BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

--------------------------------------------------------------- Applications of : : HAWAIIAN AIRLINES, INC. :

and : Docket DOT-OST-2010-0018 UNITED AIRLINES, INC. : : in the matter of 2010 U.S.-Haneda : Combination Service Allocation Proceeding :

--------------------------------------------------------------- REPLY OF UNITED AIRLINES, INC. Communications with respect to this document should be sent to: Hershel I. Kamen Senior Vice President–Alliances, Regulatory and Policy Daniel A. Weiss Managing Director–International Affairs and Regulatory UNITED AIRLINES, INC. 233 South Wacker Drive 10th Floor – HDQIZ Chicago, IL 60606 (872) 825-6828 hershel.kamen@united.com dan.weiss@united.com Steve Morrissey Managing Director–Regulatory Affairs and Policy Karine R. Faden Managing Counsel–Regulatory, Antitrust & Competition UNITED AIRLINES, INC. 1225 New York Avenue, NW Suite 1100 – DCAIZ/DCALD Washington, DC 20005 (202) 521-4373 (202) 521-4363 steve.morrissey@united.com karine.faden@united.com Thomas Newton Bolling Vice President and Deputy General Counsel UNITED AIRLINES, INC. 233 South Wacker Drive 11 th Floor – HDQLD Chicago, IL 60606 (872) 825-8068 thomas.bolling@united.com Douglas P. Kelley Senior Counsel–Regulatory, Antitrust & Competition UNITED AIRLINES, INC. 1600 Smith Street HQSLG-15 Houston, TX 77002 (713) 324-5156 doug.kelley@united.com Lorraine B. Halloway Gerald F. Murphy CROWELL & MORING LLP 1001 Pennsylvania Avenue, NW Washington, DC 20004 (202) 624-2500 lhalloway@crowell.com gmurphy@crowell.com Counsel for United Airlines, Inc. December 16, 2013BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

--------------------------------------------------------------- Applications of : : HAWAIIAN AIRLINES, INC. :

and : Docket DOT-OST-2010-0018 UNITED AIRLINES, INC. : : in the matter of 2010 U.S.-Haneda : Combination Service Allocation Proceeding :

--------------------------------------------------------------- REPLY OF UNITED AIRLINES, INC. I. INTRODUCTION Hawaiian’s 1 Answer underscores why United’s Application to provide competitive and first ever U.S. carrier service in the large San Francisco-Tokyo market between United’s San Francisco hub gateway and Tokyo Haneda should be selected under the Department’s public interest standards – which are based on providing the most benefits to the greatest number of consumers. While Hawaiian’s proposal to serve the small Kona gateway may have its attributes, it pales in comparison to the plentiful connecting opportunities, extensive catchment area, economic benefits and new entrant competition that are among the hallmarks of United at San Francisco. And there is only one Tokyo Haneda slot pair available in this proceeding. Moreover, public stakeholders who stand to reap the significant consumer benefits that would flow from United’s proposed San Francisco-Tokyo Haneda service have urged the selection of United’s proposal. San Francisco International Airport and the United Master Executive Council of the Air Line Pilots Association, International have submitted pleadings supporting United’s Application. They are joined by Democratic Leader Nancy Pelosi, Members of the California

1 Common names are used for airlines.Reply of United

Page 2 Congressional Delegation, San Francisco Mayor Edwin Lee and other civic and business partners in recognizing that United’s San Francisco-Tokyo Haneda proposal best meets the needs of the flying public and their communities. Exhibits UA-R-121 and UA-A-110; see also Docket DOT-OST-2010-0018. The Department should select United’s proposal because:

 United’s San Francisco-Tokyo Haneda proposal will provide first time nonstop U.S. carrier competition between the West Coast and Tokyo Haneda and is supported by longstanding Department precedent favoring new entrants, like United, over incumbents, like Hawaiian, in limited entry markets.

 Only United’s proposal will introduce new and/or competitive U.S. carrier service and a large hub network for Tokyo Haneda passengers throughout the Western U.S., including smaller communities, in addition to offering plentiful connecting opportunities across the entire U.S. mainland.

 United’s proposed San Francisco gateway is four times the size of Hawaiian’s proposed Kona gateway and, unlike the Kona-Tokyo market, the San Francisco-Tokyo market has shown growth in the short period of time since the last Tokyo Haneda allocation proceeding.

 United continues to grow its Asia/Pacific operations at San Francisco and its San Francisco hub is the largest airline operation on the West Coast, thus making San Francisco an ideal gateway. Hawaiian’s Kona-Tokyo Haneda service proposal should not be selected over United’s proposal to provide new entrant San Francisco-Tokyo Haneda service because:

 Hawaiian is an incumbent at Tokyo Haneda already holding one of only four slot pairs reserved for U.S. carriers, whereas United is the only U.S. carrier serving Japan that has not been given the opportunity to serve Tokyo Haneda to the benefit of its customers, coworkers and communities; longstanding DOT policy indicates that Hawaiian’s proposal should be dismissed in favor of United’s new entrant Application.

