BEFORE THE DEPARTMENT OF TRANSPORTATION OFFICE OF THE SECRETARY WASHINGTON, D.C.

__________________________________________ ) Application of ) ) HAWAIIAN AIRLINES, INC. ) Docket DOT-OST-2010-0018 ) in the matter of 2010 U.S.-Haneda ) Combination Services Allocation Proceeding ) __________________________________________)

APPLICATION OF HAWAIIAN AIRLINES, INC. FOR SERVICE BETWEEN KONA, HAWAII AND TOKYO, JAPAN (HANEDA AIRPORT)
Communications with respect to this document should be addressed to: Mark B. Dunkerley President & Chief Executive Officer Hoyt H. Zia Senior Vice President, General Counsel & Corporate Secretary

Mark K. Arimoto Associate General Counsel

Hawaiian Airlines, Inc. P.O. Box 30008 Honolulu, HI 96820-0008 Jonathan B. Hill J. Parker Erkmann Benjamin M. Berlin Dow Lohnes PLLC 1200 New Hampshire Ave., NW Suite 800 Washington, DC 20036 (202) 776-2000 (202) 776-4725 (fax) jhill@dowlohnes.com perkmann@dowlohnes.com bberlin@dowlohnes.com Counsel for Hawaiian Airlines, Inc.

October 24, 2013BEFORE THE DEPARTMENT OF TRANSPORTATION OFFICE OF THE SECRETARY WASHINGTON, D.C.

__________________________________________ ) Application of ) ) HAWAIIAN AIRLINES, INC. ) Docket DOT-OST-2010-0018 ) in the matter of 2010 U.S.-Haneda ) Combination Services Allocation Proceeding ) __________________________________________)

APPLICATION OF HAWAIIAN AIRLINES, INC. FOR SERVICE BETWEEN KONA, HAWAII AND TOKYO, JAPAN (HANEDA AIRPORT) In light of American Airlines, Inc.’s decision to terminate its New York (JFK)-Tokyo Haneda service as of December 1, 2013, thus free ing up an additional frequency for US carriers to operate to Tokyo’s Haneda airport, Hawaiian Ai rlines, Inc. (“Hawaiian” ) respectfully submits this Application for the allocation of a slot pa ir for daily scheduled combination services at Tokyo International Airport (“Haneda”). 1 Hawaiian proposes to inst itute service to and from Kona International Airport, K ona, Hawaii (“Kona”). Kona is the second largest O & D market without direct service. 2
OPENING STATEMENT Through this application Hawaiian seeks to ex pand and strengthen its already successful entry into the U.S.-Japan comb ination service market. In th e 2010 proceeding, Hawaiian stated

