ANSWER AND REBUTTAL EXHIBITS OF AMERICAN AIRLINES

Transcription

1 ANSWER AND REBUTTAL EXHIBITS OF AMERICAN AIRLINES 2016 U.S.-Haneda Combination Services Allocation Proceeding Docket DOT-OST May 5, 2016 Tokyo Haneda Los Angeles Dallas/Fort Worth

2 CONTENTS Consolidated Answer of American Airlines, Inc. Rebuttal Exhibits Series 100: American Should Be Awarded Permanent LAX-HND Authority Series 200: American s DFW-HND Service Proposal Maximizes the Public Benefits Far Better Than Any Other Applicant s Proposed Service Series 300: American s DFW Hub Is Larger and More Comprehensive Than Delta s MSP Hub American Has Committed to Growing DFW, While Delta s Growth at MSP Has Been Stagnant, at Best Series 400: Delta Has Grown and Continues to Grow Its SEA Hub, While It Shrinks and De-Emphasizes MSP Series 500: As Part of Its Unsuccessful Efforts to Derail the U.S.-Japan Liberalization Talks, Delta Claimed New Haneda Service Would Mean the End of Many of Its Narita Services Series 600: Delta s Proposed MSP-HND Service Will, by Delta s Own Admission, Mean the End of MSP-NRT Service, Resulting in a Net Loss of Benefits for Passengers Using MSP Series 700: United s Proposed EWR-HND Service, in Addition to Providing Inferior Connectivity to American s Proposed DFW-HND Service, Also Would Duplicate Upcoming JFK-HND Service of United s Star Alliance Partner, ANA Series 800: Delta s Repetitive Assertions About Being Disadvantaged in Japan Are Belied by the Facts. To the Contrary, American Remains Significantly Hamstrung in the U.S.-Japan and the U.S.-Northeast Asia Markets Compared to Both Delta and United

3 BEFORE THE U.S. DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C. ) Application of ) ) AMERICAN AIRLINES, INC. ) ) Docket DOT-OST in the matter of 2016 U.S.-Haneda ) Combination Services Allocation ) Proceeding ) ) CONSOLIDATED ANSWER OF AMERICAN AIRLINES, INC. Communications with respect to this document should be addressed to: Howard Kass Vice President Regulatory Affairs Robert A. Wirick Managing Director Regulatory and International Affairs John B. Williams Senior Analyst Regulatory and International Affairs AMERICAN AIRLINES, INC th Street, NW Washington, D.C (202) howard.kass@aa.com robert.wirick@aa.com john.b.williams@aa.com Paul T. Denis Steven G. Bradbury William B. Sohn Thomas J. Miller DECHERT LLP 1900 K Street NW Washington, D.C (202) paul.denis@dechert.com steven.bradbury@dechert.com william.sohn@dechert.com thomas.miller@dechert.com May 5, 2016

4 TABLE OF CONTENTS Executive Summary... 1 Discussion... 4 I. American s Proposed Frequencies to Haneda Maximize Public Benefits by Creating the Most Optimal Mainland Gateways to Haneda, Providing the Most U.S. Connectivity of Any Proposed Service, and Enhancing Mainland U.S.-Japan Competition... 4 A. American s Proposed LAX-HND Service Will Serve the Largest Mainland U.S.-Tokyo O&D Route, Provide Superior Connectivity in Both Countries, and Foster Greater Competition in Mainland U.S.-Japan and Mainland U.S.-Northeast Asia Service... 5 B. Among All Proposed New Gateways to Haneda, DFW Creates New Nonstop Service Where It Is Most Needed and Provides the Most Connectivity and Competitive Benefits... 7 II. Delta s Proposed MSP-HND and ATL-HND Frequencies Would Impede Competition and Fail to Advance the Public Interest A. Awarding Two Daytime Haneda Slot-Pairs to American Rather than Delta Is the Best Way to Improve Mainland U.S.-Japan Competition B. Minneapolis, Like Detroit and Seattle Before It, Cannot Support Nonstop Service to Haneda on Delta s Network C. Delta s Proposed Minneapolis-Haneda Service Would Actually Result in a Net Loss of Public Benefits by Displacing Delta s Existing Narita Service III. United s Proposed EWR-HND Service Would Duplicate ANA s Service, Fail to Contribute to Mainland U.S.-Japan Competition, and Create Minimal Connectivity to Haneda Conclusion... 23

5 BEFORE THE U.S. DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C. ) Application of ) ) AMERICAN AIRLINES, INC. ) ) Docket DOT-OST in the matter of 2016 U.S.-Haneda ) Combination Services Allocation ) Proceeding ) ) CONSOLIDATED ANSWER OF AMERICAN AIRLINES, INC. American Airlines, Inc. ( American or AA ) submits the following Consolidated Answer in response to the Applications of Delta, United, and Hawaiian for the allocation of slotpairs at Tokyo s Haneda Airport (HND). 1 Executive Summary The award of two daytime Haneda slot-pairs to American will maximize public benefits. It will improve existing service to Haneda and provide new service where it is needed most, creating unrivaled connectivity and strengthening transpacific competition. American s proposed daytime service between Los Angeles International Airport (LAX) and Haneda addresses the largest source of mainland U.S.-Tokyo demand more effectively than American s current nighttime service, creates more connections than Delta s proposed LAX-HND service, and enables additional mainland U.S.-Tokyo competition. American s proposed service between Dallas/Fort Worth International Airport (DFW) and Haneda establishes a new U.S. gateway to Haneda in the central U.S., connects Haneda to more U.S. destinations and more U.S.-origin 1 Common names are used for all airlines in this Answer.

6 Answer of American Airlines, Inc. Page 2 of 24 passengers than any other proposed gateway in this proceeding, and enhances competition on mainland U.S.-Japan and mainland U.S.-Northeast Asia routes, where American and oneworld are a distant third to the SkyTeam and Star alliances. By both improving the mainland U.S.- Tokyo services available to passengers and stimulating new inter-alliance competition, American s proposal offers the greatest public benefits of any pending application and should be approved by the Department in its entirety. Delta: In a desperate and overreaching effort to stymie American and oneworld from inaugurating competing service, Delta seeks to reinforce its existing dominance over American and oneworld in service to Japan and Northeast Asia by requesting two daytime slot-pairs for service to Haneda from gateways east of the Rocky Mountains. Delta s proposal would be irrational but for its obvious purpose of excluding competing service by American. Just as Delta previously tried and failed to serve Tokyo from Detroit and Seattle, its proposed service from Minneapolis to Haneda would likely prove unsustainable given Delta s lack of beyond-haneda connections. Worse still, Delta concedes that its proposal guarantees it would pull down existing service from Minneapolis (MSP) to Narita. Passengers who use Delta s MSP-Narita service today rely on that service to reach destinations beyond Tokyo, and the traveling public would be worse off if Delta s proposal were granted. Delta has done its best to keep Haneda slots out of the hands of competitors and has repeatedly stymied the talks that led to the February 2016 agreement enabling this proceeding. The Department should not allow Delta again to play keep away with valuable Haneda slots, depriving passengers of the competitive benefits that would result from an award of two daytime slot-pairs to American.

7 Answer of American Airlines, Inc. Page 3 of 24 United: United s proposed service between Haneda and Newark would duplicate the JFK service planned by United s metal-neutral joint venture partner All Nippon Airways ( ANA ), and thereby would fail to create the diversity of U.S. gateways to Haneda or the increase in competition sought by the Department. Whatever the potential benefits of United s proposed EWR service, those benefits would be realized by too few passengers given the limited connectivity United offers at Newark. United s proposed service would connect to less than a quarter of the destinations provided by American s proposed DFW-HND service. In addition to limiting passenger options, United s proposal would hamper competition by further concentrating the limited slot-pairs for U.S.-Haneda service within Star Alliance, which already serves the lion s share of mainland U.S.-Japan traffic and has nearly half the Haneda slots available for U.S. service. In order to maximize customer choice, bring the benefits of Haneda service to the broadest possible cross-section of the traveling public, and stimulate new competition, the Department should reject United s EWR proposal and award two daytime slot-pairs to American. Hawaiian: Given the unique attributes of Honolulu-Haneda service, American s Consolidated Answer is focused on the relative merits of slot allocations among mainland U.S. gateways. * * * In sum, American s proposal offers the best combination of improved services, breadth of passenger benefits, and enhanced competition of any of the applications pending before the Department. Given the limited number of slots available to U.S. carriers at Haneda (and their infrequent availability), this proceeding presents the Department with a rare opportunity to expand access to Haneda to U.S. passengers throughout the United States. And particularly

8 Answer of American Airlines, Inc. Page 4 of 24 given the troubled and litigious history of access to Haneda, the Department should seize the chance now to correct longstanding competitive imbalances on mainland U.S.-Japan routes and create an unparalleled gateway in the central U.S. to Northeast Asia at American s DFW hub. The Department should therefore award American daytime Haneda slot-pairs for daily LAX- HND and DFW-HND frequencies to serve optimally existing demand for travel to Tokyo, to offer the largest number of Americans connectivity to Haneda, and to improve the competitive environment in mainland U.S.-Japan and mainland U.S.-Northeast Asia service. Discussion I. American s Proposed Frequencies to Haneda Maximize Public Benefits by Creating the Most Optimal Mainland Gateways to Haneda, Providing the Most U.S. Connectivity of Any Proposed Service, and Enhancing Mainland U.S.-Japan Competition The Department s goals of meeting the needs of the traveling and shipping public, promoting geographic diversity among U.S. gateways to Haneda, and growing U.S.-Japan and mainland U.S-Asia competition are best satisfied by the award of one daytime slot-pair to American for daily service to Haneda from Los Angeles and one daytime slot-pair to American for daily service to Haneda from Dallas/Fort Worth. American s proposed daytime LAX-HND service will serve the largest mainland U.S.-Tokyo O&D route and offers superior connectivity to Delta s proposed LAX-HND service. American s proposed new DFW-HND frequency will best meet existing demand for mainland U.S.-Tokyo travel, create unrivaled connectivity to Haneda, and promote competition by allowing American and oneworld to overcome the effect of historical awards of authority under more restrictive bilateral agreements.

9 Answer of American Airlines, Inc. Page 5 of 24 A. American s Proposed LAX-HND Service Will Serve the Largest Mainland U.S.- Tokyo O&D Route, Provide Superior Connectivity in Both Countries, and Foster Greater Competition in Mainland U.S.-Japan and Mainland U.S.- Northeast Asia Service American s successful LAX-HND service is the culmination of American s multiyear effort, with the Department s support, to inject competition in LAX-HND service against the SkyTeam and Star alliances, and the Department should make American s authority to fly this frequency permanent. American s daytime LAX-HND service enables travelers to take advantage of broad connectivity through American s major hub at LAX. And, critically, American s proposed service out of LAX ensures intra-gateway competition at LAX as well as inter-gateway competition to both Haneda and points beyond Tokyo. Competitive nonstop service to Haneda is needed more at LAX than anywhere else in the continental United States. It is uncontested that in the continental United States, demand for U.S.-Tokyo travel is greatest at LAX. 2 The Department s first priority should be to award one daytime frequency for LAX-HND service, and that frequency should be awarded to American. The benefits of American s proposed daytime LAX-HND service exceed any of the other Haneda services at Los Angeles. Since inaugurating LAX-HND service in February, American has enjoyed rapid passenger acceptance flying the route with a brand new 787 Dreamliner. 3 In sharp contrast to Delta s behavior at Seattle, American has lived up to its commitment to operate this service on a daily basis. 4 American has also invested substantial resources both to acquire the route and on 2 Ex. AA-R Ex. AA-R-107. American can upgauge from its Boeing 787 Dreamliner proposed for daytime LAX- HND service to a Boeing 777 if merited by demand, thereby growing LAX-HND traffic on American s service. 4 Ex. AA-R-108.

10 Answer of American Airlines, Inc. Page 6 of 24 the route and has received positive feedback from travelers. 5 The elimination of this service would harm the Los Angeles traveling public, and it would stymie American s ongoing effort to build a gateway to Asia at LAX to compete more effectively against the SkyTeam and Star alliances in providing mainland U.S.-Japan and mainland U.S.-Northeast Asia service. 6 As the largest carrier at LAX, American s proposed daytime LAX-HND service also creates superior connectivity for traffic between Los Angeles and Haneda. Compared to Delta, American s proposed daytime service creates more U.S. connections in both directions and serves almost 10 percent more connecting O&D passengers. 7 As in the Brazil Combination Frequency Proceeding, the benefit to the public of providing travelers access to American s LAX hub supports the award in this proceeding of one daytime slot-pair to American at LAX. 8 American s service also creates many connections in Japan. 9 These connections are particularly important for the Los Angeles community, due to its large Japanese-American population and its numerous Japanese businesses. The loss of American s LAX-HND service would mean the loss of these connections through LAX and HND, and the Department should not allow that to happen. 5 Ex. AA-R See Application of American Airlines, Inc., at Exs. AA-R-102, See Order to Show Cause, 2013/14 US-Brazil Combination Frequency Proceeding, Docket DOT-OST (June 20, 2013), at 7 (finding public would benefit from American s strength at Los Angeles, combined with its ability to provide convenient connections at Los Angeles ). 9 Ex. AA-604.