 Despite Hawaiian’s best efforts to justify selection of its Kona-Tokyo Haneda proposal over United at San Francisco, Hawaiian relies principally on:
o the characteristics of the Honolulu-Tokyo market and strangely not the KonaTokyo market that Hawaiian proposes to serve;Reply of United

Page 3
o the generally poor service records of the other incumbent U.S. carriers at Tokyo

Haneda – which are of no relevance since neither those carriers nor those gateways are at issue in this proceeding; and
o misrepresentations and unsubstantiated assumptions regarding other carriers’ plans in the San Francisco-Tokyo market. The Department’s public interest standards compel the selection of the proposal that would maximize consumer benefits for the greatest number of nonstop U.S.-Tokyo passengers and their communities. In evaluating which applicant should be authorized to serve which gateway, the Department should consider the carriers’ ability to flow traffic through their proposed gateways on their own connecting flights, the size of the local markets to be served and new competition for U.S. airlines that already offer nonstop service at Tokyo Haneda. Based on these criteria, United’s proposed San Francisco-Tokyo Haneda service is the clear winner. United replies to Hawaiian’s Answer as follows and urges the Department to grant its Application to provide San Francisco-Tokyo Haneda service.II. HAWAIIAN’S ANSWER DEMONSTRATES WHY UNITED’S SAN FRANCISCOTOKYO HANEDA PROPOSAL SHOULD BE SELECTED OVER HAWAIIAN’S PROPOSAL A. By Any Measure, United’s Proposal To Serve The Large San Francisco-Tokyo Market Offers Far More Public Benefits Than Hawaiian’s Proposed Kona-Tokyo Haneda Service The Department’s selection criteria compel an award to United in this proceeding. Selecting the largest market available to maximize the number of passengers who will benefit from the introduction of nonstop Tokyo Haneda service at the gateway supporting the largest traffic volume will meet the Department’s “principal objective” in allocating slots to “maximize public benefits...that will likely result in service that best meets the needs of the travelling andReply of United

Page 4 shipping public.” Order 2013-11-9 at 3; see also Orders 2012-8-20 at 3 and 2010-1-17 at 2.2 Consideration of the relative merits of each of United’s and Hawaiian’s proposals, especially the number of passengers who would benefit from the connecting networks of the applicants’ U.S. gateways, in addition to the relative volumes of local Tokyo traffic flowing from each gateway, weighs heavily in favor of United’s San Francisco-Tokyo Haneda proposal. 3 United’s proposed San Francisco-Tokyo Haneda service will enhance the competitive environment between the West Coast and Japan by adding a new U.S. carrier at Tokyo Haneda and make daily nonstop U.S. carrier service available in each of the two largest West Coast markets, as well as provide extensive connecting opportunities for Tokyo Haneda passengers. United at San Francisco will provide competitive new entrant service to approximately 1.7million Americans – 1.5 million of which are beyond San Francisco. Exhibits UA-R-104 and R108. By contrast, Hawaiian’s negligible catchment area at Kona would cover fewer than 60,000 consumers and its proposed service would offer no connections to the U.S. mainland whatsoever. Exhibit UA-R-108; see also Hawaiian Application at 3. United at San Francisco will provide roundtrip, online connections to/from Tokyo Haneda to 16 states and 29 points across the U.S. –and at least one way, online connections to 22 states and 43 points across the U.S. Exhibits UAR-110 and R-111. United will also offer first time U.S. carrier connecting service and/or

2 A plain reading of each of the Department’s three instituting orders regarding Tokyo Haneda slots demonstrates that Hawaiian’s claim that the Department has somehow changed its focus in this proceeding does not withstand scrutiny. See Hawaiian Answer at 22-23.

3 See Final Rule and Policy Statement on Procedures and Criteria for Selecting Carriers for Limited-Entry Markets, 51 Fed. Reg. 43180, 43187 (Dec. 1, 1986).Reply of United

Page 5 competitive connecting service between 17 smaller communities in the Western U.S.4 Exhibit UA-R-109. Hawaiian’s only response to the plentiful connecting opportunities offered by United at San Francisco is a meaningless comparison between Tokyo Haneda-only connecting traffic (as opposed to the correct metric of all Tokyo connecting traffic) at United’s unique mainland connecting points and Kona, and to assert that there is no benefit to United providing connecting service that will compete with Delta at Los Angeles and Seattle. 5 See Hawaiian Answer at 45-47. Hawaiian also erroneously claims that United plans to downgauge to a B-787 aircraft due to overcapacity in the San Francisco-Tokyo market. See Hawaiian Answer at 11. Rather, United is planning to use the fuel-efficient, technologically-advanced B-787 aircraft for its proposed San Francisco-Tokyo Haneda service because it will be the most efficient use of United’s available fleet resources for this operation and others. The B-787 is also the optimal aircraft choice given its ability to open up new markets and ensure service viability and consumer benefits over the long term. 6 United contends that Hawaiian’s ‘the biggest aircraft should always win’ argument

4 Despite Hawaiian’s failed attempts to belittle the unique interior connections United’s proposed San Francisco-Tokyo Haneda service would offer to smaller communities like Boise, Modesto and Eugene (along with major U.S. cities like Chicago and Houston), these communities, as evidenced by the celebration of newly-announced United service at Sun Valley, highly value their connecting service to major hubs like United at San Francisco. See, e.g. , Celebration Planned for First SFO Flight, IDAHO MOUNTAIN EXPRESS AND GUIDE (Dec. 11, 2013), http://www.mtexpress.com/index2.php?ID=2007149679#.Uqf4qXi9LCR.

