page counter OST-2019-0014 - 2019 US-Tokyo (Haneda) Combination Services Allocation Proceeding - Instituting Proceeding

Home | Search | Help
OST by Number | OST by Order | OST by Carrier | OST by Subject | OST by Day
OIA by Carrier/Subject | OIA by Day | FAA by Number | FAA by Subject | FAA by Day| Charter Office


OST-2019-0014 - 2019 US-Tokyo (Haneda) Combination Services Allocation Proceeding - Instituting Proceeding

 

OST-2010-0018 - 2010 US-Tokyo (Haneda) Combination Services Allocation Proceeding

US-Japan Bilaterals

 


2019 US-Tokyo (Haneda) Combination Services Allocation Proceeding

Order 2019-2-5
OST-2019-0014 - 2019 US-Tokyo (Haneda) Proceeding
OST-2016-0048 - 2016 US-Tokyo (Haneda) Proceeding

Issued and Served February 7, 2019

Order Instituting Proceeding

The Department is instituting the 2019 Haneda Combination Services Allocation Proceeding to allocate up to twelve daytime slot pairs for US-carrier Haneda scheduled combination services. The Department expects to allocate the slot pairs for an indefinite term, subject to a start-up condition and to the Department’s standard 90-day dormancy condition. For any slot pair not used for a period of 90 days, the allocation with respect to that slot pair would expire automatically and revert to the Department for reallocation.

The Department also denies the motion of Delta Air Lines, Inc. for US gateway flexibility for current and future awards of Haneda slot pairs. Should the amended US-Japan agreement enter into force, US carriers would face an October 2019 deadline to file applications with Japanese authorities for takeoff and landing slot times at Haneda airport.

Based on the pleadings submitted in connection with Delta’s motion, it is clear that granting Delta’s request to consider gateway flexibility in this proceeding would introduce a complex and controversial element to the Department’s standard approach to deciding carrier selection proceedings that could substantially delay resolution of the case. The Department concludes that the public interest strongly favors structuring this proceeding to permit a prompt final decision in time for the selected carriers to meet the anticipated October 2019 deadline. The Department therefore declines to include consideration of gateway flexibility in this proceeding and, accordingly, denies Delta’s motion.

In light of the Department’s goal of reaching a prompt final decision, the following procedural schedule for submissions has been established:

Petitions for Reconsideration February 14
Answers to Petitions February 19
Applications February 21
Answers February 28
Replies March 7

By: Joel Szabat


 

February 21, 2019

Application of American Airlines

American requests the allocation of four Haneda slot-pairs for the following proposed services, in order of preference:

  1. One daily year-round service between Dallas/Fort Worth and Haneda
  2. One additional daily year-round service between Los Angeles and Haneda
  3. One additional daily year-round service between Dallas/Fort Worth and Haneda
  4. One daily year-round service between Las Vegas and Haneda

American currently provides one daily year-round LAX-HND service using a slot-pair awarded by the Department in 2016.

American’s top request is to commence daily nonstop Haneda service from its DFW hub, and its third request is to commence a second daily nonstop DFW-HND service. Obtaining slots for this service has long been American’s priority. The Dallas/Fort Worth area is a thriving local market for travel to and from Tokyo, yet it lacks any Haneda service today. American’s first and third proposals will bring much-needed Haneda service to the region, and will create many connections on both sides of the ocean via American’s and JAL’s respective networks at DFW and Haneda. As the runner-up in the Department’s 2016 Haneda proceeding, DFW-HND service greatly merits two of the newly-available Haneda slot-pairs.

Ample Haneda service is needed in Los Angeles more than anywhere else in the country. In the continental United States, Los Angeles is the largest O&D market for traffic to and from Tokyo, and it is home to many Japanese Americans. The current limitations on Haneda slots, however, have deprived Los Angeles residents of the optimal level of Haneda service; the majority of LAX-Tokyo flights use Narita, which is much less convenient for Tokyo O&D travelers. To ensure that Los Angeles has sufficient service to Haneda, American’s proposed LAX-HND service should receive one of the twelve newly-available Haneda slot-pairs.

Counsel: Dechert LLP, Michael Weiner, 202-261-3300




February 21, 2019

Application of Delta Air Lines

Delta applies for six daily pairs of US-Haneda combination slots to provide scheduled foreign air transportation of persons, property and mail to Haneda from the following US gateways, in order of priority:

  1. Seattle
  2. Detroit
  3. Atlanta
  4. Portland
  5. Honolulu #1
  6. Honolulu #2

The United/ANA and American/JAL joint ventures currently control 85% of Tokyo-Continental United States flying. The prospective Hawaiian/JAL joint venture and already approved United/ANA joint venture similarly control 86% of the Tokyo-Hawaii market. Delta is the only carrier participating in this proceeding that would enhance competition in these markets by expanding at Haneda.

For the sake of establishing competitive balance in Hawaii, Delta urges the Department to award it both of the Haneda-Honolulu slot pairs it seeks in this Application. Delta’s ability to attract a broad Japanese customer base is hampered without a presence in the key Tokyo-Honolulu market, which is by far the top US-Tokyo market. Two daily flights would allow Delta to compete with Hawaiian and JAL, which collectively have three daily flights, as well as the already immunized alliance between United and ANA.

The current US-Haneda slot environment is unfair to existing and prospective US-Haneda competitors that are not party to a metal-neutral joint venture with a Japanese carrier and, as such, cannot benefit from the flexibility afforded to the Japanese carrier partners. The lack of gateway restrictions for Japanese carriers renders ineffectual the Department’s gateway assignments on those carriers’ metal-neutral JV partners (i.e., American and United, and potentially Hawaiian). Of the five current ANA/United slot pairs, four are gateway flexible by virtue of ANA’s inherent flexibility. Of the three current JAL/American slot pairs, two are gateway flexible by virtue of JAL’s inherent flexibility. By contrast, Delta only operates two slot pairs to Haneda – both of which are gateway restricted. Delta is thus effectively subject to, and disadvantaged by, a different, more stringent regulatory scheme compared to its US-flag Haneda competitors United, American and, soon (potentially), Hawaiian. The competitive imbalance at Haneda will be exacerbated if the Department does not grant Delta’s application, in full, for six daily flights to Haneda from Seattle, Detroit, Atlanta, Portland, and Honolulu.

Counsel: Delta, Alexander Krulic, 202-216-0700




February 21, 2019

Application of Hawaiian Airlines

Hawaiian Airlines, Inc. respectfully submits this Application for the allocation of three of the twelve additional daytime Haneda operating authorities for daily scheduled, year-round, combination services at Tokyo International Airport. Hawaiian proposes to institute the following three daily flights from Honolulu, Hawai’i to Haneda:

Frequency Winter  
1 1240 HNL-HND 1730 1920 HND-HNL 0710
2 1040 HNL-HND 1530 2150 HND-HNL 0940
3 1340 HNL-HND 1830 2020 HND-HNL 0810
Frequency Summer  
1 1410 HNL-HND 1730 1920 HND-HNL 0815
2 1210 HNL-HND 1530 2150 HND-HNL 1045
3 1510 HNL-HND 1830 2020 HND-HNL 0915

Hawaiian respectfully submits to the Department that, based on the size of the Hawai’i-Japan market, Hawaiian’s track record of service in this market, the public benefits that will result from Hawaiian’s expanded service, and the Department’s interest in promoting diverse business models like Hawaiian’s, the record supports awarding Hawaiian an additional three daily frequencies.

While Hawaiian’s prior Haneda applications have been focused on the local market, the instant proceeding represents an opportunity for Hawaiian to serve passengers at previously unreachable points beyond Tokyo. With additional and earlier daytime authority being available and its new codeshare relationship with Japan Airlines, Hawaiian expects connecting traffic to points behind and beyond Tokyo, primarily to cities in domestic Japan, to grow significantly, increasing the quantity and quality of service options as well as needed competition. The additional connecting opportunities and the size of the Japan-Hawai’i market justify the Department’s granting three additional authorities to Hawaiian to serve the Tokyo-Honolulu market.

Counsel: Cooley LLP, Parker Erkmann, 202-842-7800

OST-2018-0009 - Hawaiian and JAL Codesharing
OST-2018-0084 - Hawaiian and JAL ATI Proceeding




February 21, 2019

Application of United Airlines

United applies for a total of six Haneda slot pairs for daily, year-round, nonstop service to Haneda from the following hub cities in order of priority:

First Priority: Three slot pairs for service to Haneda from Newark Liberty International Airport, Chicago O’Hare International Airport, and Washington-Dulles International Airport.

