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DOT starts new proceeding for added HND slots

DOT starts new proceeding for added HND slots

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Old Mar 7, 19, 7:58 am   -   Wikipost
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Here are the applications for flight slots at HND (12 slots available to US carriers):

UA (six slots requested)
HND - EWR/ORD/IAD/LAX/IAH/GUM
Application of United Airlines (508 pages)
Answer of United Airlines (154 pages) "United's proposal will make the best use of scarce Haneda slots and provide the greatest public benefits, and No other carrier has demonstrated the benefits of its proposals more than United"
Consolidated reply of United Airlines (148 pages) "Our proposal is best, and the other guys misrepresented the facts."

HA (three slots requested)
HND - HNL (3x daily)
Application of Hawaiian Airlines (118 pages)
Answer of Hawaiian Airlines (111 pages) "Why HA is best, here's what's wrong with DL's request, here's what's wrong with UA's request, and here's what's wrong with AA's request"
Consolidated Reply of Hawaiian Airlines (33 pages) "Our proposal is best, and here's what's wrong with DL, UA and AA's proposals"

AA (four slots requested)
HND - DFW/LAX/DFW/LAS (DFW is AA's first and third preference)
Application of American Airlines (135 pages)
Answer of American Airlines (106 pages) "Only AA adds competition, DL squanders scarce resources, and don't reward UA further"
Consolidated Reply of American Airlines (111 pages) "Here's why DFW, LAX and LAS should be selected, and UA's baseless attacks on AA distract from UA's poor proposal"

DL (six slots requested)
HND - SEA/DTW/ATL/PDX/HNL/HNL (HNL Is DL's fifth and sixth preference)
Application of Delta Air Lines (199 pages)
Answer of Delta Air Lines (90 pages) "DL's proposal maximizes public benefits, DL's proposal should be granted in full before UA, AA, and HA are considered, and DL deserves the slot times it has requested"
Reply of Delta Air Lines (75 pages) "Answers from UA, AA and HA underscore why DL's proposal should be granted in full, and B6's answer is irrelevant to this proceeding"

And the odd filing:
Answer of Jetblue Airways Corporation (6 pages) "If it is important for DOT to grant DL's application for slots at HND, it is equally important to allow JetBlue to enter LHR and AMS"
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Old Feb 7, 19, 3:30 pm
  #1  
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DOT starts new proceeding for added HND slots

DOT is out this afternoon with an order inviting proposals for a dozen new daytime flights to Tokyo Haneda airport. Even if Delta gets just three slots (SEA, ATL, DTW), I expect that would be the end of Delta's service to Narita. I'd say 4 slots is far more likely, which means one of PDX/HNL/SIN/MNL would also move. No matter what, though, by Summer Season 2020, I suspect Delta will have Gatwick'd Narita.

Current NRT service:
HA: HNL 1x
AA: ORD, DFW, LAX all 1x
UA: ORD, DEN, HNL, IAH, LAX, EWR, SFO, IAD all 1x and GUM 3x

So, most likely distribution is 1 to Hawaiian, 3 to American, and then either 4-4 Delta/United or 5-3 Delta/United because of United's JV with ANA.

Will be fascinating to watch. I suspect Delta will seek seven — then the question becomes what would they forego if they only get five.

Here's the full order:

https://airlineinfo.com/ostpdf103/476.pdf

Last edited by 3Cforme; Feb 7, 19 at 5:41 pm
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Old Feb 7, 19, 3:50 pm
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While it might mean yet another shift from NRT to HND, I think saying it will be 'the end' for Delta flights to NRT is very premature.

Does the DOT have any influence over the flights to SIN/MNL? I would assume even if they do, they would not consider a HND slot for these routes over a US city.
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Old Feb 7, 19, 4:36 pm
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Originally Posted by CPMaverick View Post
Does the DOT have any influence over the flights to SIN/MNL? I would assume even if they do, they would not consider a HND slot for these routes over a US city.
SIN/MNL are likely on the chopping block if this comes through and they don’t separately receive slots - as you say, I doubt they would be eligible for the DOT allocation. I imagine those two remaining hub routes would probably go to ICN, SEA, or get cut entirely in favor of MU/KE connections.

