BEFORE THE DEPARTMENT OF TRANSPORTATION ... Reply of...815 Connecticut Avenue, NW Suite 500 –...

BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

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2019 U.S.-HANEDA COMBINATION SERVICES : Docket DOT-OST-2019-0014 ALLOCATION PROCEEDING :

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CONSOLIDATED REPLY OF UNITED AIRLINES, INC.

Communications with respect to this document should be sent to:

Steve Morrissey Vice President-Regulatory & Policy UNITED AIRLINES, INC. 815 Connecticut Avenue, NW Suite 500 – DCAIZ Washington, DC 20006 (202) 521-4373 [email protected]

Daniel A. Weiss Managing Director- International Affairs & Regulatory UNITED AIRLINES, INC. 233 South Wacker Drive 10th Floor – HDQIZ Chicago, IL 60606 (872) 825-6828 [email protected]

March 7, 2019

James F. Conneely Assistant General Counsel-Regulatory, Environmental, and Government Affairs UNITED AIRLINES, INC. 233 South Wacker Drive 11th Floor – HDQLD Chicago, IL 60606 (872) 825-8311 [email protected]

Abby L. Bried Amna Arshad JENNER & BLOCK LLP 1099 New York Avenue, NW Washington, DC 20001 (202) 639-6877 (202) 639-5344 [email protected] [email protected]

Counsel for United Airlines, Inc.

mailto:[email protected]





i

TABLE OF CONTENTS

EXECUTIVE SUMMARY ............................................................................................................ 1

ARGUMENT .................................................................................................................................. 5

I. THE PUBLIC BENEFITS OF UNITED’S PROPOSAL ARE UNMATCHED ............... 5

A. United’s Proposal Offers New U.S. Gateways ....................................................... 6

B. United’s Proposal Will Bring Competition to Existing Gateways ......................... 7

C. United’s Proposal Will Promote Geographic Diversity.......................................... 8

D. United’s Proposal Will Provide a Larger Number of Consumers with Expanded Benefits and Choices .............................................................................. 9

E. United’s Proposal Will Provide New Service in the Market ................................ 10

II. UNITED’S PROPOSAL IS WELL-SUPPORTED BY U.S. CONSUMERS ANDCOMMUNITIES .............................................................................................................. 11

A. Newark/New York ................................................................................................ 11

B. Chicago ................................................................................................................. 12

C. Washington, D.C. .................................................................................................. 13

D. Los Angeles .......................................................................................................... 14

E. Houston ................................................................................................................. 14

F. Guam ..................................................................................................................... 15

III. THE SIGNIFICANT PUBLIC BENEFITS OF UNITED’S APPLICATIONOUTWEIGH OTHER CARRIERS’ UNSUPPORTED CLAIMS ................................... 15

A. United Remains the Only Carrier Focused on Actual Benefits to U.S. Consumers............................................................................................................. 15

B. The Department’s Criteria Require Consideration of the U.S.-Asia Market as a Whole ............................................................................................................. 20

C. American, Delta and Hawaiian Misrepresent the Facts ........................................ 23

1. American ................................................................................................... 23

2. Delta .......................................................................................................... 24

3. Hawaiian ................................................................................................... 28

IV. CONCLUSION ................................................................................................................. 29

ATTACHMENT 1

EXHIBITS

BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

----------------------------------------------------------------------- : 2019 U.S.-HANEDA COMBINATION SERVICES : Docket DOT-OST-2019-0014 ALLOCATION PROCEEDING : : -----------------------------------------------------------------------

CONSOLIDATED REPLY OF UNITED AIRLINES, INC.

United1 submits the following Consolidated Reply in response to the Answers of

American, Delta and Hawaiian for slot pairs at Haneda Airport2 pursuant to the Department’s

Instituting Order.3

EXECUTIVE SUMMARY

The Department’s decisional criteria in this proceeding is crystal clear:

The principal objective in this proceeding will be to maximize public benefits. In this regard, the Department will consider which applicant or applicants will most likely offer and maintain service that best meets the needs of the traveling and shipping public. The Department will also consider the effects of each service proposal on the overall competitive environment, including effects on the market structure and on competition in the U.S.-Japan market and in any other market shown to be relevant. In addition, where relevant, consideration may be given to other factors historically used for carrier selection.4

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,”5 or to rectify Hawaiian’s position as a

“small carrier compared to every other applicant in this proceeding.”6

1 Common names are used for airlines. 2 United incorporates in its Reply the defined terms as used in its Application and Answer in this docket. 3 See DOT Order 2019-2-5, Docket DOT-OST-2019-0014 (Feb. 7, 2019) (“Instituting Order”). 4 See Instituting Order at 2. 5 American Answer at 17. 6 Hawaiian Answer at 22.

Consolidated Reply of United Page 2

After two rounds of filings, United is the only carrier solely focused on utilize ng the scarce

and valuable Haneda slots to benefit U.S. 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 U.S. 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 U.S. for flights to Tokyo Haneda, significant cost and time savings, multiple

Haneda gateways across the U.S., 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. (See infra Section II.) United intends for this Consolidated Reply 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.

United has provided a thorough Application and supplemented in its Answer even more

information buttressing its proposal with the data and facts that make clear that it is United that is

best positioned to maximize the public benefits of these slots. United’s Tokyo Haneda proposal

continues to see robust support from interested parties across the country, such as:

• Elected leaders from:

o New Jersey including Governor Murphy, U.S. Representatives Sires, Gottheimer, Sherrill, Van Drew, Smith, Malinowski, Pascrell, Watson Coleman, Kim, Pallone, New Jersey Assembly Members Land and Milam as well as State Senators Andrzejczak, Diegnan Jr., and Kean, Jr, and Mayor Bollwage of Elizabeth, New Jersey;

o Virginia’s congressional delegation including Senators Kaine and Warner and

Representatives Wexton, Scott, Wittman, Connolly, Griffith, Beyer, McEachin, Cline, Luria, Riggleman and Spanberger;


o Illinois including Chicago’s Mayor Emanuel and members of the Congressional delegation including Representative Bost, Bustos, Casten, Davis, Davis, Foster, Garcia, Kelly, Krishnamoorthi, LaHood, Lipinski, Quigley, Rush, Schakowsky, Shimkus, Underwood, and Schneider, and State Representative Durkin;

o California including Congresswoman Brownley and State Senators Allen and Hill;

and

o Texas including Congressman Cloud, Houston Mayor Turner and Vice Mayor Davis.

• More than 30 letters of support from connecting airports that will benefit from United’s

proposed service including St. Louis Lambert International Airport (STL), Greenville-Spartanburg International Airport (GSP), Southwest Florida International Airport (RSW), Tampa International Airport (TPA), Cincinnati / Northern Kentucky International Airport (CVG), McGhee Tyson Airport in Knoxville (TYS), and Nashville International Airport (BNA).

(See Attachment 1.) In addition, filed separately today in this docket are additional letters

of support from:

• More than 30 additional stakeholder letters of support including: Metropolitan Washington Airport Authority (MWAA), the Illinois Manufacturers Association, the Japanese Chamber of Commerce of Southern California, Choose Chicago, Asian American Chamber of Commerce, former Illinois Governor James Thompson and Chairman of the Midwest U.S.-Japan Association, the Association for a Better New York, and the New Jersey Chamber of Commerce;

• More than 50 additional letters of support from United Airlines customers including those from T. Allan McArtor, Chairman Emeritus Airbus Americas, Inc., BAE Systems, Symantec and Bristol Myers Squibb; and

• More than 1,100 additional letters of support from United Airlines employees bringing the

total number of employee support letters to over 9,400.

United has identified its priorities consistent with the Instituting Order7 as the following:

to serve Newark/New York, Chicago, and Washington, D.C. (first-priority); Los Angeles (second-

priority); and Houston and Guam (third-priority). United firmly believes each of these gateways

meets and exceeds the Department’s above criteria, even more so when viewed as a whole.

7 As for Delta’s assertion that United’s method of identifying its priorities is “gamesmanship” or somehow “circumvent[s]” the Department’s instructions, United was simply following Delta’s cue from the 2016 Haneda Combination Allocation Services Proceeding where Delta identified its priorities in an identical manner.


United’s proposal will provide new gateway service to Haneda (Newark Liberty, Washington,

D.C., Houston, and Guam), inject inter-alliance competition (Los Angeles), promote geographic

diversity (all of the proposed gateways), provide a large number of consumers benefits of nonstop

and connections to Tokyo Haneda (all of the proposed gateways), and provide incremental new

service in the Tokyo market (Newark/New York, Los Angeles, Guam). (See infra Section II-B.)

Because of these unmatched benefits, United’s Application has received an unprecedented level

of support from the proposed cities, airports, communities, elected officials, customers and

employees. (See infra Section III.)

And importantly, no matter how much the other applicants attempt to say otherwise,

United’s proposal is inherently pro-competitive. While other carriers continue to obfuscate facts

and focus on peripheral issues, United continues to place the greatest emphasis and focus on U.S.

consumers and communities. However, United finds it necessary to correct the record and make

even clearer the benefits of United’s proposal despite other carriers’ empty and unsupported efforts

to suggest otherwise. (See infra Section IV.)

To visualize the key benefits across United’s proposed gateways, see Figure 1, below.


Figure 1

ARGUMENT

I. THE PUBLIC BENEFITS OF UNITED’S PROPOSAL ARE UNMATCHED

As United noted in both its Application and Reply, the Department’s principal objective in

this proceeding is “to maximize public benefits.”8 In considering which proposals maximize

public benefits, the Department employs a multi-factor test that assesses which carrier is best

positioned to offer, maintain, and expand access for the traveling public.9 In addition to

considering the overall consumer benefits, the Department also considers “other factors

historically used for carrier selection.”10 In this proceeding, these factors have included:

8 See Instituting Order at 2. 9 Id. 10 Id.


• Offering new gateway service to Haneda;

• Bringing competition to existing gateways;

• Promoting geographic diversity;

• Providing a large number of consumers expanded benefits and choice;

• Providing new service in the marketplace.

United’s Application and Answer in this proceeding clearly demonstrate that United’s proposal

will meet and exceed these standards by offering more benefits to consumers and communities

than any other carrier.

A. United’s Proposal Offers New U.S. Gateways

One factor the Department has determined is a significant benefit to the traveling public

when evaluating air carrier proposals is the opening of new U.S. gateways.11 United’s proposal

would offer new service to Tokyo Haneda from its Newark Liberty, Washington, D.C., Houston,

and Guam gateways. This is the same number of new gateways that Delta proposes to offer, and

is double the number of new gateways that American proposes to offer. Hawaiian’s proposal

notably provides no public benefits when assessed on this metric.

More than just offering new flights, United’s proposal will provide countless benefits to

consumers in those markets who do not currently have the option to fly to Haneda. In the

Newark/New York market, United’s service between Newark Liberty and Haneda will provide the

traveling public with different benefits than other New York City area airports. In the Washington,

D.C. market, United’s flight would expand the options available for the traveling public, military

personnel flying to and from Okinawa, and the Japanese companies that employ more than 15,000

workers in Virginia. In the Houston market, United’s service would strengthen the connection

11 See, e.g., Order to Show Cause, Order 2012-11-12, at 6, Docket DOT-OST-2010-0018 (Nov. 15, 2012); Final Order, Order 2013-2-4, at 4, Docket-DOT-OST-2010-0018 (Feb. 5, 2013).


between the U.S. center of commerce for the oil, natural gas, and energy business with Tokyo (see

Exhibit UA-A111). And finally, in the Guam market, United’s service would benefit passengers

in the large local Guam-Tokyo market for tourism, trade and national defense development.

B. United’s Proposal Will Bring Competition to Existing Gateways

The Department has historically and consistently recognized substantial value in

competition by new entrant U.S. carriers at existing gateways, even where a new entrant is a

member of a joint venture that currently serves the gateway through the foreign carrier.12 As the

Department recognized in the Order implementing this proceeding, in determining whether an

application maximizes public benefits, it will consider “the effects of each service proposal on the

overall competitive environment, including effects on the market structure and on competition in

the U.S.-Japan market and in any other market shown to be relevant.”13 One such market that is

relevant in this proceeding is the local market between Los Angeles and Tokyo Haneda.

United’s Los Angeles proposal will allow it to operate its own metal in competition to

Delta and American in the largest U.S. mainland-Tokyo market. Currently, both Delta and

American offer service from Los Angeles to Haneda, but United does not operate its own flight.

(See Exhibit UA-A119.) United’s proposed service at Los Angeles would thus give United the

opportunity to compete metal-to-metal with American and Delta and more broadly in the Southern

California-Japan marketplace, which would benefit consumers through increased carrier choices.

(See Exhibit UA-144.) United’s proposal will also provide more convenient options for U.S.

consumers in cities across the West Coast, including San Diego, Las Vegas, and Phoenix, as well

12 See Order to Show Cause, Order 2014-2-23, at 4, Docket DOT-OST-2010-0018 (Feb. 28, 2014) (stating that “United’s proposal would introduce a new entrant at Haneda, a factor that the Department has historically given considerable weight in carrier selection proceedings, and we tentatively find that the opportunity to introduce a new entrant at Haneda would make the best use of the one available slot pair.”). 13 See Instituting Order at 2.


as benefits beyond what ANA’s flight provides, including 25 new connecting flight options and

ten cities that do not connect to ANA at Los Angeles. (See Exhibit UA-R105.)

C. United’s Proposal Will Promote Geographic Diversity

The Department has consistently held that geographic diversity is a crucial consideration

in determining the public benefits of a carrier’s proposal for frequency allocation for Haneda.14

United’s proposal offers six Haneda flights strategically placed across the entire United States –

including Newark and Washington, D.C. on the East Coast, Houston in the central U.S., Chicago

in the Midwest, Los Angeles on the West Coast, and Guam in the Pacific. United’s proposal will

bring benefits to consumers in all areas of the country, including connecting 36 U.S. states and

112 U.S. points with Tokyo Haneda. (See Exhibits UA-A139 and UA-A140.) United’s proposal

advances geographic diversity more than any other carrier. For example, American’s proposal

focuses on just three states that are all relatively close to one another. (See Exhibit UA-A122.)

And Hawaiian’s proposal would not add a single new U.S. gateway in the Hawaiian network for

U.S.-Haneda service or more broadly across the U.S. industry’s Haneda network.

Moreover, United is the only carrier that has explained its proposed decision to switch

some of its Tokyo flights from Narita to Haneda. As United articulated, the decision is based upon

the historic traffic mix for the flight in question. For example, United determined that flights that

historically transport passengers primarily to Tokyo or to points in Japan should switch to Haneda.