Second Priority: One slot pair for service to Haneda from Los Angeles International Airport.

Third Priority: Two slot pairs for service to Haneda from George Bush Intercontinental/Houston Airport and AB Won Pat Guam International Airport.

United’s proposed Haneda service will offer new incremental service to Haneda from Newark/New York, Los Angeles and Guam to meet growing demand. The remaining proposed slot pairs for Chicago, Washington, and Houston service will shift United’s existing service from Narita International Airport to Haneda to better serve consumers and communities across the United States.

United would add to its existing Guam-Tokyo service the first ever daily, scheduled service between Guam and Haneda – allowing Guam’s tourism industry to compete effectively with Hawaii for the large Japanese market. As for Narita, United will continue to provide service from its East Coast hub at Newark/New York, from the central US via Denver International Airport. United will also continue to serve Narita from its West Coast Asia/Pacific gateway at San Francisco, as well as from Los Angeles.

Counsel: Jenner & Block, Aby Bried, 202-639-6877


 


February 28, 2019

Answer and Rebuttal Exhibits of American Airlines

American seeks four Haneda slot-pairs to bring much-needed competition to the US-Japan and US-Asia markets, where American has long trailed Delta and United due to its historical disadvantages. The full grant of American’s application will improve competition for transpacific travelers, while leaving ample slot-pairs for other carriers to introduce and expand Haneda service at their key gateways as well. In sharp contrast to American’s modest request, Delta and United each aim to capture half of the available Haneda slot-pairs for themselves, while Hawaiian wants three more Haneda slot-pairs to balloon service on a single route. The grant of any of their overreaching proposals at American’s expense would suppress competition and harm the traveling public. Because only a thriving US-Japan and US-Asia competitive environment will create the most benefits for passengers, American’s application should be granted in full.

None of the other applicants advance any convincing reasons why their exorbitant requests merit selection over American’s four proposals.

Counsel: Dechert LLP, Michael Weiner, 202-261-3300




February 28, 2019

Answer of Delta Air Lines

At their core, the applications in this case invite the Department to distinguish luxury from need. Given the enormous disparity in slot portfolios between United/ANA, American/JAL, and (prospectively) Hawaiian/JAL, on the one hand, and Delta, on the other, any slots awarded to United, American and/or Hawaiian at the expense of Delta’s proposal would exacerbate the competitive imbalance at Haneda. Because of their existing or prospective joint ventures, United, American, and Hawaiian do not need an allocation of any Haneda slots from the Department to provide many of the public benefits cited in their applications. Rather, they will have ample access to Haneda through the metal-neutral joint ventures with their Japanese partners. In contrast, Delta’s slot proposal is based on need – the need to establish a meaningful presence at Tokyo’s preferred airport, the need to inject some semblance of competitive balance at Haneda, and the need to serve Haneda from a diverse array of communities that currently do not enjoy nonstop or convenient one-stop service to Tokyo’s preferred airport.

Rather than further entrench United and American at Haneda and add to the stockpile of slots they already hold at that airport through their metal-neutral joint venture partnerships, the Department and the traveling public would be better served by an award of six slot pairs to Delta. The Department can best address this competitive imbalance by granting Delta’s application in full, and then allocating the remaining six slots as the Department deems appropriate among the competing proposals from United, American and/or Hawaiian. Delta expresses no view as to how those remaining six slots should be awarded, but urges the Department to consider the competitive balance at Haneda when making those decisions, as well as the strong possibility that any awards to United, American and Hawaiian could very well be duplicative – either now or in the near-term – of service provided by the Japanese JV partners.

Delta urges the Department to grant its application to provide new nonstop service to Tokyo’s prized Haneda airport from Seattle, Detroit, Atlanta, Portland, and Honolulu.

Counsel: Delta, Christopher Walker, 202-216-0700




February 28, 2019

Consolidated Answer of Hawaiian Airlines

Hawaiian’s proposal to serve Haneda from Honolulu is the strongest application in this proceeding. Based on the size of the market – Tokyo-HNL is the largest US-Japan market with the most Tokyo passengers – the Department is more than justified in granting at least four frequencies to HNL. While the applications of other airlines include meritorious service proposals, those proposals in the aggregate either contemplate serving smaller markets or propose smaller aircraft and consequently will result in fewer public interest benefits. As will be discussed specifically below, the other airlines propose services that overlap with existing service or the service of immunized partners, may result in takedowns of Narita service, and introduce connections that are duplicative. In light of the comparison between the public interest benefits of Hawaiian’s proposal and the proposals of other airlines, Hawaiian respectfully submits that its historical performance, the significant public interest benefits that will result from its expanded service, and its unique business model as a relatively smaller carrier serving a leisure destination support the grant of Hawaiian’s Application.

Counsel: Cooley LLP, Parker Erkmann, 202-842-7800




February 28, 2019

Answer of JetBlue Airways

Delta advanced several arguments in support of its application that are identical to JetBlue’s arguments in parallel antitrust immunity proceedings that are pending before the Department. Specifically, Delta has described a “stark competitive imbalance at Haneda” and asserted that it needs additional slots to “provid[e] meaningful competition” and “enhance competition with the various joint ventures that have been granted ATI or are pending antitrust immunization, which dominate US-Japan travel.” Delta’s comments regarding the dangers of unchecked immunized joint ventures operating from Haneda, and the importance of the Department fostering opportunities for non-immunized carriers to compete with the immunized joint ventures, apply with equal force at other slot-restricted and access-restricted airports, including but not limited to London Heathrow Airport and Amsterdam Airport Schiphol. Delta’s various arguments support JetBlue’s pending requests that the Department take steps to ensure meaningful competition at these slot-restricted European airports.

Delta cannot have it both ways. It cannot seek Department assistance for additional access at Haneda while seeking to deny it to JetBlue at LHR and AMS. Should the Department accept Delta’s rationale and grant it the additional Haneda slots it seeks based on the arguments advanced by Delta, then fundamental fairness and due process dictate that the Department also recognize JetBlue’s need for similar access at LHR and AMS.

To the extent that enabling Delta to enter LHR and Haneda was key to ensuring not only de jure but also de facto open skies when the US entered into open skies agreements with the EU and Japan, respectively, JetBlue’s ability to enter and compete at LHR and AMS today is critical to ensuring that de facto open skies continue to exist in key US-UK and US-Europe markets. JetBlue agrees with Delta that “DOT has [the] power to better level the competitive landscape” at slot-restricted airports and urges the Department to proceed in an even-handed manner not only at Haneda, but also at both Heathrow and Schiphol.

Counsel: JetBlue, Robert Land, 202-715-2565




February 28, 2019

Consolidated Answer of United Airlines

The competing applications do not focus on US consumers and communities but instead are myopically concerned with their own commercial agendas. Their applications reflect poorly formulated proposals with no regard to the actual service needs between the US and Tokyo. American’s and Delta’s proposals reflect both carriers’ continued lack of commitment to Tokyo. Delta, one of the world’s largest airlines, continues to revise history to paint itself a victim of competition, when in fact it is a victim of its own Asia strategy. American’s Application confirms that Tokyo is an after-thought, as its proposed gateways are inferior to United’s. And Hawaiian continues to be single-mindedly focused on Japanese tourists, rather than US consumers.

In addition, Delta continues to skew reality to match its narrative and its continued focus on United’s relationship with ANA distorts the facts. Repeating an untruth often enough does not make it the truth. If United had more than enough slots through ANA to meet consumers’ demands, United’s Application would be unnecessary and the resources United is expending to undertake this effort superfluous. However, this is not the case. United does not and cannot control ANA’s Haneda slots, the overwhelming majority of which are slotted for Japanese domestic service, and United requires its own Haneda slots to provide greater access, convenience, and the high level of transpacific service US consumers have come to expect. United’s Application for enhanced Haneda service reflects its recognition – along with that of the Department in this proceeding – of the importance of Haneda to consumers. No amount of Delta’s misstatements and diversions can obscure the main issue in this proceeding: which carrier is most likely to offer and maintain Haneda service for the benefit of the US traveling public. And based on the applications alone, which reflect the applicants’ best efforts to showcase and demonstrate the benefits of their proposals, that carrier is without a doubt United.