5 The Department has recognized the benefits of such competitive connecting service options in carrier selection proceedings. See, e.g., Order 2000-7-19 at 5 (prioritizing the competitive service options for passengers in Delta’s Atlanta catchment area for connecting service to Colombia over the services offered by American at Miami and Continental at Houston).

6 United’s proposed San Francisco-Tokyo Haneda flights will also complement its daily San Francisco-Tokyo Narita service, which will continue to operate and offer alternative time of day departures and arrivals as well as service for customers who prefer Tokyo Narita or are making connections there. United’s flight schedules will provide consumers with the opportunity to optimize Tokyo Haneda and Tokyo Narita (via San Francisco) for their individual travel needs. UA-R-112 and R-113.Reply of United

Page 6 is dated thinking. With airlines facing a heated competitive environment and an ever-increasing need to maximize operational efficiency, the focus has shifted to finding the aircraft that best balances demand and efficiency to help ensure long term viability of services. The fact that United has been forthright regarding its fleet plans for San Francisco-Tokyo Haneda service should be applauded rather than chastised, as Hawaiian attempts cynically to do.7 Moreover, the Department has recognized that “aircraft size and capacity matter more in some route proceedings and less in others.” Order 94-7-1 at 9; see also Orders 2006-6-25 at 19 (greater capacity outweighed by new-entrant competition and market structure benefits) and 1990-4-44 at 7 (“aircraft size should not be considered a major selective criterion in the Honolulu-Tokyo market” where Delta’s “nonstop service from Honolulu to Pacific Rim countries other than Japan leaves capacity on its smaller aircraft which would otherwise be filled with passengers traveling through Japan to these other Pacific Rim destinations”). United’s plans to utilize the most efficient aircraft for its proposed first ever U.S. carrier San Francisco-Tokyo Haneda service, the extensive Asia/Pacific services United already provides at its San Francisco hub, and the new entrant competition it will provide with Delta on the West Coast, all outweigh significantly the flight Hawaiian proposes to offer at Kona.

7 The veracity of Hawaiian’s aircraft size argument is questionable given its President & CEO’s public statements on the subject: “One of the things that’s really important to [Hawaiian] is to find not only an airframe, but also an engine which is economic from a maintenance perspective as well as fuel burn perspective.” Vinay Bhaskara, Interview: Hawaiian Airlines Chief Executive Mark Dunkerley, ASPIRE AVIATION (Sep. 13, 2012),http://www.aspireaviation.com/2012/09/13/interview-hawaiian-airlines-chief-executive-markdunkerley/. Hawaiian’s related questioning as to United’s desire to succeed at Tokyo Haneda is also entirely without foundation. See Hawaiian Answer at 47.Reply of United

Page 7 B. Hawaiian’s Kona-Tokyo Haneda Proposal Cannot Stand On Its Own, And Most

Of The Information Provided In Hawaiian’s Answer Is Irrelevant In This Proceeding Hawaiian’s Kona-Tokyo Haneda proposal cannot stand on its own and does not merit selection over United’s comprehensive hub gateway at San Francisco. Hawaiian’s Answer goes to great lengths to conflate Kona with the State of Hawaii as a whole and Honolulu, in particular. Hawaiian also attempts to ascribe to United problems that other incumbent U.S. carriers may have experienced with their Tokyo Haneda services. All told, Hawaiian devotes approximately 90 pages to discussing the Hawaii-Tokyo market, Hawaiian’s incumbent Honolulu-Tokyo Haneda service, and the service records of other U.S. carriers’ U.S.-Mainland-Tokyo Haneda gateways. The small Kona-Tokyo market does not reasonably compare to the San Francisco-Tokyo market. Kona comprises only 4% of all Hawaii-Tokyo passengers. Exhibit UA-R-100. And this figure represents a nearly 3% decrease in Kona’s share of total Hawaii-Tokyo traffic since last year’s proceeding. Exhibit UA-R-101. By contrast, San Francisco is an international business center that accounts for 33% of all California-Tokyo traffic. Exhibit UA-R-102. The size of theKona-Tokyo market has also decreased by 34% during that same time period (Exhibit UA-R103), while the San Francisco-Tokyo market is up 7%. Exhibit UA-R-104. United at San Francisco will also reach 1.7 million consumers – 29 times more than Hawaiian at Kona. Exhibit UA-R-108. In terms of potential economic benefits, San Francisco is home to 31 of the 54 Fortune 500 companies located in California, California has overall annual exports of $161 billion and $13.1 billion to Japan (1,617 times and 131 times, respectively, more than Hawaii), Japanese imports comprise nearly 25% of California’s $376 billion in annual imports, and there are 110,000 Japanese companies operating in the state. Exhibits UA-R-114 to R-116; R-118;Reply of United