1 See American’s October 23, 2013 letter to Esta Rosenberg, Chief, U.S. Air Carrier Licensing Division, returning the slot pair to the Department of Transportation. 2 Hawaiian recognizes that United Airlines has file d a competing application for the slot pair at Haneda, and that under the Ashbacker doctrine, the Department is required to institute proceedings to allocate the requested authorityDOT-OST-2010-0018 Application of Hawa iian Airlines, Inc. Page 2 of 12
that the award of Haneda slots was an integral part of its pl an to become an important new competitor in Japan. Since the award of the in itial Honolulu-Haneda sl ot pair, Hawaiian has delivered on those promises. Since 2010, Hawaiian has initiated direct se rvice from Honolulu to Tokyo Haneda, Osaka-Kansai, Sendai, Fukuoka, a nd Sapporo-Chitose. Hawaiian also offers codeshare service with ANA to Hiroshima, Kagoshima, Oita, Okinawa, Osaka-Itami and Sapporo-Chitose. Hawaiian’s initiation of se rvice between Kona and Haneda will insure maximum utilization of the limited frequencies av ailable at Haneda by providing service to not only the international market with the highest demand for service from and to Kona, but the second highest O&D market without non-stop service to Tokyo. It will provide the first service between Kona, Hawaii and Tokyo’s close-in airpor t, Haneda. Based upon the data available, Hawaiian’s present Haneda service has generate d more traffic than any other authorized destination. Kona will provide the same highest a nd best use of the scarce resource, slot pairs to Haneda. Hawaiian expects high Japanese demand for its proposed Kona service. Despite not having nonstop service to Tokyo, Kona already has more point of sale Japan passengers than 13 existing U.S. markets with Tokyo nonstop service. This application represents the continua tion of a logical and carefully thought-out expansion of service, consistent with Hawaiian’ s business plan of establ ishing itself as a major air carrier in the Pacific. Ha waiian has sought to capitalize on the unique geographic location of its hub operations in the middle of the Pacific Ocean by increasing its services all along the Pacific Rim. In addition to providing servic e to the continental United States, Hawaiian now serves destinations in Japan, South Korea, Tahi ti, American Samoa, Australia, New Zealand, and Taiwan, and has announced service to China. In itiating highly-demanded service from HanedaDOT-OST-2010-0018 Application of Hawa iian Airlines, Inc. Page 3 of 12 to Kona is a natural progressi on in the execution of Hawaiian’s business strategy. Hawaiian has consistently and repeatedly re quested a second Haneda frequency from the initiation of this proceeding. 3 Hawaiian’s proposed service to Kona, Hawaii’s second largest destination for Japanese tourists without non-stop service, will be a timely and l ogical response to a destination that has always experienced strong and reliab le passenger demand, maximizing the benefits for the traveling public, Hawaii and the United States. Hawaiian’s longstanding commitment to the Japa nese market facilitated the success of its first Haneda service. Its cu rrent service between Haneda a nd Honolulu has been the most successful service of all gatewa ys approved in the 2010 proceedi ng. As Hawaiian predicted in the 2010 proceeding, traffic between Honolulu and Tokyo has increased by significantly more than any other route awarded in that proceedi ng. Hawaiian’s initial c onfidence and resulting success is based in substa ntial part on Hawaiian’s long-standing and deep ties to the Japanese market. During the 1980s and early 1990s, Hawaiia n was the largest provide r of charter service between the United States and Japan, and it has had a sales presence in Japan for nearly four (4) decades. Hawaiian also maintain s a Japanese language website. 4 Hawaiian’s proposed service to Kona also, uni quely, will infuse much-needed additional spending by foreign nationals into Hawaii’s tour ism-based economy. Because Hawaiian expects the overwhelming majority of the traffic on the proposed route to originate in Japan, the