Flights that have a disproportionate number of consumers connecting to points beyond Tokyo in

the Asia Pacific region should continue to operate to Narita. United’s proposal has considered the

overall consumer need for travel to Tokyo, to points in Japan beyond Tokyo and to other points in

14 See Order to Show Cause, Order 2016-7-14, at 9, Docket DOT-OST-2016-0048 (Jul. 20, 2016); Order to Show Cause, Order 2010-5-7, at 10, Docket DOT-OST-2010-0018 (May 7, 2010).


the Asia/Pacific region, and it is not clear that any of the other three applicants gave such

consideration in developing their future Tokyo plans.

D. United’s Proposal Will Provide a Larger Number of Consumers with Expanded Benefits and Choices

Put simply, United’s proposal will provide more benefits to U.S. consumers and

communities than any other application. United alone has provided extensive documentation of

these benefits – including the aggregate time savings and dollar savings for consumers that new

United flights at Haneda would offer, examples of itinerary-level time savings to various points in

Japan beyond Tokyo, as well as increased flight options from Tokyo Haneda to key destinations

in Japan.

United’s Application will provide the following benefits:

• United’s combined U.S. mainland gateways will connect Haneda with 112 airports, totaling over three million annual bookings and nearly two-thirds of all U.S.-Tokyo demand. (See Exhibit UA-R101.)

• Add three new flights to Tokyo: Newark Liberty, Los Angeles and Guam, all with significant demand to Tokyo. (See Exhibit UA-R102.)

• Provide first-ever Haneda service to Newark Liberty, the largest market on the East Coast for Tokyo demand and the U.S. center of business and finance. This would connect 43 U.S. airports to Haneda, resulting in a catchment area totaling 1.2 Million annual Tokyo bookings. (See UA Application, Exhibit UA-126.)

• Provide U.S. carrier Haneda service at Chicago, a key logistics and transportation hub in the central U.S., providing greater time-of-day utility for Haneda-bound passengers, resulting in hours of time savings. (See UA Application, Exhibits UA133-134.)

• Shift United’s existing Washington, D.C. service to Tokyo from Narita to Haneda to provide more convenient downtown access to Haneda and points beyond from the seat of the U.S. federal government at Washington, D.C., connecting 35 U.S. airports to Haneda and totalling over 1.2 Million in annual Tokyo bookings. (See UA Application, Exhibits UA100, 138-139.)

• Provide greater time savings for consumers traveling from Los Angeles to Haneda by providing flights at different times of day than ANA’s service and providing additional service in the largest U.S. mainland-Tokyo market and the home of the largest Japanese foreign-born population in the U.S. mainland. (See UA Application, Exhibits UA110-111.)


• Provide the South/Southeast with a Haneda gateway at the energy capital of the world, Houston, providing geographic diversity, increased time savings (see UA Application, Exhibits UA148-150), as well as competitive balance to the gateways proposed by American at Dallas/Ft. Worth and Delta at Atlanta.

• Provide important and needed U.S. service to Haneda from Guam, which has a market size totalling over 800,000 annual bookings (see Exhibit UA-R103) and will provide more connecting opportunities, and more convenience for travellers going to points beyond Tokyo to points in Japan (see United Application, Exhibits UA113, 154-156) while allowing Guam to better compete with Hawaii for Japanese traffic.

• Provide consumers unmatched connectivity to 37 points across Japan via ANA at Haneda (30 of which are served by ANA only at Haneda versus Narita), thereby reducing travel time and eliminating time-consuming ground transfers between Narita and Haneda. (See United Application, Exhibits UA119-120.)

• For United’s Chicago-Haneda proposal, United’s service would provide benefits beyond what ANA’s flight provides, including 136 new connecting flight options and 37 cities that do not connect to ANA at Chicago. (See Exhibit UA-R104.)

• For United’s Los Angeles-Haneda proposal, United’s service would provide benefits beyond what ANA’s flight provides, including 25 new connecting flight options and 10 cities that do not connect to ANA at Los Angeles. (See Exhibit UA-R105.)

• Provide additional connecting flight options at Haneda compared to Narita for U.S. service personnel traveling between the U.S. and Okinawa.

Based on the foregoing, as well as the numerous benefits demonstrated in United’s

Application and Answer, it is clear that of all carriers, United is best positioned to offer and

maintain service to Haneda.

E. United’s Proposal Will Provide New Service in the Market

Finally, United’s proposal also provides new service to Tokyo. United’s five-route U.S.

mainland proposal will connect Haneda with 112 airports, totaling over 3 million annual bookings,

and accounting for nearly two thirds of United States-Tokyo demand. (See Exhibit UA-R101.)

United will add almost 350,000 annual seats to Tokyo, more than Hawaiian and nearly four times

more than American or Delta. (See Exhibit UA-A113.) United will also add approximately 44,000

annual business class seats to Tokyo, double that of Hawaiian’s proposal, three times more than

Delta, and six times more than American. (See Exhibit UA-A114.) Finally, United’s proposal


includes three times the number of incremental flights to Tokyo compared to both American’s and

Delta’s proposals. (See Exhibit UA-A112.)

II. UNITED’S PROPOSAL IS WELL-SUPPORTED BY U.S. CONSUMERS AND COMMUNITIES

United stands out from the other applicants as having received overwhelming support from

communities, consumers, employees and others. As described by several key supporters below

and in the numerous answers and letters filed in the docket, United’s proposal will produce

concrete benefits that are welcomed by the communities and consumers it serves. (See Attachment

1.)

A. Newark/New York

New Jersey Parties

• As the largest U.S.-Tokyo market on the East Coast, Newark/New York is the logical choice for the Department to expand service to Tokyo Haneda.15

• This is particularly true given that United’s proposed Newark Liberty service to Haneda will supplement its existing daily nonstop Newark/New York City-Tokyo Narita service, thereby providing the travelling public with additional choice, increased capacity, and greater convenience.16

Port Authority of New York/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.17

• The Port Authority believes that both NRT and HND have an important role in serving the Tokyo Metropolitan region and is gratified that United plans to serve both airports from EWR.18

15 See Answer of the New Jersey Parties at 1, Docket DOT-OST-2019-0014 (Feb. 28, 2019). 16 Id. at 3. 17 See Answer of Port Authority of New York/New Jersey at 1, Docket DOT-OST-2019-0014 (Feb. 28, 2019). 18 Id. at 2.


• In addition to serving a distinct market within the region, the proposed EWR flight would capitalize on United’s impressive domestic and international network. United’s HND-EWR service will be bringing seamless and convenient connections throughout its EWR network, especially to the entire East Coast of the United States.19

• United’s HND-EWR service will serve a large, affluent market with strong ties to Japan that does not currently benefit from such service. The proposed route will fill this void and will benefit from United’s extensive network at EWR. This link is not only critical to the New York and New Jersey region, but it will also benefit the entire East Coast of the United States.20

New Jersey Chamber of Commerce

• Today, Newark Liberty lacks non-stop service to Tokyo Haneda despite the fact that approximately four million people live within 20 miles of the airport. Newark/New York is the largest market on the East Coast for travel demand to Tokyo. United’s proposal will connect Tokyo Haneda with Newark/New York and 43 other U.S. airports United serves from its Newark Liberty hub. This area represents approximately 1.2 million annual bookings to Tokyo.21

B. Chicago

City of Chicago Department of Aviation

• 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.22

• United’s proposed service to Haneda would meet the substantial demand for business and leisure travel between Chicago and Tokyo, as well as points beyond. Chicago, and indeed the Central U.S., depends on convenient air transportation service to Tokyo and other Japanese cities. Collectively, Japanese investment in the Midwest has provided an estimated 150,000 American jobs within the region, and more than 45,000 in Illinois alone.23

• There are approximately 67 Japanese companies in the Chicago-area alone which are not headquartered in Tokyo, with combined annual revenues of over $444

19 Id. 20 Id. at 4. 21 See New Jersey Chamber of Commerce Letter to Secretary Chao, Docket DOT-OST-2019-0014 (Feb. 28, 2019). 22 Id. at 2. 23 Id. at 3.


billion, including Nissan, Seiko Epson, and Toshiba. These companies would benefit from Haneda’s superior domestic connectivity.24

Illinois Congressional Delegation, United States House of Representatives

• Chicago has the highest demand for Tokyo travel in the central U.S. and the seventh largest Japanese foreign-born community in the U.S. O’Hare is not only an economic driver for Chicago but for all of Illinois and the greater Midwestern region. New access to Tokyo will help promote growth across the state and beyond its borders.25

C. Washington, D.C.

Metropolitan Washington Airports Authority

• Should DOT approve its application, United Airlines will continue to play this vital role in an even greater capacity for the benefit of U.S. consumers and communities like the Washington, D.C. region.26

• The Washington, D.C. region is one of the top ten Tokyo origin-destination markets in the United States, generating significant business, government and tourist travel with Japan. In addition, IAD is a large connecting hub for United Airlines that will offer Tokyo Haneda passengers seamless online connections to over 265 daily departures serving over 118 nonstop destinations in 2019.27

Virginia Chamber of Commerce

• From a business development prospective, the proposed Washington Dulles route would provide a more direct and desirable connection to Tokyo. This route could increase business and governmental contacts between the United States and Japan and would complement current marketing efforts to attract foreign direct investment to Virginia. Further, nonstop service from Washington, D.C. could encourage Virginia-based and Fortune 5000 companies to expand sales and production in Japan, as well as other markets throughout East Asia.28

Washington Airports Task Force

• United’s proposal to inaugurate a flight from Dulles to Tokyo Haneda Airport would strengthen a bridge between the seats of government in both the U.S. and Japan, two of the largest democracies and economies in the world, and it would

24 Id. at 4. 25 See Joint Letter to Secretary Chao, Docket DOT-OST-2019-0014 (Feb. 28, 2019). 26 See Letter from Metropolitan Washington Airports Authority, Docket DOT-OST-2019-0014 (Feb. 25, 2019). 27 Id. 28 See Letter Virginia Chamber of Commerce, Docket DOT-OST-2019-0014 (Feb. 28, 2019).


provide a far more convenient travel option for civilian and military employees of both countries’ governments.29

D. Los Angeles

Congresswoman Julia Brownley (CA-26), United States House of Representatives

• For decades, United has played a pivotal role in facilitating tourism, trade and commerce between the U.S. and Japan, demonstrating a strong commitment to serving U.S. consumers’ needs . . . With greater frequency of flights and a wide network of connecting points, consumers and businesses will see improved convenience and benefits from United’s proposed flights.30

E. Houston

City of Houston

• The City greatly appreciates the Department’s ongoing commitment to overall liberalization of the international air services regime and the expansion of opportunities that enhance the ability of U.S. passengers and shippers to access the services they need. The Department’s long-term efforts and significant success in developing Open Skies and other liberalized agreements have played a major role in the City’s ability to expand its international air services and to become a major global air transportation hub.31

• 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.32

• In addition to those advantages, the public interest would benefit from enabling Houston-Haneda service from United that is competitive with that of other U.S. gateways – including particularly Dallas-Ft. Worth and Atlanta, should those cities receive new Haneda service – and with foreign carrier competition at Houston.33

Houston Mayor Sylvester Turner

• United’s proposal includes a flight from Houston George Bush Intercontinental Airport (IAH), which would strengthen the air services bridge from the U.S. center of commerce for the oil, gas and energy industries in Houston to Tokyo.34

29 See Washington Airports Task Force Letter to Secretary Chao, Docket DOT-OST-2019-0014 (Mar. 7, 2019). 30 See Joint Letter to Secretary Chao, Docket DOT-OST-2019-0014 (Mar. 4, 2019). 31 See Answer of City of Houston at 2-3, Docket DOT-OST-2019-0014 (Feb. 28, 2019). 32 Id. 33 Id. at 4. 34 See Houston Mayor Sylvester Turner’s Letter to Secretary Chao, Docket DOT-OST-2019-0014 (Mar. 7, 2019).


Mario Diaz, Director of Aviation, City of Houston

• With greater frequency of flights and a wide network of connecting points, United’s proposal will help expand consumer and business service options in the Houston market. The City of Houston urges DOT to approve United Airlines’ Tokyo Haneda proposal.35

F. Guam

Thomas, Ada, Executive Manager, A.B. Won Pat International Airport

• Tokyo and the broader Japanese market are strategically important to Guam, which relies upon the Japanese leisure travelers for tourism and job creation on the island. The Guam-Japan market is significant in size, yet there is no direct service to Haneda, the closest airport to central Tokyo, while Hawaii already has multiple flights to Haneda. United’s proposed flight between Tokyo Haneda and Guam would generate additional demand and give U.S. and Japanese consumers access to more than 30 points in Japan that travelers currently cannot access via Tokyo Narita.36

III. THE SIGNIFICANT PUBLIC BENEFITS OF UNITED’S APPLICATION OUTWEIGH OTHER CARRIERS’ UNSUPPORTED CLAIMS

A. United Remains the Only Carrier Focused on Actual Benefits to U.S. Consumers

As the Department made clear in its Instituting Order, the “principal objective in this

proceeding will be to maximize public benefits.”37 However, American, Delta, and Hawaiian

spend far more time complaining about how the other carriers’ proposals will cause them harm,

and seeking to cause each other harm, than they do considering the benefits they would bring to

the traveling public. Only United is focused on maximizing its routes and operations to maximize

the public benefits. United estimates that over 585,000 consumers annually would fly on its six

proposed flights to Tokyo Haneda. That is a substantial benefit for consumers that the other

applicants cannot match.

35 See Mario Diaz Letter to Secretary Chao, Docket DOT-OST-2019-0014 (Feb. 28, 2019). 36 See Thomas Ada, Executive Manager, A.B. Won Pat International Airport Letter to Secretary Chao, Docket DOT-OST-2019-0019 (Feb. 28, 2019). 37 See Order 2019-2-5, at 2, Docket DOT-OST-2016-0048 (Feb. 2, 2019).


In its Consolidated Answer, Delta spends roughly only seven of 36 pages describing its

proposal and benefits. American devotes nearly half of its time attacking United and the other

airlines in this proceeding and Hawaiian uses just 16 of 49 pages to bolster its own proposal.

Pointing out the alleged weakness in another’s proposal does nothing to strengthen their own, let

alone benefit the public.

This is particularly true where, as here, the criticism leveled against United is inaccurate or

contradictory. Delta, for instance, calls United’s second and third priority proposals to serve

Houston, Los Angeles, and Guam “perfunctory.”38 Not only did United fully explain the benefits

those routes would bring to the public, it was also careful to place those routes in the broader

context of United’s network and the U.S.-Japan market as well. In fact, Delta faults United for

being so thorough as to “study the broader dynamics of travel between U.S. and Asia”39 in its

Application. In contrast, Delta spends the majority of its effort complaining that United’s

Application is “littered with mischaracterizations”40 and mocking United’s “zealous advocacy”41

instead of making use of the filing to fully develop arguments in favor of its proposal.