Counsel: Jenner & Block, Abby Bried, 202-639-6877




Febraury 28, 2019

Letters in Support of American Airlines

Counsel: American, John Williams




February 28, 2019

Letters and Testimonials in Support of United Airlines

  1. Letters of Support of Employees
  2. Letters of Support from Customers
  3. Public Expressions of Support

Counsel: Jenner & Block, Amna Arshad, 202-639-5344




February 28, 2019

Answer of the City of Chicago Department of Aviation in Support of the Application of United Airlines

Service between Chicago and Haneda will complement and significantly enhance the Asia service currently operating at O’Hare (including United’s own services to Beijing, Hong Kong, and Shanghai). Currently, United and Japanese carriers All Nippon Airways and Japan Airlines each operate daily year-round flights between O’Hare and Tokyo’s Narita International Airport. American Airlines operates a year-round, three-times weekly flight between O’Hare and Narita, which JAL (American’s oneworld partner) supplements with four additional weekly flights during the summer months. ANA also operates a daily year-round flight between O’Hare and Haneda, which it shifted from Narita in 2016.

Shifting United’s existing service from Narita to Haneda would result in substantial public benefits. Haneda provides much more convenient access to downtown Tokyo, eliminating the need for cumbersome and often unpredictable surface connections, allowing business travelers to maximize their productive time in Tokyo and, in some cases, reducing the number of required overnight stays. Demand for service to the Chicago-area from Japan is primarily composed of time-sensitive business travelers, which benefit tremendously from the improved access to Tokyo’s business district which United’s proposed Haneda service would afford. Indeed, travelers on United’s proposed schedule would arrive in Haneda at 3:55 p.m. during the summer season and 4:30 p.m. during the winter season, facilitating dinner meetings and time with family that ANA’s service between O’Hare and Haneda does not currently afford.

Counsel: Kaplan Kirsch & Rockwell, Stephen Kaplan, 202-955-5600




February 28, 2019

Answer of the City of Houston

United’s services between Houston and Japan are vitally important to the Houston community. Japan is Houston’s 7th-largest international trading partner, and the value of that trade has grown substantially over the past decade, reaching a record high of $6.4 billion in 2017.4 The strong and varied business and cultural ties that Houston and Japan share make convenient air service linkages essential. Houston is fortunate to be the chosen location for nearly 150 subsidiary operations of over 100 Japanese businesses, and Houston firms have 20 subsidiary locations in Japan. Furthermore, Houston has a substantial Japanese, foreign-born population that would benefit from the convenience that Haneda services can provide. Not only are the City’s air transportation services to Japan vital as the key link for the Houston region’s global industries and the traveling public, they also play an important role as a major connecting point for services between Latin America and Japan given Houston’s location and its status as one of the US’ largest gateways for Latin America air services.

In addition to those advantages, the public interest would benefit from enabling Houston-Haneda service from United that is competitive with that of other US gateways – including particularly Dallas-Ft. Worth and Atlanta should those cities receive new Haneda service – and with foreign carrier competition at Houston. United’s commitment to Tokyo and the Asia/Pacific market has played an important role in Houston’s ability to obtain the international services that the City needs. Prior to
implementation of the US-Japan Open Skies agreement in 2010, United and Houston jointly supported the US Government’s efforts to reach that breakthrough agreement, which has brought extensive benefits to the Houston and Texas regions as well as to their connecting passengers. United’s plan to add the convenience of Haneda flights to those benefits is a further demonstration of this commitment.

Counsel: Rachel Trinder, 703-927-5657




February 28, 2019

Answer of the New Jersey Parties

Without a doubt, the most important service enhancement for US-Japan consumers is nonstop service to close-in Tokyo Haneda. Despite the fact that Newark/New York is the largest metropolitan area in the United States and that there are over four million people currently living within 20 miles of Newark Liberty west of the Hudson River, the airport is not able to offer nonstop service to Tokyo Haneda. United’s proposed daily Newark/New York City-Tokyo Haneda service will thus offer new, convenient service to a substantial number of travelers. Indeed, United’s proposed Newark Liberty-Tokyo Haneda catchment area represents 1.2 million annual bookings. United’s proposal will provide service to far more travelers than any of the other new proposed gateways.

By: Newark Regional Business Partnership, Chip Hallock, 973-242-4209




February 28, 2019

Answer of the Port Authority of New York and New Jersey

The Port Authority is pleased to note that United has ranked its EWR-HND application as a top priority. As the only applicant proposing to serve the New York and New Jersey region, it is essential that United be granted this right. The New York and New Jersey region, centered by the City of New York, is the global capital of finance, media and fashion and the host city to the United Nations. United is the only US-flag carrier currently offering nonstop service from this region to Asia, and the region will greatly benefit from this additional service to United’s Asian network from EWR.

Just as HND and NRT serve distinct roles for Tokyo, each airport within the Port Authority’s portfolio has a distinct role. EWR and JFK are both large international gateways airports with diverse route networks that are used by residents of and visitors to New York City and the entire New York and New Jersey region. Nevertheless, many variables, including geography and traffic challenges, create distinct local markets for EWR and JFK. Residents and visitors have strong preferences to use EWR when their origin or destination is located in New Jersey. Further, the market dynamics of EWR and JFK differ in airline market share and alliance partner makeup. United operates a connection hub with an expansive domestic network and commands majority market share. Although there is current service to JFK from HND, EWR is a distinct market that remains unserved.

Counsel: PANYNJ, Steven Marinko




February 28, 2019

Answer of the Port of Portland in Support of the Application of Delta Air Lines

Additional Letters of the Port of Portland in Support of the Application of Delta Air Lines

Grant of Delta’s application for PDX-HND nonstop service is critical to the Oregon economy and travelling public. All the carrier applicants agree that Haneda is the superior Tokyo airport, and, as Delta has stated in its application, Narita service is not sustainable in the long term. The PDX-Tokyo route which began over 30 years ago at Narita, has become a pillar of Oregon’s trade with Japan and is an integral component of Oregon’s future growth and economic health.

The Haneda route is a top community priority and has received overwhelming support from community and business leaders. Attached to this filing are strong letters of support from Governor Brown of Oregon, the full Oregon Congressional Delegation along with three members of the Washington delegation, Mayor Wheeler of Portland, businesses including Nike, Intel, Columbia Sportswear, Japanese Business Association (Shokookai) representing all major Japanese investors in the region, the Japan-America Society of Oregon as well as representatives from the leading cultural, educational and tourism promotion organizations in our region.

By: Ann Gravatt




February 28, 2019

Answer of the Port of Seattle

In addition to being the largest US O&D market to Tokyo without service into Haneda, the allocation of one of Haneda’s twelve new daytime slot pairs to Seattle would provide numerous secondary cities with their lowest-circuity access into Haneda, bringing significant public benefits to the largest possible geographic area.

Granting Delta’s application for Seattle-Haneda service would not only be in the best interest of Seattle and the entire northwest quadrant of the country, but would also foster the DOT’s long--standing objective to increase inter-gateway competition in limited entry markets. In previous orders, the Department has found that “the establishment of a wholly new US gateway for nonstop Haneda service, i.e., Seattle, outweighs the benefits of adding a second nonstop flight to San Francisco,” and that “given the very limited opportunities for US carrier service to Haneda, we tentatively do not find…arguments persuasive for adding more Haneda service at Los Angeles while other significant US-Tokyo gateways have no access to Haneda.” Both findings are equally applicable in the current proceeding.

Counsel: Tom Tanaka, 206-787-3007


 

March 1, 2019

Support Letter of World Affairs Council of Dallas/Ft. Worth for American Airlines

Counsel: American, John Williams

 

March 4, 2019

Support Letters for American Airlines

Counsel: American, John Williams

 

March 5, 2019

Support Letters for American Airlines

  • Bank of Nevada, Nevada State Bank, Vegas PBS, Eide Bailly LLP, HighTower Las Vegas, Newmark Knight Frank, Southwest Gas Corporation, Piercy Bowler Taylor & Kern, The Beckley Group, William Hill

Counsel: American, John Williams




March 5, 2019

Support Letter for American Airlines

  • President of UNLV

Counsel: American, John Williams

 

March 6, 2019

Support Letter for American Airlines

  • Gordon Ramsay

Counsel: American, John Williams


 

March 7, 2019

Consolidated Reply of American Airlines

The Department’s goals of maximizing public benefits and enhancing competition will be served best by this balanced allocation of ten slot-pairs. No allocation that awards half the Haneda slot-pairs to one network carrier while disfavoring another carrier’s top priorities will create greater public benefits.