11 Answer of American Airlines, Inc. Page 7 of 24 B. Among All Proposed New Gateways to Haneda, DFW Creates New Nonstop Service Where It Is Most Needed and Provides the Most Connectivity and Competitive Benefits Dallas/Fort Worth has more current demand for Tokyo service and greater potential for increased demand than any new gateway proposed in this proceeding. The two airports located east of the Rocky Mountains proposed by Delta Minneapolis (MSP) and Atlanta (ATL) share a common trait: Each currently supports just one daily flight to Narita that likely would be terminated if the proposed Haneda service were introduced. Dallas/Fort Worth, by contrast, currently supports three daily flights to Narita (operated by American and JAL), and daily service between DFW and Narita will remain alongside new service to Haneda. Once United s partner ANA begins flying to JFK from Haneda using its new daytime Haneda slots, Dallas/Fort Worth s three current daily flights to Tokyo make it the largest gateway to Tokyo that would have no nonstop service to Haneda if American s application were not approved. 10 On this basis alone, the Department should award American one daily frequency at DFW before considering any other new mainland U.S.-Haneda gateway. In addition to meeting DFW s demand for service to Haneda, American s proposed DFW-HND service will create superior connectivity in every respect: DFW has more connections in both directions; DFW has more unique connections; and DFW has more connecting and local O&D traffic to Tokyo than every other proposed gateway. 10 ANA was awarded the two new Haneda slot-pairs for U.S.-Japan service made available to Japanese carriers and plans to begin service from Haneda to New York and Chicago. See, e.g., Kaname Ohira, ANA Plans 1st Flights to Chicago, N.Y., from October, The Asahi Shimbun (Mar. 28, 2016), AJ html (last accessed May 4, 2016).

12 Answer of American Airlines, Inc. Page 8 of 24 Using an apples-to-apples comparison of connectivity, 11 DFW is far and away number one among all proposed new gateways: Figure 1: Comparison of Connectivity at Proposed New Mainland U.S. Gateways to Haneda 12 Notably, Delta s proposed MSP-HND service would create only half the connections in both directions, and United s proposed EWR-HND service would create only a quarter: Figure 2: Comparison of Connections in Both Directions at Proposed New Mainland U.S. Gateways to Haneda American has applied a minimum domestic connection time of 45 minutes, a maximum connection time of 4 hours, circuity of less than 150 percent, and a minimum of 5 weekly frequencies. 12 Ex. AA-R-203. For international connections, American uses a minimum connection time of 75 minutes rather than 45 minutes. American s methodology is otherwise unchanged. Id. 13 Ex. AA-R-201.

13 Answer of American Airlines, Inc. Page 9 of 24 As these charts show, no proposal does more to expand access to Haneda for travelers located east of the Rocky Mountains than American s DFW-HND service. The growth of Japanese businesses in the Dallas/Fort Worth region and in the State of Texas also makes Dallas/Fort Worth superior to Minneapolis and Atlanta as a gateway to Haneda. As explained in American s Application, many Japanese businesses are relocating their U.S. headquarters to Dallas/Fort Worth, most notably Toyota, which is building a $300 million campus that will employ nearly 4,000 people in The same cannot be said for Minneapolis and Atlanta, which is why Delta s application focuses almost exclusively on nearby U.S.-owned companies, some of which may have no demand for nonstop service to Tokyo. 15 The Department has previously recognized Haneda s advantages to... U.S. business travelers in particular, and the Department should ensure that business travelers have nonstop access to Haneda from one of the most important states for Japanese businesses and U.S.-Japan trade. 16 Finally, as explained in American s Application and contrary to Delta s misleading assertions, new service by American from DFW to Haneda is needed to challenge SkyTeam s and Star s dominance in mainland U.S.-Japan and mainland U.S.-Northeast Asia service. 17 By awarding American a slot-pair for service to Haneda from Dallas/Fort Worth, the Department not only will link Haneda to the proposed gateway with the most demand and connectivity, it also 14 Application of American Airlines, Inc., at E.g., Application of Delta Air Lines, Inc., at Ex. DL-303 ( Minnesota Home to 17 Fortune 500 Companies ); id. at Ex. DL-404 ( Georgia Home to 20 Fortune 500 Companies ). 16 Order to Show Cause, 2010 U.S.-Haneda Combination Services Allocation Proceeding, Docket DOT- OST (Mar. 27, 2015), at Ex. AA-R-802, 806.

14 Answer of American Airlines, Inc. Page 10 of 24 will maximize public benefits by adding significant new inter-alliance competition between the U.S. and Japan. 18 II. Delta s Proposed MSP-HND and ATL-HND Frequencies Would Impede Competition and Fail to Advance the Public Interest Delta s application should be rejected for several reasons. First, and as discussed in American s Application, American s proposed DFW service is the best option for serving Haneda from the central U.S., offering vastly superior connectivity than Delta s proposed MSP service. Second, American s proposal will add much-needed competition on mainland U.S.- Japan routes that Delta has historically both dominated and mishandled. Third, Delta s proposed Minneapolis service is almost certainly nonviable and simply reflects Delta s ongoing efforts to prevent other carriers from offering competing service to Haneda. Finally, Delta s proposed Haneda service would by Delta s own admission wipe out Delta s service from Minneapolis to Narita at the expense of travelers who currently use Delta s MSP-Narita service for destinations beyond Tokyo. Having failed to undermine the talks that led to the February 2016 agreement enabling this proceeding, Delta has apparently concluded that it stands to gain more from operating MSP- Haneda service at a loss than it does from facing new, robust competition from American on mainland U.S.-Japan routes. The Department should reject this obstructionist plan and seize this rare opportunity to bolster competition by granting American s proposal for two daytime slotpairs to fly to Haneda. 18 See Final Order and Order to Show Cause, 2007/2008/2009 U.S.-China Air Services and Combination Frequency Allocation Proceeding (September 25, 2007), at (noting that an award to American would promote inter-alliance competition because it would permit the oneworld alliance... to gain more access to the China market and observing that [t]he Star and SkyTeam alliances have significantly more access to the China market. ).

15 Answer of American Airlines, Inc. Page 11 of 24 A. Awarding Two Daytime Haneda Slot-Pairs to American Rather than Delta Is the Best Way to Improve Mainland U.S.-Japan Competition Delta disingenuously claims that it needs three Haneda slot-pairs to enhance the U.S.- Japan competitive landscape. 19 In reality, as the only applicant to request three slot-pairs, Delta is doing its best to limit rather than increase competition. To make the case that it is somehow disadvantaged compared to American/JAL and United/ANA, Delta cherry-picks data from both U.S.-Haneda and U.S.-Tokyo service at its convenience. Elsewhere, Delta defines these alleged markets in ways that bear little relation to U.S.-Japan traffic. For example, Delta supports its claim that United/ANA and American/JAL currently dominate the U.S.-Haneda market with data purporting to show global Haneda flight departure share ignoring that only eight daily Haneda departures are to U.S. destinations. 20 Instead, Delta lumps in ANA s and JAL s slot holdings at Haneda that are used primarily for domestic flights in Japan and non-u.s. international flights to give a misleading impression of American s competitive presence on mainland U.S.-Japan routes. Rather than rely on tortured and inconsistent market definitions, the Department should follow its stated goal of improving competition in the U.S.-Japan market. 21 Under that metric, American and JAL are a distant third compared to Delta and United/ANA: 19 Application of Delta Air Lines, Inc., at Id. at 2 (citing Ex. DL-107, purporting to show that SkyTeam represents just 2% of total HND departures. Total HND departures is irrelevant to U.S.-Haneda service and U.S.-Japan competition). 21 DOT Order , at 2 (emphasis added) ( Instituting Order ).

16 Answer of American Airlines, Inc. Page 12 of 24 Figure 3: Onboard Mainland U.S.-Japan Passenger Traffic by U.S. Carriers and Japanese Partners 22 The Department should reject Delta s call to create slot parity at one airport in one city at the expense of broader competition on services to Japan and Northeast Asia. 23 Consistent with its goal of promoting U.S-Japan and U.S.-Northeast Asia competition, the Department awarded a Haneda slot-pair to American in 2010 to provide enhanced alliance competition in the overall U.S.-Asia market, as well the U.S.-Japan market, where members of the other alliances are significant participants. 24 But the need for competition from American and oneworld is greater today than it was in 2010, because the SkyTeam and Star alliances have only gained ground: 22 Ex. AA-R Application of Delta Air Lines, Inc., at Order to Show Cause, 2010 U.S.-Haneda Combination Services Allocation Proceeding, Docket DOT- OST (May 7, 2010), at 11.

17 Answer of American Airlines, Inc. Page 13 of 24 Figure 4: Mainland U.S.-Northeast Asia Onboard Passenger Traffic by Alliance Group 25 Indeed, American and JAL do not dominate U.S.-Japan and U.S.-Tokyo service, but are instead disadvantaged in mainland U.S.-Japan service compared to their respective competitors. American lacks Delta s and United s Fifth Freedom rights in Japan, and as Delta acknowledges, JAL operates in the penalty box. 26 Accordingly, although Delta claims JAL and American will have the ability to allocate [daytime Haneda slot-pairs] to any gateway 27 in the United States, the reality is that JAL s penalty box status prevented it from being awarded any daytime slot-pairs at Haneda or reallocating its existing nighttime slot-pairs. This existing disparity would be made even worse if the Department awarded Delta additional slots to create slot parity, as Delta would likely use its Haneda slots as vehicles to reinforce its position over American and JAL, just as Delta did with its Seattle-Haneda slot-pair that it held onto for as long 25 Ex. AA-R Application of Delta Air Lines, Inc., at Id. at 7.

18 Answer of American Airlines, Inc. Page 14 of 24 as it could. The award of two Haneda slot-pairs to American will not fully cure the current competitive imbalance on mainland U.S.-Japan and mainland U.S.-Northeast Asia service, but it is an important first step towards correcting the disparity and promoting stronger inter-alliance competition. B. Minneapolis, Like Detroit and Seattle Before It, Cannot Support Nonstop Service to Haneda on Delta s Network In addition to offering inferior connectivity and weakening mainland U.S.-Japan competition, Delta s proposed MSP-Haneda service would likely fail commercially. First, it is unlikely that MSP-Haneda would prove commercially successful because Delta neither operates nor codeshares on any flights beyond Haneda. This distinction is critical because nearly twothirds of Delta s existing MSP-Tokyo traffic (through Delta s MSP-Narita service) goes to destinations beyond Tokyo. In its application, Delta chose not to mention that most of the traffic on its MSP-Narita route is beyond-tokyo traffic, which Delta s Fifth Freedom rights in Japan enable it to serve. Delta s application in this proceeding claims MSP has a large number of Tokyo O&D passengers each year. 28 But less than four months ago, Delta s Executive Vice President and Chief Legal Officer Ben Hirst told the Metropolitan Airports Commission of Minneapolis that this large number is just 25 local passengers per flight (about 10 percent of the onboard passengers). 29 Passengers connecting over, but not originating at, MSP represent 2.5 times the share of local passengers as a percentage: 28 Application of Delta Air Lines, Inc., at Statement of Ben Hirst, Delta Air Lines, Inc., to the Metropolitan Airports Commission (Jan. 19, 2016) ( Hirst Statement to MAC ). Ben Hirst s remarks are available at metroairports/ metroairports_04597ee2-f1f2-4f10-89f7-6109c3980ba5.mp4, beginning at roughly 25:00 in the video, beginning at 40:00. In addition to the 25 local MSP-NRT O&D passengers, another 25% of Tokyo-bound onboard passengers on Delta s MSP-NRT service originate behind MSP.

19 Answer of American Airlines, Inc. Page 15 of 24 Figure 5: Local and Connecting Traffic on Delta s MSP-NRT Frequency 30 The upshot is that Delta s proposed service from Minneapolis to Haneda cannot meet the needs of nearly two-thirds of Delta s current MSP-Narita passengers, almost certainly rendering the service commercially non-viable. Indeed, Delta has openly acknowledged that it needs connecting traffic to make MSP-Tokyo service worthwhile. In January of this year, Delta s Executive Vice President and Chief Legal Officer explained to the Minneapolis airport authority, Delta operates a delicate balance of seats between the beyond points in Asia and Tokyo. It takes both kinds of traffic to support the nonstop flights we have to Tokyo. 31 He added that 20 percent of Delta s revenue from [MSP-Narita] service comes from Osaka, Bangkok, and Shanghai passengers, which are just three of the five beyond-tokyo destinations where Delta flies. 32 Delta has offered no reason for the Department to expect that this essential traffic will be replaced with Tokyo O&D traffic on Delta s proposed MSP-HND service. Second, the historic failures of Delta s service to Tokyo out of Detroit (DTW) and Seattle (SEA) demonstrate that Minneapolis will similarly fail. Over the past several years, Delta has 30 Ex. AA-R Hirst Statement to MAC, at 29:05 (emphasis added). 32 Id. beginning at 39:45.

20 Answer of American Airlines, Inc. Page 16 of 24 invested enormously in its Seattle hub, which has seen more new routes, more capacity, and more traffic, often at the expense of Delta s Minneapolis hub. 33 Delta failed to sustain Seattle- Haneda service, in the process fighting tooth-and-nail to prevent other carriers from using the slot-pair to serve Haneda. Now, despite having deemphasized Minneapolis in its network, Delta is acting contrary to commercial realities by seeking a slot-pair for MSP-HND service, even though that service is likely to suffer the same fate as SEA-HND. Delta s motivation is transparent: to keep other carriers out of Haneda as part of its longstanding strategy. Indeed, every new statement Delta makes shows that its request for an MSP-HND frequency is based on exclusionary and political objectives, rather than a bona fide interest in operating commercially viable service to Haneda. 34 Preemptively seeking to address its previous failures to serve Haneda, Delta claims that other applicants should not be permitted to distort Delta s history with other U.S. gateways that turned out not to be viable nighttime gateways. 35 But there is no reason for other applicants to distort Delta s history; that history speaks for itself. Besides Delta s pattern of downsizing its aircraft serving its Haneda frequencies almost immediately after beginning service, Delta has twice abandoned service to Haneda from two gateways that closely resemble Minneapolis: 33 Ex. AA-R-402, 403, Kristin Leigh Painter, Delta s Bastian Says MSP at Top of List for Routes to Tokyo s Haneda, StarTribune (May 5, 2016), (last accessed May 5, 2016) (noting that request for MSP-HND service was a thank-you gesture to Minnesota s government officials and business leaders who quickly mobilized on Delta s behalf to plea with the DOT. ). 35 Application of Delta Air Lines, Inc., at 14 n. 33.

