OST-96-1091
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OST-96-1091
1998 US-Japan Interim Frequency Allocation Proceeding / 1998 Japan Combination Service Proceeding
OST-98-3419 | OST-96-1091 | OST-96-1126 (49527) | February 10, 1998
Application
of American Airlines for Pendente Lite Exemption - Chicago-Tokyo
American proposes to begin Chicago-Tokyo service on May 1, 1998, using 238-seat MD-11 aircraft.
Motion of American
Airlines to Consolidate
American Airlines, Inc., under the Department's Notice of February 3, 1998 setting forth procedures for awarding new rights made available by the agreement of January 30, 1998 between the United States and Japan, hereby moves to consolidate the Chicago-Tokyo and New York-Tokyo portion of its application of February 21, 1996 for certificate authority in OST-96-1091, and the Dallas/Ft. Worth-Osaka portion of its application of April 26, 1994 for certificate authority in Docket 49527 (OST-96-1126), into the .1998 U.S.-Japan Combination Service Proceeding, OST-98-3419.
Counsel: American, Carl Nelson, 202-496-5647
1998 US-Japan Combination Service Proceeding
February 13, 1998
Answer of Hawaiian Airlines to:
1998 US-Japan Combination Service Proceeding
February 13, 1998
OST-96-1091 | February 17, 1998
Chart 1 | Chart 2 | Chart 3 | Chart 4 | Chart 5 | Chart 6 | Chart 7 | Chart 8
By: Richard Cunnion, Director Airline & Destination Marketing
Consolidated Answer of Northwest Airlines
Counsel: Northwest, Megan Rae Poldy, 202-842-3193
Answer of Greater Orlando Aviation Authority
in Support of TWA
Counsel: Preston Gates, Jonathan Blank, 202-662-8450
Answer of The City of Philadelphia, Division of
Aviation in Support of US Airways
Attachment: Comparison of Selected Demographic Information Between Philadelphia and St. Louis
Counsel: Galland Kharasch, Morris Garfinkle, 202-342-5200
Answer of The Port of Portland
Consolidated Answer of The Regional Business
Partnership - Newark
Answer of Regional Commerce and Growth Assocation
St. Louis Advantages as the Location for a New US-Japan Air Route | Letters in Support
By: Richard Fleming, President
Answer of The St. Louis Parties
Appendix A: Japanese Businesses in Missouri | Appendix B: Missouri Businesses in Japan | Appendix C: Most US Airways Cities Have or Will Have Japan Service via Multiple Hubs/Proposal Cities without Single-Carrier Japan Service
Counsel: St. Louis and Steptoe Johnson, Richard Taylor, 202-429-6459
Answer of Trans World Airlines
Counsel: TWA and Richard Fahy
Counsel: US Airways and O'Melveny Myers, Donald Bliss, 202-383-5300
1998 US-Japan Combination Service Proceeding / American Airlines / US-Tokyo/Osaka
OST-98-3419 | OST-96-1091 | 49527 | OST-96-1126 | March 24, 1998
Supplement No. One to Application of American Airlines
American urges the Department to grant American's request for one additional San Jose-Tokyo frequency to enable American to operate a daily pattern of service in this important market.
Counsel: Carl Nelson, Jr., 202.496.5647
1998 US-Japan Combination Service Proceeding
OST-98-3419 | OST-96-1091 | OST-96-1126 | OST-96-1199 | March 26, 1998
Comments of American Airlines in Support of
Order 98-3-15
The Department was also correct in concluding the restricted-entry MOU carriers, like American, must be able to implement their new services promptly. Otherwise, the incumbent carriers -- which have unlimited rights to mount new U.S.Japan operations -- would further lengthen their lead in the marketplace, to the detriment of competition.
Counsel: American, Carl Nelson, 202-496-5647, carl_nelson@amrcorp.com
Objections and Consolidated Answer of Continental and
Continental Micronesia
Since Continental and Continental Micronesia alone are seeking 16 frequencies for service starting after 1998, it is not "too early to say" sufficient numbers of frequencies will be unavailable. Clearly, they will not. Under these circumstances, the Department's decision to award authority based solely on start-up dates without full comparative consideration is unlawful, particularly when the result will be an award of large numbers of frequencies to American, JAL's partner, for Tokyo service at non-hub U.S. gateways and to Delta for small Japan markets.
