The DOT order is 9 pages long, but I tried to cut and paste in the relevant sections on the pleadings by the carriers and the decision explanation by DOT. POSITION OF THE PARTIES
American asserts that Los Angeles is the largest U.S. mainland Origin & Destination (O&D) market to Tokyo, with two times more local passengers than San Francisco and six times more local passengers than Seattle. American states that the Los Angeles-Haneda market is currently served by the Star alliance, through flights operated by All Nippon Airways Co., Ltd. (ANA) displaying the designator codes of United and US Airways, Inc. (US Airways); and by the SkyTeam alliance, through flights operated by Delta. American argues that its proposal would enhance inter-alliance competition in the large Los Angeles-Haneda market by allowing its alliance, oneworld, to compete directly with Star and SkyTeam.
American also states that it would provide significant connecting opportunities for 25 U.S. cities, including the 10 largest U.S. mainland-Tokyo O&D markets.4 Through its immunized cooperative relationship with Japan Airlines Co., Ltd. (JAL), it would provide connecting opportunities beyond Haneda to 29 cities in Japan, as well as to Shanghai, Beijing, Bangkok, Hong Kong, Seoul, Singapore, and Taiwan.
The competing carriers contend that the Los Angeles-Tokyo market is already well served and the market would not support an additional Los Angeles-Haneda flight. United argues that the Los Angeles-Tokyo market already has nearly twice the amount of service as San Francisco, and selecting Los Angeles would leave San Francisco - the second largest West Coast-Tokyo market - without any nonstop U.S. carrier service to Haneda. Delta contends that, if American receives the Los Angeles-Haneda slots, it would likely reduce its current Los Angeles-Narita service, as it did with its New York (JFK)-Narita service when it was awarded a New York-Haneda slot pair.7 Hawaiian argues that American?s track record of repeated cancellations on its New York (JFK)-Haneda service suggests that an additional allocation at Los Angeles would be a waste of valuable resources.
Delta maintains that its proposal would make the most productive use of the Haneda slot pair. Delta states that Seattle is the largest U.S.-Tokyo O&D market without any nonstop Haneda service, and that Seattle competes with San Francisco and Los Angeles for U.S.-Tokyo traffic. Delta states that, through the combination of its own services and its partnership with Alaska, Delta would provide one-stop service to Haneda from 42 points in the United States.
Delta notes that, subsequent to the 2010 U.S.-Haneda Combination Services Allocation Proceeding, the American/JAL and United/ANA joint ventures were granted antitrust immunity, and argues that American and United are able to access Haneda through the metal-neutral transpacific joint venture flights of their Japanese partners.10 Delta further states that it is the sole independent network competitor against the Star and oneworld immunized alliances, and that only its proposal would preserve the three-way alliance competitive market structure that currently exists in the U.S.-Haneda market.
The competing carriers question the viability of Delta?s proposal, given the size of the Seattle-Haneda market and the fact that Delta?s proposed connections rely heavily on code-share service provided by Alaska. American argues that Seattle is the sixth largest Tokyo O&D market and the smallest market proposed in this proceeding, and points out that Los Angeles is the largest O&D market proposed in this proceeding.12 Hawaiian asserts that the Seattle market is not large enough to support additional Tokyo service and that Delta?s proposal will suffer the same fate as its Detroit-Haneda service.
United calls Delta?s competition arguments based on metal neutrality misguided, contending that additional opportunities for U.S. carriers, consumers, and communities are key benefits of immunized joint ventures.14
Hawaiian asserts that, of the four U.S. carrier services to Haneda, its Honolulu-Haneda service has been the most successful, and that an award for Kona-Haneda service would make the best use of the slot pair. Hawaiian states that Kona is underserved as the second-largest U.S.-Tokyo O&D market without nonstop service to/from Tokyo, and the only market proposed in this proceeding without nonstop service to Tokyo. Hawaiian further states that only its proposal will provide a sustainable ongoing volume of passengers.15 Hawaiian argues that selecting its proposal would reduce concentration in markets dominated by the oneworld, SkyTeam, and Star alliances, while doubling Hawaiian?s Tokyo service.
Hawaiian acknowledges that its proposal would largely serve Japan originating passengers, but asserts that the introduction of a nonstop Kona-Haneda flight would have a substantial positive impact on Hawaii?s tourism-based economy, create over 1,400 U.S. jobs, and generate $74 million in new exports annually.
The competing carriers generally argue that an award to Hawaiian would place half of the limited Haneda opportunities in the state of Hawaii, and that the public interest would not be served by primarily benefiting Japanese leisure passengers. Delta and United argue that Hawaiian does not need a limited Haneda slot pair since it is free to begin service at Narita.19 The competing carriers also question the timeline for instituting Hawaiian?s proposed service, given Hawaiian?s own acknowledgement that Kona International Airport may require updates to Customs and Immigration facilities.
United maintains that its San Francisco-Haneda proposal would best maximize public benefits by combining the large San Francisco gateway with numerous online connections, claiming the most online connections of any applicant in this proceeding. United argues that its proposal would provide nonstop Haneda service in the second largest West Coast-Tokyo market, a market that is nearly three times larger than the Seattle-Tokyo market.21 United further argues that it has the largest and most comprehensive hub on the West Coast, and that its San Francisco-Haneda proposal would reach a catchment area far larger than the proposals offered by Delta and Hawaiian.
United asserts that it is the only U.S. carrier serving Japan that is not permitted to operate at Haneda with its own aircraft and crews, and that selection of its proposal would establish competitive parity among U.S. carriers at Haneda, while also providing competition with the San Francisco-Haneda services provided by American?s oneworld partner, JAL.