21 Answer of American Airlines, Inc. Page 17 of 24 Disregarded in Detroit: After downgrading its 403-seat B747 aircraft to a 241-seat A330 aircraft after just 37 flights, Delta suspended its DTW-HND service in September 2011 until April 2012, and then permanently abandoned the frequency in October Seatless in Seattle: In Delta s first year of operating this service, Delta failed to maintain daily service for several months. Delta then effectively ceased service on its SEA-HND frequency in October 2014, operating it a total of only 17 times in a 182- day period. 37 Notably, Delta s SEA-HND service is the only West Coast service to Haneda to fail; five different carriers have made LAX-HND and SFO-HND service successful. Delta s failures in Detroit and Seattle suggest that it cannot viably support service to Haneda from gateways with smaller U.S.-Tokyo traffic and a dependence on travel to beyond-tokyo destinations, like Minneapolis. Delta s history also includes its refusal to relinquish its unused slot-pair for SEA-HND service, in contrast to American s voluntary return of its slot-pair used for JFK-HND service. In fact, Delta distorts its own history by claiming that it promptly returned its slot pair when it determined its SEA-HND service was not commercially viable. 38 But Delta s prompt return occurred only after the Department issued a final order requiring Delta to fly the SEA-HND frequency daily or lose it an order that was issued following a contested six-month proceeding that arose from Delta s virtual abandonment of the route for a full traffic season. 39 Delta s proposed MSP-HND service creates the clear potential for a repeat of the 2015 Haneda proceeding, which the Department can guard against only by rejecting Delta s proposal. 36 Application of American Airlines, Inc., Ex. AA-301, 2010 U.S.-Haneda Combination Services Allocation Proceeding, Docket DOT-OST (Jan. 5, 2015). 37 Id. at Exs. AA-312, Application of Delta Air Lines, Inc., at 14 n. 33 (emphasis added). 39 Final Order, 2010 U.S.-Haneda Combination Services Allocation Proceeding, Docket DOT-OST (June 14, 2015), at 9-10.

22 Answer of American Airlines, Inc. Page 18 of 24 Delta s troubled history of depriving U.S. travelers of access to Haneda in order to protect its entrenched position from competition should lead the Department to disregard Delta s suggestion that the 2015 Seattle proceeding should have no bearing on the current proceeding. 40 Delta s claim that its poor record of serving Haneda is irrelevant cannot be reconciled with its argument earlier this year that the Department should reject Frontier s proposed service to Cuba due to Frontier s poor record of sustaining new, speculative service. 41 As Delta dramatically stated in the Cuba proceeding: Delta s Cuba Answer Exhibit DL-A Here, the Department should learn from Delta s history of desperately trying to keep competing carriers out of Haneda, or else risk seeing more of the same as Delta rehashes the same strategies to stifle competition. C. Delta s Proposed Minneapolis-Haneda Service Would Actually Result in a Net Loss of Public Benefits by Displacing Delta s Existing Narita Service Even if Delta s MSP-HND service somehow proved viable, it would inevitably displace Delta s existing MSP-Narita service. Delta admits as much, noting in its application that Haneda growth will reduce demand for Narita, and that current projections showing increasing passenger demand for service to Haneda Airport suggest that NRT service from MSP 40 Application of Delta Air Lines, Inc., at 14 n Answer of Delta Air Lines, Inc., 2016 U.S.-Cuba Frequency Allocation Proceedings, Docket DOT- OST (Mar. 14, 2016), at Answer of Delta Air Lines, Inc., Ex. DL-A-0701, 2016 U.S.-Cuba Frequency Allocation Proceedings, Docket DOT-OST (Mar. 14, 2016), at 2.

23 Answer of American Airlines, Inc. Page 19 of 24 will not be sustainable. 43 Regardless of whether Delta s MSP-Narita service would survive on its own, a slot-pair enabling Delta to launch MSP-HND service guarantees that Delta s MSP- Narita service will not be sustainable, leaving Minneapolis passengers without any of the onestop beyond-tokyo connections that they currently enjoy through Narita. Without that MSP- Narita service, passengers flying out of Minneapolis on the Delta network would be forced to double-connect to reach numerous destinations in Asia, including Bangkok, Singapore, Taipei, Manila, and Ho Chi Minh City. Rather than benefit the public, Delta s proposal would therefore leave a great number of Delta s current passengers who fly from or through Minneapolis worse off than they are today. The public will benefit most from an award that will allow passengers to fly to both Narita and Haneda depending on their preferences and connecting needs and that is exactly what American s proposal achieves. American and oneworld will continue to serve Narita from DFW even after the commencement of Haneda service. American s proposal means more choice, not less, for passengers traveling from the mainland U.S to Tokyo, Japan, and Northeast Asia. And unlike Delta s proposed MSP-HND service, American s service out of DFW, American s largest hub, offers the tremendous connectivity needed to ensure that the service is commercially viable. Accordingly, the Department should grant American s application and deny Delta s proposal for Haneda service out of Minneapolis. 43 Application of Delta Air Lines, Inc., at 19.

24 Answer of American Airlines, Inc. Page 20 of 24 III. United s Proposed EWR-HND Service Would Duplicate ANA s Service, Fail to Contribute to Mainland U.S.-Japan Competition, and Create Minimal Connectivity to Haneda Although United touts the Newark/New York City metropolitan area as the largest U.S.-Tokyo market outside the West Coast, 44 United fails to mention that its alliance partner ANA will soon provide nonstop service between Haneda and the New York metro area. As widely reported by the Japanese media, ANA which was awarded the two additional daytime Haneda slot-pairs made available to Japanese carriers due to JAL s being in the penalty box plans to begin service between Haneda and JFK in October. 45 In short, United/ANA will already be serving the New York-Haneda traffic through JFK. And, of course, ANA could operate that (or another) service to Newark. United has noted the Department s preference against duplicative services in a prior Haneda proceeding, explaining that the Department [has] looked unfavorably on duplicative service proposals in limited-entry route proceedings. 46 Now, however, United is proposing just such duplicative service, as its proposed Newark-Haneda service would overlap with the announced service of its metal-neutral joint venture partner. United s proposal would therefore thwart the Department s objective of promoting geographic diversity among U.S. gateways for Haneda services, 47 and would instead concentrate new U.S-Haneda service in one region of the country. 44 Application of United Airlines, Inc., at See, e.g., Kaname Ohira, ANA Plans 1st Flights to Chicago, N.Y., from October, The Asahi Shimbun (Mar. 28, 2016) (last accessed Apr. 28, 2016). 46 Consolidated Answer of United Airlines, Inc., 2010 U.S.-Haneda Combination Services Allocation Proceeding, Docket DOT-OST (Sept. 6, 2012), at Instituting Order, at 2.

25 Answer of American Airlines, Inc. Page 21 of 24 Worse, United s proposed service would further concentrate mainland U.S.-Tokyo services in one alliance, squandering the opportunity this proceeding offers the Department to increase competition. United and ANA not only have the largest share of mainland U.S.-Japan traffic and frequencies; they also have the lion s share of Haneda slots. 48 If United were to be awarded Newark-Haneda authority, United and ANA would hold six of the twelve available Haneda slot-pairs for U.S. service, and five of the ten daytime slot-pairs. The Department should not permit the alliance that already enjoys the largest share of mainland U.S.-Japan service and an enormous share of mainland U.S.-Northeast Asia service to gain a new stronghold at Haneda when the Department has the opportunity to award these slots to American at DFW and increase competition. American has nowhere near the Northeast Asian network that United has, primarily because it lacks relationships with any carriers in China and South Korea. As a result, American must grow in new destinations in Northeast Asia as space becomes available, as at Haneda, to help rectify the current imbalance in mainland U.S.- Northeast Asia services. Even without United s second slot-pair, the Star Alliance will still have the most Haneda slots for mainland U.S.-Japan service of the three alliances. Awarding United, rather than American, a second slot-pair will frustrate the Department s objective of increasing competition. In addition to diversifying U.S. gateways to Haneda and enhancing competition, American s proposed service from DFW offers four times the connectivity of United s proposed service from EWR. American s proposed DFW-HND service provides 104 U.S. connections in both directions, compared to just 24 from EWR, while serving more than twice as much local 48 Ex. AA-302, 305.

26 Answer of American Airlines, Inc. Page 22 of 24 and connecting traffic. 49 DFW s coverage is also far more comprehensive, connecting passengers from 34 states to Haneda, compared to just 13 states for EWR: Figure 7: Comparisons of Connections and States Connected Between DFW and EWR 50 American s expansive network from DFW reaches nearly every state that United s smaller EWR network connects to Haneda, plus many states that will continue to lack connecting access to Haneda should the Department award EWR-HND service at DFW s expense. Because United s proposed EWR-HND service is duplicative, thwarts the Department s objective of increasing mainland U.S.-Japan and U.S-Northeast Asia competition, and creates relatively little connectivity, it would produce few net public benefits if awarded. The Department should not prioritize a second frequency to Haneda for the New York/Newark region especially one within the same global alliance over a new frequency for Dallas/Fort Worth that makes Haneda accessible for millions of new travelers across the U.S. Unlike American s proposed DFW service, United s proposed service will do little for most travelers from east of the Rocky Mountains that currently lack any connections to Haneda. If it awarded 49 Ex. AA-R-202, Ex. AA-R-701.

27 Answer of American Airlines, Inc. Page 23 of 24 this service over American s proposed DFW-HND service, the Department would waste a rare opportunity to diversify U.S. gateways to Haneda, create widespread access to Haneda, and enhance mainland U.S.-Japan and mainland U.S.-Northeast Asia competition. Conclusion American s proposed daytime services to Haneda from Los Angeles and Dallas/Fort Worth maximize public benefits by best meeting the needs of local and connecting travelers, creating unrivaled connectivity throughout the United States, and injecting new competition into mainland U.S.-Japan and mainland U.S.-Northeast Asia service. No other proposal comes close. Delta s proposed frequencies even if its proposed MSP-HND service somehow overcame the odds and avoided the same fate as Delta s failed service to Haneda from Detroit and Seattle would only add to the existing competitive imbalance on mainland U.S-Japan services and, as Delta concedes, would guarantee the loss of existing services to Narita that currently benefit passengers. United s proposed service to Haneda from Newark would stifle competition by further concentrating U.S.-Haneda services in the dominant Star alliance while failing to add geographic diversity to U.S. gateways given ANA s announced JFK service. For the reasons stated above, American respectfully requests that the Department of Transportation award it two daytime Haneda slot-pairs for LAX-HND and DFW-HND service.

28 Answer of American Airlines, Inc. Page 24 of 24 Respectfully submitted, Howard Kass Vice President Regulatory Affairs Robert A. Wirick Managing Director Regulatory and International Affairs John B. Williams Senior Analyst Regulatory and International Affairs AMERICAN AIRLINES, INC th Street, NW Washington, D.C (202) Paul T. Denis Steven G. Bradbury William B. Sohn Thomas J. Miller DECHERT LLP 1900 K Street NW Washington, D.C (202) paul.denis@dechert.com steven.bradbury@dechert.com william.sohn@dechert.com thomas.miller@dechert.com May 5, 2016

29 CERTIFICATE OF SERVICE I certify that on May 5, 2016, I caused to be served a copy of the foregoing Consolidated Answer of American Airlines, Inc. by upon those addressees listed below: robert.finamore@dot.gov (Department of Transportation) brian.hedberg@dot.gov (Department of Transportation) todd.homan@dot.gov (Department of Transportation) peter.irvine@dot.gov (Department of Transportation) brett.kruger@dot.gov (Department of Transportation) susan.mcdermott@dot.gov (Department of Transportation) benjamin.taylor@dot.gov (Department of Transportation) john.s.duncan@faa.gov (Federal Aviation Administration) englets@state.gov (Department of State) alex.krulic@delta.com (Delta Air Lines) chris.walker@delta.com (Delta Air Lines) kquinn@pillsburylaw.com (Counsel for Delta Air Lines) amna.arshad@pillsburylaw.com (Counsel for Delta Air Lines) christopher.leuchten@pillsburylaw.com (Counsel for Delta Air Lines) aaron.alter@hawaiianair.com (Hawaiian Airlines) perkmann@cooley.com (Counsel for Hawaiian Airlines) jrenehan@cooley.com (Counsel for Hawaiian Airlines) mthorpe@dfwairport.com (DFW) dflint@lawa.org (LAWA) smengistu@lawa.org (LAWA) steve.morrissey@united.com (United Airlines) dan.weiss@united.com (United Airlines) thomas.bolling@united.com (United Airlines) abby.bried@united.com (United Airlines) james.conneely@united.com (United Airlines) mwarren@crowell.com (Counsel for United Airlines) gmurphy@crowell.com (Counsel for United Airlines) sseiden@crowell.com (Counsel for United Airlines) nssparks@fedex.com (Federal Express) anita.mosner@hklaw.com (Counsel for UPS) rpommer@atlasair.com (Atlas Air) kevin.montgomery@polaraircargo.com (Polar Air Cargo) info@airlineinfo.com (Airline Info) John B. Williams