Under a balanced distribution of ten Haneda slot-pairs, the Department’s primary focus would be to maximize public benefits with the remaining two slot-pairs. This would involve the following Haneda proposals: American’s LAS-HND proposal; Delta’s PDX-HND and two HNL-HND proposals; United’s LAX-HND, IAH-HND and Guam-HND proposals; and
Hawaiian’s two HNL-HND proposals.

Among all these proposed Haneda services, American’s proposed Haneda service at Las Vegas unquestionably will create the most public benefits. Aside from being the only gateway proposed in this proceeding without any nonstop Tokyo service, many factors support the award of Haneda service in Las Vegas: it will serve strong local and Japanese demand, improve passenger choice and convenience, promote geographic diversity, enhance inter-gateway competition, and deliver substantial, first-time economic benefits to the State of Nevada. The other candidates for the two remaining Haneda slot-pairs fall into three categories: (1) proposals for service from other primarily Japanese-originating markets with multiple existing daily services to Tokyo (Honolulu and Guam, with Honolulu also enjoying multiple existing daily services to Haneda); (b) markets with significantly smaller PDEWs than Las Vegas (Portland and Houston); and (c) proposals distinctly inferior to American’s for service on the same route (LAX).

In contrast to the balanced distribution of slot-pairs proposed by American, the other applicants each filed answers urging the Department to reject most or all of American’s proposals. But these answers provide no convincing reason for the Department to deny the traveling public the benefits of any of American’s proposals.

Counsel: Dechert LLP, Michael Weiner, 202-261-3300




March 7, 2019

Reply of Delta Air Lines

The answers filed by United, American and Hawaiian underscore why Delta’s US-Haneda service proposals will create the greatest competitive benefits for the traveling public. The dominance of the immunized United/ANA, American/JAL, and (prospective) Hawaiian/JAL metal-neutral joint ventures creates a strong public interest need to establish and maintain competition at Haneda – an anomalous, non-open skies airport in an otherwise Open Skies country. Delta is the only competitor in this proceeding that would bring competitive discipline to the metal-neutral joint ventures operating at Haneda. The traveling public will benefit if Delta is able to compete with those carriers on a more level playing field, but it can only do so if the Department grants Delta six Haneda slot pairs in this route case.

None of the answers filed by United, American, or Hawaiian refute Delta’s well-documented position that Delta, as the only competitor in this proceeding without a current or prospective Japanese JV partner, is inherently disadvantaged at Haneda. Nor do any of the competing applicants dispute the fact that this route case presents the one opportunity for Delta to obtain greater access to Haneda. Delta’s competitive disadvantage at Haneda, coupled with the strength of its service proposals, warrant a full award of six slots to serve Haneda starting in the summer 2020 season.

A grant of slots to United, American, and/or Hawaiian at the expense of any of Delta’s proposed routes would be additive to the routes already (or prospectively) available to them under the umbrella of immunized cooperation with ANA and JAL and would result in increased concentration and less competition on hundreds of US-Haneda O&D markets. The US-Haneda proposals submitted by United, American, and Hawaiian, while meritorious in many respects, suffer from the same fundamental flaw: they are inherently duplicative of current or prospective service by their immunized metal-neutral joint venture partners.

Finally, the Department should ignore JetBlue’s “cameo” Answer. The arguments JetBlue makes are logically flawed and irrelevant to this proceeding.

Counsel: Delta, Christopher Walker, 202-216-0700




March 7, 2019

Consolidated Reply of Hawaiian Airlines

Because Hawaiian proposes to serve the largest market in this proceeding, Hawaiian respectfully submits that its proposal to serve Haneda from Honolulu is the strongest application. Hawaiian agrees with Delta that “Honolulu will serve the largest US-Tokyo market” and appreciates that, despite its prior opposition to additional Hawai’i frequencies, Delta now recognizes the “important Hawaiian market.” Hawaiian further agrees with Delta that Hawai’i deserves more authority: “in the context of such a large set of international slots potentially coming online at Haneda, additional [Hawai’i-Haneda] service is warranted at this time.” Hawaiian could not agree more strongly.

In contrast, the answers of United and American argue that Honolulu should not be awarded multiple frequencies in this proceeding. In doing so, neither American nor United contest the size of the Tokyo-Honolulu market. Instead, they assert that the “geographic diversity” offered in their applications favors selection of their proposals over the Honolulu authorities proposed by Hawaiian and Delta. While Hawaiian recognizes the important role that geographic diversity can play in a route allocation proceeding, that factor does not prevail when the market size of one gateway overwhelms the others.

In a proceeding where sufficient frequencies are available to serve diverse interests, the Department will grant multiple frequencies to the largest markets. Recently, in the 2016 US-Cuba Route Allocation Proceeding, the Department analyzed applications to serve Havana, Cuba to initiate scheduled service there for the first time in more than fifty years. Carriers proposed markets from across the country, but the Department carefully scrutinized the likely local demand. In the absence of traffic data, the Department found “that the Cuban-American population centers in the United States are the areas in most need of scheduled service to Havana…” and “that Florida markets, particularly South Florida markets, deserve a substantial allocation of Havana frequencies to address the service needs of the large local traffic base.” To serve the anticipated demand, the Department allocated nearly 12 of the 20 available Havana frequencies to the South Florida airports of Miami and Fort Lauderdale, which are located in a single metropolitan region.

Application of the decisive principle in the US-Cuba Allocation Proceeding to this proceeding requires the allocation of at least four frequencies to HND-HNL service. Here, the Department does not need to infer the likely demand. The pattern is well established, and the Hawai’i-Japan market dwarfs all of the other markets

Counsel: Cooley LLP, Parker Erkmann, 202-842-7800




March 7, 2019

Consolidated Reply of United Airlines

Nowhere does the Department state that its sole focus is to restore Delta’s presence in Japan that it has voluntarily and strategically been relinquishing, to help American play catch-up due to Delta’s and United’s alleged “four-decade head start,” or to rectify Hawaiian’s position as a “small carrier compared to every other applicant in this proceeding.”

After two rounds of filings, United is the only carrier solely focused on utilizing the scarce and valuable Haneda slots to benefit US consumers and communities that it serves in a thoughtful, strategic and overall holistic manner. As described and supported in detail in United’s Application and Answer, United’s proposed Haneda routes will optimize the US public benefit these types of proceedings are based upon. United’s application will give consumers a greater number of routing and fare options, increased connectivity to points in Japan beyond Tokyo, enhanced connection options across the US for flights to Tokyo Haneda, significant cost and time savings, multiple Haneda gateways across the US, continued options to fly to Narita for access to Asia/Pacific destinations that airport provides, and in gateways served by ANA, United proposes flights at different times of day.

United intends to rise above the other carriers’ cacophony focusing on their own self-interested agendas and to urge the Department to remain focused on its mandate to serve the public interest, which requires a responsible balancing of the enumerated factors with the principal goal of maximizing public benefits.

Counsel: Jenner & Block, Abby Bried, 202-639-6877




March 7, 2019

Reply of Dallas/Ft. Worth International Airport Board, Owner and Operator

The Dallas Fort Worth International Airport Board, the owner and operator of Dallas Fort Worth International Airport, together with Dallas Mayor Mike Rawlings, Fort Worth Mayor Betsy Price, Texas Senator John Cornyn, and Texas Governor Greg Abbott, strongly encourages the United States Department of Transportation to award two pairs of daytime operational slots at Tokyo Haneda Airport to American Airlines, for American to operate two daily roundtrips between HND and its largest hub, DFW.

By: John Ackerman




March 7, 2019

Reply of the Delta Master Executive Council of the Air Line Pilots Association, Int'l

Delta MEC, on behalf of its members, respectfully submits that a full grant of Delta’s Application for six US-Haneda slot pairs will provide the greatest benefits to the traveling public. In addition to new service to Haneda for Delta’s customers and employees from the proposed gateways, Delta’s overall service proposal will enhance competition with the metal-neutral joint ventures that have already been granted antitrust immunity or are pending ATI, which currently dominate US-Japan travel. Delta’s Tokyo operations were moved from their original location at Haneda to Tokyo’s Narita Airport following a change in Japanese airport policy in 1978, which shifted international flights to Narita. Since that time, ANA and JAL have built large hub operations at Haneda, which also benefit their joint venture partners.

