12-33 at 7. Delta’s Seattle-Haneda proposal would create this important new convenience, 

while United’s proposal would merely duplicate existing nonstop service on the San 

Francisco-Haneda route. Furthermore, United and ANA have flexibly within their alliance to 

offer San Francisco-Haneda service at their discretion, but Seattle will only receive Haneda 

service if the DOT approves Delta’s request. DL-A-202, 203.

Second, Delta’s proposal is superior from the standpoint of network service benefits. 

Seattle would be established as a major new gateway to Haneda in the Pacific Northwest 

region. Despite strong economic ties and a vigorous two-way trade relationship with Japan, 

Seattle and the Pacific Northwest have no effective service to Tokyo’s preferred downtown 

airport. Existing West Coast gateways in California are not viable for Pacific Northwest 
Delta Answer

Page 10

passengers, because they involve more than a thousand miles of additional circuity in each 

direction. DL-A-205. Because Seattle lies on the great circle route to Tokyo for the most 

U.S. cities, Seattle can provide effective intergateway competition with San Francisco and 

Los Angeles throughout the United States. United and Delta/Alaska would provide the 

same number of round-trip connections (32), DL-A-206; however, in most cases travel via 

Seattle is less circuitous, and Seattle would benefit more cities in underserved regions of the 

country that lack convenient Haneda connections today. Id.

Third, Delta will add true incremental service and capacity at Seattle, adding new 

daily Seattle-Haneda service while maintaining daily, year-round service to its Narita hub. 

United will produce fewer benefits because it will rationalize San Francisco-Narita service, 

canceling out the benefits of its proposed Haneda flight. United admits that it intends to 

operate “at least one daily Tokyo Narita flight” – whereas United currently operates two daily 

Tokyo Narita flights for seven months of the year. (UA app at n.4) Net of Narita 

cancelations, United would add less than half the new flights and capacity Delta would bring 

to the marketplace. DL-A-204.

B. Hawaiian Can Operate Tokyo-Kona Service Using Open Skies Authority; 

Hawaii Already Enjoys a Disproportionate Share of Haneda Service.

Hawaiian proposes to reestablish nonstop service between Tokyo and Kona, Hawaii. 

This route was previously operated by JAL for fourteen years from June 1996 to October 

2010. DL-A-303. Kona no longer has a functional CPB/FIS inspection facility, and 

Hawaiian concedes that the timeline and ability to resume international service at Kona is 

uncertain in light of these constraints. (HA App. at n.2).

Hawaiian does not need an award of Haneda slots to reestablish Tokyo-Kona 

service. The United States secured an open skies agreement with Japan, with the limited 

exception of Haneda. The open skies agreement includes Tokyo Narita, which is far and 
Delta Answer

Page 11

away the largest Japanese gateway to Hawaii. Yet, Hawaiian fails to offer any competitive 

service from Tokyo Narita. Instead, Hawaiian seeks out protected niche markets (such as 

Haneda), and secondary cities such as Sapporo, Fukuoka, and Osaka. DL-A-304. 

Hawaiian boasts that it has opened three new Japan gateways in the last two years. But all 

of Hawaiian’s new gateways combined generate fewer passengers than Narita, which 

Hawaiian conspicuously avoids. Id.

 If Hawaiian wishes to initiate Tokyo-Kona service, it is free to do so at Narita. 

Hawaiian does not need a further allocation of limited entry Haneda slots to provide this 

service. As detailed in Hawaiian’s open application, it has implemented a broad expansion 

strategy in the Hawaiian-Japan and Hawaii-Asia markets. While the Department may have 

been justified in providing Hawaiian preferential new entrant treatment in 2010, by its own 

account Hawaiian is now an established and successful incumbent. Hawaiian should be 

expected to take advantage of the Tokyo Narita open skies opportunities available to it 

today. 

Finally, while Haneda-Hawaii service is an attractive commercial proposition for 

carriers,3 it is not necessarily in the public interest to have so many limited entry 

opportunities concentrated in a single state. Hawaii receives three Haneda flights today, 

and a grant of Hawaiian’s application would result in half of all bilaterally authorized slots 

being concentrated in Hawaii. DL-A-302. Haneda-Hawaii flights are used almost 

exclusively by Japanese leisure passenger and do not produce benefits for the U.S. 

traveling public. DL-A-307,308.