Counsel: Continental and Crowell Moring, Bruce Keiner, 202-624-2615
Consolidated Response and Answer of The Dallas/Fort
Worth International Airport
Dallas/Fort Worth supports grant of the American, Continental and Delta supplemental requests so long as such grants do not delay the prompt finalization of Order 98-3-15 by April 30, 1998. If additional requests for 1998 frequencies are filed, all post-Order 98-3-15 requests should be decided in a separate proceeding.
Counsel: Bagileo Silverberg, Michael Goldman, 202-944-3305
Consolidated Answer of Delta Air Lines to
Amended Applications of American and Continental
In light of the high priority the Department has placed on the immediate implementation and utilization of the extremely valuable U.S.-Japan rights and the important public interest benefits that would result from such services, it makes eminent sense to limit consideration of the award of available frequencies to proposals involving service in 1998. The number of frequencies requested for 1998 services does not exceed the number of frequencies available under the U.S.-Japan MOU.
As a result of the Continental stock acquisition by Northwest Airlines, Inc., Continental is the alter ego of Northwest. Given Northwest's dominant incumbent position and its ability to serve any U.S.-Japan gateway-to-gateway and beyond market without restrictions, it would be untenable for the Department to award valuable non-incumbent carrier rights that will redound to Northwest's benefit.
Counsel: Delta and Shaw Pittman, Robert Cohn, 202-663-8060
Answer of The State of Hawaii to Supplement No
2 of Continental Micronesia
The State of Hawaii (the "State" or "Hawaii") strongly supports Supplement Number Two to the Application of Continental Micronesia, Inc. ("Continental Micronesia") filed on March 19, 1998, requesting the immediate allocation of five round trip frequencies between the U.S. and Japan in order to allow Continental Micronesia to implement new Honolulu-Tokyo service on December 15, 1998.
Answer of The State of Hawaii to Amendment No.
3 of Delta Air Lines
Counsel: Hawaii and Stephen Lachter, 202-862-4321
Answer by Massachusetts Port Authority
Massport supports DOT's tentative award of a Boston-Tokyo non-stop route to American Airlines and allocation of seven nonstop Boston-Tokyo authority to American Airlines. Massport urges that the Show Cause Order as it relates to Boston and the award of a Boston-Tokyo route and seven frequencies to American be made final immediately. DOT has often taken the step of making a Show Cause Order final within one or two days of the final date for comments. DOT is urged to use that procedure here so that American can proceed to prepare for the start of Boston-Tokyo non-stop service.
Exhibit 13 | Attachment: Letters in Support
By: MASSPORT, Charles Yelen, 617-418-4152
Objections of Northwest Airlines to Order
98-3-15
Requests that the Department reconsider its tentative decision regarding the U.S.-Japan same-country code-share frequencies and allocate all 28 of them to Continental and Northwest.
Counsel: Northwest, Megan Rae Poldy, 202-842-3193
The City of San Jose, California and the San Jose International Airport respectfully pray that the Department of Transportation will take immediate action and all steps necessary to grant American Airlines, Inc. the additional weekly frequency which it has requested to allow it to provide the required daily pattern of service between San Jose and Tokyo; and for such other and further relief consistent with the premises herein as may be found fit and in the public interest.
Counsel: Hewes Gelband, Theodore Seamon, 202.337.6200
Objections of Trans World Airlines
The Department cannot shut its eyes to the way companies actually operate, but should treat Northwest and Continental as a single economic entity. It must recognize that an award to Continental would allocate limited non-incumbent frequencies to the unrestricted carrier that already provides the most service between the U.S. and Japan.
Appendix A: Scheduled Service Between the US and Japan
Counsel: TWA and Richard Fahy, 202-457-4764, rfahy@ibm.net
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