Page 8 and R-120. Moreover, more than 561,000 Japanese visitors spend an estimated $1.1 billion in California each year. Exhibits UA-R-117 and R-119. Hawaiian’s success in the large Honolulu-Tokyo market is certainly commendable, but Kona is not Honolulu no matter how hard Hawaiian tries to make it so. Nor is United’s success at San Francisco predetermined by American and Delta’s record at Tokyo Haneda, as Hawaiian would lead the Department to believe.In addition, Hawaiian, and any other U.S. or Japanese carrier, is free to provide KonaTokyo Narita service at any time under the U.S.-Japan Open Skies Agreement and they have chosen not to do so. Despite Hawaiian’s rather optimistic claims of market potential (see, e.g,Hawaiian Answer at 26-27), Kona has failed at maintaining nonstop Tokyo service. Exhibit UAR-105. Indeed, Hawaiian provides nonstop service between Honolulu and Fukuoka, Osaka, Sapporo and Sendai, in addition to Tokyo Haneda, but does not offer Kona-Tokyo Narita service or service to Tokyo Narita from any gateway. Exhibit UA-R-107. And Hawaiian already provides online service between Kona and Tokyo Haneda, in any event. Exhibits UA-R-112 and R-113. Hawaiian’s assertions that it only was able to expand into these other open-entry U.S.- Japan markets because of its Honolulu-Tokyo Haneda slot award, and that further expansion is dependent upon Hawaiian securing an award for Honolulu-Tokyo Haneda service in this proceeding (see, e.g., Hawaiian Answer at 2 and 12), are also without merit. Hawaiian’s attempts to assign whatever problems other incumbent U.S. carriers at Tokyo Haneda may have had with their U.S. mainland gateways to United at San Francisco also rings hollow. See, e.g., Hawaiian Answer at 7-10 and 39. It is also particularly unclear how the factors that caused American (operating a gateway on the totally opposite side of the U.S. mainland) and Delta (operating a Midwest gateway also four time zones removed from the West Coast) to suspend Tokyo Haneda service would be applicable to United at San Francisco. SeeReply of United

Page 9 id., at 2 and 8. And despite Hawaiian’s attempts to insinuate otherwise, no U.S. carrier operating West Coast-Tokyo Haneda service has significantly altered its plans since startup. But unlike these other carriers – or Hawaiian for that matter – United remains the only U.S. carrier serving Japan that has not been given the opportunity to operate at Tokyo Haneda to the benefit of its customers, coworkers and communities. Awarding the available Tokyo Haneda slots to United will correct this imbalance and create the first ever nonstop U.S. carrier competition between the Western U.S. and Tokyo Haneda. Hawaiian similarly makes wholly unsubstantiated assumptions regarding the sustainability of other carriers’ existing San Francisco-Tokyo Narita service8 or decisions to offer Tokyo Narita service from San Jose – a nearby, but perfectly viable market in its own right – in an awkward attempt to challenge the strength of United’s proposal. See Hawaiian Answer at 38 and 40. In short, Hawaiian’s arguments regarding the viability of United’s proposed San Francisco-Tokyo Haneda service are thus speculative and self-serving, at best, and should be rejected out of hand. 9 Hawaiian’s arguments regarding Japanese carriers and competition in West Coast-Tokyo markets are equally flawed. By asserting that an award to United would somehow put these valuable Tokyo Haneda slots back in the hands of Japanese carriers and, further, that “an award to Hawaiian would be an important step toward protecting U.S. operating rights” (Hawaiian

8 Hawaiian goes so far as to presuppose – without foundation – that United’s proposed San Francisco-Tokyo Haneda service would drive JAL out of the San Francisco-Tokyo market entirely. See Hawaiian Answer at 35, n. 8. Such speculation is not only irresponsible but also a transparent attempt to distract from the flaws of Hawaiian’s Kona-Tokyo Haneda proposal.

9 The factors that led the Department to select United’s proposed service from its Los Angeles hub to San Jose del Cabo are equally applicable to United at San Francisco and the viability of its Tokyo Haneda service proposal: “United’s strong presence at Los Angeles (a large United hub), and its well-developed domestic network system, should help it challenge both the U.S. and foreign-flag incumbents on the route and sustain the service over time” and “United’s connecting benefits could increase the likelihood of a viable operation, thereby promoting sustained competition.” Order 2008-4-20 at 6.Reply of United

Page 10 Answer at 36 and Exhibits HA-2013A-705 and 2013A-706), Hawaiian fundamentally mischaracterizes the current Tokyo Haneda slot regime. As Hawaiian well knows, regardless of how many Tokyo Haneda slots they may hold, Japanese carriers can only operate two slot pairs each for service to the U.S. (see U.S.-Japan Memorandum of Understanding of October 25, 2010, Annex, Sec. 3), and selecting Hawaiian’s proposal to operate in the small Kona-Tokyo market would mean that United would remain the only U.S. carrier serving Japan that has not been given the opportunity to operate at Tokyo Haneda to the benefit of its customers, coworkers and communities. 10 Hawaiian further attempts to distract from this point by comparing the size and scope of its overall network to that of United. See, e.g. , Hawaiian Answer at 32. But all that matters here in terms of size is the fact that Hawaiian is 100 times larger than United at Tokyo Haneda. Exhibit UA-R-106. Moreover, the Department has a longstanding policy of favoring new entrant competition – like United’s San Francisco-Tokyo Haneda proposal – in carrier selection proceedings. See, e.g., Orders 2008-5-27 at 13 (selecting “JetBlue [because it] would offer important new-entrant benefits, not only at Cancun, but also in the U.S.-Mexico market overall, including superior market structure benefits and connecting service advantages”); 2005- 10-2 at 4 (citing the “need for new entry [with respect to U.S.-Argentina service] because of the severe restrictions on U.S. carrier service in the market, the dominant positions of the incumbents in the market, and because new entry offered the greatest prospect for improving service and competition in the market”); and 1996-4-23 (“Delta’s incumbency was relevant largely to the extent that it prevented it from offering the high level of inter-gateway competition and competition with foreign airlines that would result from the selection of [new entrant Philadelphia-Rome service from] USAir”).