Indeed, Delta seems more concerned with boosting its own competitive posture than it does

serving the public. Delta spends five pages bemoaning its “Severe Disadvantage at Haneda

Attributable to its Lack of a Joint Venture Partner.”42 It is telling that Delta’s argument for its

proposal reduces to mere parochialism: “the Department should avoid further injury to Delta’s

competitive position that would result from enriching the dominant United/ANA and

American/JAL JVs at Delta’s expense.”43 In fact, Delta believes that even granting Delta’s own

38 See Answer of Delta, at 20. 39 See id. at 24. 40 See id. at 13. 41 See id. at 24. 42 See id. at 8 (capitalization in original). 43 See id. at 12.


proposal in full would “not be sufficient, in isolation, to level the disparate playing field.”44 But

Delta makes little effort to explain how granting its proposal would benefit the public rather than

just benefiting Delta.

Similarly, American makes little effort to distinguish its own proposal as superior, and

instead waxes poetic that “United proposes an allocation of Haneda slots that would, in Percy

Shelley’s words, make the rich become richer and the poor become poorer” and complains that

“[n]o concept of public benefits favors an allocation that would widen the chasm between

American and United.”45 American fears that United is seeking to improve its “large advantage

over American” and “tighten its grip over most of the country.”46 But being large, as American

well knows, does not stop United’s proposal from offering the best and most comprehensive

benefits to the traveling public.

The facts that counter the claims by American and Delta are clear. Based on current traffic

flows, 94% of United/ANA Tokyo bookings are on city-pairs where American/JAL offer

competing service; 77% of the same United/ANA bookings are on city-pairs where Delta/Korean

offer competing service. (See Exhibit UA-R106.) The data shows 97% of United/ANA bookings

have one or more competitors to choose among, 74% of United/ANA bookings have two or more

competitors, and nearly half (42%) have three or more competitors. (See Exhibit UA-R107.)

Numerous carriers and gateways compete for traffic between Newark/New York City and Tokyo

where a snapshot of flight options shows 88 different flights from three airports in the New York

City region to either airport in Tokyo. (See Exhibit UA-R108.) As for the Chicago-Tokyo market,

data shows 29 alternate flight options, and between Washington, D.C. and Tokyo, there are 54

flight options. (See Exhibits UA-R109 and UA-R110.) Finally, as shown in Figure 2 below, when

44 See id. 45 See Answer of American, at 32. 46 See id. at 33.


comparing departure shares for a sampling of American and Delta joint venture partnerships,

United/ANA at Tokyo have the smallest share among the comparison.47

Figure 2

In the 2013/2014 U.S.-Brazil Combination Frequency Proceeding, American, contrary to

its position here, sought to leverage its position as the dominant carrier in the region in its proposal

for additional frequencies. There, American noted that “the Department has often selected

incumbents with a strong market presence over applicants with fewer existing routes by focusing

on the relative merits of each proposed gateway rather than simply adding up and comparing

existing routes and frequencies.”48 As American explained, “in the 2007 U.S.-China Combination

47 See OAG 2019, departure shares at hub cities. Paris includes CDG and ORY, London includes LHR, LGW, STN, LCY and LTN, Tokyo includes HND and NRT. IAG includes British Airways, Aer Lingus, Iberia and Vueling. ANA includes All Nippon Airways and Vanilla Air. KLM includes KLM, KLM Cityhopper, Transavia and Transavia France. 48 See Answer of American Airlines at 16, Docket DOT-OST-2013-0072 (May 3, 2013).


and All-Cargo Frequency Allocation Proceeding, United . . . was selected over Continental and

American . . . based on the merits of United’s Washington-Beijing proposal and despite claims

that such a ‘dominant’ carrier should not receive additional authority.” American then quoted the

Department’s Final Order at length:

We are not persuaded by Continental's argument that because of United's position as the carrier having the largest number of frequencies in the market, United's selection is counter to the Department's pro-competition policy. We disagree . . . . While considering the number of frequencies and the current service of each applicant . . . we weighed the various carrier selection factors in light of the particular circumstances presented in this specific case. We tentatively concluded that the public interest benefits of United’s service proposal - gaining the first-ever nonstop service to China from a new gateway representing the largest O&D market in this proceeding, coupled with the largest capacity to maximize the benefits of that new service - were compelling. Nothing asserted by Continental in its objections would now persuade us to change that analysis and conclusion.49

In fact, American even chided Delta for “count[ing] and recount[ing] American’s present

holding of Brazil frequencies as if this were a disputed Presidential election . . . . Indeed, Delta

engages in this counting exercise more than 25 times in its supplement, answer, and accompanying

exhibits.”50 American knew then, as it does now, that counting frequencies and assessing market

share “is not how the Department decides selection cases.”51

American likely focuses on United’s size because neither United’s present network nor its

proposed Haneda routes in this proceeding prevent American from growing its presence in Tokyo,

Japan, or Asia. If American was committed to increasing its U.S.-Asia service, it could initiate

service to Narita from its hubs that do not presently have that service. United gaining Haneda slots

does not prevent American from providing service to Tokyo from New York JFK, Philadelphia,

Charlotte, Miami, or Phoenix, if it so chooses. But Tokyo service is not part of American’s

49 See Answer of American Airlines, at 16-17 (quoting Final Order, Order 2007-2-10, at 6-7, Docket-DOT-OST-2013-0072). 50 See Reply of American Airlines at 2, Docket DOT-OST-2013-0072 (May 14, 2013). 51 Id.


business strategy; it has reduced service to Tokyo from Chicago to just three times per week and

described that route as a “colossal loss maker.”52 Devaluing the Tokyo and Japanese market is a

business choice American is free to make, but American should not seek to penalize United for

choosing to invest in its Tokyo and Asia markets.

As the Department has recognized in its antitrust immunity cases, “high market shares” do

not always “reflect some important aspects of the competitive environment.”53 United has worked

hard to develop a robust and efficient network in Asia, making sure it serves the right cities with

strong demand, and has smartly invested to build a system of flights giving consumers the most

and best choices. This includes entering strategic partnerships, notably with ANA, who has shown

similar commitment at Haneda. Neither United nor ANA is ashamed of this fact. United is proud

that its network has grown to serve large numbers of travelers across many cities – a testament to

the benefits it delivers to consumers – and its proposal in this proceeding fully and capably

demonstrates that fact. The other carriers in this proceeding, however, have chosen to spend their

efforts emphasizing United’s size and the harm granting United’s proposal would cause them.

Neither of these is a consideration that serves the “principal objective in this proceeding . . . to

maximize public benefits”54 and neither should impact the Department’s analysis of the consumer

benefits United’s proposal brings.

B. The Department’s Criteria Require Consideration of the U.S.-Asia Market as a Whole

Delta colorfully claims that United “strains to define the relevant market as U.S.-Asia” in

an effort to “obscure its outsized share at Haneda relative to Delta by distorting the definition of

the relevant market.”55 However, the effects on U.S.-Asia service have always been relevant in

52 See United Application, at 25. 53 See Order to Show Cause, Order 2008-4-17, at 12, Docket DOT-OST-2007-28664 (Apr. 4, 2008). 54 See Order 2019-2-5, at 2, Docket DOT-OST-2016-0048 (Feb. 2, 2019). 55 See Answer of Delta Air Lines, Inc. at 23.


U.S.-Haneda route proceedings, and this time is no different. Delta’s argument to the contrary is

wrong.

As Delta admits, the Department expressly noted in its Instituting Order that it would

“consider the effects of each service proposal on the overall competitive environment, including

effects on the market structure and on competition in the U.S.-Japan market and in any other

market shown to be relevant.”56 While Delta would characterize United’s in-depth and fulsome

“study [of] the broader dynamics of travel between the U.S. and Asia”57 as a negative, they make

no attempt to explain why the U.S.-Asia market is not relevant to this proceeding. That is because

they cannot.

As Delta CEO Ed Bastian admitted himself, Tokyo was not just Delta’s former hub for

Japanese operations; it had been, according to Mr. Bastian, Delta’s “center” for “Asian

operations.”58 United does not disagree, and similarly believes that Tokyo – both Haneda and

Narita – is vital to United’s commitment to serve both Japan and Asia more broadly. As United

explained fully in its Application, Tokyo, home to 38 million people, is a key international gateway

for Japan and the surrounding region.59 To argue that the impact of a carrier’s proposed Haneda

service on the broader U.S.-Asia market is not “relevant” is false.

Moreover, the Department further explained in its Instituting Order that it would consider,

when relevant, “other factors historically used for carrier selection.”60 The effect of a carrier’s

56 See Answer of Delta Air Lines, Inc. at 24 (quoting Order Instituting Proceeding, Order 2019-2-5, at 2, Docket DOT-OST-2016-0048 (Feb. 2, 2019). 57 See Consolidated Answer of Delta Air Lines, Inc. at 24. 58 See Trevor Williams, Delta CEO Sees Shanghai As Asia ‘Hub of the Future’ (Jun. 8, 2016), available at https://www.globalatlanta.com/delta-ceo-shanghai-is-airlines-asia-hub-of-the-future/ (“New CEO Ed Bastian said in a Bloomberg interview that the airline foresees shifting focus from Tokyo to Shanghai, its likely future Asia hub, as the city grows as a regional financial center and the country’s massive internal population grows ever more internationally mobile. ‘I think long-term we’re moving a lot of our Asian center of operations from Tokyo to Shanghai, and it should be the hub of the future,” Mr. Bastian said.’”) 59 See United Application at 7, 9-10. 60 See Order Instituting Proceeding, Order 2019-2-5, at 2, Docket DOT-OST-2016-0048 (Feb. 2, 2019).

https://www.globalatlanta.com/delta-ceo-shanghai-is-airlines-asia-hub-of-the-future/


proposed routing on service to Asia has always been relevant to route allocation proceedings in

Asia. In the 2010 Haneda proceeding, the Department, in awarding route allocation, stated that

“the ability to allocate slot pairs to enable four daily U.S.-Haneda services, allows us to reintroduce

convenient U.S.-Tokyo access while addressing a variety of important public interest objectives”

including “enhanc[ing] competition in the U.S.-Tokyo and U.S.-Asia markets.”61 In 2012, it was

Delta who relied on its “marketing relationship with Alaska” to provide “effective feed traffic for

Delta’s other Seattle services to Asia” when Delta proposed, and was awarded, new gateway

service to Haneda.62 And again in 2014, the Department held that U.S.-Asia traffic was relevant

to Haneda, stating that “[w]hen we take into account the large local traffic base at San Francisco,

combined with United’s proven ability to attract U.S.-Asia connecting traffic over its strong hub,

along with the specific attributes represented by Haneda, however, we tentatively do not find a

reason to question United’s ability to sustain its proposed Haneda service.”63

What’s more, other airlines, including Delta, have relied on the U.S.-Asia markets in

arguing for their route allocation proposals in past route proceedings. As mentioned above, Delta

relied on Alaska’s feed traffic for Delta’s other services to Asia in its 2012 Haneda proposal. In

2016, Delta cited the U.S.-Asia market in its Beijing proposal, claiming “Delta’s proposal would

increase intra-gateway competition for transpacific flights.”64 Similarly, American claimed that

“adding service to Beijing is critical not only to providing direct competition to Delta at Seattle

and United at San Francisco, but also to building American’s West Coast gateway to Asia at LAX

and enhancing transpacific competition.”65

61 See Order to Show Cause, Order 2010-5-7 at 8, Docket DOT-OST-2010-0018 (May 7, 2010); see also Final Order, Order 2010-7-2 at 6, Docket DOT-OST-2010-0018 (July 6, 2012). 62 See Order to Show Cause, Order 2012-11-12 at 6, Docket DOT-OST-2010-001 (Nov. 15, 2012). 63 See Order to Show Cause, Order 2014-2-23 at 5, Docket DOT-OST-2010-0018 (Feb. 28, 2014). 64 See Order to Show Cause, Order 2016-11-13 at 7, Docket DOT-OST-2016-0026 (Nov. 7, 2016). 65 See Order to Show Cause, Order 2016-11-13 at 3, Docket DOT-OST-2016-0026 (Nov. 7, 2016).


In light of the Department’s express statement that it would consider “other markets shown

to be relevant” in its Instituting Order, the unquestioned relevance of U.S.-Asia to the U.S.-Haneda

market and the historical weight U.S.-Asian service has been given in Haneda route proceedings,

United’s proposal correctly and comprehensively outlined the effect its U.S.-Haneda proposal

would have on the U.S.-Asia market as a whole.

C. American, Delta and Hawaiian Misrepresent the Facts

American’s, Delta’s, and Hawaiian’s Answers all contain mischaracterizations and

misstatements that United corrects for the record below.

1. American

American states that Las Vegas is a “key city in the underserved Mountain West region.”66

However, American could have multiplied the benefits to the public by offering the service from

its hub at Phoenix, which may have a smaller demand base compared to Las Vegas, but would

provide numerous connections to points in the Mountain West and the Desert Southwest including

Las Vegas. Selecting Las Vegas, however, benefits Japanese tourists to the detriment of

consumers that would have benefited from a Phoenix connection. Adding a gateway to Haneda in

the Mountain West region is notable, but it should not be a spoke point from which American

cannot connect any volume of points in the Mountain West region. American’s Las Vegas

proposal does not add competition in the Mountain West, it simply adds a flight at Las Vegas.

American claims it is disadvantaged vis-à-vis Delta and United in the central and eastern

U.S. due to the various hubs with existing or proposed Haneda service. However, instead of

seeking two slots for Dallas/Ft. Worth, American should have offered one for Dallas/Ft. Worth

and one for another one of its hubs that have lacked Tokyo service. Dallas/Ft. Worth is known to

be an inferior connection point given the added circuity. Two-thirds of communities behind United

66 See Consolidated Answer of American at 15.


and American hubs would have shorter travel times by traveling via a United hub rather than an

American hub. (See Exhibit UA-R113 at 1-3.) When excluding the market size to Tokyo from

hubs that are included in this proceeding, United’s first priority proposal beats American. Newark

Liberty, Chicago, and Washington, D.C. would connect, on a roundtrip basis, large (non-hub cities

in this proceeding), medium and small cities totaling 551,000 annual bookings with Tokyo.

American’s Dallas/Ft. Worth proposal – which, as it states, is its main way to compete for East

Coast and central U.S. traffic – would access a catchment area of approximately 508,000 annual

bookings. And for all the discussion about the U.S. points Dallas/Ft. Worth reaches, nearly twenty

points each have 730 annual Tokyo bookings – the equivalent of one passenger departing the U.S.

each day – or less.

2. Delta

Overall, Delta’s Application seeks to serve travelers bound from the U.S. to Tokyo as their

final destination, while United’s Application benefits a much broader set of passengers from the

U.S. to all of Japan. The bottom line is that Delta does not need nearly as many Haneda slots as it

claims it does, nor as many as other carriers in this proceeding given that Delta does not use Haneda

as a hub for service to the rest of Japan. Delta’s hub is at Seoul, which gives them access to points

in Japan. Delta/Korean offer 20 daily flights from the U.S. to Seoul (including three from Guam)

from 13 U.S. mainland gateways and Korean has 29 daily flights to Japan from ICN at Seoul. In

addition, and noted by United and others, Delta/Korean promotes ICN as their primary gateway

for service to Japan. (See Exhibit UA-R111 at 1-4.)