30 Rebuttal Exhibits of American Airlines List of Exhibits Page 1 of 6 Exhibit Number Title Series 100: American Should Be Awarded Permanent LAX-HND Authority AA-R-101 LAX-TYO Is the Largest Mainland U.S.-Tokyo O&D Route AA-R-102 AA-R-103 American s Proposed Daytime LAX-HND Service Provides Superior Connectivity to Delta s Proposed Daytime LAX-HND Service, and Access to 10% More U.S.-TYO O&D Traffic Than Delta s Proposed Service Delta s Proposed Daytime LAX-HND Flight Would Connect in Both Directions to 16 Destinations Available to 724,348 Connecting Passengers Less Connections and TYO O&D Passengers Than American s Proposed LAX-HND Daytime Service AA-R-104 American s Proposed Daytime LAX-HND Service Would Connect in Both Directions to 18 Destinations Available to 813,299 Connecting Passengers an Improvement Over American s Current Nighttime LAX-HND Service of 4 Net New Destinations and 190,395 Connecting TYO O&D Passengers AA-R-105 American Would Provide Needed Inter-Carrier and Inter-Alliance Competition on the LAX-HND Route AA-R-106 AA-R-107 AA-R-108 American Invested Considerable Resources to Gain Authority to Serve LAX-HND Since American Has Gained LAX-HND Authority, It Has Invested Substantial Resources on the Route American Has Lived Up to Its Commitment to Operate LAX-HND Every Day Since Inauguration of That Service Series 200: American s DFW-HND Service Proposal Maximizes the Public Benefits Far Better Than Any Other Applicant s Proposed Service AA-R-201 AA-R-202 American s Proposed DFW-HND Service Provides the Most Connectivity of Any HND Service Current or Proposed and More Than 2x the Connectivity of Proposed MSP-HND Service and 4x the Connectivity of United s Proposed EWR-HND Service And, American s Proposed DFW-HND Service Captures the Largest Amount of Local/Connecting U.S.-TYO O&D Traffic of Any Proposed or Current HND Gateway 49% Larger Than Delta s Proposed MSP-HND Gateway and 120% Larger Than United s Proposed EWR-HND Gateway

31 Rebuttal Exhibits of American Airlines List of Exhibits Page 2 of 6 Exhibit Number AA-R-203 AA-R-204 AA-R-205 AA-R-206 AA-R-207 AA-R-301 AA-R-302 AA-R-303 AA-R-304 AA-R-305 Title American s Proposed DFW-HND Service Proposal Is Superior, by Any Measure, to the Other 2nd and 3rd Preference Mainland U.S. Proposals of Other Applicants American s Proposed DFW-HND Service Would Connect in Both Directions to 104 Destinations Available to 1,194,654 Local and Connecting TYO O&D Passengers Delta s Proposed MSP-HND Service Would Connect in Both Directions to 49 Destinations (Less Than Half of American s Proposed DFW-HND Service) Available to 801,017 Local and Connecting TYO O&D Passengers (33% Less Than American s Proposed DFW-HND Service) Delta s Proposed ATL-HND Service Would Connect in Both Directions to 89 Destinations (17% Less Than American s Proposed DFW-HND Service) Available to 995,422 Local and Connecting TYO O&D Passengers (17% Less Than American s Proposed DFW-HND Service) United s Proposed EWR-HND Service Would Connect in Both Directions to 24 Destinations (77% Less Than American s Proposed DFW-HND Service) Available to 542,755 Local and Connecting TYO O&D Passengers (55% Less Than American s Proposed DFW-HND Service) Series 300: American s DFW Hub Is Larger and More Comprehensive Than Delta s MSP Hub American Has Committed to Growing DFW, While Delta s Growth at MSP Has Been Stagnant, at Best In Every Measure, American s DFW Hub Provides Larger and More Comprehensive Coverage Than Delta s MSP Hub America s Proposed DFW-HND Service Would Benefit Passengers in More States Than Delta s Proposed MSP-HND Service In the Past 5 Years, American Has Increased Its Capacity at DFW, While Delta Has Decreased Capacity at MSP Between 2011 and 2015, American Increased Its International Seats at DFW by 27%, But Delta Reduced Its International Seats at MSP American Has Increased Its Domestic Seats at DFW, While Delta Has Reduced Its Domestic Seats at MSP

32 Rebuttal Exhibits of American Airlines List of Exhibits Page 3 of 6 Exhibit Number AA-R-306 AA-R-307 AA-R-308 AA-R-309 AA-R-310 AA-R-311 AA-R-401 AA-R-402 Title Between 2011 and 2015, American s Passenger Traffic Growth at DFW Has Grown by Close to 10%, While Delta s Traffic Has Barely Changed at MSP American s DFW International Passengers Are Almost 3x the Number of Delta s at MSP, with Much Higher DFW Growth Than MSP In 2015, American Carried Almost Twice the Number of Domestic Passengers at DFW as Delta Did at MSP By Any Metric, American at DFW Has Outperformed Delta at MSP by a Wide Margin American Has Introduced 14 New International Services at DFW Since July Year-Round and Three That Operate 10 Months a Year While Delta Has Added Only Two New International Services from MSP in That Same Time Period... and Both Are Seasonal Services Only Series 400: Delta Has Grown and Continues to Grow Its SEA Hub, While It Shrinks and De-Emphasizes MSP If Delta Could Not Make SEA-HND Work, How Can It Possibly Make MSP-HND Work? Since 2010, Delta Has Actively Promoted the Shift of Its MSP-Originating Asia Passengers to Its SEA Hub AA-R-403 Since 2011, Delta Has Nearly Quadrupled Its Domestic Capacity at SEA, While Decreasing MSP Capacity by 12% AA-R-404 AA-R-405 AA-R-406 Since 2011, Delta Has Dropped 10 Domestic Destinations at MSP, But Added 24 New Destinations at SEA Since 2011, Delta Has Added Only Two New International Services from MSP, But, at SEA, Delta Has Added 9 New International Services Since 2010, Delta Has Increased Its Asia-Bound Passenger Traffic at SEA by 208%, While MSP Has Experienced a 32% Loss of Its Asia-Bound Passengers

33 Rebuttal Exhibits of American Airlines List of Exhibits Page 4 of 6 Exhibit Number AA-R-407 AA-R-408 AA-R-501 AA-R-502 AA-R-503 AA-R-504 AA-R-505 AA-R-506 AA-R-507 AA-R-508 AA-R-509 Title Delta s SEA Asia-Bound Connecting Traffic Has Quintupled in Just Six Years, While MSP Has Lost 37% of Its Asia-Bound Connecting Traffic Delta s U.S.-Asia Bridge Traffic Through SEA Has Tripled in the Last Six Years, While MSP s U.S.-Asia Bridge Traffic Has Declined by 45% Series 500: As Part of Its Unsuccessful Efforts to Derail the U.S.-Japan Liberalization Talks, Delta Claimed New Haneda Service Would Mean the End of Many of Its Narita Services In an Effort to Scupper U.S.-Japan Aviation Liberalization Negotiations, Delta Mounted an All-Out Campaign to Create Political and Media Pressure, Claiming Incremental Liberalization Would Result in Termination of Its MSP/ATL/DTW/PDX-NRT Services [Opening Haneda] Would Kill the Only Non-Stop from Minnesota to Asia Delta Says Deal Would Kill Direct Flights From MSP to Tokyo Delta Says Tokyo Hub, Including Minnesota s Only Nonstop Flight to Asia, Is at Risk Delta: Japan Deal Threatens Asian Flights Treaty Talks Imperil Delta Detroit-Tokyo Flights Delta Threatens to Pull Out [of Portland] U.S., Japan Talks Risk Delta Flights to Tokyo-Narita Commercial Impacts [of the Deal] are Imminent

34 Rebuttal Exhibits of American Airlines List of Exhibits Page 5 of 6 Exhibit Number Title Series 600: Delta s Proposed MSP-HND Service Will, by Delta s Own Admission, Mean the End of MSP-NRT Service, Resulting in a Net Loss of Benefits for Passengers Using MSP AA-R-601 AA-R-602 AA-R-603 AA-R-604 AA-R-701 AA-R-702 AA-R-703 AA-R-704 Delta Has Conceded That the MSP-NRT Route (and Others) Will Be Doomed as U.S.-Haneda Services Expand. While This May Be True Regardless of HND Awards, It Is Certainly True If Delta Is Awarded MSP-HND Service Unlike Larger Markets Such as LAX, DFW, and SFO, MSP Cannot Sustain Two Tokyo Services One to HND and One to NRT If Delta Is Awarded MSP-HND Authority, It Is Likely to Experience a Load Factor of Less Than 50% on that Route, and the Continuation of MSP-NRT with No Local TYO Traffic Will Not Be Viable Either as Delta Itself Admits Awarding Delta MSP-HND Means That Delta s MSP-NRT Service, in Delta s Words, Will Not Be Sustainable, and the Twin Cities Communities Will Lose Its One-Stop Connections Over NRT Series 700: United s Proposed EWR-HND Service, in Addition to Providing Inferior Connectivity to American s Proposed DFW-HND Service, Also Would Duplicate Upcoming JFK-HND Service of United s Star Alliance Partner, ANA America s Proposed DFW-HND Service Would Benefit Passengers in More States Than United s Proposed EWR-HND Service American s Proposed DFW-HND Service Would Connect in Both Directions to 104 Destinations Available to 1,194,654 Local and Connecting TYO O&D Passengers United s Proposed EWR-HND Service Would Connect in Both Directions to 24 Destinations (77% Less Than American s Proposed DFW-HND Service) Available to Only 542,756 Local and Connecting TYO O&D Passengers (55% Less Than American s Proposed DFW-HND Service) ANA Has Stated It Would Fly HND-JFK If It Were Awarded One of the New Japanese U.S.-HND Slot Pairs. ANA Received All Japanese U.S.-HND Slot Pairs (JAL Received None) ANA Will Be Flying NY-HND

35 Rebuttal Exhibits of American Airlines List of Exhibits Page 6 of 6 Exhibit Number Title Series 800: Delta s Repetitive Assertions About Being Disadvantaged in Japan Are Belied by the Facts. To the Contrary, American Remains Significantly Hamstrung in the U.S.-Japan and the U.S.-Northeast Asia Markets Compared to Both Delta and United AA-R-801 AA-R-802 AA-R-803 AA-R-804 AA-R-805 AA-R-806 United and Delta Have a Collarhold on U.S.-Japan Traffic and Have So for Decades Even Combined with JAL, American s Presence in the Japan-U.S. Market Is Smaller Than Delta s and United/ANA s (and United s/ United+ANA s) While Delta Has No Connectivity at Haneda to Japanese Destinations, Delta Can Effectively Serve Japanese Cities Through Its Northeast Asia Partners Hubs, Representing 97.8% of U.S.-Japan O&D Delta s Current LAX-HND Service Has Not Been Disadvantaged by Not Having Japan Access Beyond HND For Decades, Delta and United Have Dominated the Northeast Asia-U.S. Market With Their Strong Northeast Asia Partners, Delta Through SkyTeam and United Through Star Alliance Have Widened the Gap with American and oneworld in the Northeast Asia-U.S. Market

36 Series 100: American Should Be Awarded Permanent LAX-HND Authority

37 LAX-TYO Is the Largest Mainland U.S.-Tokyo O&D Route Exhibit AA-R-101 Page 1 of 1 250,000 Top O&D Passengers Tokyo Mainland U.S. 200, , ,000 50,000 0 LAX SFO JFK LAS MCO EWR SEA DTW ATL ORD Source: U.S. DOT O&D data (YE Q3-15)

38 American s Proposed Daytime LAX-HND Service Provides Superior Connectivity to Delta s Proposed Daytime LAX-HND Service, and Access to 10% More U.S.-TYO O&D Traffic Than Delta s Proposed Service Exhibit AA-R-102 Page 1 of 1 American Connections in Both Directions for Its Proposed LAX-HND Service Summary: Connection TYO O&D Connections Both Ways: 18 Local O&D Passengers: 237,022 Connecting O&D Passengers: 813,299 Connecting + Local O&D Passengers: 1,050,321 American will upgauge its aircraft should traffic warrant it SFO 142,941 JFK 117,486 MCO 74,008 SEA 67,500 ATL 54,404 ORD 50,269 PDX 49,375 DFW 48,226 BOS 47,888 DEN 37,536 PHX 25,094 SAN 23,898 SLC 21,279 PHL 17,395 AUS 15,411 PIT 9,289 SJC 7,205 TUS 4,094 Total Connecting O&D Passengers 813,299 Sources: OAG Schedules (July 2016); U.S. DOT O&D YE Q Note: Maximum connection time is 4 hours; minimum domestic to domestic connect time is 45 minutes; minimum international to domestic connect time is 75 minutes; circuity less than 150%; minimum of 5x weekly frequencies.

39 Delta s Proposed Daytime LAX-HND Flight Would Connect in Both Directions to 16 Destinations Available to 724,348 Connecting Passengers Less Connections and TYO O&D Passengers Than American s Proposed LAX-HND Daytime Service In Rebuttal to Delta Application at Page 17, and Exhibit DL-202 Exhibit AA-R-103 Page 1 of 1 Delta Connections in Both Directions for Its Proposed LAX-HND Daytime Service Summary: Connection TYO O&D Connections Both Ways: 16 Local O&D Passengers: 237,022 Connecting O&D Passengers: 742,348 Connecting + Local O&D Passengers: 979,370 SFO 142,941 JFK 117,486 LAS 112,904 SEA 67,500 ATL 54,404 PDX 49,375 DFW 48,226 DEN 37,536 MSP 26,804 SAN 23,898 SLC 21,279 AUS 15,411 MSY 12,086 SJC 7,205 SMF 3,828 OAK 1,463 Total Connecting O&D Passengers 742,348 American Daytime LAX-HND Service Connecting O&D Delta Daytime LAX-HND Service Connecting O&D American Greater By Passengers Percentage 813, ,348 70, % Sources: OAG Schedules (July 2016); U.S. DOT O&D YE Q Note: Maximum connection time is 4 hours; minimum domestic to domestic connect time is 45 minutes; minimum international to domestic connect time is 75 minutes; circuity less than 150%; minimum of 5x weekly frequencies.