10 The Department previously chose to allocate one daily pair of Tokyo Haneda slots to American, which, like United, has an immunized Japanese alliance partner (see Order 2010-7- 2), and Hawaiian fails to explain why United should not receive equal treatment.Reply of United

Page 11 III. UNITED’S SAN FRANCISCO-TOKYO HANEDA PROPOSAL BEST MEETS THE PUBLIC INTEREST CRITERIA FOR SELECTION IN THIS PROCEEDING For all of the reasons stated in this Reply and in United’s Application, Supplement and Answer, the Department should select United’s proposal to serve the large San Francisco-Tokyo market at its hub at San Francisco International Airport to maximize the public benefits to the traveling and shipping public available from the allocation of a single pair of Tokyo Haneda slots. Doing so would squarely satisfy the Department’s “principle objective” in this proceeding (see Order 2013-11-9 at 3) and correct the persistent competitive imbalance among U.S. carriers serving Japan by finally giving United the opportunity to operate at Tokyo Haneda to the benefit of its customers, coworkers and communities. United’s proposed service will provide additional capacity and greater convenience for the large business communities in both San Francisco and Tokyo, the large Japanese and Asian populations in the San Francisco region, the large American community in Tokyo, and travelers throughout United’s San Francisco hub network. United’s proposed San Francisco-Tokyo Haneda service will also enhance the overall competitive environment between the U.S. and Japan by adding a new U.S. carrier at Tokyo Haneda, by introducing new carrier competition for beyond points across the Western U.S. that already have Delta connecting service via Los Angeles and Seattle, and by making daily nonstop U.S. carrier Tokyo Haneda service available in the largest West Coast-Tokyo market in which it is not available currently. Moreover, the Department has already recognized the “notable attributes” of United “offer[ing] the first U.S. carrier nonstop service using its own aircraft in the sizeable San Francisco-Tokyo Haneda market...[and] an extensive number of online connections through its San Francisco hub to an appreciable catchment area.” Order 2012-11-12 at 6.Docket DOT-OST-2010-0018

Tokyo Haneda 

## Before The Department Of Transportation 2010 U.S. – Tokyo Haneda Combination Services Allocation

Proceeding Docket DOT-OST-2010-0018

Nonstop San Francisco – Tokyo Haneda

Reply Exhibits of:Docket DOT-OST-2010-0018

Tokyo Haneda Index of Exhibits Page 1 of 2 

### United Index Of Reply Exhibits Exhibit Number Tokyo - Haneda Service Number Of Pages UA-R-100 Kona – Tokyo Represents Only 4% Of The Hawaii –

Tokyo Market 1 UA-R-101 The Kona – Tokyo Market As A Percentage Of All Hawaii

– Tokyo Traffic Has Decreased Since The Last Route Proceeding 1 UA-R-102 Kona Represents 4% Of Hawaii’s Tokyo Traffic, Whereas

San Francisco Represents 33% Of California’s Tokyo Traffic 1 UA-R-103 The Kona – Tokyo Market Size Has Decreased 34%

Since The Last Route Proceeding 1 UA-R-104 The San Francisco – Tokyo Market Size Has Increased

7% Since The Last Route Proceeding 1 UA-R-105 Despite Hawaiian’s Claims Of Market Potential, Kona

Has Failed At Maintaining Nonstop Tokyo Service 1 UA-R-106 Hawaiian, As An Incumbent, Is 100 Times The Size Of

United At Tokyo Haneda Given United Has Not Been Given The Opportunity To Operate At Haneda 1 UA-R-107 Hawaiian Has The Opportunity To Serve Tokyo Via Narita

Airport But Has Chosen To Not Do So 1 UA-R-108 United’s San Francisco – Tokyo Haneda Proposal Will

Reach 29 Times The Number Of Consumers As Hawaiian’s Kona – Tokyo Haneda Proposal 1 UA-R-109 United Proposes To Provide First Time U.S. Carrier

Connecting Service And/Or Competitive Connecting Service Between Tokyo Haneda And Smaller Western Communities 1
UA-R-110 United’s Flight Schedule Will Provide Roundtrip, Online

Connections To/From Tokyo Haneda (Via San Francisco) To 16 States And To 29 Points Across The U.S. 2 UA-R-111 United’s Flight Schedule Will Provide At Least Oneway,

Online Connections To/From Tokyo Haneda (Via San Francisco) To 22 States And To 43 Points Across The U.S. 2Docket DOT-OST-2010-0018

Tokyo Haneda Index of Exhibits Page 2 of 2 

### United Index Of Reply Exhibits Exhibit Number Tokyo - Haneda Service Number Of Pages UA-R-112 United’s Flight Schedules Will Provide Consumers The

Opportunity To Optimize Tokyo Haneda And Tokyo Narita (Via San Francisco) For Their Travel Needs 1
UA-R-113 Hawaiian Already Provides Online Service Between Kona