Despite the above, apart from quoting United’s well-supported assertions about Delta’s

joint venture with Korean repeatedly, Delta completely disavows the relationship and references

it once and only to state that the joint venture “has nothing to do with this case.”67 However, as

67 See Delta Application at 25.


discussed above and extensively in United’s filings as well as American’s and Hawaiian’s

Answers, despite Delta’s strident efforts to claim otherwise, the fact is that Delta has a joint venture

partner in Japan and Delta has further evolved its network to move to long-haul flying and a joint

venture with Korean.68 Delta’s claims that it is disadvantaged at Haneda are misleading, its own

doing, and it is not the Department’s job in this proceeding to favor Delta’s Asian network by

handing it half the available Haneda slots – particularly when Delta has made little to no effort

demonstrating the public benefits of its proposal. As United pointed out and even JetBlue – a non-

applicant – noted in its Answer,69 Delta cannot have it both ways: it cannot challenge immunized

alliances in this proceeding and simultaneously take an opposite position defending its dominant

position as a result of its immunized alliances in the transatlantic market.70

Delta claims Seattle, Detroit, Atlanta and Portland are new gateways for Haneda and that

“the other carriers are not proposing new service.”71 However, it appears Delta is shifting all of

its Narita service to Haneda; this really is not new service and, if true, then Delta will be stopping

service to Singapore and Manila, thus impacting 170,000 annual consumers currently using its

network. But by Delta’s measure, United is also offering four new Haneda gateways: Newark

Liberty, Washington, D.C., Houston and Guam. Delta also makes claims about connectivity via

its proposals at places like Atlanta and Detroit. As noted above, when making certain reasonable

assumptions and comparing network scope, United’s first priority proposal of Newark Liberty,

Chicago, and Washington, D.C. would connect communities totaling a catchment area of 551,000

annual bookings with Tokyo. Delta’s Atlanta and Detroit proposals total 542,000. The

Washington Dulles proposal connects U.S. cities with Tokyo Haneda that cumulatively sum to

68 See United Application at 8-9, and United Answer at 19-20. 69 See Answer of JetBlue Airways, Docket DOT-OST-2019-0014 (Feb. 28, 2019). 70 See id., see also United Answer at 11-12. 71 See Delta Application at 8.


160,000 more Tokyo annual bookings and 101,000 more Japan bookings beyond Tokyo than

Delta’s Minneapolis-Haneda flight provides today. Of course there are no passengers going

beyond Haneda to points in Japan on the Minneapolis flight because Delta’s hub for intra-Japan is

at Seoul.

Throughout its filings, Delta espouses the view that the only relevant market for Tokyo

passengers is Haneda. This is further evidenced by Delta’s strategy to shift its Narita service to

Haneda. While United does not dispute that Haneda is the preferred airport among the two for

people going to central Tokyo and wanting to make connections to points in Japan, Delta is wrong

when it states that Haneda is the only relevant way to serve local passengers. As United described

in its Application, Narita’s significance cannot be understated. (See United Application at 4.)

Despite basing its entire Application on this notion that Haneda is the only relevant airport, Delta

takes the opposite view when convenient for its argument, like when it states that United’s Houston

service is redundant because it already has access to Tokyo via its service to Narita.72

Delta also calls United’s Los Angeles-Haneda service “redundant” and “duplicative.”73

However, as United pointed out, its Los Angeles-Haneda service will supplement and complement

ANA’s service, providing additional time-of-day schedule options for West Coast consumers.

(See UA Application, Exhibit UA-142.) In addition, and importantly, it will inject competition

between U.S. carriers in the large Los Angeles market, providing United an opportunity to compete

in a high Tokyo demand market with its own metal. Delta states conclusively that redundancy is

a “losing equation in a route case” and cites, as the sole support, the Department’s award to Delta

of its Seattle slot in 2012 – a valuable slot that the Department is well aware Delta unabashedly

wasted to the detriment of consumers. Today, due to the Department’s tireless efforts, 12 slots are

72 See Delta Application at 22. 73 See id.


now available – not just the four nighttime slots that were available then – and carriers have more

opportunities to expand and enhance their consumers’ access to Haneda. United is unapologetic

about its desire to provide greater access at its proposed routes, including Los Angeles, and has

demonstrated the public benefits. Delta is welcome to do the same.

Delta takes umbrage74 at United’s example of a Haneda-bound passenger from Norfolk,

Virginia having to make two stops and spend the night at a United hub.75 However, Delta

completely misses the point. The example was an actual United passenger who had selected to

travel on United from Norfolk to San Francisco. Dismissing this example as a mischaracterization

and suggesting that the customer could travel on an ANA flight to Haneda, rendering United’s

proposed gateways at Newark Liberty, Chicago, or Washington, D.C. meritless, is illogical.

United provided detail on its current Haneda consumer base, how that base moves around the

United network to get to San Francisco and then Haneda. Opening gateways, such as those

mentioned in United’s first priority request, will reduce travel times, simplify connections and

enhance the travel experience for that passenger wanting to fly United from Norfolk and dozens

of other United spoke markets to Haneda. Unlike Delta, United took considerable effort to

describe in detail these types of consumer benefits that would be possible as a result of United’s

proposed service. Similarly, regarding Delta’s suggestion that United does not take its metal-

neutral joint venture with ANA seriously, Delta again has it wrong. While metal-neutrality is the

guiding principle from the carrier’s perspective, individual passengers’ wants and demands need

not be indifferent.76

74 See Answer of Delta at Exhibit DL-A-118. 75 See United Application at 19. 76 See United Application at 17-18.


3. Hawaiian

Applicants have submitted a total of 19 applications for the 12 available slot pairs, seven

of which are for routes that will principally serve Japanese leisure passengers that are not time-

sensitive (five for Honolulu, one for Las Vegas, and one for Guam). One may question if any

application has been able to adequately explain why Japanese leisure passengers that do not have

time sensitivity require access to Haneda, specifically over Narita. Hawaiian’s Application and

Answer fail to demonstrate how Haneda slots are needed to realize any of Hawaiian’s purported

benefits. Based on Hawaiian’s own methodology, 100% of their benefits could be achieved by

adding three new flights between Narita and Honolulu. Hawaiian’s supporting models group

Narita and Haneda together when calculating benefits, effectively admitting that the benefits of its

service would be the same if all three of their Honolulu routes served Narita in lieu of Haneda.77

The Department should be unconvinced that Haneda slots are necessary for Hawaiian’s proposal.

The same logic can be applied to Delta’s requested Honolulu slots and American’s Las Vegas

request. However, if the Department ultimately decides that bringing Japanese tourists to U.S.

points is an important public interest factor in this proceeding, United’s proposal to serve Guam

merits an award before Honolulu gets its third, fourth, fifth, sixth and seventh slots via Hawaiian

and Delta’s proposals.

Hawaiian cites the economic benefits and job stimulus that its proposed service would

generate. By that measure, United’s addition of three new flights would also be seen as driving

benefit to the U.S. economy from Japanese visitors. Because only Hawaiian and United propose

to add three new flights to Tokyo in this proceeding, those are the only two carriers involved in

the comparison. Based on the formula and data inputs from the Hawaiian model (Exhibit HA-A-

208), and using an average spend per visitor of $1,442, United estimates its three route proposal

77 See, e.g., Hawaiian Application at 36, 41 and 43.


would generate $101.3M in economic spend for the U.S. economy, spread across United’s three

hubs at Newark Liberty, Los Angeles, and Guam.

Hawaiian “questions United’s commitment”78 to Guam due to the fact that it is part of

United’s third-priority proposal. However, United’s history at Guam makes clear its commitment,

having recently celebrated 40 years of service between Guam and Japan and even more recently

50 years of service between Guam and the Micronesian Islands. And while there was a temporary

dip in traffic due to Japanese tourists’ concerns about traveling to Guam, given North Korean

geopolitical issues, the market has since recovered. (See Exhibit UA-R112.) In addition, Hawaiian

incorrectly measures its high load factors at Honolulu with United’s at Guam. United did

downgauge flights between Guam and Tokyo to help right-size capacity to the temporary lull in

Japanese travel. That is no longer the case, as United’s B777-200 high density aircraft are coming

back to the Guam-Tokyo market for peak season.

Finally, Hawaiian makes light of its pending application for antitrust immunity for its joint

venture with JAL. However, regardless of the outcome of its ATI application, Hawaiian currently

codeshares with JAL on a large combination of flights between Hawaii and Japan and, in total, the

codeshare partners have 11.4 daily flights now and likely will in the future, more than any other

carrier and partnership in any U.S. state to Japan market. That alone should relegate Hawaiian to

the end of the line in getting more Haneda slots.

IV. CONCLUSION

WHEREFORE, for the foregoing reasons, United respectfully reiterates its request that the

Department grant its Application for six Haneda slot pairs for daily, year-round, nonstop service

to Haneda in the following order of priority: First-Priority - Newark Liberty-Haneda, Chicago-

78 See Hawaiian Application at 39.


Haneda, and Washington-Dulles-Haneda slot pairs; Second-Priority - Los Angeles-Haneda slot

pair; and Third-Priority - Houston-Haneda and Guam-Haneda slot pairs.

Respectfully submitted,

JENNER & BLOCK LLP

______________________________________ Abby L. Bried Amna Arshad Counsel for United Airlines, Inc.

March 7, 2019

ATTACHMENT 1

1

What They’re Saying: United to Tokyo Haneda Federal, State and Local Leaders Support United’s Proposed Service

March 7, 2019

United’s proposal for six new daily direct flights from U.S. hubs to Tokyo Haneda Airport – which would connect five of the six largest metropolitan areas in the U.S. mainland and Guam to the closest airport to downtown Tokyo – has received more than 8,000 letters of support from customers, employees and federal, state and local leaders. Below are highlights from some of the letters United’s proposal has garnered thus far from elected officials and business leaders who recognize that the proposed flights would benefit their communities by providing more and better options for consumers for air travel between the U.S. and Japan. Learn more about United’s proposed service at www.unitedtohaneda.com. Letters from Elected Officials Senators Robert Menendez (NJ) and Cory Booker (NJ), United States Senate:

• “If approved, [United’s] proposal will more effectively link Tokyo Haneda with the New Jersey and New York market, as well as 43 other U.S. airports served from Newark Liberty. A new flight from Newark Liberty to Haneda would complement Newark Liberty’s existing flight to Narita, increasing travel options for consumers to Tokyo. The proposed flight will also simplify connections for travelers and in some cases reduce travel times to points in Japan.”

o Joint Letter to Secretary Chao, February 21, 2019 Senators Mark R. Warner (VA) and Tim Kaine (VA), United States Senate:

• “The proposed D.C. route will simplify connections and improve travel options for consumers, including U.S. servicemembers traveling between the DC area and Okinawa on United’s Japanese partner ANA. United’s proposal will also benefit Fortune 500 companies with substantial sales or ties to Japan that are headquartered in the D.C. area.”

o Joint Letter to Secretary Chao, February 28, 2019 Senators Richard Durbin (IL) and Tammy Duckworth (IL), United States Senate:

• “Increasing access to Tokyo from Chicago is important to our constituents in Illinois because Chicago is home to the seventh largest Japanese foreign-born community in the country and because there is substantial demand from business travel between Chicago and Tokyo given the number of Fortune 500 companies with ties to Japan headquartered in the Chicago area.”

o Joint Letter to Secretary Chao, February 21, 2019

Illinois Congressional Delegation, United States House of Representatives: • “Chicago has the highest demand for Tokyo travel in the central U.S. and the seventh largest Japanese

foreign-born community in the U.S. O’Hare is not only an economic driver for Chicago but for all of Illinois and the greater Midwestern region. New access to Tokyo will help promote growth across the state and beyond its borders.”

o Joint Letter to Secretary Chao, February 28, 2019

Houston Area Congressional Delegation, United States House of Representatives: • “United’s flight would offer customers a competitive alternative for Tokyo Haneda service from other

southern and southeastern U.S. hubs, and serve as a gateway between Latin America and Japan.”

http://www.unitedtohaneda.com/

2

o Letter to Secretary Chao, February 28, 2019 Congresswoman Julia Brownley (CA-26), United States House of Representatives:

• “For decades, United has played a pivotal role in facilitating tourism, trade and commerce between the U.S. and Japan, demonstrating as strong commitment to serving U.S. consumers’ needs…With greater frequency of flights and a wide network of connecting points, consumers and businesses will see improved convenience and benefits from United’s propose flights.”

o Letter to Secretary Chao, March 4, 2019

Congressman Al Green (TX-9), United States House of Representatives: • “United Airlines’ application will greatly benefit my hometown of Houston, my state of Texas, and the

rest of the country.” o Letter to Secretary Chao, February 28, 2019

Congressman Kevin Brady (TX-8), United States House of Representatives:

• “UA’s proposal includes a flight from Houston George Bush Intercontinental Airport (IAH), which would strengthen a bridge from the center of commerce for the oil, gas and energy industries to Tokyo Haneda.”

o Letter to Secretary Chao, February 19, 2019 Congressman Doug LaMalfa (CA-1), United States House of Representatives:

• “A new Haneda flight would add to United’s existing flight from Los Angeles to Narita, giving additional choices and simpler connections to consumers in the West, including the large number of U.S. servicemembers who travel from California to Okinawa.”

o Letter to Secretary Chao, February 20, 2019

Illinois Governor JB Pritzker: • “United’s proposal includes a flight from Chicago O’Hare International Airport (ORD) to Tokyo Haneda,

which would connect this primary Midwest logistics and transportation hub to Haneda and provide more convenient travel options for U.S. consumers.”


Guam Governor Lourdes A. Leon Guerrero: • “Tokyo and the broader Japanese market are strategically important to Guam, which relies upon the

Japanese leisure travelers for tourism and job creation on the island.” o Letter to Secretary Chao, February 15, 2019

Newark Mayor Ras J. Baraka:

• “I strongly urge the Department of Transportation to approve United Airline’s request to connect my community with Tokyo’s most convenient airport – Haneda.”