By: Ryan Schnitzler




March 7, 2019

Answer of the Las Vegas Convention and Visitors Authority and Clark County Department of Aviation

The LVCVA and McCarran respectfully and enthusiastically respond in strong support of American Airlines’ Las Vegas to Tokyo Proposal to serve Tokyo’s Haneda Airport. The Proposal best meets the needs of the traveling and shipping public and creates substantial economic benefits for Las Vegas, the State of Nevada, the Mountain West region and the United States.

By: Rosemary Vassiliadis, 702-261-5211




March 7, 2019

Reply of the Port of Portland to the Consolidated Answer of American Airlines

The Port of Portland hereby responds to the Consolidated Answer of American Airlines in which American questions the viability of the proposed PDX-HND nonstop service. American’s concerns are misplaced.

The sustained success of the existing Narita service is sufficient to rebut American’s claims. Furthermore, there is compelling evidence that the proposed 2020 Haneda service should be even stronger than the longstanding Narita service.

the acid test of PDX-HND route viability is whether an airline will commit resources to fly it. Here, that test has been met by Delta’s proposal to provide the service. Delta’s long history serving PDX-TYO puts it in a unique position to evaluate the route’s sustainability, and it has chosen to commit significant and valuable resources to serving the route.

By: Curtis Robinhold





March 7, 2019

Re: Support Letters for American Airlines

  1. Congresswoman Dina Titus (NV-1)
  2. Congressman Mark Ameodei (NV-2)
  3. Congresswoman Susie Lee (NV-3)
  4. Congressman Steven Horsford (NV-4)




March 7, 2019

Re: Support Letters for American Airlines - US-Japan Council

  1. Los Angeles-Haneda
  2. Las Vegas Haneda
  3. Dallas/Fort Worth-Haneda

By: Irene Hirano Inouye




March 7, 2019

Re: Support Letter for American Airlines - Toyota Motor North America

American Airlines, Inc. hereby files into Docket OST-2019-0014 a letter of support from James E. Lentz, Chief Executive Officer of Toyota Motor North America, Inc. for our proposed Dallas/Fort Worth-Tokyo Haneda service.




March 7, 2019

Re: Support Letters of American Airlines

1. Mikito Kiname, President & Chief Executive Officer – Fujitsu America, Inc.
2. Joseph M. DePinto, President & Chief Executive Officer – 7-Eleven, Inc.
3. Masahiro Ikeno, Preident & Chief Executive Officer – NEC Corporation of America
4. Hideto Nishitani, Chairman/President & Chief Executive Officer – ORIX Corporation USA





March 7, 2019

Re: Support Letters of American Airlines

1. Ann Burroughs, President & Chief Executive Officer – Japanese American National Museum
2. Craig Tomiyoshi, Chair of Board of Directors – Japanese American Cultural & Community Center
3. Jessica Duboff, Vice President of Public Policy – Los Angeles Area Chamber of Commerce
4. Dennis Kuhl, Chairman – Los Angeles Angels
5. Bill Imada, Chairman – IW Group, Inc.

Counsel: American, John Williams




March 7, 2019

Re: Support Letters of Hawaiian Airlines

  1. Senator Brian Schatz (D-HI)
  2. Senator Mazie Hirono (D-HI)
  3. Congresswoman Tulsi Gabbard (HI-2)
  4. Congressman Ed Case (HI-1)
  5. Governor of Hawaii

Counsel: Cooley LLP, Parker Erkmann, 202-776-2036




March 7, 2019

Re: Support Letters of United Airlines

Stakeholders - Metropolitan Washington Airport Authority, Washington Airports Task Force, Virginia Chamber of Commerce, the Illinois Manufacturers Association, the Japanese Chamber of Commerce of Southern California, Wilmington, NC Chamber of Commerce, Choose Chicago, Los Angeles Coastal Chamber of Commerce, Los Angeles Department of Convention & Tourism Development, Chicagoloand Chamber of Commerce, Asian American Chamber of Commerce, Dulles Regional Chamber of Commerce, former Illinois Governor James Thompson and Chairman of the Midwest US-Japan Association, Chicago Japan External Trade Organization, Los Angeles Tourism & Convention Board, the Association for a Better New York, Illinois Chamber of Commerce, Chinese Chamber of Commerce of Guam, Northern Virginia Chamber of Commerce, Staten Island Economic Development Corporation, the New Jersey Chamber of Commerce, and Chairman Emeritus of Airbus Americas

Employees




March 7, 2019

Re: Support Letter of United Airlines

  • Governor of Texas

Counsel: Jenner & Block, Amna Arshad, 202-639-5344

 

March 7, 2019

Re: Support Letter of American Airlines

  • Governor of Texas

Counsel: Ameican, John Williams




March 8, 2019

Re: Support Letter of Congresswoman Lizzie Fletcher (TX-7) for United Airlines

Growth in the energy industry and growth in trade ties continue to more closely intertwine our regions' economies. In the last decade, investment in the Houston area by Japanese companies has increased by more than 35%. Japanese-owned companies directly employ over 50,000 workers in Texas with more than 150 Japanese-affiliated companies in Houston, many of them headquartered in Texas 7th District.

The proposed United Houston route will directly connect our region to Tokyo, drastically reducing travel times for many of my constituents. With a higher frequency of flights and network connecting points throughout the United States, travelers and businesses stand to gain from these routes. I urge the Department of Transportation to give all due consideration and a timely response on this proposal.

By: Lizze Fletcher

 


March 7, 2019

Re: Support Letter of American Airlines

  • Wayne Newton

Counsel: Ameican, John Williams




March 7, 2019

Re: Los Angeles World Airports in Support of American Airlines

With almost 261,000 annual passengers flying between LAX and HND, we have the largest contiguous US market of travelers. An additional flight at LAX by American would provide immediate benefit to a significant number of US travelers and serve as one of the best uses of a scarce round trip slot at HND.

By: LAWA, Deborah Flint

 

March 11, 2019

Support Letter of Los Angeles Convention & Visitors Board for American Airlines

Greater Los Angeles has the largest demand between LAX-HND of all markets in the contiguous US serving almost 261,000 passengers annually. An additional flight at LAX by American would provide immediate benefit to a significant number of US travelers and serve as one of the best uses of a scarce roundtrip slot to HND.

By: Ernie Wooden




March 13, 2019

Re: Support Letters for American Airlines - Dallas/Ft. Worth

  1. President & CEO Dallas Regional Chamber
  2. President University of North Texas
  3. Vice President GTT International / USA Gateway
  4. President Courtesy Travel
  5. President TaeYoung Tours & Travel
  6. Senior Vice President The Travel Corporation
  7. General Manager Four Seasons Tour and Travel
  8. CEO Adam Travel
  9. President Cruise Planners
  10. Managing Director Ole Travel

Counsel: American, John Williams




March 13, 2019

Re: Support Letters for American Airlines - Las Vegas

  1. Regional President Caesars Entertainment
  2. President & CEO Las Vegas Metro Chamber of Commerce
  3. President Japan America Society of Nevada
  4. Director of Government Affairs Henderson Chamber of Commerce
  5. COO Las Vegas Global Economic Alliance
  6. CEO Boulder City Chamber of Commerce
  7. President & CEO Latin Chamber of Commerce Nevada
  8. President & CEO Visit Reno Tahoe
  9. President Urban Chamber of Commerce
  10. Chef & Owner Restaurant Guy Savoy Las Vegas

Counsel: American, John Williams

 


March 15, 2019

Re: Support Letters for American Airlines - Dallas/Fort Worth

  • Thirteen members of Texas Congressional Delegation

Counsel: American, John Williams




March 15, 2019

Re: Support Letters for American Airlines - Dallas/Fort Worth

  • Executive Director Japan-America Society of Dallas/Fort Worth
  • Vice President Greater Dallas Asian American Chamber of Commerce
  • President & CEO Fort Worth Chamber of Commerce
  • President & CEO Fort Worth Convention & Visitors Bureau
  • Vice President Ascend North Texas

Counsel: American, John Williams




March 15, 2019

Re: Support Letters for American Airlines - Las Vegas

  • Mayor of City of Las Vegas
  • City of Las Vegas Councilmember
  • Chair and Vice Chair Clark County Board of Commissioners
  • Mayor Pro Tem City of Boulder City
  • City of North Las Vegas Councilmember
  • City of Mesquite, NV Councilmember