And Tokyo Haneda, Whereas United Has Not Had The Opportunity To Serve Tokyo Haneda With Its Own Aircraft And Crews 2

UA-R-114 California State Exports And Imports Total $161.7B And

$376.3B Respectively In 2012 1 UA-R-115 Japan Represents $13.1B In California Exports And

$41.5B In California Imports In 2012 1 UA-R-116 California’s Exports And Exports To Japan Far Surpass

Those Of Hawaii 1 UA-R-117 Japanese Visitors To California Total 561,000 And

Generate An Estimated Spend Of Over $1.1B 2 UA-R-118 More Japanese Companies Employ Workers In California

Than Companies From Any Other Country 1 UA-R-119 Average Japanese Spending In California Totals $1,969

Per Visitor Compared To The Overall Average At $1,883 UA-R-120 There Are 54 Fortune 500 Companies In California, With

31 Companies Residing in the San Francisco Area 2 UA-R-121 Letters Of Support 2 UA-R-122 United Products And Services 4Docket DOT-OST-2010-0018

Tokyo Haneda UA-R-100 Page 1 of 1 

### Kona - Tokyo Represents Only 4% Of The Hawaii - Tokyo Market

Source: MIDT YE September 2013 Note: Tokyo = Tokyo Haneda + Tokyo Narita Rebuttal To HA-2013A-303 305 306



### Hawaii - Tokyo Market Size 1,475,008 Kona - Tokyo Market Size 59,484 Kona Share Of State Total 4.0%

Hawaii - Tokyo StatisticsDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-101 Page 1 of 1 

### The Kona - Tokyo Market As A Percentage Of All Hawaii - Tokyo Traffic

Has Decreased Since The Last Route Proceeding

Source: MIDT YE September 2013, previous route proceeding Reply Exhibits of United Note: Tokyo = Tokyo Haneda + Tokyo Narita Rebuttal To HA-2013A-303 305 306 Kona Share Of Hawaii’s Total Traffic To/From Tokyo

Kona Share Of State Total Has Decreased Nearly Three Percentage PointsDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-102 Page 1 of 1

Rebuttal To HA-2013A-303 305 306

Source: MIDT YE September 2013 Note: Tokyo = Tokyo Haneda + Tokyo Narita 

### Kona Represents 4% Of Hawaii’s Tokyo Traffic, Whereas San Francisco Represents 33% Of California’s Tokyo Traffic

Gateway Share Of States’ Total Traffic To/From TokyoDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-103 Page 1 of 1

Rebuttal To HA-2013A-303 305 306 

### The Kona –Tokyo Market Size Has Decreased 34% Since The Last Route Proceeding

Kona – Tokyo Market Size

Source: MIDT YE September 2013, previous route proceeding Reply Exhibits of United Note: Tokyo = Tokyo Haneda + Tokyo Narita The Kona - Tokyo Market Size Has Decreased 34%Docket DOT-OST-2010-0018

Tokyo Haneda UA-R-104 Page 1 of 1

Rebuttal To HA-2013A-303 305 306 

### The San Francisco -Tokyo Market Size Has Increased 7% Since The Last Route Proceeding

San Francisco – Tokyo Market Size

Source: MIDT YE September 2013, previous route proceeding Reply Exhibits of United Note: Tokyo = Tokyo Haneda + Tokyo Narita The San Francisco - Tokyo Market Size Has Increased 7%Docket DOT-OST-2010-0018

Tokyo Haneda UA-R-105 Page 1 of 1 

### Despite Hawaiian’s Claims Of Market Potential, Kona Has Failed At Maintaining Nonstop Tokyo Service

Source: OAG Rebuttal To HA-2013A-303 305 306Docket DOT-OST-2010-0018

Tokyo Haneda UA-R-106 Page 1 of 1 

### Hawaiian, As An Incumbent, Is 100 Times The Size Of United At Tokyo Haneda Given United Has Not Been Given The Opportunity To Operate At Haneda Rebuttal To HA-2013A-113 707

Source: October 2013 OAG Note: To set the record straight, United notes that Hawaiian (like UA) codeshares on ANA’s HNL-HND frequency, bringing Hawaiian’s HNL-HND marketing activity to 14 weekly frequencies. Tokyo Haneda Market SizeDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-107 Page 1 of 1 

### Hawaiian Has The Opportunity To Serve Tokyo Via Narita Airport But Has Chosen To Not Do So Rebuttal To HA-2013A-Series 200 Exhibits

Source: October 2013 OAG Hawaiian’s Japan Operations



## Foreign Point Open Entry HA Service Fukuoka Yes Yes Osaka Yes Yes Sapporo Yes Yes Sendai Yes Yes Tokyo Haneda No Yes Tokyo Narita Yes NODocket DOT-OST-2010-0018

Tokyo Haneda UA-R-108 Page 1 of 1

Rebuttal To HA-2013A-Series 900 Exhibits

Proposal U.S. – Tokyo Passengers UA @ San

Francisco Larger UA @ San Francisco 1,717,184 29 Times HA @ Kona 59,484

U.S. – Tokyo Passengers

Source: MIDT YE September 2013, United 2013 Tokyo Haneda application Note: Tokyo = Tokyo Haneda + Tokyo Narita, United catchment area includes roundtrip connect points only. Hawaiian’s application was unclear regarding specific beyond Kona connecting points, if any. 