Houston Mayor Sylvester Turner • “United’s proposal includes a flight from Houston George Bush Intercontinental Airport (IAH), which

would strengthen the air services bridge from the U.S. center of commerce for the oil, gas and energy industries in Houston to Tokyo.”

o Letter to Secretary Chao, March 1, 2019

Los Angeles Mayor Eric Garcetti: • “With greater frequency of flights and a wide network of connecting points, consumers and businesses

will see improved convenience and benefits from United’s proposed flight from LAX.” o Letter to Secretary Chao, February 25, 2019

Assemblyman Gordon M. Johnson (NJ-37), New Jersey General Assembly:

• “United’s proposal includes a new flight from Newark Liberty International Airport (EWR) to Tokyo Haneda, which would strengthen the bridge between each country’s center for commerce and finance, creating far more convenient options for consumers and business leaders traveling between two of the largest cities in the world.”

o Letter to Secretary Chao, February 22, 2019 Speaker M. Kirkland Cox (VA-66), Virginia House of Delegates:

3

• “The proposed Washington, D.C. route will simplify connections and improve travel options for consumers, including U.S. servicemembers traveling between the D.C. area and Okinawa.”

o Letter to Secretary Chao, February 15, 2019 Assemblyman Jim Frazier (CA-11), California State Assembly:

• “Substantial demand also exists for business travel between Los Angeles and Tokyo. Japanese-owned companies directly employ over 119,000 workers in California, and employ over 85,000 workers with wages of $5.4 billion in Southern California. In 2017, California exported nearly $13 billion in goods to Japan.”

o Letter to Secretary Chao, February 15, 2019 Letters from Business and Industry Leaders Japanese Chamber of Commerce and Industry of New York, Inc.:

• “For decades, United has played a pivotal role in facilitating tourism, trade and commerce between the U.S. and Japan, demonstrating unparalleled commitment to serving U.S. consumers’ needs in Japan. United is the only U.S. carrier to provide an extensive network of flights to Tokyo from all of its hubs. Should the Department of Transportation approve its application, United Airlines will continue to play this vital role in an even greater capacity for the benefit of U.S. consumers.”

o Letter to Secretary Chao, February 19, 2019 Japan Society:

• “If approved, United’s flight from Newark Liberty to Haneda would add to United’s existing flight to Narita, increasing travel options for consumers to Tokyo.”

o Letter to Secretary Chao, February 20, 2019 Commerce and Industry Association of New Jersey:

• “Demand for Tokyo travel from the Newark/New York metropolitan area is strong and currently underserved.”


New Jersey Chamber of Commerce: • “Today, Newark Liberty lacks non-stop service to Tokyo Haneda despite the fact that approximately

four million people live within 20 miles of the airport. Newark/ New York is the largest market on the East Coast for travel demand to Tokyo. United’s proposal will connect Tokyo Haneda with Newark/ New York and 43 other U.S. airports United serves from its Newark Liberty hub. This area represents approximately 1.2 million annual bookings to Tokyo.”


Virginia Chamber of Commerce: • “From a business development prospective, the proposed Washington Dulles route would provide a

more direct and desirable connection to Tokyo. This route could increase business and governmental contacts between the United States and Japan and would complement current marketing efforts to attract foreign direct investment to Virginia. Further, nonstop service from Washington, D.C. could encourage Virginia-based and Fortune 5000 companies to expand sales and production in Japan, as well as other markets throughout East Asia.”

o Letter to Secretary Chao, February 28, 2019 Greater Houston Partnership:

• “United has demonstrated an unparalleled, long-term commitment among U.S. carriers to serving consumers’ travel needs from the United States to Tokyo and the surrounding region. Operating the world’s most comprehensive route network, United is best positioned to maximize new flight opportunities for the traveling public.”

o Letter to Secretary Chao, February 21, 2019 World Business Chicago:

• “I understand the value these additional flights will bring to Chicago and its citizens. As our city’s economic development agency, World Business Chicago works to drive inclusive economic growth for all Chicagoans and to build upon our strong presence around the world. Our international reach is a driver for our economy, and we strongly rely on our corporate partners, like United, to help us drive growth.”


4

Guam Visitors Bureau: • “The Guam-Japan market is significant in size, yet there is no direct service to Haneda, the closest

airport to central Tokyo, while Hawaii already has multiple flights to Haneda. United’s proposed flight between Tokyo Haneda and Guam would generate additional demand and give U.S. and Japanese consumers access to more than 30 points in Japan that travelers currently cannot access via Tokyo Narita.”

o Letter to Secretary Chao, February 18, 2019 Letters from Labor Leaders: David P. Bourne, Director, Teamsters Airline Division:

• “A grant of new Haneda service will create a stronger, more competitive United, benefitting a broad range of stakeholders, including United’s nearly 90,000 employees across the United States and the world. From pilots to caterers to maintenance workers, improved and expanded United service to Haneda can help deliver more opportunities for United’s employees.”

o Letter to Secretary Chao, February 27, 2019 Captain Todd Insler, Chairman, United Master Executive Council, Air Line Pilots Association, International (ALPA):

• “The United MEC wholly supports the Department in its mandate to maximize consumer and community benefits by considering which applicants will offer and maintain service that best meets the needs of the traveling and shipping public. Granting United’s proposal is consistent with the Department’s principal goal in this proceeding to maximize public benefits: it will deliver demonstrable public interest benefits to consumers, promote geographic diversity among U.S. hubs, and provide competitive alternatives to the other U.S. carriers and Japanese carriers operating between the U.S. and Japan.”

o Letter submitted to the Department of Transportation, February 27, 2019 Ken Diaz, President, United Master Executive Council, Association of Flight Attendants (AFA):

• “On behalf of the more than 25,000 United Airlines Flight Attendants, I am writing to you today in support of United’s recent application for the six (6) slot pairs at Tokyo’s Haneda Airport from six of United’s hub locations. Approval of these applications would offer more options and convenience for consumers from U.S. cities where the demand for travel to Tokyo and beyond is highest.”

o Letter to Secretary Chao, February 26, 2019 Craig Symons, President, Professional Airline Flight Control Association, United Airlines (PAFCA-UAL)

• On behalf of the 435 FAA licensed Flight Dispatchers at United Airlines, I strongly urge the Department of Transportation to approve United Airlines’ request for flights to Tokyo Haneda from five of the six largest metropolitan areas in the U.S. mainland and a new flight between Guam and Haneda.


Bill Hutson, President, International Association of Machinists and Aerospace Workers (IAMAW), Capital Air Lodge 1759:

• “On behalf of the 1,800 United Airlines workers that we proudly represent at Washington Dulles International Airport (“IAD”), I am writing in strong support for United Airlines’ application to the Department of Transportation (“DOT”) for additional flights to Tokyo Haneda Airport in Japan.”

o Letter to Secretary Chao, February 26, 2019 Sharon Sugiyama, President, International Association of Machinists and Aerospace Workers (IAMAW) LL2339G:

• “Guam should have the opportunity to compete with Hawaii for Japanese travelers and benefit from the same economic stimulus that Tokyo Haneda flights have delivered to Honolulu, Kona and other communities in Hawaii.”

o Letter to Secretary Chao, February 26, 2019 Letters from Airport and Aviation Authorities 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,

5

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.”

o Answer of the Port Authority of New York and New Jersey in Support of UAL, February 28, 2019

City of Chicago Department of Aviation:

• “United’s proposed service to Haneda would meet the substantial demand for business and leisure travel between Chicago and Tokyo, as well as points beyond. Chicago, and indeed the Central U.S., depends on convenient air transportation service to Tokyo and other Japanese cities. Collectively, Japanese investment in the Midwest has provided an estimated 150,000 American jobs within the region, and more than 45,000 in Illinois alone.”

o Answer of the City of Chicago in Support of UAL, February 28, 2019 Washington Airports Task Force:

• “United’s proposal to inaugurate a flight from Dulles to Tokyo Haneda Airport would strengthen a bridge between the seats of government in both the U.S. and Japan, two of the largest democracies and economies in the world, and it would provide a far more convenient travel option for civilian and military employees of both countries’ governments.”

o Letter to Secretary Chao, March 1, 2019 Mario Diaz, Director of Aviation, City of Houston:

• “With greater frequency of flights and a wide network of connecting points, United’s proposal will help expand consumer and business service options in the Houston market. The City of Houston urges DOT to approve United Airlines’ Tokyo Haneda proposal.”

o Letter to Secretary Chao, February 19, 2019 Thomas Ada, Executive Manager, A.B. Won Pat International Airport:

• “Tokyo and the broader Japanese market are strategically important to Guam, which relies upon the Japanese leisure travelers for tourism and job creation on the island. The Guam-Japan market is significant in size, yet there is no direct service to Haneda, the closest airport to central Tokyo, while Hawaii already has multiple flights to Haneda. United’s proposed flight between Tokyo Haneda and Guam would generate additional demand and give U.S. and Japanese consumers access to more than 30 points in Japan that travelers currently cannot access via Tokyo Narita.”


1 Harrison Street, S.E., 5th Floor, P.O. Box 7000, Leesburg, VA 20177-7000 MS #1 (703) 777-0204 {Phone} • (703) 777-0421 {Fax} • [email protected] {email}

Loudoun County, Virginia www.loudoun.gov Phyllis J. Randall Chairwoman At Large Loudoun County Board of Supervisors

March 4, 2019 The Honorable Elaine L. Chao Secretary United States Department of Transportation 1200 New Jersey Avenue, S.E. Washington, D.C. 20590 Re: Docket DOT-OST-2019-0014 Dear Secretary Chao: I write today in strong support of United Airlines’ application to the Department of Transportation (DOT) for authority to operate nonstop flights from Washington Dulles International Airport (Dulles) to Tokyo’s Haneda Airport in Japan. I understand that United’s application is part of the DOT’s route proceeding to award frequencies for new flights at Tokyo Haneda Airport that would start later this year or in 2020. I appreciate that, for decades, United has played a pivotal role in facilitating tourism, trade and commerce between the U.S. and Japan, demonstrating an unparalleled commitment to serving U.S. consumers’ needs for travel options to and from Japan. United is the only U.S. carrier to provide an extensive network of flights to Tokyo from all of its hubs, including Dulles. Should the DOT approve its application, United will continue to play this vital role in an even greater capacity for the benefit of U.S. consumers broadly and Washington area travelers and businesses more specifically. United’s proposal to inaugurate a flight from Dulles to Tokyo Haneda Airport would strengthen a bridge between the seats of government in both the U.S. and Japan, two of the largest democracies and economies in the world, and it would provide a far more convenient travel option for civilian and military employees of both countries’ governments. It is important to note that, beyond governmental travel, the Washington metropolitan area is the second largest point on the East Coast for Tokyo travel demand. And in addition to the large local market between Washington and Tokyo, United’s proposed Dulles flight will facilitate easier connections via Dulles between Tokyo Haneda Airport and 35 other U.S. cities representing 1.2 million annual Tokyo bookings. The proposed Dulles-Tokyo Haneda route will simplify connections and improve travel options for all consumers, including U.S. servicemembers traveling between the Washington area and military bases throughout Japan, including those in Okinawa. United’s Japanese partner, ANA, has many daily flights between Tokyo Haneda and Okinawa that will connect to and from United’s proposed Dulles-Tokyo Haneda flights. United’s proposal will also benefit numerous companies that are headquartered in the Washington metropolitan area, including many listed on the Fortune 500, that have substantial sales to, or corporate ties with, organizations located in Japan.

2

With a hub at Dulles, United plays a very important role in the worldwide travels, both domestically and internationally, of Washington area travelers and businesses due to its great frequency of flights and comprehensive network. This is amply demonstrated by United operating in excess of 250 daily nonstop flights from Dulles to more than 30 international and over 70 domestic destinations this year. Thus, the improved convenience and benefits to be derived by local travelers and businesses from United’s proposed nonstop Dulles-Tokyo Haneda flights makes the value proposition offered by the Dulles hub that much more compelling. Therefore, I strongly urge the Department of Transportation to approve United Airlines’ Dulles-Tokyo Haneda Airport proposal. Sincerely,

Phyllis J. Randall, Chair at-Large Loudoun County Board of Supervisors

March 7, 2019 The Honorable Elaine L. Chao Secretary United States Department of Transportation 1200 New Jersey Avenue, S.E. Washington, D.C. 20590 Re: Docket DOT-OST-2019-0014 Dear Secretary Chao, I write today in strong support for United Airlines’ application to the Department of Transportation (DOT) for additional flights to Tokyo Haneda Airport in Japan. United’s application is part of the DOT’s route proceeding for new flights at Tokyo Haneda airport that would start in summer 2020. For decades, United has played a pivotal role in facilitating tourism, trade and commerce between the U.S. and Japan, demonstrating unparalleled commitment to serving U.S. consumers’ needs in Japan. United is the only U.S. carrier to provide an extensive network of flights to Tokyo from all its hubs. Should the Department of Transportation approve its application, United Airlines will continue to play this vital role in an even greater capacity for the benefit of U.S. consumers. United’s proposal includes a flight from Chicago O’Hare International Airport (ORD) to Tokyo Haneda, which would connect this primary Midwest logistics and transportation hub to Haneda and provide more convenient travel options for U.S. consumers. Chicago has the highest demand for Tokyo travel in the central U.S. and the seventh largest Japanese foreign-born community in the U.S. The proposed route will connect Tokyo Haneda with Chicago and 80 U.S. points United serves from ORD, an area that represents approximately 1.6 million annual Tokyo bookings. The flight will simplify connections to Tokyo Haneda for consumers at these points served via United’s hub at ORD. There is substantial demand for business travel between Chicago and Tokyo given the number of Fortune 500 companies with substantial sales or ties to Japan that are headquartered in the Chicago area. With greater frequency of flights and a wide network of connecting points, consumers and businesses will see improved convenience and benefits from United’s proposed flights. I strongly urge the Department of Transportation to approve United Airlines’ Tokyo Haneda proposal. Regards,

Daniel J. Cronin Chairman DuPage County Board

COMMITTEES: Economic Development, Chair | Budget and Fiscal Affairs | Ethics, Election & Council Governance Public Safety & Homeland Security | Quality of Life | Transportation Technology and Infrastructure

900 Bagby, 1st Floor · Houston, Texas 77002 · (832) 393-3009 · [email protected]

Jerry V. Davis

City of Houston Council Member, District B

Office of the Vice Mayor Pro-Tempore

March 4, 2019 The Honorable Elaine L. Chao Secretary United States Department of Transportation 1200 New Jersey Avenue, S.E. Washington, D.C. 20590

Re: Docket DOT-OST-2019-0014

Dear Secretary Chao, I write today in strong support for United Airlines’ application to the Department of

Transportation (DOT) for additional flights to Tokyo Haneda Airport in Japan. United’s application is part of the DOT’s route proceeding for new flights at Tokyo Haneda airport that would start in summer 2020. For decades, United has played a pivotal role in facilitating tourism, trade and commerce between the U.S. and Japan, demonstrating unparalleled commitment to serving U.S. consumers’ needs in Japan. United is the only U.S. carrier to provide an extensive network of flights to Tokyo from all its hubs. Should the Department of Transportation approve its application, United Airlines will continue to play this vital role in an even greater capacity for the benefit of U.S. consumers.

