FA9295 and jbpdx, thought I'd copy in AA's arguments against DL's PDX-HND here:
Full PDF available for download here: https://www.regulations.gov/document?D= ... -0014-0016Delta’s Portland and Honolulu Proposals, If Granted, Will Squander Scarce Haneda Slot-Pairs While Preventing Competition from Other Carriers
Due to the limited number of Haneda slot-pairs available and the need for competition from American, Delta should not be granted excess slot-pairs to launch Haneda services at PDX and HNL. Delta’s proposed PDX-HND and HNL-HND services will expand Tokyo service at gateways where it will not maximize public benefits, while depriving other communities of Haneda service that need it greatly. Moreover, with negligible connectivity, Delta’s proposals will do little to improve Haneda access for U.S. passengers. Rejecting American’s proposed Haneda services to allow Delta to launch service in Portland or Honolulu will only harm competition in the continental United States.Based on Portland’s Small Local Demand and Extremely Limited Connectivity, Delta’s PDX-HND Proposal Offers Few Benefits and May Not Be Sustainable
Delta’s proposed PDX-HND service would give Delta Haneda service at three West Coast gateways, including two in the Pacific Northwest: LAX, SEA, and PDX. Few passengers would benefit from PDX-HND service. Delta’s application states that Portland - Tokyo O&D traffic consists of just 63 passengers daily each way. Las Vegas - Tokyo O&D traffic, by contrast, consists of nearly twice as many passengers daily each way. Moreover, Delta offers no meaningful connectivity at Portland: all of its listed connections are to its U.S. hubs, most of which will have nonstop Haneda service should Delta’s first three proposals be awarded. Delta’s own connecting tables show that Portland residents will have convenient access to Tokyo via Delta’s SEA-HND service; layovers at SEA in both directions will be under 90 minutes.
Accordingly, Delta’s proposed PDX-HND service is a textbook example of a proposal that does not merit selection. When the Department rejected Delta’s LAX - Beijing (PEK) proposal in 2016, for instance, the Department reasoned that “all of the connecting points Delta proposes already have connecting service to Beijing on Delta over Seattle.” The same is true here: all of Delta’s Portland connecting points also have connections via Seattle, and most will have nonstop Haneda service as well. Because Portland is sandwiched between two West Coast gateways with Haneda service via Delta, has smaller local demand, and has even smaller, duplicative connectivity, Delta’s proposed PDX-HND service should not be selected.
Moreover, passenger demand may not even be sufficient to sustain its PDX-HND proposal on a daily, year-round basis. Delta currently offers PDX-NRT service just five times weekly for most of the year. More than 40 percent of the passengers on this service are not Tokyo O&D travelers, and connect to destinations served by Delta beyond Narita. Should Delta’s flight be moved to Haneda and be expanded to year-round daily, Delta will lose passengers while increasing seats. With Portland - Tokyo O&D traffic consisting of just 63 passengers daily each way and Delta’s minimal, duplicative connectivity, there is no basis to believe that Delta’s current beyond- Narita connecting passengers will be replaced by a sufficient number of Tokyo O&D travelers.
Without an unrealistic surge in demand for Delta’s proposed PDX-HND service, it is exposed to the same seasonal performance variations that afflicted Delta’s failed SEA-HND service four years ago. When Delta suspended its SEA-HND service for the 2014 winter traffic season, Delta claimed that it was “was commercially necessary to make seasonal reductions” due to poor winter demand. In defending its actions, Delta demonstrated that “Seattle–Tokyo winter demand is more seasonal than other Haneda gateways.” Specifically, “Seattle – Tokyo winter demand is 35% less than in summer months.” “Delta’s expanding Seattle hub network will work to offset these seasonal variations in the future,” Delta told the Department. As Delta explained, increasing its Seattle connections “will provide the necessary feed needed to make the Seattle- Haneda service a continued success.”
By proposing to launch daily year-round PDX-HND service, Delta ignores the lessons of its failure in Seattle. Portland is a much smaller local market for Tokyo service, as shown in Delta’s exhibits, and it does not currently sustain year-round Tokyo service today. Based on the weaker demand for Tokyo service in the Pacific Northwest during the winter, as previously described by Delta, Delta only operates its PDX-NRT service five times weekly during the winter season and into May. And Delta’s connectivity at PDX is far worse than its connectivity at SEA was in 2014, when it was unable to sustain SEA-HND service. The cloud of uncertainty as to whether Delta can sustain PDX-HND service on a daily, year-round basis further weakens any case for awarding it.
Last edited by AS737MAX
on Sat Mar 02, 2019 8:23 am, edited 1 time in total.