American argues that United should not receive an award since United and its Star alliance partner ANA already command the largest presence in the U.S.-Japan nonstop market, operating a combined 210 weekly nonstop frequencies compared to oneworld?s 118 weekly nonstop frequencies.24 Hawaiian argues that the San Francisco-Tokyo market already has abundant service, and that the market is not large enough to accommodate United?s proposed service addition.25 Delta contends that, if United were awarded a San Francisco-Haneda slot pair, it would reduce its San Francisco-Narita service, while Delta?s proposal would inject true new capacity to Tokyo.
TENTATIVE DECISION
We have tentatively decided that it is in the public interest to grant the motion of Delta to move its Detroit-Haneda slot pair to provide daily scheduled services between Seattle, Washington and Tokyo?s Haneda International Airport, rather than select an alternative use for that slot pair.
Since we last examined the allocation of Haneda slots in the 2010 U.S.-Haneda Combination Services Allocation Proceeding, we have had the benefit of two years of U.S. carrier experience operating within the limited arrival/departure-time window at Haneda. We also now have the benefit of knowing which U.S. gateways Japanese carriers have chosen to serve with their limited slot pair allocations ? Honolulu and Los Angeles for ANA; and Honolulu and San Francisco for JAL.
Against this background, and having considered the entire record before us, we tentatively select Delta?s proposed Seattle-Haneda service. We tentatively find that Delta?s proposal would best serve the public interest by providing the first nonstop Haneda service on a significant mainland U.S.-Tokyo route that currently lacks any such service, thereby establishing a new U.S. gateway to Haneda. We tentatively find that Delta?s proposed service would further serve the public interest by providing a number of western cities with a first one-stop connecting opportunity to Haneda.27 We tentatively find in addition that other cities that now enjoy one-stop connections over more southerly gateways would gain the option of service over a less circuitous northwest gateway.28Allowing Delta to move from Detroit to Seattle would also advance one of the prime objectives we sought to achieve in our last Haneda proceeding, namely, seeking with our limited number of Haneda opportunities to address a diversity of public interest goals. We tentatively find that an outcome that brings first-time Haneda service and first U.S.-flag Haneda service to the sixth-largest O&D market, while also promoting the geographic diversity of the U.S.-Haneda gateways, would be consistent with our established approach for the award of limited Haneda slot opportunities and would best serve the public interest.
The competing carriers argue that Delta?s proposal should not be selected because the Seattle-Tokyo O&D market is the smallest proposed in this proceeding. We tentatively find, however, that only Delta?s proposal would open Haneda access to a new region of the country, the Pacific Northwest, resulting in a greater number of service options for the traveling public.
We have also considered the competing carriers? argument that Delta?s connecting services rely too heavily on services operated by its code-share partner Alaska.29 Alaska points out, however, that its marketing relationship with Delta is more comprehensive than traditional code-share arrangements, and that Alaska and Delta regularly adjust their schedules to facilitate effective connections.30 Also, Delta notes that Alaska provides effective feed traffic for Delta?s other Seattle services to Asia.31 Therefore, we tentatively find that the proposed connections, offered through Delta?s marketing relationship with Alaska, further support the viability of Delta?s proposed new gateway service and grant of Delta?s motion.
We tentatively find that the public benefits that would be achieved by our tentative selection outweigh the benefits of the other applications.
We recognize that American would provide service in the largest U.S.-Tokyo market proposed in this proceeding. However, we note that Los Angeles already has two daily nonstop flights to Haneda. Delta serves Los Angeles-Haneda with its own flights, and United offers Los Angeles-Haneda service through its code share with ANA. Given the very limited opportunities for U.S. carrier service to Haneda, we tentatively do not find American?s arguments persuasive for adding more Haneda service at Los Angeles while other significant U.S.-Tokyo gateways have no access to Haneda.
United?s proposal offers certain notable attributes. It would offer the first U.S.-carrier nonstop service using its own aircraft in the sizeable San Francisco-Haneda market, the second largest U.S.-Tokyo O&D market in this case. United also would offer an extensive number of on-line connections through its San Francisco hub to an appreciable catchment area. On balance, however, we tentatively find that our public interest objectives in this proceeding would be better served by establishing the first U.S.-flag nonstop Haneda service of any sort at Seattle. While San Francisco may not have service to Haneda from a U.S. carrier operating its own aircraft, American offers daily nonstop San Francisco-Haneda service through its code share with JAL. While United?s San Francisco hub might arguably reach more passengers than the combined Delta/Alaska hub at Seattle, we tentatively find that the Delta proposal offers important advantages of its own in terms of catchment area. Specifically, we note that Delta will provide more new cities with first one stop Haneda service than United; that it will better serve the Pacific Northwest; and that, in a number of cases, service via Seattle is less circuitous than service over San Francisco.33 Against this background, we tentatively find that an award to Delta represents the better allocation of this limited Haneda opportunity.
While we note that Kona currently lacks nonstop service to Tokyo, we recognize that the State of Hawaii now enjoys three of the eight total U.S.-Haneda route-opportunities available to U.S. and Japanese carriers. Consistent with our ongoing goal of using our limited Haneda rights to address a variety of public interest objectives, including the objective of geographically diverse gateways, we tentatively find that the public interest would be better served by opening Haneda nonstop access to a new region of the country, the Pacific Northwest, than by allocating a fourth Haneda route to Hawaii.
Our tentative decision to allow Delta to move its slot pair to Seattle is limited to the proposal considered in this proceeding. Should any carrier, including Delta, currently serving Haneda wish to change its gateway, it should expect a comparable comparative selection proceeding to determine whether it is in the public interest to allow the carrier to do so.
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