United’s proposal includes a flight from Houston George Bush Intercontinental Airport (IAH),

which would strengthen a bridge from the center of commerce for the oil, gas and energy industries to Tokyo Haneda. There is substantial demand for business travel between Houston and Tokyo. Japanese-owned companies directly employ over 50,000 workers in Texas, and there are 150 Japanese-affiliated companies in Houston. Further, Texas is home to 48 Fortune 500 Companies with 21 located in the immediate Houston vicinity.

The proposed Houston route will simplify connections to Tokyo Haneda and in some cases will

reduce travel times between points in the U.S. and points in Japan. United's Houston proposal will connect Tokyo Haneda with 32 U.S. airports. Finally, United’s flight would offer customers a competitive alternative for Tokyo Haneda service from other southern and southeastern U.S. hubs, and serve as a gateway between Latin America and Japan.

With greater frequency of flights and a wide network of connecting points, consumers and

businesses will see improved convenience and benefits from United’s proposed flights. I strongly urge the Department of Transportation to approve United Airlines’ Tokyo Haneda proposal.

Sincerely,

Jerry V. Davis Vice Mayor Pro-Tempore Council Member, District B

March 4, 2019 The Honorable Elaine L. Chao Secretary United States Department of Transportation 1200 New Jersey Avenue, S.E. Washington, D.C. 20590 Re: Docket DOT-OST-2019-0014 Dear Secretary Chao, I write today in support of United Airlines’ application to the Department of Transportation (DOT) for additional flights to Tokyo Haneda Airport in Japan. United’s application is part of the DOT’s route proceeding for new flights at Tokyo Haneda airport that would start in summer 2020. For decades, United has played a pivotal role in facilitating tourism, trade and commerce between the U.S. and Japan. Should the Department of Transportation approve its application, United Airlines will continue to play this vital role in an even greater capacity for the benefit of U.S. consumers and communities like Columbus. United’s U.S. mainland-Haneda proposal under consideration by the Department includes service from Newark Liberty International Airport (EWR), Chicago O’Hare International Airport (ORD), Washington Dulles International Airport (IAD), Los Angeles International Airport (LAX), and George Bush Intercontinental Airport (IAH). United’s proposal would give Central Ohio more than 20 daily options from John Glenn Columbus International Airport (CMH) to make single-connection service to Tokyo Haneda – the preferred airport for consumers flying to Tokyo or for those that wish to connect beyond Haneda to other points in Japan. United’s proposal will add new flights into the U.S.-Tokyo Haneda market, simplify connecting itineraries and reduce travel time for consumers. Together, the proposed flights from five U.S. mainland hub cities will connect Tokyo Haneda with 112 U.S. airports, representing approximately two thirds of U.S.-Tokyo demand, or more than three million annual Tokyo bookings. I believe the Columbus community stands to benefit from the enhanced choice and convenience offered by United’s proposal, which will help support American businesses and help grow the U.S. economy. I urge the Department of Transportation to approve United Airlines’ request to connect my community with Tokyo’s most convenient airport – Haneda. Sincerely, Torrance A. Richardson, A.A.E. Executive Vice President & Chief Operating Officer

BOARD OF COMMISSIONERS PRESIDENT AND CEO A. Dexter Samuels Ph.D., Chair John E. Doerge Robert J. Joslin Douglas E. Kreulen Aubrey B. Harwell III, Vice Chair William H. Freeman Christy Smith Amanda Farnsworth, Secretary James W. Granbery Nancy Sullivan, PE C. David Briley, Mayor Page 1 of 1

February 28, 2019 The Honorable Elaine L. Chao Secretary United States Department of Transportation 1200 New Jersey Avenue, S.E. Washington, D.C. 20590 Re: Docket DOT-OST-2019-0014 Dear Secretary Chao, I am writing to convey Nashville International Airport’s strong support of United Airlines’ application to the Department of Transportation (DOT) for additional flights to Tokyo Haneda Airport (HND) in Japan. If approved, this greatly-needed air service would add six daily nonstop flights to HND, beginning summer 2020, from Newark Liberty International Airport (EWR), Chicago O’Hare International Airport (ORD), Washington Dulles International Airport (IAD), Los Angeles International Airport (LAX), Houston George Bush Intercontinental Airport (IAH), and Guam’s A.B. Won Pat International Airport (GUM). United is pursuing these flights to meet customer demand and to benefit travelers – American and Japanese. Granting United’s application is in the best interest of the American economy, given that it will accommodate air service to key business, government and cultural hubs where demand for flights to Haneda is the highest. In fact, these flights would connect Tokyo Haneda Airport with 112 U.S. airports, representing approximately two-thirds of U.S.-Tokyo demand, or more than three million annual Tokyo bookings. Nashville International Airport (BNA) has a particular interest in United’s application, given that nearly 180 Japanese-owned companies operate in Tennessee, including Nissan North America, Yorozu Automotive, M-Tek, Bridgestone Americas, and Denso Manufacturing. We anticipate significant demand for and utilization of this service by Tennesseans, should United’s application be approved. I strongly believe time will show that demand for this service will only grow, and in the next few years, we hope that BNA will be added to the list of airports providing nonstop service to HND. In fact, adding a nonstop flight from Nashville to Tokyo is a key strategic component of our expansion of international air service at BNA, as we seek to meet the demands of businesses and consumers. I believe United’s application is warranted, appropriate, and advantageous for the reasons stated above. I strongly urge the Department of Transportation to approve United Airlines’ request and bring travelers closer to Tokyo with additional air service. We have much to gain. Thank you for your consideration. Sincerely, Douglas E. Kreulen, A.A.E. President and CEO Nashville International Airport (BNA)

!_____________________________________________________________

February 26, 2019

The Honorable Elaine L. Chao Secretary United States Department of Transportation 1200 New Jersey Avenue, S.E. Washington, D.C. 20590

Re: Docket DOT-OST-2019-0014

Dear Secretary Chao,

On behalf of the Greenville-Spartanburg Airport District, I write today in strong support of United Airlines’ application to the Department of Transportation (DOT) for additional flights to Tokyo Haneda Airport in Japan. United’s application is part of the DOT’s route proceeding for new flights at Tokyo Haneda airport that would start in summer 2020. For decades, United has played a pivotal role in facilitating tourism, trade and commerce between the U.S. and Japan. Should the Department of Transportation approve its application, United Airlines will continue to play this vital role in an even greater capacity for the benefit of U.S. consumers and communities like mine.

United’s U.S. mainland-Haneda proposal under consideration by the Department includes service from Newark Liberty International Airport (EWR), Chicago O’Hare International Airport (ORD), Washington Dulles International Airport (IAD), Los Angeles International Airport (LAX), and George Bush Intercontinental Airport (IAH). United’s proposal would give my community single-connection service to Tokyo Haneda – the preferred airport for consumers flying to Tokyo or for those that wish to connect beyond Haneda to other points in Japan.

United’s proposal will add new flights into the U.S.-Tokyo Haneda market, simplify connecting itineraries and reduce travel time for consumers. Together, the proposed flights from five U.S. mainland hub cities will connect Tokyo Haneda with 112 U.S. airports, representing approximately two thirds of U.S.-Tokyo demand, or more than three million annual Tokyo bookings. I believe the Greenville-Spartanburg International Airport and Upstate South Carolina will benefit from the enhanced choice and convenience offered by United’s proposal, as it will support businesses and help grow the U.S. economy.

I strongly urge the Department of Transportation to approve United Airlines’ request to connect my community with Tokyo’s most convenient airport – Haneda.

Sincerely,

David N. Edwards, Jr. President/CEO

2000 GSP Drive, Suite 1 ● Greer, SC 29651 ● Phone: 864.877.7426 ● Fax: 864.848.6225 www.gspairport.com

VIA Terminal Building 3002 Heritage Way, 3rd Floor Harlingen, TX 78550 T. 956 430 8605 F. 956 430 8619 www.flythevalley.com

February 27, 2019 The Honorable Elaine L. Chao, Secretary United States Department of Transportation 1200 New Jersey Avenue, S.E. Washington, D.C. 20590 Re: Docket DOT-OST-2019-0014 Dear Secretary Chao, I write today in strong support of United Airlines’ application to the Department of Transportation (DOT) for additional flights to Tokyo Haneda Airport in Japan. United’s application is part of the DOT’s route proceeding for new flights at Tokyo Haneda airport that would start in summer 2020. For decades, United has played a pivotal role in facilitating tourism, trade and commerce between the U.S. and Japan. Should the Department of Transportation approve its application, United Airlines will continue to play this vital role in an even greater capacity for the benefit of U.S. consumers and communities like mine. United’s U.S. mainland-Haneda proposal under consideration by the Department includes service from Newark Liberty International Airport (EWR), Chicago O’Hare International Airport (ORD), Washington Dulles International Airport (IAD), Los Angeles International Airport (LAX), and George Bush Intercontinental Airport (IAH). United’s proposal would give my community single-connection service to Tokyo Haneda – the preferred airport for consumers flying to Tokyo or for those that wish to connect beyond Haneda to other points in Japan. United’s proposal will add new flights into the U.S.-Tokyo Haneda market, simplify connecting itineraries and reduce travel time for consumers. Together, the proposed flights from five U.S. mainland hub cities will connect Tokyo Haneda with 112 U.S. airports, representing approximately two thirds of U.S.-Tokyo demand, or more than three million annual Tokyo bookings. I believe Valley International Airport stands to benefit from the enhanced choice and convenience offered by United’s proposal, which will help support American businesses and help grow the U.S. economy. I strongly urge the Department of Transportation to approve United Airlines’ request to connect my community with Tokyo’s most convenient airport – Haneda. Respectfully, Marv Esterly Director of Aviation

February 28, 2019 The Honorable Elaine L. Chao Secretary United States Department of Transportation 1200 New Jersey Avenue, S.E. Washington, D.C. 20590 Re: Docket DOT-OST-2019-0014 Dear Secretary Chao, I write today in strong support of United Airlines’ application to the Department of Transportation (DOT) for additional flights to Tokyo Haneda Airport in Japan. United’s application is part of the DOT’s route proceeding for new flights at Tokyo Haneda airport that would start in summer 2020. For decades, United has played a pivotal role in facilitating tourism, trade and commerce between the U.S. and Japan. Should the Department of Transportation approve its application, United Airlines will continue to play this vital role in an even greater capacity for the benefit of U.S. consumers and communities like mine. United’s U.S. mainland-Haneda proposal under consideration by the Department includes service from Newark Liberty International Airport (EWR), Chicago O’Hare International Airport (ORD), Washington Dulles International Airport (IAD), Los Angeles International Airport (LAX), and George Bush Intercontinental Airport (IAH). United’s proposal would give my community single-connection service to Tokyo Haneda – the preferred airport for consumers flying to Tokyo or for those that wish to connect beyond Haneda to other points in Japan. United’s proposal will add new flights into the U.S.-Tokyo Haneda market, simplify connecting itineraries and reduce travel time for consumers. Together, the proposed flights from five U.S. mainland hub cities will connect Tokyo Haneda with 112 U.S. airports, representing approximately two thirds of U.S.-Tokyo demand, or more than three million annual Tokyo bookings. I believe North Carolina Ports Authority stands to benefit from the enhanced choice and convenience offered by United’s proposal, which will help support American businesses and help grow the U.S. economy. I strongly urge the Department of Transportation to approve United Airlines’ request to connect my community with Tokyo’s most convenient airport – Haneda. Sincerely,

Paul J. Cozza Executive Director

LEE COUNTY PORT AUTHORITYDirect Dial: (239)590-4600

Fax: (239)590-4688

February 26, 2019

JEFFMULDER, A.A.E.

EXECUTIVE DIRECTOR

RICHARD WM. WESCH

PORT AUTHORITY ATTORNEY

BOARD OFPORT COMMISSIONERS

BRIAN HAMMAN

LARRY KlKER

FRANK MANN

JOHN E. MANNING

CECIL L PENOERGRASS

The Honorable Elaine L. ChaoSecretary

United States Department of Transportation1200 New Jersey Avenue, S.E.Washington, D.C. 20590

Re: Support for Additional United Flight to HND (Docket DOT-OST-2019-0014)

Dear Secretary Chao,

I write today in support of United Airlines' application to the Department ofTransportation (DOT) for additional flights to Tokyo Haneda Airport in Japan.United's application is part of the DOT'S route proceeding for new flights atTokyo Haneda airport that would start in summer 2020. For decades. United has

played a pivotal role in facilitating tourism, trade and commerce between the

U.S. and Japan. Should the Department of Transportation approve its

application. United Airlines will continue to play this vital role in an evengreater capacity for the benefit ofU.S. consumers and communities like mine.

United's U.S. mainland-Haneda proposal under consideration by the Department

includes service from Newark Liberty International Airport (EWR), ChicagoO'Hare International Airport (ORD), Washington Dulles International Airport(IAD), Los Angeles International Airport (LAX), and George BushIntercontinental Airport (IAH). As one of the top US airlines serving theSouthwest Florida International Airport (RSW), United's proposal would givethe southwest Florida community single-connection service to Tokyo Haneda -

the preferred airport for consumers flying to Tokyo or for those that wish to

connect beyond Haneda to other points in Japan.

United's proposal will add new flights into the U.S.-Tokyo Haneda market,

simplify connecting itineraries and reduce travel time for consumers. Together,

the proposed flights from five U.S. mainland hub cities will connect TokyoHaneda with 112 U.S. airports, representing approximately two thirds ofU.S.-

Tokyo demand, or more than three million annual Tokyo bookings. I believe the

patrons ofRSW, serving more than 25% of the State of Florida geographically,stands to benefit from the enhanced choice and convenience offered by United's

proposal, which will help support American businesses and help grow the U.S.

economy.

SOUTHWEST FLORIDA INTERNATIONAL AIRPORT11000 Terminal Access Road, Suite 8671 Fort Myers, Florida 33913-8213

www.flylcpa.com

Page TwoFebruary 26, 2019Elaine L. Chao

I urge the Department of Transportation to approve United Airlines' request to

connect our community with Tokyo s most convenient airport - Haneda.

Sincereh

t/-

Mark R. Fisher, AAEDeputy Executive Director - DevelopmentLee County Port Authority - RSW & FMY

EXHIBITS

1

United to Tokyo Haneda

2

Before The Department Of Transportation

2019 Haneda Combination Services

Allocation Proceeding

DOT-OST-2019-0014

Newark Liberty / Chicago / Washington, D.C.

