US DoT Filing: 2010 US-Tokyo (Haneda) Combination Services Allocation Proceeding

OST-2010-0018

August 3, 2012

Answer of United Air Lines to Motion of Delta Air Lines

Despite the Department's selection of Delta1 to operate daily nonstop Detroit-Haneda and Los Angeles-Haneda B-747 service by Order 2010-7-2, Delta has failed to deliver on the commitments in its Haneda service proposal over the last two years, and granting its request to now move one of its US gateways from Detroit to Seattle (see Motion of Delta filed July 30, 2012 in this docket) would further perpetuate the inefficient use of these scarce, highly valuable Haneda slots. United therefore urges the Department to deny Delta's request and instead allocate one daily pair of US-Tokyo Haneda combination slots for United to provide scheduled foreign air transportation of persons, property and mail with its own aircraft between San Francisco and Tokyo Haneda. Moreover, United is ready, willing and able to commence daily nonstop San Francisco-Haneda service within 90 days of the Department's allocation.

Counsel: Crowell & Moring, Lorraine Halloway, 202-624-2500

Source: AirlineInfo, http://airlineinfo.com/