SEA-SIN seems unlikely-ish as long as SQ is in town, unless DL feels like picking a fight, but I’m not even sure they could get fifth freedom rights from South Korea. It’s not out of the question - KE does have authority for LAX-GRU, so there’s a reciprocity argument to be made on that end, at least. Seems likelier than PVG, at least. Maybe DTW-SIN, although that’s pushing the boundaries of route length...
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Old Feb 7, 19, 4:42 pm
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Originally Posted by CPMaverick View Post
While it might mean yet another shift from NRT to HND, I think saying it will be 'the end' for Delta flights to NRT is very premature.

Does the DOT have any influence over the flights to SIN/MNL? I would assume even if they do, they would not consider a HND slot for these routes over a US city.
With the recent events of watching MNL and SIN drop from 744/777 down to the 763 and the dropping of routes exNRT such as GUM/BKK/ICN/HKG/HNL (from 3 to 1) I really can't imagine DL keeping those routes in the event DL gets awarded 4 slots at HND. HNL can be captured with the JV with KE nonstop HNL-NRT and SIN could just as easily be flown as a connection with KE via ICN.

DL only has four NRT flights they would want shifted to HND exUSA with ATL/SEA/PDX/DTW. They settle for four and shift all flying to HND, that would be a very plausible idea that it could mean the end for NRT flying.
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Old Feb 7, 19, 4:58 pm
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Good luck for DL getting a HND slot to run HND-MNL or HND-SIN that connects well with their transpacific flights.

I think those intra-Asia routes are toast and folks will connect through ICN on KE. JAL just added a HND-MNL route.

My guess is that it's down to PDX vs HNL for the 4th slot.

I think a 5th freedom ICN-SIN flight could happen if DL wants to stay in SIN.
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Old Feb 7, 19, 6:52 pm
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I predict DL makes a play for 6 out of 12 slots:

HND-DTW
HND-SEA
HND-ATL
HND-HNL
HND-JFK
HND-PDX

I'm surprised no additional nighttime slots were generated from the new agreement. While they're not ideal for the mainland, they would - and have - worked perfectly for HNL/KOA. Considering how underutilized nighttime slots are, the two sides should've negotiated an extra slot pair or two.

Last edited by FireEmblemPride; Feb 7, 19 at 7:02 pm
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Old Feb 7, 19, 8:48 pm
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Given that DL received two HND slot pairs in the last round versus one each for UA and AA. I doubt that they will still receive more pairs than either one of them in this next round.
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Old Feb 7, 19, 9:00 pm
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Originally Posted by Fanjet View Post
Given that DL received two HND slot pairs in the last round versus one each for UA and AA. I doubt that they will still receive more pairs than either one of them in this next round.
Agreed. Delta has repeatedly made a mockery of the DOT with HND slots. I'd be cool with it if they didn't get any. Hawaiian Airlines is the only airline that has operates their HND frequencies at 100% service levels.
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Old Feb 7, 19, 9:23 pm
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Originally Posted by Fanjet View Post
Given that DL received two HND slot pairs in the last round versus one each for UA and AA. I doubt that they will still receive more pairs than either one of them in this next round.
DL will likely continue to receive more pairs than either one as the DOT has always considered these awards in the context of the existing JVs that AA and UA have with JL and NH respectively. Given that the US carriers are getting 12 slot pairs, this means that the Japanese side is going to get 12 as well for new US-Japan daytime flights and you can bet that DL will argue (and likely be somewhat successful at it) that the distribution needs to consider that AA and UA will benefit from those 12 as well.

Originally Posted by FireEmblemPride
I predict DL makes a play for 6 out of 12 slots:

HND-DTW
HND-SEA
HND-ATL
HND-HNL
HND-JFK
HND-PDX
I agree with the above scenario. Given that DL got 50% of the slots the last round, I don't see why they wouldn't apply for at least 6 of the 12 and argue that they need those to compete effectively with the two JVs. Also, these slots are for US-Japan nonstops only and not for any third party countries, so even if they wanted to, they couldn't apply for HND-SIN/MNL as part of the 12 anyway, which means MNL and SIN from TYO will be toast. So in applying for the 12 they can essentially move all of the other NRT-US flights over, and even apply for a new one - JFK.
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Old Feb 7, 19, 9:23 pm
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Originally Posted by readywhenyouare View Post


Agreed. Delta has repeatedly made a mockery of the DOT with HND slots. I'd be cool with it if they didn't get any. Hawaiian Airlines is the only airline that has operates their HND frequencies at 100% service levels.
If I recall correctly, Delta's initial two HND authorities were DTW and LAX nighttime slots. While Delta originally operated these with 747s, they did reduce them to 777 service, I'd presume with DOT's approval.