Los Angeles

Houston / Guam

United Airlines Reply Exhibits

DOT-OST-2019-0014

3

Index of Exhibits Page 1 of 2

Exhibit Number

2019 Haneda Combination Services Allocation Proceeding

Number Of Pages

UA-R100 United’s Proposed United States Mainland - Tokyo Service 1

UA-R101 United’s Five Route U.S. Mainland Proposal Will Connect Haneda With 112 Airports, Totaling Over 3.0 Million Annual Bookings, And Accounting For Nearly Two-Thirds Of United States - Tokyo Demand

2

UA-R102 United’s Proposed Gateways For New Tokyo Haneda Service Are Among The Largest In The U.S. Mainland

1

UA-R103 The Guam - Tokyo Market Size Total Over 800,000 Annual Bookings

1

UA-R104 United’s Chicago - Tokyo Haneda Proposal Provides Benefits Beyond What ANA’s Flight Provides, Including 136 New Connecting Flight Options And 37 Cities That Do Not Connect To ANA At Chicago

1

UA-R105 United’s Los Angeles - Tokyo Haneda Proposal Provides Benefits Beyond What ANA’s Flight Provides, Including 25 New Connecting Flight Options And Ten Cities That Do Not Connect To ANA At Los Angles

1

UA-R106 Consumers Have Numerous Choices For Travel On City Pairs Between The United States And Tokyo

1

UA-R107 The Vast Majority Of United/ANA Customers Travel In City Pairs With Multiple Options On Other Carriers

1

DOT-OST-2019-0014

4

Index of Exhibits Page 2 of 2

Exhibit Number

2019 Haneda Combination Services Allocation Proceeding

Number Of Pages

UA-R108 Numerous Carriers Compete For Traffic Between Newark/New York And Tokyo On A Connecting Basis

3

UA-R109 Numerous Carriers Compete For Traffic Between Chicago And Tokyo On A Connecting Basis

2

UA-R110 Numerous Carriers Compete For Traffic Between Washington, D.C. And Tokyo On A Connecting Basis

3

UA-R111 Delta Has Access To Japan Via Its Joint Venture Partner Korean At Seoul

4

UA-R112 The Guam - Japan Market Has Recovered Since The North Korea Geopolitical Crisis Impacted Japanese Tourists’ Willingness To Travel To Guam

1

UA-R113 Two-Thirds Of Communities Behind United And American Hubs Would Have Shorter Travel Times Traveling Via An United Hub

3

5

Consumer and Community Benefits

DOT-OST-2019-0014 UA-R100

Page 1 of 1

6

United’s Proposed United States Mainland - Tokyo Service

Note: United’s proposal is for year-round service. San Francisco - Haneda service currently operated. United’s proposal also includes a new flight between Guam and Haneda

Six Haneda Flights Strategically Deployed Across The U.S. – West Coast: San Francisco and Los Angeles – Midwest: Chicago – South/Southeast: Houston – East Coast: Newark Liberty and Washington, D.C.

Four Narita Flights Strategically Deployed Across The U.S. – West Coast: San Francisco and Los Angeles – Central: Denver – East Coast: Newark Liberty

DOT-OST-2019-0014 UA-R101

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112 Airports With RoundTrip Access To Tokyo Haneda

Akron/Canton Columbus Ithaca Monterey San DiegoAlbany Corpus Christi Jackson Nashville San Francisco

Appleton Dallas/Ft. Worth Jacksonville New Orleans San Luis ObispoAshville Dayton Kansas City New York/LaGuardia Santa BarbaraAspen Denver Knoxville Newark/New York SavannahAtlanta Detroit Lafayette Norfolk ScrantonAustin Elmira/Corning Lake Charles Oklahoma City Shreveport

Baltimore Evansville Las Vegas Orlando Sioux FallsBangor Fayetteville Lexington Pensacola South Bend

Baton Rouge Fort Lauderdale Little Rock Philadelphia St LouisBirmingham Fort Myers Los Angeles Phoenix State College

Boston Fort Wayne Louisville Pittsburgh SyracuseBuffalo Fresno Madison Portland, ME Tampa

Burlington Grand Rapids Manchester, NH Presque Isle TulsaCedar Rapids Green Bay Memphis Providence Washington/Dulles

Champaign/Urbana Greensboro Miami Quincy Washington/NationalCharleston Greenville Middletown Raleigh/Durham West Palm BeachCharlotte Gulfport Midland/Odessa Richmond Westchester Cty

Chattanooga Harlingen Milwaukee Roanoke WichitaChicago Hartford Minneapolis/St. Paul Rochester Wilmington

Cincinnati Houston Mission/McAllen Rochester, MNCleveland Huntsville Mobile Saginaw/Bay CtyColumbia Indianapolis Moline San Antonio

Note: U.S. - Tokyo boking demand totals approximately 5.0M annually Source: Adjusted MIDT TME November 2018. MIDT compared to DOT T100 to account for bookings made via carrier website and not captured in standard GDS channels. Metropolitan areas combined CHI = ORD/MDW. DAL = DFW/DAL. HOU = IAH/HOU. LOS = LAX/ONT/LGB. NYC = EWR/JFK/LGA. WAS = DCA/IAD/BWI. TYO = NRT/HND

United’s Five Route U.S. Mainland Proposal Will Connect Haneda With 112 Airports, Totaling Over 3.0 Million Annual Bookings, And Accounting For Nearly Two-Thirds Of United States - Tokyo Demand

DOT-OST-2019-0014 UA-R101

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8

3.1 1.9

United’s Proposal Will Reach A Catchment Area Of 3.1M Annual U.S. - Tokyo Bookings, Or 61% Of All U.S. -

Tokyo Bookings

MIDT Annual Bookings (000)

United Catchment

Area

Remainder U.S

Note: U.S. - Tokyo boking demand totals approximately 5.0M annually Source: Adjusted MIDT TME November 2018. MIDT compared to DOT T100 to account for bookings made via carrier website and not captured in standard GDS channels. Metropolitan areas combined CHI = ORD/MDW. DAL = DFW/DAL. HOU = IAH/HOU. LOS = LAX/ONT/LGB. NYC = EWR/JFK/LGA. WAS = DCA/IAD/BWI. TYO = NRT/HND

United’s Five Route U.S. Mainland Proposal Will Connect Haneda With 112 Airports, Totaling Over 3.0 Million Annual Bookings, And Accounting For Nearly Two-Thirds Of United States - Tokyo Demand

DOT-OST-2019-0014 UA-R102

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United’s Proposed Gateways For New Tokyo Haneda Service Are Among The Largest In The U.S. Mainland

727

553

352

138 133 132 119 109 97 82 66

0

100

200

300

400

500

600

700

800

Los

Ang

eles

New

ark/

New

Yor

k C

ity

San

Fran

cisc

o

Chi

cago

Las

Vega

s

Seat

tle

Was

hing

ton

D.C

.

Bos

ton

San

Die

go

Orla

ndo

Hou

ston

U.S. Mainland - Tokyo Annual Demand

Rank 1 2 3 4 5 6 7 8 9 10 11

MID

T An

nual

Boo

king

s (0

00)

Los Angeles Rank #1

Newark/New York City Rank #2

Chicago Rank #4

Washington, D.C. Rank #7

Houston Rank #11

Source: Adjusted MIDT TME November 2018. MIDT compared to DOT T100 to account for bookings made via carrier website and not captured in standard GDS channels. Metropolitan areas combined CHI = ORD/MDW. DAL = DFW/DAL. HOU = IAH/HOU. LOS = LAX/ONT/LGB. NYC = EWR/JFK/LGA. WAS = DCA/IAD/BWI. TYO = NRT/HND

DOT-OST-2019-0014 UA-R103

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The Guam - Tokyo Market Size Totals Over 800,000 Annual Bookings

871

0

100

200

300

400

500

600

700

800

900

1,000

Guam

Guam - Tokyo Annual Demand

MID

T An

nual

Boo

king

s (0

00)

Source: Adjusted MIDT TME November 2018. MIDT compared to DOT T100 to account for bookings made via carrier website and not captured in standard GDS channels. Metropolitan areas combined CHI = ORD/MDW. DAL = DFW/DAL. HOU = IAH/HOU. LOS = LAX/ONT/LGB. NYC = EWR/JFK/LGA. WAS = DCA/IAD/BWI. TYO = NRT/HND

DOT-OST-2019-0014 UA-R104

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United’s Chicago - Tokyo Haneda Proposal Provides Benefits Beyond What ANA’s Flight Provides, Including 136 New Connecting Flight Options And 37 Cities That Do Not Connect To ANA At Chicago

Notes: Connection builder for July 2019. Nonstop and one stop connections only. Connections with a minimum and maximum connection time of 45 minutes and four hours, respectively, and a maximum circuity (relative to great circle distance) of 1.5. These connection criteria differ and are less restrictive than those used to quantify behind/beyond connections in United’s application cited at UA-135, 191, 192, 204, 205. Airports sized by total number of connecting options

Behind Gateway Connections At Chicago

DOT-OST-2019-0014 UA-R105

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United’s Los Angeles - Tokyo Haneda Proposal Provides Benefits Beyond What ANA’s Flight Provides, Including 25 New Connecting Flight Options And Ten Cities That Do Not Connect To ANA At Los Angeles

Notes: Connection builder for July 2019. Nonstop and one stop connections only. Connections with a minimum and maximum connection time of 45 minutes and four hours, respectively, and a maximum circuity (relative to great circle distance) of 1.5. These connection criteria differ and are less restrictive than those used to quantify behind/beyond connections in United’s application cited at UA-146, 195, 196, 207, 208. Airports sized by total number of connecting options

Behind Gateway Connections At Los Angeles

DOT-OST-2019-0014 UA-R106

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Consumers Have Numerous Choices For Travel On City Pairs Between The United States And Tokyo

Notes: Chart depicts percent of United/ANA O&D adjusted bookings traveling in city-pairs where the other carrier had at least a 5% O&D adjusted bookings share. City pairs with at least 1 BPDEW and where United/ANA had at least a 5% O&D share. City-pairs between the U.S. (excluding Guam) and Tokyo. Shares are based on the carrier that marketed the largest proportion of an itinerary’s distance Source: MIDT TME November 2018, US DOT T100

93.7%

77.3%

20.8% 15.6%

6.0%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

American/JAL Delta/Korean Hawaiian Airlines Singapore Airlines Air Canada

Perc

ent o

f Boo

king

s

Proportion of United/ANA U.S.-Tokyo Bookings Traveling in City-Pairs With Options on Other Carriers

Based on current traffic flows, 94% of United/ANA U.S.-Tokyo bookings are on city-pairs where

AA/JL offer competing service and 77% of bookings are on city-pairs

served by DL/KE

DOT-OST-2019-0014 UA-R107

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The Vast Majority Of United/ANA Customers Travel In City Pairs With Multiple Options On Other Carriers

Notes: Chart depicts percent of United/ANA O&D adjusted bookings traveling in city-pairs where the other carrier had at least a 5% O&D adjusted bookings share. City pairs with at least 1 BPDEW and where United/ANA had at least a 5% O&D share. City-pairs between the U.S. (excluding Guam) and Tokyo. Shares are based on the carrier that marketed the largest proportion of an itinerary’s distance Source: MIDT TME November 2018, US DOT T100

Proportion of United/ANA U.S.-Tokyo Bookings Traveling in City-Pairs With Options on Other Carriers

97.0%

74.1%

42.4%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

1 or More 2 or More 3 or More

Perc

ent o

f Boo

king

s

DOT-OST-2019-0014 UA-R108

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Numerous Carriers Compete For Traffic Between Newark/New York And Tokyo On A Connecting Basis

Notes: Cities sized by adjusted MIDT bookings Source: MIDT TME November 2018, US DOT T100

Tokyo New York

Most Common One-Stop Routings: New York - Tokyo

YYZ

DOT-OST-2019-0014 UA-R108

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Notes: Connections with a minimum and maximum connection time of 45 minutes and four hours, respectively, and a maximum circuity (relative to great circle distance) of 1.5. Source: OAG

New York, NY-NJ-Tokyo, JapanFlights for Wednesday Apr 10, 2019

Options on carriers other than United and ANA

Departure

Time

Originating

Airport

Flight

Number 1

Connect

Airport

Flight

Number 2

Destination

Airport

Arrival

Time

Total

Time

1 12:55 AM JFK SU 123 SVO SU 264 NRT 10:30 AM 20:35

2 1:25 AM JFK BR 31 TPE BR 198 NRT 1:15 PM 22:50

3 1:35 AM JFK CI 11 TPE CI 100 NRT 1:15 PM 22:40

4 1:35 AM JFK CX 845 HKG CX 526 NRT 1:15 PM 22:40

5 1:35 AM JFK CX 845 HKG CX 548 HND 1:55 PM 23:20


7 1:45 AM JFK CZ 600 CAN CZ 385 HND 2:20 PM 23:35

8 1:55 AM EWR CX 899 HKG CX 526 NRT 1:15 PM 22:20

9 1:55 AM EWR CX 899 HKG CX 548 HND 1:55 PM 23:00

10 1:55 AM EWR CX 899 HKG CX 504 NRT 2:30 PM 23:35

11 5:01 AM EWR AA 1150 DFW AA 175 NRT 2:00 PM 19:59

12 5:01 AM EWR AA 1150 DFW JL 11 NRT 3:30 PM 21:29

13 5:30 AM LGA AA 1597 DFW AA 175 NRT 2:00 PM 19:30

14 5:30 AM LGA AA 1597 DFW JL 11 NRT 3:30 PM 21:00

15 6:00 AM EWR DL 954 MSP DL 121 HND 1:45 PM 18:45

16 6:00 AM EWR DL 1319 ATL DL 295 NRT 2:35 PM 19:35

17 6:00 AM LGA DL 2962 ATL DL 295 NRT 2:35 PM 19:35

18 6:00 AM JFK AA 171 LAX AA 169 NRT 3:55 PM 20:55

19 6:00 AM JFK AA 171 LAX JL 61 NRT 4:45 PM 21:45

20 6:05 AM LGA DL 1981 MSP DL 121 HND 1:45 PM 18:40

21 6:10 AM JFK DL 2850 ATL DL 295 NRT 2:35 PM 19:25

22 6:30 AM JFK AA 2242 DFW AA 175 NRT 2:00 PM 18:30


24 6:30 AM JFK AA 2242 DFW JL 11 NRT 3:30 PM 20:00




28 6:51 AM EWR AA 2728 DFW JL 11 NRT 3:30 PM 19:39

29 6:51 AM EWR AA 2728 DFW AA 61 NRT 4:45 PM 20:54

30 6:59 AM JFK DL 2395 MSP DL 121 HND 1:45 PM 17:46



33 7:08 AM EWR AA 2485 ORD JL 9 NRT 3:35 PM 19:27

34 7:08 AM EWR AA 2485 ORD AA 153 NRT 3:55 PM 19:47

35 7:10 AM JFK DL 2954 SEA DL 167 NRT 1:30 PM 17:20

36 7:10 AM LGA DL 869 DTW DL 275 NRT 2:25 PM 18:15

37 7:20 AM EWR DL 1607 DTW DL 275 NRT 2:25 PM 18:05

38 7:30 AM LGA AA 370 ORD JL 9 NRT 3:35 PM 19:05

39 7:30 AM LGA AA 370 ORD AA 153 NRT 3:55 PM 19:25



DOT-OST-2019-0014 UA-R108

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New York, NY-NJ-Tokyo, JapanFlights for Wednesday Apr 10, 2019