### United’s San Francisco - Tokyo Haneda Proposal Will Reach 29 Times The Number Of Consumers As Hawaiian’s Kona – Tokyo Haneda ProposalDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-109 Page 1 of 1

Rebuttal To HA-2013A-Series 900 Exhibits 

### United Proposes To Provide First Time U.S. Carrier Connecting Service And/Or Competitive Connecting Service Between Tokyo Haneda And Smaller Western Communities

San Francisco Eureka Eugene Boise

Modesto Reno Sacramento

United Proposed Connecting Tokyo Haneda Service Proposed Tokyo Haneda Gateway

Palm Springs Santa Barbara Monterey Redding Chico Redmond

Tucson Fresno San Luis Obispo Crescent City Medford

Source: United 2013 Tokyo Haneda application Note: Roundtrip and/or one-way connections shown based on summer schedules.Docket DOT-OST-2010-0018

Tokyo Haneda UA-R-110 Page 1 of 2

Rebuttal To HA-2013A-Series 200 Exhibits

San Francisco

Source: United 2013 Tokyo Haneda application Note: Roundtrip connections shown based on summer schedules. 

### United’s Flight Schedule Will Provide Roundtrip, Online Connections To/From Tokyo Haneda (Via San Francisco) To 16 States And To 29 Points Across The U.S.

States With Tokyo Haneda Connecting ServiceDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-110 Page 2 of 2

Rebuttal To HA-2013A-Series 200 Exhibits

Source: United 2013 Tokyo Haneda application Note: Roundtrip connections shown based on summer schedules.

Points With Tokyo Haneda Connecting Service

San Francisco Boise Boston

Burbank Chicago Cleveland

Dallas/Ft. Worth Denver Eugene Eureka

Houston Las Vegas Los Angeles Medford
Modesto Monterrey New York / JFK New York / Newark

Ontario Phoenix Portland Redding

Redmond
Reno Sacramento

Salt Lake City Santa Barbara

San Diego Seattle

Washington DC 

### United’s Flight Schedule Will Provide Roundtrip, Online Connections To/From Tokyo Haneda (Via San Francisco) To 16 States And To 29 Points Across The U.S.Docket DOT-OST-2010-0018

Tokyo Haneda UA-R-111 Page 1 of 2

Rebuttal To HA-2013A-Series 200 Exhibits

San Francisco

Source: United 2013 Tokyo Haneda application Note: Based on summer schedules, Alaska not shown. 

### United’s Flight Schedule Will Provide At Least Oneway, Online Connections To/From Tokyo Haneda (Via San Francisco) To 22 States And To 43 Points Across The U.S.

States With Tokyo Haneda Connecting ServiceDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-111 Page 2 of 2

Rebuttal To HA-2013A-Series 200 Exhibits

Points With Tokyo Haneda Connecting Service

San Francisco Boise Boston

Burbank Chicago Cleveland

Dallas/Ft. Worth Denver Eugene
Eureka

Houston Las Vegas Los Angeles Medford
Modesto Monterrey New York / JFK New York / Newark

Ontario Phoenix Portland Redding

Redmond
Reno Sacramento

Salt Lake City Santa Barbara

San Diego Seattle

Washington DC

Source: United 2013 Tokyo Haneda application Note: Based on summer schedules, Anchorage not shown. Baltimore Chico
Fresno Orange County Palm Springs Philadelphia

Tuscon Crescent City

Kansas City Minneapolis

New Orleans San Antonio San Luis Obispo 

### United’s Flight Schedule Will Provide At Least Oneway, Online Connections To/From Tokyo Haneda (Via San Francisco) To 22 States And To 43 Points Across The U.S.Docket DOT-OST-2010-0018

Tokyo Haneda UA-R-112 Page 1 of 1

Rebuttal To HA-2013A-Series 200 Exhibits

Source: United 2013 Tokyo Haneda application Note: Based on summer schedules. 

### United’s Flight Schedules Will Provide Consumers The Opportunity To Optimize Tokyo Haneda And Tokyo Narita (Via San Francisco) For Their Travel Needs

Flight # Depart Kansas City Arrive San Francisco Equipment Type Frequency Flight # Depart San Francisco Arrive Tokyo Haneda Equipment Type Frequency 5481 16:29 18:17 CR7 1234567 875 19:20 22:10 B777 1234567

Flight # Depart Tokyo Narita Arrive San Francisco Equipment Type Frequency Flight # Depart San Francisco Arrive Kansas City Equipment Type Frequency 838 15:50 9:25 B747-400 1234567 4970 12:25 17:53 CR7 1234567 Kansas City To Tokyo Haneda

Tokyo Narita To Kansas City Split Service Utilizing Tokyo Haneda And Tokyo Narita

Service Utilizing Tokyo Haneda Only

Flight # Depart Cleveland Arrive San Francisco Equipment Type Frequency Flight # Depart San Francisco Arrive Tokyo Haneda Equipment Type Frequency 1472 12:30 14:55 B737-800 1234567 875 19:20 22:10 B777 1234567

Flight # Depart Tokyo Haneda Arrive San Francisco Equipment Type Frequency Flight # Depart San Francisco Arrive Cleveland Equipment Type Frequency 876 00:05 17:55 B777 1234567 1685 22:40 6:15 B737-800 1234567 Cleveland To Tokyo Haneda