 3

 Delta would welcome the opportunity to provide Haneda-Honolulu service. Delta is the 

only Tokyo-Honolulu competitor that does not have the ability to provide service from 

Haneda, placing Delta at a competitive disadvantage to Hawaiian, Star, and oneworld. 

Delta requested, but did not receive Haneda-Honolulu slots in the 2010 proceeding. 
Delta Answer

Page 12

In summary, Delta’s service proposal is superior to Hawaiian’s because:

• Seattle and the Pacific Northwest have no nonstop service to Haneda, 

whereas Hawaii has three daily Haneda flights. DL-A-302, 309.

• Seattle nonstop service will benefit 114,000 nonstop Tokyo O&D passengers 

vs. 80,000 at Kona. DL-A-301.

• Seattle service will benefit U.S. travelers while Kona service will benefit 

Japanese tourists. DL-A-307.

• Kona does not have functional CBP/FIS facilities, and there can be no 

certainty that these facilities will be available at Kona in the near future, if at 

all. DL-A-306.

• Delta’s proposal will preserve and enhance competition among the U.S.-

Japan network competitors at Haneda; Hawaiian’s proposal would consume 

Haneda limited entry authority for a niche market that can readily be served 

using open skies rights.

C. American’s Proposal to Provide a Third Los Angeles-Haneda Flight Would 

be Detrimental To Alliance Competition and Produce No New Service 

Benefits.

Oneworld already holds the three U.S.-Haneda slots pairs – more than any other 

U.S.-Japan competitor. Los Angeles has two daily nonstop Haneda flights, and 

American/JAL have the option to add a third Los Angeles service under their metal neutral 

joint venture. An award to American would undermine the competitive distribution of 

Haneda slots, with oneworld holding four opportunities, Star two, and Delta one. DL-A-401. 

All of the alliance competition considerations discussed above at pages 7-9 with regard to 

the United/ANA immunized alliance are fully applicable to American/JAL. In the interest of 

brevity, we incorporate those arguments by reference and will not repeat them here. 

Delta’s Seattle-Haneda service will create important nonstop service in the largest 

U.S.-Tokyo market without this benefit, and establish a large new hub network in the 

underserved Pacific Northwest Region. DL-A-405, 406, 407. American’s proposal would 
Delta Answer

Page 13

add a third daily flight to the well served Los Angeles-Haneda marketplace, and contribute 

no new network benefits beyond those provided today by Delta and United/ANA. Id. 

American has already rationalized its JFK-Narita flight (with American flying JFKHaneda and JAL flying JFK-Narita). And, American is currently reducing Los Angeles-Narita 

from daily to 5 weekly. Should American receive additional Haneda slots, the Department 

can expect American to fully rationalize its Los Angeles-Narita flight, as it did at JFK, thereby 

canceling out the limited benefits of its Haneda proposal. DL-A-404. 

IV. Conclusion 

Delta’s request to establish Haneda service at the Seattle gateway will improve 

Delta’s utilization of its Haneda slots, enhance consumer benefits, and promote competition 

on U.S.-Haneda routes. As show above, the competing applications of United, American 

and Hawaiian would produce fewer benefits and in fact undermine the public interest 

objectives the Department seeks to achieve in this proceeding. For these reasons, we 

respectfully urge that Delta’s motion for flexibility to use its Haneda slots at the Seattle 

gateway be granted.

Respectfully submitted,

_________________________________

Alexander Van der Bellen

Managing Director, Government Affairs

 & Associate General Counsel

DELTA AIR LINES, INC.
CERTIFICATE OF SERVICE

A copy of the foregoing Answer has been served this 6th day of September, 2012, upon 

the following persons via email:

Francis.Heil@aa.com

Robert.Wirick@aa.com

dan.weiss@united.com

thomas.bolling@united.com

lhalloway@crowell.com

gmurphy@crowell.com

howard.kass@usairways.com

benjamin.slocum@usairways.com

jhill@dowlohnes.com

paul.gretch@dot.gov

keith.glatz@dot.gov

esta.rosenberg@dot.gov

brett.kruger@dot.gov

todd.homan@dot.gov

urskr@state.gov

eugene_alford@ita.doc.gov

info@airlineinfo.com

Tim.OMalley@alpa.org

Ishiwata.K@portseattle.org

Safora.I@portseattle.org

Kyle.Levine@alaskaair.com

Megan.Lawrence@alaskaair.com
Delta Answer Exhibits

Section I: Delta’s Seattle-Haneda Service Proposal Will Maximize Service and 

Competitive Benefits

Section II: Rebuttal to United Airlines

Section III: Rebuttal to Hawaiian Airlines

Section IV: Rebuttal to American Airlines
Section I: Delta’s Seattle-Haneda Service Proposal Will Maximize 

Service and Competitive Benefits
Seattle is the Largest US Mainland-Tokyo Gateway Without 

Haneda Service

• With HND service now established at LAX (x2) and SFO, SEA is the largest West Coast-Tokyo 

gateway without Haneda service

481,791

293,257 246,782

84,359 37,707

LAX JFK SFO SEA DTW

US48-Tokyo Annual Passengers

YE July 2012

HND Service

No HND Service

Docket DOT-OST-2010-0018

Exhibit DL-A-101

Page 1 of 1

Source: MIDT

Note: Delta estimates SEA-TYO true market size to be approximately 35% higher (114,000) due to sales not captured via MIDT (direct 

bookings, data from non-participating GDS’s).
Seattle is an Ideal West Coast Gateway to Haneda 

Delta and Alaska Provide Nonstop Service to 62 U.S. Points 

Note: Includes service operated by Alaska/Horizon

Source: August 2012 schedules, Diio Mi

Docket DOT-OST-2010-0018

Exhibit DL-A-102

Page 1 of 1

To ANC, FAI, JNU, SIT, KTN

Haneda
Seattle is Geographically Positioned to Optimally

Connect U.S. Traffic to Haneda

• Seattle connections are less circuitous versus other West Coast gateways for points across the US—

including the Pacific Northwest, the Southeast and the East Coast

SEA is a more direct route to HND for the most US cities

SEA

SFO

Docket DOT-OST-2010-0018

Exhibit DL-A-103

Page 1 of 1
Two Delta US-Haneda Routes are Required to Maintain 

Competitive Balance

• The DOT’s instituting order in this proceeding emphasizes competition and market structure 

benefits

• Today US-HND capacity is balanced between the three major alliance groupings

3

2 2

oneworld

AA/JL

Skyteam

DL

Star

NH/UA

US-Haneda Slot Pairs by Alliance Group

Docket DOT-OST-2010-0018

Exhibit DL-A-104

Page 1 of 1

HNL 777

JFK 777

SFO 777

HNL 767

LAX 777

LAX 332

SEA 767
All Nippon Airways, 

43%

Japan Airlines, 35%

Other Japanese 

Airlines, 17%

All Non-Japanese 

Airlines, 5%

Japanese Carriers Control 95% of Haneda Slots

Source: Counts based on August 2012 scheduled passenger operations. Does not include non-scheduled or cargo operations.

524 daily 

operations

58 daily 

operations

Docket DOT-OST-2010-0018

Exhibit DL-A-105

Page 1 of 1

422 daily 

operations

214 daily 

operations
Delta Provides the Only Broad-based US-Tokyo Alliance 

Competition to Star and oneworld

Source: August 2012 OAG schedules

Delta

27%

United/ANA

41%

American/JAL

24% Foreign Flags

8%

U.S. Mainland-Tokyo Transpacific Seat Share

Delta Does Not Have a Japanese Carrier Partner

Docket DOT-OST-2010-0018

Exhibit DL-A-106

Page 1 of 1
Section II: Rebuttal to United Airlines
An Award to United Results in a Less Competitive 

Distribution of Slots among the Alliances and Undermines 

the Competitive Market Structure at Haneda

Docket DOT-OST-2010-0018

Exhibit DL-A-201

Page 1 of 1

3 3

1

oneworld Star Delta

US-Haneda Slot Pairs by Alliance Group

HNL 777

JFK 777

SFO 777

SFO 777

HNL 767

LAX 777

LAX 332

SEA 767
United Ignores its ATI Partnership with ANA and the 

Metal-Neutral Benefits Claimed to Justify Immunity

“United’s proposed San Francisco-Haneda flights will enable it to provide U.S.-Tokyo Haneda service 

through its San Francisco hub with its own U.S. aircraft and crews”

—Application of United Airlines Inc, DOT-OST-2010-0018

“The Pacific JV will foster “metal neutrality” – a commercial environment in which joint venture partners 

share common economic incentives to promote the interests of their alliance over their individual 

corporate interests.”