Delta then moved DTW to SEA again with approval from the DOT, and with no objections from other airlines.

While you can (rightly) argue that Delta played games with the Seattle authority, it did technically follow the rules the DOT had in place.

When AA objected to the DOT, the DOT issued new guidance to Delta, who complied 100% with DOT's ruling, until they gave up the route authority.

Delta has since operated daytime slots from MSP and LAX to the letter of the law.

So where's the mockery? That they asked and got permission to use smaller aircraft and move the authority? That they complied with DOT rules, including when the DOT (again, rightly) imposed new rules after AA's objection?
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Old Feb 7, 19, 11:05 pm
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Originally Posted by WidgetTravels View Post
While you can (rightly) argue that Delta played games with the Seattle authority, it did technically follow the rules the DOT had in place.

So where's the mockery? That they asked and got permission to use smaller aircraft and move the authority? That they complied with DOT rules, including when the DOT (again, rightly) imposed new rules after AA's objection?
I think the mockery is referring to operating the flight exactly eleven times during the entire winter. Technically within the minimums, but the DOT took a dim view of that. They then required Delta to obtain prior DOT approval before canceling more than 2 flights all year (which might have even included mechanical or weather cancellation); that triggered Delta eventually giving up entirely and returning the authority to the DOT.

I think it’s fair to say that someone complying with the letter but not the spirit of an allocation of a rare resource is making a mockery of the process, and I think the way the resulting regulatory process played out was a fair resolution. I also think it was a key factor in the DOT denying Delta’s request for slot flexibility in this round of allocations...


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Old Feb 8, 19, 7:46 am
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Originally Posted by BenA View Post


I think the mockery is referring to operating the flight exactly eleven times during the entire winter. Technically within the minimums, but the DOT took a dim view of that. They then required Delta to obtain prior DOT approval before canceling more than 2 flights all year (which might have even included mechanical or weather cancellation); that triggered Delta eventually giving up entirely and returning the authority to the DOT.

I think it’s fair to say that someone complying with the letter but not the spirit of an allocation of a rare resource is making a mockery of the process, and I think the way the resulting regulatory process played out was a fair resolution. I also think it was a key factor in the DOT denying Delta’s request for slot flexibility in this round of allocations...


Maybe it is and maybe it isn't, but what DOT said about rejecting the flexibility application was they saw merit in the proposal but it was too controversial and complex to implement on the procedural schedule available.

Also, it's worth remembering that even after Delta's Seattle winter Haneda mess, DOT still gave them MSP-HND over an AA application for DFW. Government agencies don't tend to think in terms of "games" and "punishment" — there are rules and procedures and they evaluate all proposals in accordance with those things. To do any less would invite a lawsuit the government would lose.

While avgeeks might enjoy the idea of the government "punishing" a carrier, it just isn't going to happen.
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Old Feb 8, 19, 7:47 am
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The better way would be to just toss out the HND restrictions all together, and move to a full open skies for Japan and the US. Then let US carriers and JP carriers fly what they want, and buy the slots they want from other carriers at restricted airports.

DL wants more slots? I'm sure they could buy some slots from one of the smaller carriers who might not be fully utilizing it. Or DL could trade slots at JFK or LAX.
AA and UA would still have an advantage, but we could at least get the DOT out this taking months and months to decide what really could be figured out in one week. A day each for DL, UA, AA, HA to present, and a day for public comments. Done.
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Old Feb 8, 19, 8:13 am
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Why don't the Japanese authorities allocate the slots directly themselves? Why is is the US DOT involved?
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Old Feb 8, 19, 8:31 am
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It's a bilateral negotiation to make slots available for U.S. carriers. U.S. authorities grant them according to evaluations of public good.
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