Counsel: American, John Williams




March 15, 2019

Re: Support Letters for American Airlines - Los Angeles

  • President World Trade Center Los Angeles
  • Director of Government Affairs Los Angeles Rams
  • Owner, President, General Manager, In-Bound Manager and Travel Consultant Japan Tours & Travel
  • Air Product Manager STA Travel
  • Vice President of Air Operations WorldStrides
  • General Manager East-West Travel
  • President Yusen Travel USA
  • Vice President of Operations Vacation Express by Sunwing
  • President TaeYang Tours and Travel
  • Senior Vice President The Travel Corporation
  • Vice President of Guest Services Maritz Travel

Counsel: American, John Williams




March 15, 2019

Re: Support Letters for Delta Air Lines

  • Michigan Congressional Delegation
  • Michigan House of Representatives Speaker of the House
  • Wayne County Executive
  • CEO Wayne County Airport Authority
  • President & CEO Michigan Chamber of Commerce
  • Global Travel Manager for Ford Motor Company
  • Global Travel Manager for The Down Chemical Company
  • Global Travel Manager for Lear Corporation

Counsel: Delta, Christopher Walker, 202-216-0700

 

March 15, 2019

Re: Seattle Connecting Airports in Support for Delta Air Lines

  • Bellingham International Airport
  • Boise Airport
  • Juneau International Airport
  • Missoula International Airport

By: Seattle-Tacoma International Airport, Kazue Ishiwata




March 15, 2019

Re: Support Letters for United Airlines

  • Senator Diane Feinstein (D-CA)
  • County Board Chairman, Dupage County, Illinois
  • Governor of Nebraska
  • Senior Vice President Mitsui & Company
  • President & CEO Raleigh-Durham Airport Authority
  • California State Senator Robert Hertzberg
  • CEO Pittsburgh International Airport
  • California State Assembly Speaker
  • Illinois State Senate Republican Leader

Counsel: Jenner & Block, Amna Arshad, 202-639-5344

 

March 18, 2019

Support Letters for Delta Air Lines

1. Washington Congressional Delegation
2. Jay Inslee, Governor, State of Washington
3. Dow Constantine, King County Executive
4. Marilyn Strickland, Seattle Metropolitan Chamber of Commerce
5. Kris Johnson, President & CEO, The Association of Washington Business (AWB)
6. Brian P. McGowan, President & CEO, Greater Seattle Partners (GSP)
7. Cristy Eisenman, Travel Manager for Nintendo of America

Counsel: Delta, Alexander Krulic, 202-216-0700

 

March 19, 2019

Support Letters for Delta Air Lines

  1. Georgia Senate
  2. Georgia Congessional Delegation
  3. President and CEO Georgia Chamber of Commerce
  4. Executive Vice President and President External Affairs Southern Company
  5. Head of Global Travel Travelport GDS

Counsel: Delta, Christopher Walker, 202-216-0700

 

March 20, 2019

Support Letters for American Airlines - Dallas/Fort Worth

  1. Owner Japan Tours & Travel
  2. President Japan Tours & Travel
  3. General Manager Japan Tours & Travel
  4. In-Bound Manager Japan Tours & Travel
  5. Travel Consultant Japan Tours & Travel
  6. Airline Relationship Manager StudentUniverse
  7. Operations Support Manager Steamboat Ski & Resort
  8. Yacht Broker Atlantic Yacht & Ship
  9. General Manager East-West Travel
  10. President Fly My Group
  11. President Global Travel Alliance
  12. Vice President of Operations Vacation Express by Sunwing
  13. Manager of Flight Operations Vacation Express by Sunwing
  14. Vice President of Air Operations WorldStrides
  15. President Yusen Travel USA

Counsel: American, John Williams




March 20, 2019

Support Letters for American Airlines - Las Vegas

  1. Chairman of Board and CEO MGM Resorts International
  2. President and CEO, Senior Vice President of Sales The Venetian Resort Las Vegas
  3. President Wynn Las Vegas and Encore
  4. Executive Director World Trade Center Las Vegas
  5. President Vegas Golden Knights
  6. President & General Manager Las Vegas Motor Speedway
  7. President & CEO Opportunity Village
  8. Regional Vice President The Valley Health System
  9. Chief Marketing Officer NetEffect
  10. CEO Las Vegas HEALS

Counsel: American, John Williams




March 20, 2019

Support Letters for American Airlines - Los Angeles

  1. Managing Director Mountain Travel Symposium
  2. President Maritz Global Events
  3. Division President Maritz Global Events
  4. Vice President of Sourcing & Supplier Relations Maritz Global Events
  5. Director of Guest Services & Group Air Support Maritz Global Events
  6. Yacht Broker Atlantic Yacht & Ship
  7. President Fly My Group
  8. General Manager Four Seasons Tour and Travel
  9. President Cruise Planners
  10. President Global Travel Alliance
  11. CEO Adam Travel
  12. President Courtesy Travel
  13. Director of Sales for Western & Central United States Picasso Travel
  14. Product Manager Picasso Travel
  15. Managing Director Ole Travel

Counsel: American, John Williams

 


March 22, 2019

Re: Support Letters for Hawaiian Airlines

  • Chamber of Commerce Hawaii
  • JTB Hawaii, Inc.
  • Hawai’i Tourism Authority
  • Kona-Kohala Chamber of Commerce
  • PHT, Inc. dba Polynesian Hospitality
  • Hawai’i Lodging & Tourism Association

Counsel: Cooley LLP, Parker Erkmann




March 22, 2019

Re: Support Letters for United Airlines - 361 Employees

Counsel: Jenner & Block, Amna Arshad

 


March 25, 2019

Re: Support Letters for American Airlines - Los Angeles-Haneda

  • Vice President GTT International / USA Gateway
  • President, Vice President, Branch Manager, Manager of Midwest Reservations Center, Senior General Manager IACE Travel
  • Director EF Education First International
  • Vice President Nippon Express Travel USA
  • President SportsAmerica
  • Airline Relationship Manager StudentUniverse
  • Manager of Flight Operations Vacation Express by Sunwing
  • Operations Support Manager Steamboat Ski & Resort
  • Vice President of Airline Partnerships & Operations Pleasant Holidays
  • Division Director Trip Masters
  • Travel Consultant Yusen Travel

Counsel: American, John Williams




March 25, 2019

Re: Support Letters for American Airlines - Los Angeles-Haneda

  • President Nissin Travel Service (USA)
  • General Manager of Sales & Marketing, Senior Managers, Sales Office Manager, Branch Manager, Managers JTB USA
  • President M.O. Air International
  • Vice President of Sales & Marketing Riya Travel & Tours
  • Chicago Branch Manager Nippon Express Travel USA
  • Travel Consultant Yusen Travel
  • Chief Technology Officer Trip Masters

Counsel: American, John Williams




March 25, 2019

Re: Support Letters for American Airlines - Los Angeles-Haneda

  • Executive Vice President National Association of Broadcasters
  • Vice President of Supplier Management Connexions Loyalty
  • Air Manager Europe Express / Go-Today
  • Executive Vice President, Manager of Airline Contracting & Pricing Collette Guided by Travel
  • Manager GT Tours
  • CEO Trip Masters
  • Project Manager Picasso Travel
  • CEO Sky Bird Travel & Tours
  • Director of Air Operations and Special Projects The Travel Corporation USA

Counsel: American, John Williams




March 25, 2019

Re: Support Letters for American Airlines - Los Angeles-Haneda

  • President JTB USA

Counsel: American, John Williams




March 25, 2019

Re: Support Letters for American Airlines - Los Angeles-Haneda

  • Los Angeles City Councilman 1st District
  • Los Angeles City Councilman 3rd District
  • Los Angeles City Councilman 4th District
  • Los Angeles City Councilman 5th District
  • Los Angeles City Councilwoman 6th District
  • Los Angeles City Councilwoman 7th District
  • Los Angeles City Councilman 8th District
  • Los Angeles City Councilman 12th District
  • Los Angeles City Councilman 15th District

Counsel: American, John Williams

 

March 26, 2019

Re: Support Letters for American Airlines - Dallas/Ft. Worth-Haneda

  • President & CEO, Vice President of Partner Relations Int'l Ass'n of Exhibitions and Events
  • CEO Trip Masters
  • Vice President Nippon Express Travel USA
  • Director EF Education First Int'l
  • Air Product Manager STA Travel
  • Managing Director Mountain Travel Symposium
  • Director of Sales for Western & Central USA, Product Manager Picasso Travel
  • President SportsAmerica
  • Travel Consultants Yusen Travel
  • Branch Manager, General Manager IACE Travel