“...the Joint Applicants will harmonize their joint network and become indifferent as to which partner 

collects the revenues and operates the aircraft on a given itinerary.”

—United/ANA ATI Application, DOT-OST-2009-0350

 

Docket DOT-OST-2010-0018

Exhibit DL-A-202

Page 1 of 1
United Ignores its ATI Partner ANA Which Could Operate 

SFOHND Today

• Any of ANA’s current Haneda frequencies can be used to serve San Francisco under the metal 

neutral ATI with United

Origin Destination Operating

Carrier Alliance Equipment Eligible for SFO move

HND LAX NH UA/NH 777 YES

HND HNL NH UA/NH 767 YES

Docket DOT-OST-2010-0018

Exhibit DL-A-203

Page 1 of 1
Delta’s Seattle-Haneda Proposal Will Add More Than Twice 

as Many Flights and Seats to the Marketplace than United

• United admits it intends to operate “at least one daily Tokyo Narita flight” – whereas United 

currently operates two daily Tokyo Narita flights for seven months of the year

• Delta’s daily year-round Seattle-Narita service will be maintained and the new Haneda flight will 

produce true incremental benefits

163,520

81,238 730

302

Delta SEA United SFO

Annual Incremental Seats and Flights in 

West Coast-Tokyo Markets

Seats Flights Seats Flights

Docket DOT-OST-2010-0018

Exhibit DL-A-204

Page 1 of 1
Passengers Throughout the West Coast Can Conveniently 

Travel via Seattle – But Pacific Northwest Passengers are 

Inconvenienced by Travel via SFO

SEA

SFO

Docket DOT-OST-2010-0018

Exhibit DL-A-205

Page 1 of 1

SFO-HND SEA-HND

Nonstop Mileage 5,160 4,803

SFO-SEA-HND SEA-SFO-HND

Combined Connecting 

Segment Mileage 5,482 5,839

Circuity (%) 6% 22%

Circuity (Miles 

Roundtrip) 644 2,072

The Pacific Northwest and Alaska 

are more direct to HND via SEA
Delta and United Provide a Similar Number of Round-Trip 

Connections, but Delta will Better Serve the Pacific 

Northwest Region

UA SFO Connections

DL SEA Connections

To ANC, JNU, KTN

Carrier Total N. Am. RT 

Connections

East Coast RT 

Connections

West Coast RT 

Connections

Pacific NW RT 

Connections

United 36 8 28 9

Delta/Alaska 32 3 29 18

*Pacific Northwest defined as Washington, Oregon, Montana, Idaho, Alaska and Western Canada; West Coast defined as West of Texas.

Docket DOT-OST-2010-0018

Exhibit DL-A-206

Page 1 of 1
San Francisco Already Has Nonstop Haneda Service While 

Seattle Has None

2

1

0

LAXHND SFOHND SEAHND

US West Coast – Haneda Flights by Gateway

Docket DOT-OST-2010-0018

Exhibit DL-A-207

Page 1 of 1
Section III: Rebuttal to Hawaiian Airlines
Seattle-Tokyo Is Much Larger Than Kona-Tokyo Docket DOT-OST-2010-0018

Exhibit DL-A-301

Page 1 of 1

84,359

58,944

29,526

20,630

SEATYO KOATYO

Seattle-Tokyo is 43% Larger than Kona-Tokyo

Source: MIDT, YE Jul 2012

Note: Delta estimates true market size to be approximately 35% higher due to sales not captured via MIDT (direct bookings, data from nonparticipating GDS’s).