40 American s Proposed Daytime LAX-HND Service Would Connect in Both Directions to 18 Destinations Available to 813,299 Connecting Passengers an Improvement Over American s Current Nighttime LAX-HND Service of 4 Net New Destinations and 190,395 Connecting TYO O&D Passengers Exhibit AA-R-104 Page 1 of 1 American Connections in Both Directions for Its Proposed Daytime LAX-HND Service American Connections in Both Directions for Its Current Nighttime LAX-HND Service Summary: Connections Both Ways: 18 Local O&D Passengers: 237,022 Connecting O&D Passengers: 813,299 Connecting + Local O&D Passengers: 1,050,321 9 new connections versus current American LAX-HND service: MCO, SEA, ATL, ORD, DFW, SLC, AUS, PIT, TUS 5 lost connections versus current LAX-HND service: SMF, RNO, CLT, MIA, LAS Connection TYO O&D SFO 142,941 JFK 117,486 MCO 74,008 SEA 67,500 ATL 54,404 ORD 50,269 PDX 49,375 DFW 48,226 BOS 47,888 DEN 37,536 PHX 25,094 SAN 23,898 SLC 21,279 PHL 17,395 AUS 15,411 PIT 9,289 SJC 7,205 TUS 4,094 Total Connecting O&D Passengers 813,299 Connection TYO O&D SFO 142,941 JFK 117,486 LAS 112,904 PDX 49,375 BOS 47,888 DEN 37,536 MIA 25,368 PHX 25,094 SAN 23,898 PHL 17,395 CLT 9,988 SJC 7,205 SMF 3,828 RNO 1,996 Total Connecting O&D Passengers 622,904 Added Net New Destinations: 4 Added Net New Connecting O&D: 190,395 Sources: OAG Schedules (July 2016); U.S. DOT O&D YE Q Note: Maximum connection time is 4 hours; minimum domestic to domestic connect time is 45 minutes; minimum international to domestic connect time is 75 minutes; circuity less than 150%; minimum of 5x weekly frequencies.

41 American Would Provide Needed Inter-Carrier and Inter-Alliance Competition on the LAX-HND Route In Rebuttal to Delta Application at Pages 15 and 16, and Exhibit DL-112 Exhibit AA-R-105 Page 1 of 1 (Star) Tokyo Haneda (HND) (oneworld) Los Angeles (LAX) (SkyTeam) Without continuation of American s LAX-HND service, there would be no U.S. competitor to Delta and no oneworld presence to compete with Star and SkyTeam

42 American Invested Considerable Resources to Gain Authority to Serve LAX-HND In Rebuttal to Delta Application at Page 18 Exhibit AA-R-106 Page 1 of 1 Chronology October 2014 AA petitions DOT to reallocate Delta s SEA-HND slot pair to AA for LAX-HND service because Delta not flying SEA-HND December 2014 DOT institutes proceeding to consider best allocation of slot pair currently held by Delta for SEA-HND December January 2015 AA shows Delta Seatless in Seattle June 2015 DOT allows Delta to keep SEA-HND route, but imposes conditions requiring Delta to keep its flying commitment AA awarded backup authority June 2015 Delta determines that it cannot honor flying commitment for SEA-HND and returns slot pair to DOT AA backup authority activated October 2015 Delta asks DOT to strip AA of its Haneda authority October 2015 AA finally secures HND slots from Japanese Government and announces start date February 2016 AA begins LAX-HND service

43 Since American Has Gained LAX-HND Authority, It Has Invested Substantial Resources on the Route In Rebuttal to Delta Application at Page 18 Exhibit AA-R-107 Page 1 of 1 Service on the new Boeing Dreamliner

44 American Has Lived Up to Its Commitment to Operate LAX-HND Every Day Since Inauguration of That Service Exhibit AA-R-108 Page 1 of 1 American s Operation of LAX-HND Since Route Inauguration FEBRUARY 11, 2016 START DATE MARCH 2016 APRIL 2016 THROUGH MAY 5, 2016 SUN MON TUE WED THU FRI SAT SUN MON TUE WED THU FRI SAT SUN MON TUE WED THU FRI SAT SUN MON TUE WED THU FRI SAT Daily Service Daily Service Daily Service Daily Service Sources: OAG flight schedules / American Airlines internal data

45 Series 200: American s DFW-HND Service Proposal Maximizes the Public Benefits Far Better Than Any Other Applicant s Proposed Service

46 American s Proposed DFW-HND Service Provides the Most Connectivity of Any HND Service Current or Proposed and More Than 2x the Connectivity of Proposed MSP-HND Service and 4x the Connectivity of United s Proposed EWR-HND Service In Rebuttal to Delta Application at Pages 17, 20 and 22, and United Exhibits UA-106 and UA-107 Exhibit AA-R-201 Page 1 of 1 Comparison of Connections in Both Directions for Proposed U.S.-HND Service 104 2x 4x AA DFW DL ATL DL MSP UA SFO UA EWR AA LAX DL LAX Source: OAG Schedules (July 2016) Note: Maximum connection time is 4 hours; minimum domestic to domestic connect time is 45 minutes; minimum international to domestic connect time is 75 minutes; circuity less than 150%; minimum of 5x weekly frequencies.

47 And, American s Proposed DFW-HND Service Captures the Largest Amount of Local/Connecting U.S.-TYO O&D Traffic of Any Proposed or Current HND Gateway 49% Larger Than Delta s Proposed MSP-HND Gateway and 120% Larger Than United s Proposed EWR-HND Gateway In Rebuttal to Delta Application at Pages 17, 20 and 22, and United Exhibits UA-106 and UA-107 Exhibit AA-R-202 Page 1 of 1 Total Possible O&D Local and Connecting Traffic 1,194,654 1,166,311 AA 49% Larger AA 120% Larger 1,050, , , , ,756 AA DFW UA SFO AA LAX DL ATL DL LAX DL MSP UA EWR (using larger NYC, not EWR, O&D) Sources: OAG Schedules (July 2016); YE Q DOT O&D Note: O&D is at airport level, not by metro area except EWR, where O&D is EWR, JFK, LGA, HPN, and SWF.

48 American s Proposed DFW-HND Service Proposal Is Superior, by Any Measure, to the Other 2nd and 3rd Preference Mainland U.S. Proposals of Other Applicants In Rebuttal to Delta Application at Pages 20 and 22, and United Exhibit UA-107 Exhibit AA-R-203 Page 1 of 1 American s Proposed DFW-HND Service versus Delta s Proposed MSP-HND and ATL-HND and United s Proposed EWR-HND Services DFW-HND MSP-HND ATL-HND EWR-HND (NYC O&D) Connections Both Ways International Connections Unique Connections Connecting and Local O&D 1,194, , , ,756 Sources: OAG Schedules (July 2016); U.S. DOT O&D YE Q Note: Maximum connection time is 4 hours; minimum domestic to domestic connect time is 45 minutes; minimum international to domestic connect time is 75 minutes; circuity less than 150%; minimum of 5x weekly frequencies.

49 American s Proposed DFW-HND Service Would Connect in Both Directions to 104 Destinations Available to 1,194,654 Local and Connecting TYO O&D Passengers Exhibit AA-R-204 Page 1 of 1 American Connections in Both Directions for Its Proposed DFW-HND Service Summary: Connection TYO O&D DCA 12,647 TYS 2,922 SHV 801 MEI 101 Connections Both Ways: 104 JFK 117,486 LAS 112,904 MCO 74,008 MSY 12,086 CVG 11,235 SAT 10,673 GSP 2,850 PBI 2,641 GSO 2,581 CRP 777 FAR 776 FSD 776 BPT 69 CUN YYZ INT L INT L Local O&D Passengers: 48,226 EWR 67,865 DTW 55,424 ATL 54,404 ORD 50,269 TPA 10,001 CLT 9,988 STL 9,350 PIT 9,289 CHS 2,555 HSV 2,457 RSW 2,380 MKE 2,205 SGF 710 TLH 626 HOU 601 LBB 532 YUL MEX BJX CUU INT L INT L INT L INT L Connecting O&D Passengers: 1,146,428 IAH 50,177 IAD 48,817 BOS 47,888 ORF 9,128 FLL 7,722 MCI 7,399 MFE 2,202 DSM 2,142 TUL 2,042 LFT 458 EVV 411 CHA 381 AGU GDL MTY INT L INT L INT L Connecting + Local O&D Passengers: 1,194,654 DEN 37,536 MSP 26,804 MIA 25,368 PHX 25,094 LEX 6,526 MEM 5,471 SDF 4,881 BDL 4,521 PNS 1,965 LIT 1,877 CAE 1,875 SAV 1,865 AEX 292 SPS 262 GRK 261 AMA 233 QRO SLP Total Connecting O&D Passengers INT L INT L 1,146,428 CMH 22,030 TUS 4,094 BTR 1,706 ABI 196 SLC 21,279 ELP 3,758 COS 1,616 COU 167 BNA 19,770 OKC 3,714 CID 1,554 BRO 157 PHL 17,395 RIC 3,545 XNA 1,478 BMI 148 AUS 15,411 OMA 3,486 ICT 1,452 JLN 134 LGA 14,673 ABQ 3,400 FWA 1,099 BIS 119 IND 14,439 BHM 3,198 VPS 1,022 TXK 118 RDU 13,618 JAN 2,954 GPT 998 GRI 109 Sources: OAG Schedules (July 2016); U.S. DOT O&D YE Q Note: Maximum connection time is 4 hours; minimum domestic to domestic connect time is 45 minutes; minimum international to domestic connect time is 75 minutes; circuity less than 150%; minimum of 5x weekly frequencies.

50 Delta s Proposed MSP-HND Service Would Connect in Both Directions to 49 Destinations (Less Than Half of American s Proposed DFW-HND Service) Available to 801,017 Local and Connecting TYO O&D Passengers (33% Less Than American s Proposed DFW-HND Service) In Rebuttal to Delta Application at Page 20, and Exhibit DL-201 Exhibit AA-R-205 Page 1 of 1 Delta Connections in Both Directions for Its Proposed MSP-HND Service Summary: Connection TYO O&D CLE 8,804 MDW 292 Connections Both Ways: 49 JFK 117,486 EWR 67,865 DTW 55,424 MCI 7,399 DAY 6,406 BDL 4,521 BIS 119 YUL YWG INT L INT L Local O&D Passengers: 26,804 ATL 54,404 ORD 50,269 IAH 50,177 DFW 48,226 RIC 3,545 OMA 3,486 GRR 3,278 MSN 2,406 Total Connecting O&D Passengers 774,213 Connecting O&D Passengers: 774,213 BOS 47,888 DEN 37,536 CMH 22,030 SLC 21,279 MKE 2,205 DSM 2,142 CID 1,554 LNK 918 Connecting + Local O&D Passengers: 801,017 BNA 19,770 PHL 17,395 AUS 15,411 LGA 14,673 RAP 908 FAR 776 FSD 776 GRB 671 IND 14,439 ATW 635 RDU 13,618 MLI 616 DCA 12,647 LAN 612 CVG 11,235 DLH 441 BWI 10,195 GFK 402 STL 9,350 TVC 392 PIT 9,289 MOT 300 Sources: OAG Schedules (July 2016); U.S. DOT O&D YE Q Note: Maximum connection time is 4 hours; minimum domestic to domestic connect time is 45 minutes; minimum international to domestic connect time is 75 minutes; circuity less than 150%; minimum of 5x weekly frequencies.

51 Delta s Proposed ATL-HND Service Would Connect in Both Directions to 89 Destinations (17% Less Than American s Proposed DFW-HND Service) Available to 995,422 Local and Connecting TYO O&D Passengers (17% Less Than American s Proposed DFW-HND Service) In Rebuttal to Delta Application at Page 23, and Exhibit DL-401 Exhibit AA-R-206 Page 1 of 1 Delta Connections in Both Directions for Its Proposed ATL-HND Service Summary: Connection TYO O&D TPA 10,001 CHS 2,555 AVL 638 Connections Both Ways: 89 JFK 117,486 MCO 74,008 EWR 67,865 CLT 9,988 STL 9,350 PIT 9,289 HSV 2,457 RSW 2,380 PNS 1,965 TLH 626 HOU 601 ECP 582 Local O&D Passengers: 54,404 DTW 55,424 ORD 50,269 IAH 50,177 IAD 48,817 ORF 9,128 CLE 8,804 FLL 7,722 MCI 7,399 LIT 1,877 CAE 1,875 SAV 1,865 BTR 1,706 GNV 538 MGM 535 ABE 467 MYR 422 Connecting O&D Passengers: 941,018 DFW 48,226 BOS 47,888 MSP 26,804 MIA 25,368 LEX 6,526 MEM 5,471 JAX 5,213 SDF 4,881 BTV 1,626 XNA 1,478 MOB 1,246 ROA 1,204 CHO 401 CHA 381 DAB 344 MLU 295 Connecting + Local O&D Passengers: 995,422 CMH 22,030 BNA 19,770 PHL 17,395 LGA 14,673 BDL 4,521 ALB 4,451 OKC 3,714 RIC 3,545 FWA 1,099 VPS 1,022 CRW 977 SRQ 966 AEX 292 MDW 292 SBN 283 HPN 213 IND 14,439 OMA 3,486 LNK 918 MLB 205 RDU 13,618 BHM 3,198 SHV 801 EYW 181 DCA 12,647 JAN 2,954 GTR 795 DHN 173 MSY 12,086 TYS 2,922 AGS 791 YYZ INT L CVG 11,235 GSP 2,850 TRI 778 LIM INT L SAT 10,673 BWI 10,195 PBI 2,641 GSO 2,581 ILM 730 SGF 710 Total Connecting O&D Passengers 941,018 Sources: OAG Schedules (July 2016); U.S. DOT O&D YE Q Note: Maximum connection time is 4 hours; minimum domestic to domestic connect time is 45 minutes; minimum international to domestic connect time is 75 minutes; circuity less than 150%; minimum of 5x weekly frequencies.