Counsel: American, John Williams

 

March 27, 2019

Re: Support Letters for American Airlines - Dallas/Ft. Worth-Haneda

  • Chair Texas Commercial Airports Association
  • President & CEO Texas Travel Industry Association
  • President, Vice President JTB USA
  • President The Korean Society of Dallas
  • Branch Manager Nippon Express Travel
  • CTO, Division Director Trip Masters
  • Director of Guest Services & Group Air Support Maritz Global Events
  • Manager of Events Calyx Software

Counsel: American, John Williams

 

March 28, 2019

Re: Support Letters for American Airlines - Las Vegas-Haneda

  • Chef Nobu Matsuhisa

Counsel: American, John Williams




March 28, 2019

Re: Support Letters for American Airlines - Las Vegas-Haneda

  • Sr VP of Community & Government Relations The Howard Hughes Corporation
  • President & CEO The Cosmopolitan of Las Vegas
  • President & CEO Consumer Technologay Association/CES
  • Vice President & Las Vegas Market Leader Cox Communications
  • President Cragin & Pike
  • Yacht Broker Atlantic Yacht & Ship
  • President Blue Star
  • Managing Partner Bongiovi Law Firm
  • President & CEO D3 Marketing and Advertising LV
  • Founder & Senior Consultant Clarity Advisors to Management

Counsel: American, John Williams

 

March 29, 2019

Support Letters for Delta Air Lines

  • Alaska Congressional Delegation
  • Executive Director Japan-America Society of State of Washington

Counsel: Delta, Alexander Krulic, 202-216-0700




April 5, 2019

Re: Support Letters for American Airlines - Los Angeles-Haneda

  • President & CEO International Association of Exhibitions and Events
  • Manager of Events Calyx Software
  • President & CEO National Association of Music Merchants
  • General Manager H.I.S. Travel
  • Senior Vice President of Sales & Marketing Hanley Wood
  • Manager of Japan & Asia Travel, Assistant Manager, Ground Operation Air Booking Manager, Dallas Sales Office Manager JTB USA
  • President The Korean Society of Dallas

Counsel: American, John Williams

 

April 5, 2019

Support Letters for Delta Air Lines - Detroit-Haneda

  • Gretchen Whitmer, Governor – State of Michigan
  • Mike Shirkey, Senate Majority Leader - Michigan Senate

Counsel: Delta, Alexander Krulic




April 10, 2019

Re: Support Letters for American Airlines - Los Angeles-Haneda

  • Los Angeles Board of County Supervisors - Janice Hahn and Mark Ridley-Thomas

Counsel: American, John Williams

 

May 3, 2019

Employee Support Letters for Delta Air Lines - 18,425 Employees

Enclosed for submission in the above-referenced docket is a letter signed by more than 18,000 Delta employees expressing support for Delta’s application for six daily pairs of US-Haneda combination slots to provide scheduled service to Tokyo’s Haneda airport from Seattle, Detroit, Atlanta, Portland and Honolulu.

Counsel: Delta, Steven Seiden, 202-216-0700


 

Order 2019-5-13
OST-2019-0014 - 2019 US-Tokyo (Haneda) Proceeding

Issued and Served May 16, 2019

Order to Show Cause

By this Order, the US Department of Transportation tentatively allocates 12 available slot pairs for daily scheduled combination services between the United States and Tokyo International Airport (Haneda) as follows: (1) two slot pairs to American Airlines, Inc. for daily service from Dallas/Fort Worth and Los Angeles; (2) five slot pairs to Delta Air Lines, Inc. for daily service from Seattle, Detroit, Atlanta, Portland, and Honolulu; (3) one slot pair to Hawaiian Airlines, Inc. for daily service from Honolulu; and (4) four slot pairs to United Airlines, Inc. for daily service from Newark, Chicago, Washington, DC, and Los Angeles.

The Department has tentatively decided to impose a startup condition for each award. We will require the carriers to institute their proposed services within 90 days after March 29, 2020, the date on which the IATA 2020 summer season begins.

The Department directs any interested parties having objections to its tentative findings and conclusions set forth in this Order to file their objections, in the above-captioned docket, with the Department. If timely and properly supported objections are filed, the Department will afford full consideration to the matters or issues raised by the objections, and any answers thereto, before taking further action; if no objections are filed, the Department will deem all further procedural steps to be waived and will proceed to enter a final order awarding the authority proposed in this Order.

By: Joel Szabat


 

May 29, 2019

Re: Objection of AB Won Pat International Airport

Specifically, GIAA objects to the Department's tentative decision identified in the Order under Item #5, page 9, to "deny the remaining applications in this proceeding."

We believe that granting United one of the remaining slots from Haneda for service to Guam will create a more geographically diverse network of Haneda gateways, particularly to the Micronesian region, enhance US-Haneda service across a wide area and for an extensive portion of the traveling public, while promoting a more competitive marketplace.

The statement that "the large Guam-Tokyo market is already well-served at Narita," is overstated. Guam is currently served by United twice daily (and may ramp up to 3x daily service based on seasonality), using mainly B737 aircraft. Japan Airlines currently provides one frequency using a B767 aircraft. And Jeju Air exercises its Fifth Freedom Rights from Narita one time daily using a B737 aircraft. Even if United was to upgauge their aircraft to a widebody once daily, Guam's aircraft seat capacity will still not exceed 400,000 seats annually (not counting charters and additional sections based on seasonality). This a far cry when United, Continental (pre-United merger), Japan Airlines, All Nippon Airways and Northwest Airlines (Delta) served the market back prior to 9/11 with over one million seats in the market. Pricing at this time was very competitive in this O&D market but with limited options today, the propensity to travel to Guam is heavily constrained, notwithstanding the 800,000 annual bookings.

The additional Haneda slots were made possible by a US Air Force base making their airspace accessible. Guam also has major air force and naval bases with a new marine base under development to replace a base in Japan. Air service between Guam and Haneda will clearly support the military mission using a US flag carrier.

By: Thomas Ada


 


May 30, 2019

Comments of Delta Air Lines

The Department’s proposed allocation of five slot pairs to Delta will serve the public interest by increasing travelers’ access to Tokyo Haneda with Delta’s industry-leading customer service and operational reliability. As the Department recognized, the proposed awards will also “promot[e] a more competitive marketplace” by enhancing competition with the joint ventures of United/ANA and American/JAL, as well as the proposed joint venture between JAL and Hawaiian.

Delta appreciates the Department’s speed and diligence in reaching its tentative decision and urges the Department to issue a final order confirming its tentative order so that Delta may begin to make the necessary arrangements for its new Haneda services.

Counsel: Delta, Alexander Krulic, 202-216-0700




May 30, 2019

Comments of the Port of Portland

The Port commends the Department on its well-reasoned tentative decision in this proceeding. We urge the Department to make final its tentative decision to select PDX for a Tokyo Haneda slot-pair.

By: Curtis Robinhold




May 30, 2019

Comments of United Airlines

While fully supportive of the selections of Newark/New York City, Chicago, Washington, DC and Los Angeles, United believes it also presented compelling information supporting the selections of Houston and Guam. United has no doubt the public interest would be served by connecting these hubs to Haneda and looks forward to a time when United may be able to provide this service. While United understands that the Department did not address backup authority in the Show Cause Order, should the Department decide to award backup authority in its Final Order like it has done in certain past Haneda slot allocation proceedings, United reiterates its willingness to accept backup authority with a condition permitting it to implement the authority within the first year should the primary carrier withdraw from the market.

Counsel: Jenner & Block, Abby Bried/Amna Arshad, 202-639-6877/5344




May 30, 2019

Objection of Hawaiian Airlines

While Hawaiian looks forward to initiating additional service at Haneda, the Department’s decision is disappointing. The failure to award more than one Haneda route authority to Hawaiian is neither supported by the available data nor by the rationale provided in the Show Cause Order itself. The stated reasons for the Department’s allocation scheme included “promoting a more geographically diverse and competitive US-Haneda market structure” as well as “adding service and competition at the largest US-Tokyo markets.” In awarding two route authorities to serve Los Angeles while awarding only two authorities to serve Honolulu, the Department undermines these goals. Los Angeles already has more US carrier Haneda service and more Haneda service overall than Honolulu. But as the Show Cause Order itself recognizes, the size of the Tokyo-Los Angeles market is a fraction of the size of the Tokyo-Honolulu market. To the extent the Department sought to allocate authority to reflect market demand, the Show Cause Order fails to do so.