~114,000

~80,000

MIDT

True-Up
Current Distribution of HND Slots Is Concentrated In 

Hawaii, While The Pacific Northwest Has No Service Today Docket DOT-OST-2010-0018

Exhibit DL-A-302

Page 1 of 1

3

2

1 1

0

HNL LAX SFO JFK SEA

Daily HND Frequencies December 2012
JAL Served Tokyo-Kona For More Than 14 Years From 

Narita; Open Skies Opportunities Are Available to Hawaiian 

to Resume Service On The Route

93

217

366 360 357 351 359

293

364 364 359 363 357 359

301

1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

JL/JO Annual NRT-KOA Departures

Source: DOT, T-100

Docket DOT-OST-2010-0018

Exhibit DL-A-303

Page 1 of 1
Hawaiian Can Fly Additional Hawaii-Tokyo Service Today 

But Chooses Not To Do So Docket DOT-OST-2010-0018

Exhibit DL-A-304

Page 1 of 1

• Hawaiian avoids service at Tokyo Narita – the largest Japanese gateway to Hawaii

• Hawaiian selects markets where there is less competition – including HND and secondary Japan 

cities outside of Tokyo

0

7 7 7

3 0

58

14 14

7

0 0

NRTHNL HNDHNL KIXHNL FUKHNL CTSHNL NRTKOA

Hawaiian and Competitor Weekly Japan Frequencies

(Dec 2012 schedule)

Hawaiian

Competitors
Narita-Honolulu Is 46 Times Larger than Haneda-Kona

Docket DOT-OST-2010-0018

Exhibit DL-A-305

Page 1 of 1

878,180

346,115

39,639 19,305

NRTHNL HNDHNL NRTKOA HNDKOA

TYO-Hawaii MIDT Passengers for YE July 2012

Source: MIDT

• Hawaiian avoids Open Skies competition at Narita and seeks a protected limited entry advantage 

at Haneda
Hawaiian’s Application Depends on the Uncertain Ability to 

Add FIS Capabilities in Kona Docket DOT-OST-2010-0018

Exhibit DL-A-306

Page 1 of 1

“The initiation of Hawaiian’s service from Haneda to Kona may require updates to CBP/FIS facilities at 

Kona International Airport. Hawaiian already has reached out to the appropriate state and local 

officials to address this potential issue so that the facility satisfies current Department of Homeland 

Security standards in time for Hawaiian’s proposed start date for Kona-Haneda.”

-- DOT-OST-2010-0018

2012 Application of Hawaiian Airlines, Inc. p.4 footnote 2
Seattle-Haneda Will Benefit US Travelers Whereas KonaHaneda Will Benefit Japanese Tourists

33,132

1,484

SEA KOA

US Point-of-Sale Passengers Between the US and Tokyo

Year Ended July 2012

Source: MIDT

Docket DOT-OST-2010-0018

Exhibit DL-A-307

Page 1 of 1
Hawaiian’s Kona Proposal Would Benefit A Small Segment 

Of The US Population, While Delta’s Seattle Proposal Will 

Benefit Almost The Entire US

Docket DOT-OST-2010-0018

Exhibit DL-A-308

Page 1 of 1

• Kona service would benefit only Hawaii, which enjoys plentiful existing Haneda service

• Seattle service would benefit 49 of 50 US states by way of the connections Delta and Alaska 

Airlines provide via Seattle

307,385,237

1,360,301 185,079

US49 State of Hawaii Island of Hawaii

US Census Population Data for 2010
Docket DOT-OST-2010-0018

Exhibit DL-A-309

Page 1 of 1

Pacific Northwest Passengers Are More Inconvenienced By 

Lack Of Non-Stop Seattle-Haneda Service Than Kona-Haneda 

Passengers Are By Lack Of Kona-Haneda Service

• KOA-HND via HNL is only 0.1% more circuitous than KOA-HND nonstop service

• SEA-HND via LAX is 34% more circuitous than SEA-HND nonstop service

• SEA-HND via SFO is 22% more circuitous than SEA-HND nonstop service

SEA-HND KOA-HND

Nonstop Mileage 4,803 4,013

SEA-LAX-HND SEA-SFO-HND KOA-HNL-HND

Combined Connecting 

Segment Mileage 6,441 5,839 4,017

Circuity (%) 34% 22% 0.1%

Circuity (Miles 

Roundtrip) 3,276 2,072 8
Section IV: Rebuttal to American Airlines
Docket DOT-OST-2010-0018