52 United s Proposed EWR-HND Service Would Connect in Both Directions to 24 Destinations (77% Less Than American s Proposed DFW-HND Service) Available to 542,755 Local and Connecting TYO O&D Passengers (55% Less Than American s Proposed DFW-HND Service) In Rebuttal to United Exhibit UA-107 Exhibit AA-R-207 Page 1 of 1 United Connections in Both Directions for Its Proposed EWR-HND Service Summary: Connection TYO O&D YYZ INT L Connections Both Ways: 24 ATL 54,404 ORD 50,269 IAD 48,817 YUL Total Connecting O&D Passengers INT L 342,425 Local O&D Passengers (includes metro NYC): 200,330 BOS 47,888 CMH 22,030 IND 14,439 RDU 13,618 DCA 12,647 Connecting O&D Passengers: 342,425 CVG 11,235 BWI 10,195 TPA 10,001 PIT 9,289 Connecting + Local O&D Passengers: 542,755 ORF 9,128 CLE 8,804 RIC 3,545 BUF 3,522 GSP 2,850 PBI 2,641 ROC 2,296 DSM 2,142 SAV 1,865 CAK 800 Sources: OAG Schedules (July 2016); U.S. DOT O&D YE Q Note: Maximum connection time is 4 hours; minimum domestic to domestic connect time is 45 minutes; minimum international to domestic connect time is 75 minutes; circuity less than 150%; minimum of 5x weekly frequencies.

53 Series 300: American s DFW Hub Is Larger and More Comprehensive Than Delta s MSP Hub American Has Committed to Growing DFW, While Delta s Growth at MSP Has Been Stagnant, at Best

54 In Every Measure, American s DFW Hub Provides Larger and More Comprehensive Coverage Than Delta s MSP Hub Exhibit AA-R-301 Page 1 of 1 Network Comparison AA-DFW vs. DL-MSP Number of Destinations Weekly Departure Flights Weekly Departure Seats AA-DFW DL-MSP AA-DFW DL-MSP AA-DFW DL-MSP Domestic ,975 2, , ,464 International ,797 28,543 AA-DFW Greater Than DL-MSP Total ,513 3, , , % +82% +89% Source: Innovata Schedules Data (Jul-16)

55 American s Proposed DFW-HND Service Would Benefit Passengers in More States Than Delta s Proposed MSP-HND Service In Rebuttal to Delta Exhibits DL-301 Exhibit AA-R-302 Page 1 of 2 American Delta DFW Domestic Connections: 93 States: 34 ATL Domestic Connections: 47 States: 23 Source: OAG Schedules (July 2016) Note: Maximum connection time is 4 hours; minimum domestic to domestic connect time is 45 minutes; minimum international to domestic connect time is 75 minutes; circuity less than 150%; minimum of 5x weekly frequencies.

56 America s Proposed DFW-HND Service Would Benefit Passengers in More States Than Delta s Proposed MSP-HND Service In Rebuttal to Delta Exhibits DL-301 Exhibit AA-R-302 Page 2 of 2 Comparison of Connections in Both Directions of Proposed Services DFW MSP Number of Points Number of States (excluding Gateway State) States with Connections in Both Directions Alabama Arizona Arkansas Colorado Connecticut Florida Georgia Illinois Indiana Iowa Kansas Kentucky Louisiana Massachusetts Michigan Minnesota Mississippi Missouri Nebraska Nevada New Mexico New York N. Carolina N. Dakota Ohio Oklahoma Pennsylvania Ohio Oklahoma Pennsylvania S. Carolina S. Dakota Tennessee Texas Utah Virginia Wisconsin Colorado Connecticut Georgia Illinois Indiana Iowa Maryland Massachusetts Michigan Minnesota Missouri Nebraska New York N. Carolina N. Dakota Ohio Pennsylvania S. Dakota Tennessee Texas Utah Virginia Wisconsin Source: OAG Schedules (July 2016) Note: Maximum connection time is 4 hours; minimum domestic to domestic connect time is 45 minutes; minimum international to domestic connect time is 75 minutes; circuity less than 150%; minimum of 5x weekly frequencies.

57 In the Past 5 Years, American Has Increased Its Capacity at DFW, While Delta Has Decreased Capacity at MSP Exhibit AA-R-303 Page 1 of Total Seat Capacity AA-DFW vs. DL-MSP Millions Source: U.S. DOT T-100 (YE October each year) AA-DFW DL-MSP

58 Between 2011 and 2015, American Increased Its International Seats at DFW by 27%, But Delta Reduced Its International Seats at MSP Exhibit AA-R-304 Page 1 of 1 International Seat Capacity AA-DFW vs. DL-MSP AA-DFW +26.7% Millions 5 4 DL-MSP - 4.4% Source: U.S. DOT T-100 (YE October each year) AA-DFW DL-MSP

59 American Has Increased Its Domestic Seats at DFW, While Delta Has Reduced Its Domestic Seats at MSP Exhibit AA-R-305 Page 1 of 1 Domestic Seat Capacity AA-DFW vs. DL-MSP Millions Source: U.S. DOT T-100 (YE October each year) AA-DFW DL-MSP

60 Between 2011 and 2015, American s Passenger Traffic Growth at DFW Has Grown by Close to 10%, While Delta s Traffic Has Barely Changed at MSP Exhibit AA-R-306 Page 1 of 1 Total Passengers AA-DFW vs. DL-MSP Millions Source: U.S. DOT T-100 (YE October each year) AA-DFW DL-MSP

61 American s DFW International Passengers Are Almost 3x the Number of Delta s at MSP, with Much Higher DFW Growth Than MSP Exhibit AA-R-307 Page 1 of International Passengers AA-DFW vs. DL-MSP AA-DFW +32.3% 5.9 Millions DL-MSP +4.1% 1 0 Source: U.S. DOT T-100 (YE October each year) AA-DFW DL-MSP

62 In 2015, American Carried Almost Twice the Number of Domestic Passengers at DFW as Delta Did at MSP Exhibit AA-R-308 Page 1 of 1 Domestic Passengers AA-DFW vs. DL-MSP Millions Source: U.S. DOT T-100 (YE October each year) AA-DFW DL-MSP

63 By Any Metric, American at DFW Has Outperformed Delta at MSP by a Wide Margin Exhibit AA-R-309 Page 1 of Change ( ) Total Seats International Seats Domestic Seats AA-DFW 59,916,365 58,745,594 59,874,602 60,632,172 63,188, % DL-MSP 31,073,776 30,119,100 30,090,430 30,117,622 30,496, % AA-DFW 5,908,151 5,975,242 6,490,660 7,101,898 7,484, % DL-MSP 2,585,118 2,375,095 2,329,827 2,384,387 2,470, % AA-DFW 54,008,214 52,770,352 53,383,942 53,530,274 55,703, % DL-MSP 28,488,658 27,744,005 27,760,603 27,733,235 28,025, % Total Passengers International Passengers Domestic Passengers AA-DFW 47,385,157 47,262,780 48,294,666 50,237,636 52,340, % DL-MSP 24,758,530 24,564,027 24,425,919 25,213,707 25,623, % AA-DFW 4,467,357 4,648,349 5,093,701 5,485,359 5,910, % DL-MSP 2,018,810 1,934,250 1,955,584 2,009,496 2,101, % AA-DFW 42,917,800 42,614,431 43,200,965 44,752,277 46,430, % DL-MSP 22,739,720 22,629,777 22,470,335 23,204,211 23,521, % Source: U.S. DOT T-100 (YE October each year)

64 American Has Introduced 14 New International Services at DFW Since July Year-Round and Three That Operate 10 Months a Year Exhibit AA-R-310 Page 1 of 1 New International Services at DFW by AA July 2011 vs. July 2016 Beijing Shanghai Seoul Dallas/Fort Worth (DFW) Hong Kong Zacatecas Puebla Merida Roatan* Managua* Punta Cana Grand Cayman* Bogota Quito Lima Source: Innovata Schedules data * Do not operate in September and October.

65 While Delta Has Added Only Two New International Services from MSP in That Same Time Period... and Both Are Seasonal Services Only Exhibit AA-R-311 Page 1 of 1 New International Services at MSP by DL July 2011 vs. July 2016 Reykjavik* Minneapolis/St. Paul (MSP) Rome ** Source: Innovata Schedules data * Operates 5 months (May-September). ** Operates 4 months (June-September and one flight in October).

66 Series 400: Delta Has Grown and Continues to Grow Its SEA Hub, While It Shrinks and De-Emphasizes MSP

67 If Delta Could Not Make SEA-HND Work, How Can It Possibly Make MSP-HND Work? Delta failed to make SEA-HND work (the only West Coast-HND service to fail) Delta s Asian network at MSP is smaller than its SEA Asian network Delta has grown and continues to grow at SEA, while Delta continues to shrink MSP, both domestically and internationally Delta has actively promoted the shift of its Asia-bound traffic away from MSP and to SEA Exhibit AA-R-401 Page 1 of 1 So, if SEA-HND failed, and since its failure, Delta has built up SEA considerably (and at MSP s expense), there is little likelihood that MSP-HND will succeed

68 Since 2010, Delta Has Actively Promoted the Shift of Its MSP-Originating Asia Passengers to Its SEA Hub Exhibit AA-R-402 Page 1 of 2 MSP-Originated Passenger Traffic to Asia Route: DL MSP-NRT Traffic Segment: MSP-NRT Beyond Route: DL SEA-Asia Traffic Segment: MSP-Seattle-Asia Total 23,983 21,249 23,481 17,805 10,070 8,133 4,212 8,132 7,672 9,517 16,490 19,466 NRT ,217 1,053 1,386 1, ,411 PEK 5,687 4,407 3,460 3, ,826 6,331 5,411 4,643 5,465 4,583 PVG 6,720 6,342 7,918 6,753 6,373 5, ,309 3,629 2,421 HKG 6,545 5,721 7,263 6,375 2,120 1, ,268 4,284 7,433 ICN 5,031 4,779 4,840 1, ,289 3,618 Change (10-15) -15, ,254 Source: US DOT Segment O&D Note: SEA includes PEK, ICN, PVG, NRT and HKG, MSP includes NRT.

69 Since 2010, Delta Has Actively Promoted the Shift of Its MSP-Originating Asia Passengers to Its SEA Hub Exhibit AA-R-402 Page 2 of 2 MSP-Originated Passenger Traffic to Asia 25,000 23,983 20,000 19,466 15,000 15,254 10,000 8,133 5,000 4, ,000-10,000-15,000-20,000 (15,850) Change (10-15) SEA MSP Source: US DOT Segment O&D Note: SEA includes PEK, ICN, PVG, NRT and HKG, MSP includes NRT.

70 Since 2011, Delta Has Nearly Quadrupled Its Domestic Capacity at SEA, While Decreasing MSP Capacity by 12% Exhibit AA-R-403 Page 1 of 1 DL Domestic Weekly Frequency at MSP vs. SEA (July 2011 = 100) Source: Innovata Schedules data Jul-11 Jul-12 Jul-13 Jul-14 Jul-15 Jul-16 MSP SEA

71 Since 2011, Delta Has Dropped 10 Domestic Destinations at MSP, But Added 24 New Destinations at SEA Exhibit AA-R-404 Page 1 of 1 DL Domestic Destinations MSP vs. SEA Jul-11 Jul-12 Jul-13 Jul-14 Jul-15 Jul-16 Change MSP SEA Source: Innovata Schedules data

72 Since 2011, Delta Has Added Only Two New International Services from MSP, But, at SEA, Delta Has Added 9 New International Services Exhibit AA-R-405 Page 1 of 1 New DL International Services at MSP July 2011 vs. July 2016 Reykjavik* Minneapolis/St. Paul (MSP) Rome ** New DL International Services at SEA July 2011 vs. July 2016 Edmonton London Vancouver Calgary Toronto Paris Seoul Seattle (SEA) Shanghai Hong Kong Source: Innovata Schedules data * Operates 5 months (May-September). ** Operates 4 months (June-September and one flight in October).

73 Since 2010, Delta Has Increased Its Asia-Bound Passenger Traffic at SEA by 208%, While MSP Has Experienced a 32% Loss of Its Asia-Bound Passengers Exhibit AA-R-406 Page 1 of 1 700,000 DL Total Segment O&D Passengers on Asian Routes From MSP vs. SEA 674, % 600, , , , , , , , ,072-32% Source: US DOT Segment O&D Note: SEA includes PEK, ICN, PVG, NRT and HKG, MSP includes NRT. SEA MSP

74 Delta s SEA Asia-Bound Connecting Traffic Has Quintupled in Just Six Years, While MSP Has Lost 37% of Its Asia-Bound Connecting Traffic Exhibit AA-R-407 Page 1 of 1 DL Total Behind Gateways + Bridge Traffic on Asian Routes From MSP vs. SEA 450, , , % 350, , , , , , ,000 50,000 84, ,517-37% Source: US DOT Segment O&D Note: SEA includes PEK, ICN, PVG, NRT and HKG, MSP includes NRT. MSP SEA

75 Delta s U.S.-Asia Bridge Traffic Through SEA Has Tripled in the Last Six Years, While MSP s U.S.-Asia Bridge Traffic Has Declined by 45% Exhibit AA-R-408 Page 1 of 2 400,000 Bridge Traffic Through MSP vs. SEA United States-Asia 350, , , , , ,000 50, SEA MSP Source: US DOT Segment O&D Note: SEA includes PEK, ICN, PVG, NRT and HKG, MSP includes NRT.