The Show Cause Order also evidences a prevailing, longstanding bias against smaller air carriers. The Department considered a varied array of interests in tentatively allocating Haneda routes, but in awarding only a single authority to Hawaiian the Department failed to fulfill a foundational statutory obligation. The Department’s authorizing statute directs the Secretary to promote the “strengthening of small air carriers to ensure a more effective and competitive airline industry.” The Show Cause Order fell short of meeting this goal. It will escape no one’s notice that the three largest US air carriers that serve 98% of the long-haul international capacity received all but one of the new Haneda opportunities. The Department’s proceedings must not ossify the market dominance of the largest US carriers. Indeed the Show Cause Order as proposed compounds the grievous disregard of the interests of smaller carriers and the competition and consumer choice they provide to the ever more entrenched interests of the largest carriers.

Hawaiian has not shied away from competition with the largest airlines in the world, but governmental institutions charged with providing a level playing field – and even charged with the duty to strengthen smaller carriers – should not, when given the opportunity, further strengthen the hand of the largest, legacy airlines as was done in the Show Cause Order.

The Department still has the opportunity to rectify the misallocation, and Hawaiian respectfully submits that the Department should do so by reallocating one of the awards for LAX service to Hawaiian for service to Honolulu.

Counsel: Cooley, Parker Erkmann, 202-842-7800


 


June 10, 2019

Consolidated Response of American Airlines

American respectfully requests that the Department dismiss the objections of Hawaiian and the AB Won Pat International Airport Authority, Guam, and finalize its award of two Haneda slot-pairs to American. Neither objecting party presents “any new evidence that would warrant a different outcome.” Both parties’ objections consist entirely of arguments that the Department has already considered, or that are plainly irrelevant to the Department’s public interest findings. Accordingly, there is no basis for the Department to rescind its tentative awards to American.

None of the information contained in GIAA’s objection shows that the Department’s tentative allocation of Haneda slot-pairs should be modified. GIAA provides no new evidence that a Guam-HND service would create greater public benefits than any of the twelve tentative Haneda awards. Even United did not object to the non-selection of its GUM-HND proposal in its Comments to the Show Cause Order. The Department provided sound reasons for rejecting this proposal and its tentative decision should be affirmed.

American urges the Department to award backup authority in this proceeding, as it has done in prior proceedings. The award of backup authority will enable American to inject US-Haneda competition without the necessity of another lengthy selection proceeding, creating greater benefits for passengers. American stands ready to institute service promptly should any carrier fail to operate the services that it was awarded on the committed daily, year-round basis.

(awarding backup Haneda authority to American); Final Order 2015-6-14, 2010 US-Haneda Combination Services Allocation Proceeding, Docket OST-2010-0018 (June 15, 2015), at 15-16 (same); Final Order 2018-12-1, Applications of Spirit Airlines, Inc. and American Airlines, Inc. for US-Colombia Frequency Allocations, Dockets OST-2008-0239 and OST-2008-0258 (Dec. 2, 2008), at 3 (awarding backup US-Colombia authority to American); Final Order 2005-3-40, 2005/2006 US-China Air Services Case and Designations, Docket OST-2004-19077 (Apr. 1, 2005), at 7 (awarding backup US-China authority to American).

Counsel: Dechert LLP, Michael Weiner, 202-261-3300




June 10, 2019

Answer of United Airlines

United submits this Answer to reiterate its support for the Department’s Show Cause Order and to address Hawaiian’s Objection and request to reallocate one of two slot pairs tentatively awarded for Los Angeles-Haneda service to Hawaiian to operate an additional Honolulu-Haneda flight. Hawaiian’s objections are irrelevant to this proceeding, entirely without merit, and ultimately unpersuasive. None of Hawaiian’s arguments should persuade the Department to reconsider its clear and well-reasoned slot allocations at Los Angeles and elsewhere.

First, this proceeding is about making the best use of newly available and valuable Haneda slots and the principal decisional criteria in the Department’s Instituting Order is to maximize public benefits—not to “bolster the business” of Hawaiian. Among the factors the Department weighs is which applicants will most likely offer and maintain service that best meets the needs of the traveling public, the effects of each service proposal on the overall competitive environment, and historical factors considered in past route proceedings. Thus, Hawaiian’s self-proclaimed small size is not the basis upon which the Department did not grant Hawaiian multiple slot pairs as its Objection would lead to believe. In fact, the opposite has been the case for years—Hawaiian has had double the number of slots as United, and for many years, Hawaiian was operating at Haneda when United had no slots at all.

Second, Hawaiian suggests without any basis that the Department reallocate one Los Angeles slot to Honolulu. As the Department recognized, “selection of United at Los Angeles would inject US-carrier operated intra-gateway competition into the market against the services provided by American and Delta, thereby giving all three major network carriers an own-metal presence in this market.” The Department also recognized that an allocation to United for Los Angeles-Haneda service “would result in net new Los Angeles-Tokyo capacity.” In addition to the above, United’s Los Angeles proposal would also serve the largest US mainland market to Tokyo, provide consumers with an alternate gateway to Haneda on the West Coast, provide 27 connecting flight options at Haneda compared to only nine at Narita, and would also connect various US cities with Haneda. Given the many quantifiable benefits of United’s Los Angeles proposal in particular, Hawaiian’s suggestion that the Department reallocate it to Honolulu is baseless.

Third, Hawaiian has not produced any evidence to contradict the fact that Hawaiian’s Honolulu-Haneda traffic is primarily and predominantly leisure traffic that is neither time-sensitive nor airport-sensitive. Indeed, Hawaiian’s filings in this proceeding make clear that its business model is to bring “tourists” to the United States. While United agrees serving leisure customers and enhancing travel options to island communities is important and would have supported an allocation to United for first-ever Guam-Haneda service, United agrees with the Department’s decision in this proceeding to prioritize access to Haneda, Tokyo’s downtown business hub for business and other time-critical travelers.

Fourth, Hawaiian makes an inapposite comparison to the Department’s 2016 Cuba route proceeding. Although Hawaiian is correct that the Department considered the “large local traffic base” as the main factor in awarding a substantial allocation of Havana frequencies to South Florida markets, that principle is not equally applicable to allocating routes in this proceeding. As the Department well knows, the Tokyo market is unique and markedly different from the Havana market in several respects. Most significantly, Tokyo has two major airports while Havana only has one major airport. When allocating routes to Tokyo, it is thus not only important for the Department to consider demand, but is also important for the Department to consider the relative benefits of each Tokyo airport and to maximize the public interest benefits by considering the types of traffic that can be anticipated on each route and matching the route to the appropriate Tokyo airport. The Department has correctly done that in this case. Additionally, the Havana market differs from the Haneda market in that in the South Florida-Havana market, the large demand base is in the US. Conversely, in the Hawaii-Tokyo market, the large demand base is in the foreign country—Japan. Hawaiian’s comparison of the Haneda case to the Havana case is thus nonsensical.

Fifth and finally, Hawaiian’s Objection also introduces its wholly irrelevant lease dispute with Los Angeles World Airport into this proceeding. United is unclear how Hawaiian’s frustrations with its real estate position at LAWA should weigh into the Department’s decision to award it Haneda slots to an entirely different airport—Honolulu. United respectfully submits that the Department should disregard this commentary in its entirety as irrelevant and nonresponsive to the issues in this case.

Counsel: Jenner & Block, Abby Bried, 202-639-6877


 

Order 2019-8-6
OST-2019-0014 - 2019 US-Tokyo (Haneda) Proceeding

Issued and Served August 9, 2019

Final Order

By this Order, the US Department of Transportation makes final its tentative decision to allocate 12 available slot pairs for daily scheduled combination services between the United States and Tokyo International Airport (Haneda) as follows: (1) two slot pairs to American Airlines, Inc. for daily service from Dallas/Fort Worth and Los Angeles; (2) five slot pairs to Delta Air Lines, Inc. for daily service from Seattle, Detroit, Atlanta, Portland, and Honolulu; (3) one slot pair to Hawaiian Airlines, Inc. for daily service from Honolulu; and (4) four slot pairs to United Airlines, Inc. for daily service from Newark, Chicago, Washington, DC, and Los Angeles.

By: Joel Szabat


Home | Search | Help
OST by Number | OST by Order | OST by Carrier | OST by Subject | OST by Day
OIA by Carrier/Subject | OIA by Day | FAA by Number | FAA by Subject | FAA by Day| Charter Office