Tokyo Haneda To ClevelandDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-113 Page 1 of 2

Rebuttal To HA-2013A-Entire Application And Answer

Source: Hawaiian website 

### Hawaiian Already Provides Online Service Between Kona And Tokyo Haneda, Whereas United Has Not Had The Opportunity To Serve Tokyo Haneda With Its Own Aircraft And Crews

Flight: HA 147 Duration: 43m Aircraft: Boeing 717 Depart: 3:06pm Kailua/Kona (KOA) Arrive: 3:49pm Honolulu (HNL) Layover in HNL: 2h 36m Flight: HA 457 Duration: 8h 40m Aircraft: Airbus A332 Depart: 6:25pm Honolulu (HNL) Arrive: 10:05pm Arrives Next Day (+1) Tokyo (HND) Kona To Tokyo HanedaDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-113 Page 2 of 2

Rebuttal To HA-2013A-Entire Application And Answer

Source: Hawaiian website 

### Hawaiian Already Provides Online Service Between Kona And Tokyo Haneda, Whereas United Has Not Had The Opportunity To Serve Tokyo Haneda With Its Own Aircraft And Crews

Flight: HA 458 Duration: 7h 25m Aircraft: Airbus A332 Depart: 11:55pm Tokyo (HND) Arrive: 12:20pm Honolulu (HNL) Layover in HNL 4h 43m Flight: HA 388 Duration: 43m Aircraft: Boeing 717 Depart: 5:03pm Honolulu (HNL) Arrive: 5:46pm Kailua/Kona (KOA) Tokyo Haneda To KonaDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-114 Page 1 of 1

Rebuttal To HA-2013A-Series 600 Exhibits California 2012 Exports In Billions

Total: $161.7 Billion

Source: California Data Sheet April 2013 

### California State Exports And Imports Total $161.7B And $376.3B Respectively In 2012

California 2012 Imports In Billions

Total: $376.3 BillionDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-115 Page 1 of 1

Rebuttal To HA-2013A-Series 600 Exhibits

Source: California Data Sheet April 2013 

### Japan Represents $13.1B In California Exports And $41.5B In California Imports In 2012

Japan Rank Among Asian Countries Regarding

California Exports & Imports
Export Rank: 2 nd Import Rank: 2nd California Trade Statistics In BillionsDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-116 Page 1 of 1

Source: California Data Sheet April 2013, U.S. Census Export Data by State 

### California’s Exports And Exports To Japan Far Surpass Those Of Hawaii State Export Statistics In Billions

State Export Statistics To Japan In Billions

Rebuttal To HA-2013A-Series 600 ExhibitsDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-117 Page 1 of 2

Rebuttal To HA-2013A-Series 600 Exhibits

Source: California Data Sheet April 2013, latest data available 

### Japanese Visitors To California Total 561,000, And Generated An Estimated Spend Of Over $1.1B

2011 Japanese Visitors To CaliforniaDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-117 Page 2 of 2

Rebuttal To HA-2013A-Series 600 Exhibits

Estimated Japanese Visitors Spend In California In Billions 

### Japanese Visitors To California Total 561,000, And Generated An Estimated Spend Of Over $1.1B

Source: California Data Sheet April 2013, 2011 statistics shown, assumes a 7.6 average night stay per tripDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-118 Page 1 of 1

Rebuttal To HA-2013A-Series 600 Exhibits

Source: California Data Sheet April 2013 

### More Japanese Companies Employ Workers In California Than Companies From Any Other Country

Number Of Foreign Companies Operating In CaliforniaDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-119 Page 1 of 1

Rebuttal To HA-2013A-Series 600 Exhibits

Source: California Data Sheet April 2013, 2011 statistics shown, assumes a 7.6 average night stay per trip 

### Average Japanese Spending In California Totals $1,969 Per Visitor Compared To The Overall Average At $1,883

Foreign Traveler Spend In CaliforniaDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-120 Page 1 of 2

Rebuttal To HA-2013A-Series 600 Exhibits

Source: Fortune Magazine 

### There Are 54 Fortune 500 Companies In California, With 31 Companies Residing In The San Francisco Area Fortune 500 Companies In CaliforniaDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-120 Page 2 of 2

Rebuttal To HA-2013A-Series 600 Exhibits

Source: Fortune Magazine 

### There Are 54 Fortune 500 Companies In California, With 31 Companies Residing In The San Francisco Area
Fortune 500 Companies In San Francisco AreaDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-121 Page 1 of 2 

### Letters Of Support



## United provides letters of support for daily, nonstop service between San Francisco and Tokyo Haneda. United notes additional letters of support were filed in United’s answer in this year’s proceeding as well as in United’s 2012 San Francisco – Tokyo Haneda

applicationDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-121 Page 2 of 2 

### Letters Of SupportDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-122 Page 1 of 4 

### United Products And Services



## United provides samples of various in-flight

products and servicesDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-122 Page 2 of 4 

### United Products And Services

United’s GlobalFirst CabinDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-122 Page 3 of 4 

### United Products And Services

United’s BusinessFirst CabinDocket DOT-OST-2010-0018

Tokyo Haneda UA-R-122 Page 4 of 4 

### United Products And Services
United’s New Economy Cabin