76 Delta s U.S.-Asia Bridge Traffic Through SEA Has Tripled in the Last Six Years, While MSP s U.S.-Asia Bridge Traffic Has Declined by 45% Exhibit AA-R-408 Page 2 of 2 120, , ,592 Bridge Traffic Through MSP vs. SEA United States-Asia 80,000 60,000 40,000 20,000 24,863 69,715 56,877 44, ,000-40,000-60,000 (46,715) Change (10-15) SEA MSP Source: US DOT Segment O&D Note: SEA includes PEK, ICN, PVG, NRT and HKG, MSP includes NRT.

77 Series 500: As Part of Its Unsuccessful Efforts to Derail the U.S.-Japan Liberalization Talks, Delta Claimed New Haneda Service Would Mean the End of Many of Its Narita Services

78 In an Effort to Scupper U.S.-Japan Aviation Liberalization Negotiations, Delta Mounted an All-Out Campaign to Create Political and Media Pressure, Claiming Incremental Liberalization Would Result in Termination of Its MSP/ATL/DTW/PDX-NRT Services Exhibit AA-R-501 Page 1 of 1 Interviews with newspapers in Portland Presentation to MSP Airport Interviews with newspapers in Detroit Interviews with newspapers in Atlanta Interviews with newspapers in Minneapolis- St. Paul Press Release Claims of The Sky Is Falling! to Congressional Delegations of MN, GA, MI, OR and WA

79 [Opening Haneda] Would Kill the Only Non-Stop from Minnesota to Asia Exhibit AA-R-502 Page 1 of 1

80 Delta Says Deal Would Kill Direct Flights From MSP to Tokyo Exhibit AA-R-503 Page 1 of 1

81 Delta Says Tokyo Hub, Including Minnesota s Only Nonstop Flight to Asia, Is at Risk Exhibit AA-R-504 Page 1 of 1

82 Delta: Japan Deal Threatens Asian Flights Exhibit AA-R-505 Page 1 of 1 Atlanta Journal Constitution, 12:00 a.m. Friday, Jan. 22, 2016

83 Treaty Talks Imperil Delta Detroit-Tokyo Flights Exhibit AA-R-506 Page 1 of 1

84 Delta Threatens to Pull Out [of Portland] Exhibit AA-R-507 Page 1 of 1 February 06, 2016 at 3:00 PM, updated February 07, 2016 at 11:40 AM

85 U.S., Japan Talks Risk Delta Flights to Tokyo-Narita Exhibit AA-R-508 Page 1 of 1 By Kate Modolo posted Jan. 22, 2016 Updated on Jan. 25, 2016

86 Commercial Impacts [of the Deal] are Imminent Exhibit AA-R-509 Page 1 of 1 Posted Feb. 18, 2016

87 Series 600: Delta s Proposed MSP-HND Service Will, by Delta s Own Admission, Mean the End of MSP-NRT Service, Resulting in a Net Loss of Benefits for Passengers Using MSP

88 Delta Has Conceded That the MSP-NRT Route (and Others) Will Be Doomed as U.S.-Haneda Services Expand. While This May Be True Regardless of HND Awards, It Is Certainly True If Delta Is Awarded MSP-HND Service Exhibit AA-R-601 Page 1 of 1 With expanded access to Haneda, Delta expects that Haneda growth will reduce demand for Narita. Delta Application, page 12 SOURCE: Delta s Tokyo Narita operations, including LAX-NRT and MSP-NRT, will soon be affected as service to Haneda expands. Delta Application, page 12 Delta s current projections showing increasing passenger demand for service to Haneda Airport suggest that NRT service from MSP will not be sustainable. Delta Application, page 19 Delta projects that demand for its LAX-HND service will continue to grow as Delta offers convenient daytime services, even as LAX-NRT becomes unsustainable in the near future given increased Haneda flying. Delta Application, page 18

89 Unlike Larger Markets Such as LAX, DFW, and SFO, MSP Cannot Sustain Two Tokyo Services One to HND and One to NRT In Rebuttal to Delta Application at Page 19, and Delta Exhibit DL-303 Exhibit AA-R-602 Page 1 of 3 The MSP-TYO O&D is tiny 25 Local MSP-TYO passengers per day [Delta Special Counsel Ben] Hirst said of the 250 travelers flying between Tokyo and Minneapolis daily, about 10 percent are flying to or from MSP, the rest are connecting to other airports. MPR News, January 19,

90 Unlike Larger Markets Such as LAX, DFW, and SFO, MSP Cannot Sustain Two Tokyo Services One to HND and One to NRT In Rebuttal to Delta Application at Pages 12 and Exhibit AA-R-602 Page 2 of 3 Passenger Distribution on Delta s Current MSP-NRT Flight Only 37% of the passengers are MSP-originating passengers 65% of the passengers are not even destined for TYO, but are going beyond TYO Narita to other destinations LOCAL MSP-TYO 10% 15,681 pax CONNECTING Behind MSP TYO 25% 40,422 pax CONNECTING MSP Beyond TYO 27% 43,874 pax BRIDGE TRAFFIC Behind MSP Beyond TYO 38% 60,095 pax Only 10% of the passengers are Local MSP-TYO passengers Only 35% of the passengers are destined for TYO Source: U.S. DOT Segment O&D Data (Full-year 2015)

91 Unlike Larger Markets Such as LAX, DFW, and SFO, MSP Cannot Sustain Two Tokyo Services One to HND and One to NRT In Rebuttal to Delta Application at Pages 12 and Exhibit AA-R-602 Page 3 of 3 60,000 60,095 50,000 40,000 40,422 43,874 30,000 20,000 15,681 10,000 0 Local Traffic Connecting Behind MSP-TYO Connecting MSP-Beyond TYO Bridge Traffic Source: U.S. DOT Segment O&D Data (Full-year 2015)

92 If Delta Is Awarded MSP-HND Authority, It Is Likely to Experience a Load Factor of Less Than 50% on that Route, and the Continuation of MSP-NRT with No Local TYO Traffic Will Not Be Viable Either as Delta Itself Admits Exhibit AA-R-603 Page 1 of 2 MSP-NRT and MSP-HND Forecast MSP-TYO Local Behind MSP- TYO MSP- Beyond TYO Current DL MSP-NRT Organic Growth Rate DL Market Share Forecast DL MSP-TYO Distribution Between NRT and HND Forecast MSP-NRT MSP-HND MSP-NRT MSP-HND 15, % 85.0% 23,194 0% 100% - 23,194 40, % 3.0% 62,813 0% 100% - 62,813 43,874 67,141 91% 9% 61,015 6,126 Japan 2, % 19.3% 4,527 10% 90% 453 4,074 DL 5th Freedom 28,246 42, % 0% 42,091 - Other 12,785 20,523 90% 10% 18,471 2,052 Bridge 60,095 88,767 94% 6% 83,059 5,708 Japan 3,408 4,909 10% 90% 491 4, % 0.7% DL 5th Freedom 46,472 70, % 0% 70,959 - Other 10,215 12,900 90% 10% 11,610 1,290 Total Segment O&D Passengers 160, , ,074 97,841 Route Load Factor 67.8% 46.1% MSP-HND Flight Would Require Unattainable Stimulation Just to Reach Load Factors 10% Below Current MSP-NRT Load Factor To reach Load Factor Stimulation Required 70% 219% 75% 265% 80% 311% Current MSP-NRT Load Factor: 87.8% Sources: U.S. DOT Segment O&D data; American analysis Notes: 1/ Growth rate based on historical CAGR (10-15) (U.S. DOT O&D data); 2/ Markets with negative growth rate is assumed to maintain current market size.

93 If Delta Is Awarded MSP-HND Authority, It Is Likely to Experience a Load Factor of Less Than 50% on that Route, and the Continuation of MSP-NRT with No Local TYO Traffic Will Not Be Viable Either as Delta Itself Admits Exhibit AA-R-603 Page 2 of 2 Assumptions traffic as basis A Forecast of Parallel MSP-HND and MSP-NRT Routes 2. Organic market growth rate Local MSP-TYO: 1.2% Behind MSP-TYO: 5.2% MSP-Beyond TYO: 4.4% Bridge: 3.7% 3. Increase of Delta market share by 50% (capped at 85%) 4. B777 for each flight (DL current MSP-NRT aircraft and proposed MSP-HND aircraft) 5. Distribution of traffic between MSP-HND and MSP-NRT flights Local MSP-TYO: 100% to MSP-HND Behind MSP-TYO: 100% to MSP-HND MSP-Beyond TYO o o o To Japan domestic: 10% to MSP-NRT, 90% to MSP-HND To destinations operated by Delta beyond NRT: 100% to MSP-NRT To other destinations beyond NRT: 90% to MSP-NRT, 10% to MSP-HND Not Included in Assumptions (all exclusions benefit DL and MSP-NRT forecast) New services between U.S. Mainland and Haneda No new U.S. carrier U.S. Mainland and Haneda No new Japanese carrier services (even though ANA awarded both of the 2 new HND slot pairs and the right to move existing 2 HND slot pairs from nighttime to daytime), and: o ANA has said it will start JFK-HND o ANA likely start ORD-HND (Delta s own view) No new nonstop services in Delta-operated beyond markets (MNL, PVG, TPE, SIN, BKK) even though new services have been started or announced that will compete for the MSP-Beyond TYO and Bridge Traffic MU PVG-ORD Started in Apr-16 UA SIN-SFO Starting in Jun-16

94 Awarding Delta MSP-HND Means That Delta s MSP-NRT Service, in Delta s Words, Will Not Be Sustainable, and the Twin Cities Communities Will Lose Its One-Stop Connections Over NRT In Rebuttal to Delta Application at Page 19 Exhibit AA-R-604 Page 1 of 1 Minneapolis/St. Paul Shanghai (5,946) Tokyo Narita Taipei (5,324) Almost 35,000 Twin Cities passengers will lose one-stop service beyond NRT to 6 Asia destinations if Delta is awarded MSP-HND Bangkok (2,691) Singapore (6,785) Ho Chi Minh City* (7,912) Manila (6,264) *On Delta s SkyTeam Partner, Vietnam Airlines Source: U.S. DOT Segment O&D (2015) Note: Figures in the parentheses represent O&D passengers to/from MSP on Delta s MSP-NRT service.

95 Series 700: United s Proposed EWR-HND Service, in Addition to Providing Inferior Connectivity to American s Proposed DFW-HND Service, Also Would Duplicate Upcoming JFK-HND Service of United s Star Alliance Partner, ANA

96 America s Proposed DFW-HND Service Would Benefit Passengers in More States Than United s Proposed EWR-HND Service In Rebuttal to United Exhibits Exhibit AA-R-701 Page 1 of 2 American United DFW Domestic Connections: 93 States: 34 EWR Domestic Connections: 22 States: 13 Source: OAG Schedules (July 2016) Note: Maximum connection time is 4 hours; minimum domestic to domestic connect time is 45 minutes; minimum international to domestic connect time is 75 minutes; circuity less than 150%; minimum of 5x weekly frequencies.

97 America s Proposed DFW-HND Service Would Benefit Passengers in More States Than United s Proposed EWR-HND Service In Rebuttal to United Exhibits Exhibit AA-R-701 Page 2 of 2 Comparison of Connections in Both Directions of Proposed Services DFW EWR Number of Points Number of States (excluding Gateway State) States with Connections in Both Directions Alabama Arizona Arkansas Colorado Connecticut Florida Georgia Illinois Indiana Iowa Kansas Kentucky Louisiana Massachusetts Michigan Minnesota Mississippi Missouri Nebraska Nevada New Mexico New York N. Carolina N. Dakota Ohio Oklahoma Pennsylvania Ohio Oklahoma Pennsylvania S. Carolina S. Dakota Tennessee Texas Utah Virginia Wisconsin Florida Georgia Illinois Indiana Iowa Maryland Massachusetts New York N. Carolina Ohio Pennsylvania S. Carolina Virginia Source: OAG Schedules (July 2016) Note: Maximum connection time is 4 hours; minimum domestic to domestic connect time is 45 minutes; minimum international to domestic connect time is 75 minutes; circuity less than 150%; minimum of 5x weekly frequencies.