Departure

Time

Originating

Airport

Flight

Number 1

Connect

Airport

Flight

Number 2

Destination

Airport

Arrival

Time

Total

Time


42 7:59 AM LGA DL 1989 MSP DL 121 HND 1:45 PM 16:46


44 8:00 AM JFK AA 1 LAX JL 61 NRT 4:45 PM 19:45


46 8:10 AM JFK AA 2234 DFW JL 11 NRT 3:30 PM 18:20




50 8:40 AM EWR AC 7647 YYZ AC 1 HND 3:40 PM 18:00

51 8:45 AM LGA AC 705 YYZ AC 1 HND 3:40 PM 17:55

52 9:00 AM EWR AA 1049 ORD JL 9 NRT 3:35 PM 17:35

53 9:00 AM EWR AA 1049 ORD AA 153 NRT 3:55 PM 17:55

54 9:00 AM LGA AA 2121 BOS JL 7 NRT 4:30 PM 18:30


56 9:05 AM LGA DL 2837 DTW DL 275 NRT 2:25 PM 16:20

57 9:25 AM JFK AA 1140 BOS JL 7 NRT 4:30 PM 18:05





62 10:00 AM JFK CX 841 HKG CX 542 HND 9:35 PM 22:35

63 10:20 AM LGA AC 707 YYZ AC 1 HND 3:40 PM 16:20

64 10:30 AM EWR AC 7659 YYZ AC 1 HND 3:40 PM 16:10


66 11:00 AM JFK AA 179 SFO JL 1 HND 7:00 PM 19:00

67 11:30 AM JFK JL 3 NRT 2:40 PM 14:10

68 12:40 PM EWR CA 820 PEK CA 421 HND 8:00 PM 18:20

69 12:40 PM EWR CA 820 PEK CA 183 HND 9:30 PM 19:50

70 1:10 PM JFK JL 5 HND 4:25 PM 14:15

71 1:55 PM JFK OZ 221 ICN OZ 108 NRT 9:10 PM 18:15

72 1:55 PM JFK OZ 221 ICN OZ 178 HND 11:30 PM 20:35

73 2:00 PM JFK KE 82 ICN KE 705 NRT 9:05 PM 18:05

74 2:00 PM JFK KE 82 ICN KE 719 HND 10:50 PM 19:50

75 5:30 PM JFK AM 403 MEX AM 58 NRT 6:20 AM 23:50

76 6:05 PM JFK AA 100 LHR JL 42 HND 5:25 AM 22:20

77 7:00 PM JFK AA 106 LHR JL 42 HND 5:25 AM 21:25

78 7:30 PM JFK BA 176 LHR BA 7 HND 7:10 AM 22:40



81 9:00 PM JFK LX 15 ZRH LX 160 NRT 7:50 AM 21:50


83 9:35 PM EWR BA 188 LHR BA 7 HND 7:10 AM 20:35

84 9:55 PM EWR LX 19 ZRH LX 160 NRT 7:50 AM 20:55

85 9:55 PM JFK AF 11 CDG AF 276 NRT 8:20 AM 21:25

86 10:00 PM JFK KL 644 AMS KL 861 NRT 8:40 AM 21:40

87 10:00 PM JFK LO 27 WAW LO 79 NRT 8:40 AM 21:40

88 11:30 PM EWR SK 902 CPH SK 983 NRT 9:35 AM 21:05


DOT-OST-2019-0014 UA-R109

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Numerous Carriers Compete For Traffic Between Chicago And Tokyo On A Connecting Basis


Most Common One-Stop Routings: Chicago - Tokyo

Tokyo Chicago

YYZ

DOT-OST-2019-0014 UA-R109

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Numerous Carriers Compete For Traffic Between Chicago And Tokyo On A Connecting Basis


Chicago, IL-Tokyo, JapanFlights for Wednesday Apr 10, 2019


Departure

Time

Originating

Airport

Flight

Number 1

Connect

Airport

Flight

Number 2

Destination

Airport

Arrival

Time

Total

Time

1 12:30 AM ORD BR 55 TPE BR 198 NRT 1:15 PM 22:45

2 6:00 AM ORD DL 1808 ATL DL 295 NRT 2:35 PM 18:35

3 6:00 AM MDW DL 1781 ATL DL 295 NRT 2:35 PM 18:35

4 6:10 AM MDW DL 3564 MSP DL 121 HND 1:45 PM 17:35

5 7:00 AM ORD DL 2295 SEA DL 167 NRT 1:30 PM 16:30

6 7:00 AM ORD DL 2547 DTW DL 275 NRT 2:25 PM 17:25

7 7:00 AM ORD DL 1771 ATL DL 295 NRT 2:35 PM 17:35

8 7:05 AM ORD AA 1625 DFW AA 175 NRT 2:00 PM 16:55

9 7:05 AM ORD AA 1625 DFW JL 11 NRT 3:30 PM 18:25

10 7:05 AM ORD AA 1384 LAX AA 169 NRT 3:55 PM 18:50


12 7:05 AM ORD AA 1384 LAX JL 61 NRT 4:45 PM 19:40

13 7:20 AM MDW DL 498 ATL DL 295 NRT 2:35 PM 17:15

14 7:20 AM ORD AA 2384 BOS JL 7 NRT 4:30 PM 19:10

15 7:43 AM ORD DL 3625 MSP DL 121 HND 1:45 PM 16:02

16 7:53 AM ORD AA 2428 DFW JL 11 NRT 3:30 PM 17:37


18 8:00 AM ORD AC 502 YYZ AC 1 HND 3:40 PM 17:40


20 9:05 AM ORD AA 1163 LAX JL 61 NRT 4:45 PM 17:40

21 9:50 AM ORD AA 1338 YVR JL 17 NRT 4:30 PM 16:40

22 10:00 AM ORD AC 504 YYZ AC 1 HND 3:40 PM 15:40

23 10:00 AM ORD AA 1045 SEA JL 67 NRT 4:25 PM 16:25

24 10:23 AM ORD AA 2634 SFO JL 1 HND 7:00 PM 18:37

25 11:45 AM ORD AA 1470 SFO JL 1 HND 7:00 PM 17:15

26 12:25 PM ORD JL 9 NRT 3:35 PM 13:10

27 12:35 PM ORD KE 38 ICN KE 1 NRT 8:00 PM 17:25

28 12:35 PM ORD KE 38 ICN KE 705 NRT 9:05 PM 18:30

29 12:50 PM ORD AA 153 NRT 3:55 PM 13:05

DOT-OST-2019-0014 UA-R110

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Numerous Carriers Compete For Traffic Between Washington, D.C. And Tokyo On A Connecting Basis


Most Common One-Stop Routings: Washington, D.C. - Tokyo

Tokyo Washington, D.C.

YYZ

DOT-OST-2019-0014 UA-R110

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Numerous Carriers Compete For Traffic Between Washington, D.C And Tokyo On A Connecting Basis


Washington, DC-Tokyo, JapanFlights for Wednesday Apr 10, 2019


Departure

Time

Originating

Airport

Flight

Number 1

Connect

Airport

Flight

Number 2

Destination

Airport

Arrival

Time

Total

Time

1 1:20 AM IAD CX 869 HKG CX 526 NRT 1:15 PM 22:55

2 1:20 AM IAD CX 869 HKG CX 548 HND 1:55 PM 23:35

3 1:20 AM IAD CX 869 HKG CX 504 NRT 2:30 PM 0:10

4 5:30 AM BWI DL 2280 ATL DL 295 NRT 2:35 PM 20:05

5 6:00 AM BWI DL 2869 MSP DL 121 HND 1:45 PM 18:45

6 6:00 AM DCA DL 2136 ATL DL 295 NRT 2:35 PM 19:35

7 6:00 AM IAD DL 1653 ATL DL 295 NRT 2:35 PM 19:35

8 6:05 AM DCA AA 2210 DFW AA 175 NRT 2:00 PM 18:55

9 6:05 AM DCA AA 2210 DFW JL 11 NRT 3:30 PM 20:25

10 6:25 AM DCA DL 2090 MSP DL 121 HND 1:45 PM 18:20

11 6:33 AM IAD AA 2617 DFW AA 175 NRT 2:00 PM 18:27

12 6:33 AM IAD AA 2617 DFW JL 11 NRT 3:30 PM 19:57

13 6:51 AM BWI AA 1403 DFW AA 175 NRT 2:00 PM 18:09

14 6:51 AM BWI AA 1403 DFW JL 11 NRT 3:30 PM 19:39

15 6:51 AM BWI AA 1403 DFW AA 61 NRT 4:45 PM 20:54



18 6:59 AM DCA AA 1839 DFW JL 11 NRT 3:30 PM 19:31



21 7:05 AM DCA AA 1275 LAX AA 169 NRT 3:55 PM 19:50

22 7:05 AM DCA AA 1275 LAX JL 61 NRT 4:45 PM 20:40

23 7:09 AM BWI AA 2582 ORD JL 9 NRT 3:35 PM 19:26

24 7:15 AM IAD AA 252 LAX AA 169 NRT 3:55 PM 19:40

25 7:15 AM IAD AA 252 LAX JL 61 NRT 4:45 PM 20:30

26 7:30 AM IAD DL 2938 ATL DL 295 NRT 2:35 PM 18:05

27 7:40 AM DCA DL 1789 DTW DL 275 NRT 2:25 PM 17:45

28 7:44 AM DCA AA 2304 ORD JL 9 NRT 3:35 PM 18:51

29 7:44 AM DCA AA 2304 ORD AA 153 NRT 3:55 PM 19:11



32 8:30 AM IAD DL 3822 MSP DL 121 HND 1:45 PM 16:15

33 8:30 AM DCA DL 2032 MSP DL 121 HND 1:45 PM 16:15

34 8:30 AM DCA AA 2169 BOS JL 7 NRT 4:30 PM 19:00


36 9:17 AM BWI AA 2856 ORD JL 9 NRT 3:35 PM 17:18

37 9:17 AM BWI AA 2856 ORD AA 153 NRT 3:55 PM 17:38


39 9:40 AM DCA DL 841 DTW DL 275 NRT 2:25 PM 15:45

40 9:40 AM DCA AA 2537 ORD JL 9 NRT 3:35 PM 16:55

DOT-OST-2019-0014 UA-R110

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Numerous Carriers Compete For Traffic Between Washington, D.C And Tokyo On A Connecting Basis


Washington, DC-Tokyo, JapanFlights for Wednesday Apr 10, 2019


Departure

Time

Originating

Airport

Flight

Number 1

Connect

Airport

Flight

Number 2

Destination

Airport

Arrival

Time

Total

Time

41 9:40 AM DCA AC 7613 YYZ AC 1 HND 3:40 PM 17:00

42 9:40 AM DCA AA 2537 ORD AA 153 NRT 3:55 PM 17:15

43 9:51 AM BWI DL 984 DTW DL 275 NRT 2:25 PM 15:34

44 9:57 AM IAD DL 6225 DTW DL 275 NRT 2:25 PM 15:28

45 10:05 AM BWI AC 7503 YYZ AC 1 HND 3:40 PM 16:35

46 10:23 AM BWI AA 3326 ORD AA 153 NRT 3:55 PM 16:32


48 10:50 AM IAD AC 7371 YYZ AC 1 HND 3:40 PM 15:50

49 1:20 PM IAD KE 94 ICN KE 1 NRT 8:00 PM 17:40

50 1:20 PM IAD KE 94 ICN KE 705 NRT 9:05 PM 18:45

51 1:20 PM IAD KE 94 ICN KE 719 HND 10:50 PM 20:30

52 9:20 PM BWI BA 228 LHR BA 7 HND 7:10 AM 20:50

53 10:20 PM IAD BA 292 LHR BA 7 HND 7:10 AM 19:50

54 10:30 PM IAD LH 415 MUC LH 714 HND 10:50 AM 23:20

DOT-OST-2019-0014 UA-R111

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Delta Has Access To Japan Via Its Joint Venture Partner Korean At Seoul

Source: carrier website

Osaka

Nagoya

Narita

DOT-OST-2019-0014 UA-R111

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Sapporo

Fukuoka

Haneda

DOT-OST-2019-0014 UA-R111

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25



Niigata

Aomori

Komatsu

DOT-OST-2019-0014 UA-R111

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Okayama

Oita

DOT-OST-2019-0014 UA-R112

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The Guam - Japan Market Has Recovered Since The North Korea Geopolitical Crisis Impacted Japanese Tourists’ Willingness To Travel To Guam

Source: MIDT

• The Guam - Japan Market Contracted In August 2017

• Since August 2018 The Market Has Grown Month To Month, Hitting 3% Growth In December 2018

DOT-OST-2019-0014 UA-R113

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Two-Thirds Of Communities Behind United And American Hubs Would Have Shorter Travel Times By Traveling Via An United Hub

Connection builder for July 15, 2019. One stop connections only. Excludes airports with proposed/existing nonstop

service by UA/AA. Connections with a minimum and maximum connection time of 45 minutes and four hours,

respectively, and a maximum circuity (relative to great circle distance) of 1.5. Behind gateways served by both

United and American. Airports sized by bookings to Japan. Includes all routes applied for by AA and UA and existing

HND service

Source: OAG

DOT-OST-2019-0014 UA-R113

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Minimum Travel Time to Haneda Over Hub






HND service

Source: OAG

DOT-OST-2019-0014 UA-R113

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Minimum Travel Time to Haneda Over Hub






HND service

Source: OAG

CERTIFICATE OF SERVICE

I certify that on March 7, 2019, the following parties were served with an electronic copy

of the above document in accordance with the Department’s Rules of Practice:

Alaska Airlines [email protected] American Airlines [email protected]

[email protected] [email protected] [email protected]

Atlas Airlines [email protected] Delta Air Lines [email protected]

[email protected] [email protected]

FedEx [email protected] [email protected]

Hawaiian Airlines [email protected] [email protected] [email protected]

Polar Air Cargo [email protected] UPS [email protected]

[email protected] State/FAA/DOT/Commerce [email protected]

[email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected]

Port Authority of New York & New Jersey [email protected] [email protected] [email protected] [email protected]

Metropolitan Washington Airports Authority [email protected] City of Chicago Department of Aviation [email protected]

[email protected] [email protected] [email protected] [email protected]

Los Angeles World Airport [email protected] Houston Airport System [email protected] Guam International Airport [email protected] Ambassador of Japan, Washington, D.C. U.S. mail

March 7, 2019

BEFORE THE DEPARTMENT OF TRANSPORTATION ... Reply of...815 Connecticut Avenue, NW Suite 500 –...

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