Exhibit DL-A-401

Page 1 of 1

An Award to American Results in a Less Competitive 

Distribution of Slots among the Alliances and Undermines 

the Competitive Market Structure at Haneda

LAX 777

HNL 777

JFK 777

SFO 777

HNL 767

LAX 777

LAX 332

SEA 767

4

2

1

oneworld Star Delta

US-Haneda Slot Pairs by Alliance Group
Docket DOT-OST-2010-0018

Exhibit DL-A-402

Page 1 of 1

“Only the closer cooperation made possible through a joint venture based on metal neutrality – or 

indifference as to which airline actually carries a customer – will maximize the consumer benefits that 

immunized alliances make possible.”

“By providing for the broad sharing of revenue on a metal neutral foundation, the JBA will ensure that 

American and JAL act for the benefit of – and are compensated for their contribution to – the alliance 

as a whole.” 

--- American/JAL ATI Application ,DOT-OST-2010-0034 

 (12Feb2010)

American Ignores its ATI Partnership with JAL and the 

Metal-Neutral Benefits Claimed to Justify Immunity

“Delta’s Detroit-Haneda authority should be reallocated to American Airlines to operate service 

between Los Angeles and Haneda.” 

“Global alliance competition between Los Angeles and Haneda is limited to Star and SkyTeam. There 

is no Los Angeles-Haneda nonstop service operated or marketed by oneworld.”

--- Application of American Airlines Inc. ,DOT-OST-2010-0018 

 (27Aug2012)
Docket DOT-OST-2010-0018

Exhibit DL-A-403

Page 1 of 1

• Any of JAL’s current Haneda frequencies can be reallocated to serve Los Angeles under the metal 

neutral ATI joint venture with American

Origin Destination Operating

Carrier Alliance Equipment Eligible for LAX move

HND SFO JL AA/JL 777 YES

HND HNL JL AA/JL 777 YES

HND JFK AA AA/JL 777 NO

American’s Proposal Ignores its ATI Partner JAL, Which 

Could Operate LAXHND Today
Delta’s Proposal Would Introduce Incremental West Coast 

Capacity While American’s Proposal Would Not Docket DOT-OST-2010-0018

Exhibit DL-A-404

Page 1 of 1

• Delta’s daily year-round Seattle-Narita service will be maintained and the new Haneda flight will 

produce true incremental benefits

• American will rationalize their LAXNRT frequency in favor of LAXHND

• American has completely canceled JFK-NRT and relinquished this market to JAL

• American is already reducing LAX-NRT this winter (7x to 5x weekly in January 2013)

163,520

0

730

0

Delta SEA American LAX

Annual Incremental Seats and Flights in 

West Coast-Tokyo Markets

Seats Flights Seats Flights
Docket DOT-OST-2010-0018

Exhibit DL-A-405

Page 1 of 1

Passengers Throughout the West Coast Can Conveniently 

Travel via Seattle – But Pacific Northwest Passengers Are 

Inconvenienced By Travel Via LAX

SEA

LAX

The Pacific Northwest and Alaska 

are more direct to HND via SEA

LAX-HND SEA-HND

Nonstop Mileage 5,487 4,803

LAX-SEA-HND SEA-LAX-HND

Combined Connecting 

Segment Mileage 5,757 6,441

Circuity (%) 5% 34%

Circuity (Miles 

Roundtrip) 540 3,276
Delta’s Seattle Proposal Provides More Unique Roundtrip 

Connections and Better Service to the Pacific Northwest 

than AA’s Los Angeles Proposal

Docket DOT-OST-2010-0018

Exhibit DL-A-406

Page 1 of 1

DL SEAHND AA LAXHND

R/T connection cities without direct TYO service 25 14

R/T connection cities with direct TYO service 7 10

Total 32 24

Unique US Roundtrip Connection Cities

Based on Summer 2012 IATA Schedules

AA LAX Connections

DL SEA Connections

To ANC, JNU, KTN

To ANC
Los Angeles Already Has Nonstop Haneda Service While 

Seattle Has None Docket DOT-OST-2010-0018

Exhibit DL-A-407

Page 1 of 1

2

1

0

LAXHND SFOHND SEAHND

US West Coast – Haneda Flights by Gateway