98 American s Proposed DFW-HND Service Would Connect in Both Directions to 104 Destinations Available to 1,194,654 Local and Connecting TYO O&D Passengers In Rebuttal to United Application at Pages 5 and 8-9 Exhibit AA-R-702 Page 1 of 1 American Connections in Both Directions for Its Proposed DFW-HND Service Summary: Connection TYO O&D DCA 12,647 TYS 2,922 SHV 801 MEI 101 Connections Both Ways: 104 JFK 117,486 LAS 112,904 MCO 74,008 MSY 12,086 CVG 11,235 SAT 10,673 GSP 2,850 PBI 2,641 GSO 2,581 CRP 777 FAR 776 FSD 776 BPT 69 CUN YYZ INT L INT L Local O&D Passengers: 48,226 EWR 67,865 DTW 55,424 ATL 54,404 TPA 10,001 CLT 9,988 STL 9,350 CHS 2,555 HSV 2,457 RSW 2,380 SGF 710 TLH 626 HOU 601 YUL MEX BJX INT L INT L INT L ORD 50,269 PIT 9,289 MKE 2,205 LBB 532 CUU INT L Connecting O&D Passengers: 1,146,428 IAH 50,177 IAD 48,817 BOS 47,888 ORF 9,128 FLL 7,722 MCI 7,399 MFE 2,202 DSM 2,142 TUL 2,042 LFT 458 EVV 411 CHA 381 AGU GDL MTY INT L INT L INT L Connecting + Local O&D Passengers: 1,194,654 DEN 37,536 MSP 26,804 MIA 25,368 PHX 25,094 LEX 6,526 MEM 5,471 SDF 4,881 BDL 4,521 PNS 1,965 LIT 1,877 CAE 1,875 SAV 1,865 AEX 292 SPS 262 GRK 261 AMA 233 QRO SLP Total Connecting O&D Passengers INT L INT L 1,146,428 CMH 22,030 TUS 4,094 BTR 1,706 ABI 196 SLC 21,279 ELP 3,758 COS 1,616 COU 167 BNA 19,770 OKC 3,714 CID 1,554 BRO 157 PHL 17,395 RIC 3,545 XNA 1,478 BMI 148 AUS 15,411 OMA 3,486 ICT 1,452 JLN 134 LGA 14,673 ABQ 3,400 FWA 1,099 BIS 119 IND 14,439 BHM 3,198 VPS 1,022 TXK 118 RDU 13,618 JAN 2,954 GPT 998 GRI 109 Sources: OAG Schedules (July 2016); U.S. DOT O&D YE Q Note: Maximum connection time is 4 hours; minimum domestic to domestic connect time is 45 minutes; minimum international to domestic connect time is 75 minutes; circuity less than 150%; minimum of 5x weekly frequencies.

99 United s Proposed EWR-HND Service Would Connect in Both Directions to 24 Destinations (77% Less Than American s Proposed DFW-HND Service) Available to Only 542,756 Local and Connecting TYO O&D Passengers (55% Less Than American s Proposed DFW-HND Service) In Rebuttal to United Application at Pages 5 and 8-9, and United Exhibits UA Exhibit AA-R-703 Page 1 of 1 United Connections in Both Directions for Its Proposed EWR-HND Service Summary: Connection TYO O&D YYZ INT L Connections Both Ways: 24 ATL 54,404 ORD 50,269 IAD 48,817 YUL Total Connecting O&D Passengers INT L 342,425 Local O&D Passengers (includes metro NYC): 200,330 BOS 47,888 CMH 22,030 IND 14,439 RDU 13,618 DCA 12,647 Connecting O&D Passengers: 342,425 CVG 11,235 BWI 10,195 TPA 10,001 PIT 9,289 Connecting + Local O&D Passengers: 542,756 ORF 9,128 CLE 8,804 RIC 3,545 BUF 3,522 GSP 2,850 PBI 2,641 ROC 2,296 DSM 2,142 SAV 1,865 CAK 800 Sources: OAG Schedules (July 2016); U.S. DOT O&D YE Q Note: Maximum connection time is 4 hours; minimum domestic to domestic connect time is 45 minutes; minimum international to domestic connect time is 75 minutes; circuity less than 150%; minimum of 5x weekly frequencies.

100 ANA Has Stated It Would Fly HND-JFK If It Were Awarded One of the New Japanese U.S.-HND Slot Pairs. ANA Received All Japanese U.S.-HND Slot Pairs (JAL Received None) ANA Will Be Flying NY-HND In Rebuttal to United Application at Pages 5-6 and 8-9 Exhibit AA-R-704 Page 1 of 1 Almost Certain Scenario If UA Awarded EWR-HND Service PLUS: UA Would Codeshare on ANA s JFK-HND Service NH NH/UA* HND NH JFK HND NH/UA* JFK NRT UA EWR NRT UA/NH* EWR UA 4 TYO-NY Daily Flights 2 by NH, 2 by UA JFK, EWR UA/NH* 4 TYO-NY Daily Flights By UA and NH (2 Operated, 2 Marketing by Each Carrier)

101 Series 800: Delta s Repetitive Assertions About Being Disadvantaged in Japan Are Belied by the Facts. To the Contrary, American Remains Significantly Hamstrung in the U.S.-Japan and the U.S.-Northeast Asia Markets Compared to Both Delta and United

102 The Facts Show Clearly That Delta Is Not Disadvantaged in Japan

103 United and Delta Have a Collarhold on U.S.-Japan Traffic and Have So for Decades In Rebuttal to Delta Application at Pages 4-5 and 16, and Delta Exhibits DL-111 and DL-112 Exhibit AA-R-801 Page 1 of 2 Onboard Passenger Traffic by U.S. Carriers Japan-U.S. 4,500,000 4,000,000 3,500,000 3,000,000 2,500,000 2,000,000 1,500,000 1,000, , UA DL AA Source: U.S. DOT T-100 data Note: In this Series 800, UA includes CO and DL includes NW.

104 United and Delta Have a Collarhold on U.S.-Japan Traffic and Have So for Decades In Rebuttal to Delta Application at Pages 4-5 and 16, and Delta Exhibits DL-111 and DL-112 Exhibit AA-R-801 Page 2 of 2 Onboard Passenger Traffic by U.S. Carriers Japan-U.S. AA UA DL % AA smaller than average of UA and DL ,180 2,938,178 4,097,986-81% ,014 2,651,488 3,464,427-81% ,165 2,732,511 3,356,642-83% ,615 2,631,402 3,083,093-82% ,371 3,059,776 3,549,087-79% ,745 3,262,759 3,743,697-75% ,372 3,264,713 3,858,963-74% ,154 3,057,442 3,807,685-79% ,020 2,572,210 3,783,120-77% ,655 2,365,718 3,243,410-75% ,791 2,551,372 3,566,343-76% ,037 2,406,607 3,415,526-76% ,604 2,638,773 3,684,351-77% ,654 2,644,403 3,541,582-78% ,806 2,646,159 3,189,119-81% Source: U.S. DOT T-100 data Note: In this Series 800, UA includes CO and DL includes NW.

105 Even Combined with JAL, American s Presence in the Japan-U.S. Market Is Smaller Than Delta s and United/ANA s (and United s/united+ana s) In Rebuttal to Delta Application at Pages 4-5 and 16, and Delta Exhibits DL-111 and DL-112 Exhibit AA-R-802 Page 1 of 2 Onboard Passenger Traffic by U.S. Carriers/Japanese Partners Japan-U.S. AA+JL vs. DL AA+JL vs. to UA and UA+NH 4,500,000 4,000,000 4,500,000 4,000, ,500,000 3,500,000 3,000,000 3,000,000 2,500,000 2,500,000 2,000, ,000, ,500,000 1,500,000 1,000,000 1,000, , , Source: U.S. DOT T-100

106 Even Combined with JAL, American s Presence in the Japan-U.S. Market Is Smaller Than Delta s and United/ANA s (and United s/united+ana s) In Rebuttal to Delta Application at Pages 4-5 and 16, and Delta Exhibits DL-111 and DL-112 Exhibit AA-R-802 Page 2 of 2 Onboard Passenger Traffic by U.S. Carriers/Japanese Partners Japan-U.S. AA+JL AA/JL vs. DL DL % DL Greater ,251,519 3,415,526 52% ,428,062 3,684,351 52% ,482,795 3,541,582 43% ,501,377 3,189,119 27% AA+JL AA/JL vs. UA and UA/NH UA %UA Greater AA+JL UA+NH % UA+NH Greater ,251, ,607 7% 2,251,519 3,428,123 52% ,428,062 2,638,778 9% 2,428,062 3,843,292 58% ,482,795 2,644,403 7% 2,482,795 4,020,615 62% ,501,377 2,646,159 6% 2,501,377 4,179,079 67% Source: U.S. DOT T-100 data

107 While Delta Has No Connectivity at Haneda to Japanese Destinations, Delta Can Effectively Serve Japanese Cities Through Its Northeast Asia Partners Hubs, Representing 97.8% of U.S.-Japan O&D In Rebuttal to Delta Application at Pages 4-5 and 16 Exhibit AA-R-803 Page 1 of 1 JL-HND Services Japan-U.S. O&D Passengers % of Total Japan-U.S. O&D Passengers KE-ICN Service MU/FM-PVG Service Cumulative % of Japan-U.S. O&D Passengers TYO 3,399, % 63.3% OSA 939, % 80.7% NGO 476, % 89.6% FUK 230, % 93.9% OKA 120, % 96.1% CTS 68, % 97.4% HIJ 20, % 97.4% OKJ 8, % 97.6% KMQ 7, % 97.6% MSJ 5, % 97.7% MYJ 3, % 97.7% KMJ 3, % 97.7% KOJ 2, % 97.7% NGS 2, % 97.7% KMI 1, % 97.7% TAK 1, % 97.7% UBJ 1, % 97.7% OIT 1, % 97.7% AXT 1, % 97.7% KCZ 1, % 97.8% HKD % 97.8% TKS % 97.8% AOJ % 97.8% AKJ % 97.8% OBO % 97.8% KKJ % 97.8% KUH % 97.8% MMB % 97.8% IZO % 97.8% GAJ % 97.8% ASJ % 97.8% SHM - 0.0% 97.8% Total 5,301, % 97.8% Source: Innovata Schedules Data (Mar-16) / U.S. DOT O&D Data (YE 3Q15)

108 Delta s Current LAX-HND Service Has Not Been Disadvantaged by Not Having Japan Access Beyond HND In Rebuttal to Delta Exhibit DL-204 Exhibit AA-R-804 Page 1 of 1 100% 90% LAX-HND v.v. Load Factor YE 3Q15 50,000 45, MIDT Connecting Passengers Japan-Continental U.S. DL-LAX vs. NH-HND 47,810 80% 40,000 70% 35,000 60% 30,000 50% 40% 30% January-September Average DL: 83.0% NH: 82.2% 25,000 20,000 15,000 12,762 20% 10,000 10% 5,000 0% Jan Feb Mar Apr May Jun Jul Aug Sep DL NH 0 DL-LAX NH-HND Sources: U.S. DOT T-100 (YE 3Q15) / MIDT booking data

109 Delta and United Are Each Larger Than American in Northeast Asia

110 For Decades, Delta and United Have Dominated the Northeast Asia-U.S. Market In Rebuttal to Delta Application at Pages 4-5 and 16, and Delta Exhibits DL-111 and DL-112 Exhibit AA-R-805 Page 1 of 2 Onboard Passenger Traffic by U.S. Carriers Northeast Asia-U.S. 5,000,000 4,500,000 4,000,000 3,500,000 3,000,000 2,500,000 2,000,000 1,500,000 1,000, , AA UA DL Source: U.S. DOT T-100 Notes: 1/ Northeast Asia includes Japan, South Korea and Mainland China; 2/ In this Series 800, UA includes CO and DL includes NW.

111 For Decades, Delta and United Have Dominated the Northeast Asia-U.S. Market In Rebuttal to Delta Application at Pages 4-5 and 16, and Delta Exhibits DL-111 and DL-112 Exhibit AA-R-805 Page 2 of 2 Onboard Passenger Traffic by U.S. Carriers Northeast Asia-U.S. AA UA DL % AA Smaller Than Average of UA and DL ,180 3,266,582 4,283,684-83% ,014 3,084,283 3,649,135-83% ,165 3,073,632 3,400,506-84% ,615 3,008,115 3,083,093-83% ,371 3,697,497 3,549,087-80% ,745 4,174,235 3,743,697-78% ,008,891 4,293,978 3,858,963-75% ,465 4,280,900 3,854,740-79% ,666 3,754,095 3,966,717-78% ,408 3,502,779 3,424,857-76% ,101 3,932,687 3,835,165-75% ,067,381 3,965,857 3,868,874-73% ,168,077 4,284,005 4,199,639-72% ,218,452 4,286,345 4,204,559-71% ,167,907 4,355,605 4,029,231-72% Source: U.S. DOT T-100 Note: Northeast Asia includes Japan, South Korea and Mainland China.

112 With Their Strong Northeast Asia Partners, Delta Through SkyTeam and United Through Star Alliance Have Widened the Gap with American and oneworld in the Northeast Asia-U.S. Market In Rebuttal to Delta Application at Pages 4-5 and 16, and Delta Exhibits DL-111 and DL-112 Exhibit AA-R-806 Page 1 of 2 Onboard Passenger Traffic by Alliance Groups Northeast Asia-U.S. 10,000,000 9,000,000 8,000,000 7,000,000 6,000,000 5,000,000 4,000,000 3,000,000 2,000,000 1,000, oneworld SkyTeam Star Alliance Source: U.S. DOT T-100 Note: Northeast Asia includes Japan, South Korea and Mainland China.

113 With Their Strong Northeast Asia Partners, Delta Through SkyTeam and United Through Star Alliance Have Widened the Gap with American and oneworld in the Northeast Asia-U.S. Market In Rebuttal to Delta Application at Pages 4-5 and 16, and Delta Exhibits DL-111 and DL-112 Exhibit AA-R-806 Page 2 of 2 Onboard Passenger Traffic by Alliance Groups Northeast Asia-U.S. oneworld SkyTeam Star Alliance % oneworld Smaller Than Average of Star and SkyTeam ,584,077 6,409,275 6,517,154-14% ,711,784 5,477,189 5,935,886-17% ,556,763 5,480,512 5,694,670-18% ,789,828 4,993,239 5,250,966-26% ,651,318 5,830,576 6,132,212-22% ,786,929 6,233,703 6,583,512-25% ,203,732 6,481,281 6,777,730-37% ,712,807 6,586,002 6,990,296-45% ,478,709 6,554,047 6,542,919-47% ,289,451 6,068,332 6,117,513-46% ,243,782 6,847,001 6,872,441-53% ,612,863 7,162,490 7,160,323-64% ,863,535 7,807,015 7,947,051-64% ,007,593 8,026,144 8,469,310-64% ,120,478 7,918,075 8,967,988-63% Source: U.S. DOT T-100 Note: Northeast Asia includes Japan, South Korea and Mainland China.

114