3 See Application of Hawaiian Airlines, DOT-OST-2010-0018, (Feb. 16, 2010), at 5, 7; Consolidated Answer of Hawaiian Airlin es, DOT-OST-2010-0018, (Mar . 1, 2010), at 1-2, 4; Consolidated Reply of Hawaiian Airlin es, DOT-OST-2010-0018, (Mar. 8, 2010), at 3; Objections of Hawaiian Airlines, DOT-OST -2010-0018, (May 5, 2010), at 2; Answer of Hawaiian Airlines, DOT-OST-2010-0018, (Dec. 21, 2010) , at 1; Application and Consolidated Answer of Hawaiian Airlines, DOT-OST-2010-0018, (Apr. 7, 2011), at 6. 4 See http://www.hawaiianairlines.co.jp/.DOT-OST-2010-0018 Application of Hawa iian Airlines, Inc. Page 4 of 12 economic impact on Hawaii’s economy of Hawa iian’s service will be significant due to increased spending in the Hawaiia n Islands by Japanese tourists. Unlike the other proposal to date that focuses on U.S. originating traffic, Hawaiian’s Japanese orig inating service provides the unique economic benefit to the United States and Hawaii of bringing significant additional spending to Hawaii and the United States that will create jobs and further benefits within the economies of Hawaii and the United States as a whole and does not e xport US dollars and spending to a foreign country. Hawaiian has discussed its service proposals w ith representatives of its major Japanese travel partners; based on its pres ent service and the indications of interest in the new proposed service, Hawaiian is confident that there is sufficient demand to support its proposed Kona service. Unlike the underwhelming track record of the other Haneda routes operated by U.S. flag carriers, the consistent, uninte rrupted performance of the Hane da-Honolulu route substantiates Hawaiian’s confidence that the new Kona service will be a boon for its passengers as well as for the State of Hawaii and the United States. Prior, unsuccessful efforts by other carriers to service this route have included a stop in Honolulu on the return flight and the use of improperly sized airc raft. In contrast, Hawaiian will use its modern, properly-gauged A330-200s and will provide the service on a bi-directional, nonstop basis. Given its demonstrated commitment to serving the Japanese market, its superior customer service, and its financial streng th, Hawaiian is well-positioned to inaugurate new service to Kona from Haneda as part of its su ccessful and growing Asian network.DOT-OST-2010-0018 Application of Hawa iian Airlines, Inc. Page 5 of 12
Public Interest The primary public interest benefits resulti ng from Hawaiian’s initiation of daily service to Kona from Haneda include: (1) maximizing the use of a scarce resource, frequencies to Haneda, by introducing new service to a highly p opular gateway for Japanese passengers; (2) increasing competition and reduci ng market concentration through a smaller and independent U.S. competitor with the operational and financia l strength to mount and sustain service in the market against significantly larger U.S. and forei gn carriers; (3) ensuring that the benefits of the frequency available are not essen tially given to Japanese carriers that operate under antitrust immunity with their United States partners, su ch as United and its Star Alliance partner, All Nippon Airways (who already provides service betw een the U.S. and Haneda via LAX), and (4) leveraging the economic benefit that Hawaiian’ s Japan-originating pa ssengers bring in both business and leisure spending to the State of Hawa ii and the U.S., whereas other carrier services dependent on U.S. originating traffic takes spen ding out of the U.S. economy. As noted in the Opening Statement, Hawaiian’s initiation of serv ice to Kona would satisfy the demand in the second-largest O&D market between the United States and Tokyo without non-stop service. Hawaiian offers a differentiated product through award-winning customer service as well as the best record of on-time arrivals in the industry among U.S. carriers fo r the past nine (9) years with a proposal that maximizes the utiliz ation of the frequency available. Based upon its present service, its traffic st udies and the response it has received from the Japanese travel trade to the po ssibility of Hawaiian’s implementa tion of the additional service to Kona, Hawaiian believes there is sufficient demand by Japanese tourists to support separate daily flights between Haneda and H onolulu and Kona. Hawaiian has carefully considered whether two daily Haneda flights could be successfully ma intained. Although it is in part a consequenceDOT-OST-2010-0018 Application of Hawa iian Airlines, Inc. Page 6 of 12 of time restrictions imposed at Haneda for inte rnational flights, operating two flights with the proposed schedules would have significant appeal to travelers in the market. Travelers in Japan could depart for the airp ort after a full day of work and dinner at home, and arrive in Honolulu or Kona in time for hotel check-in. On the return tr ip, travelers could spend a full day in Kona or Honolulu and return home in ti me for work the next day. Hawaiian also will set a new standard in passenger service and consumer choice by delivering Hawaiian’s award-winning customer se rvice, modern, fuel-efficient aircraft, and strong on-time performance to these markets. Hawaiian has led all U.S. carriers in on-time performance for each of the past nine years (2004 -2012) as reported by the U.S. Department of Transportation. In support of its application, Hawaiian states as follows:
1. Hawaiian is incorporated under the laws of Delaware, and its headquarters are located in Honolulu, Hawaii.
2. Hawaiian is a citizen of the United States as defined in 49 U.S.C. § 40102(a)(15).
3. The Department has repeatedly found Ha waiian fit to provid e interstate and foreign transportation of persons, property and mail, including service to Haneda in Order 2010- 7-2. More recently, the Department approved Hawaiian for China service by Notice of Action Taken in Docket DOT-OST-2013-0071, issued April 26, 2013, approving service from Honolulu, Hawaii to Beijing, China. The Departme nt also has granted Hawaiian a blanket route integration certificate of public convenience and necessity as well as open-skies certificate authority. See Order 2007-7-3 (July 10, 2007); Order 2006- 1-1 (Mar. 7, 2006). Hawaiian asks that the Department take offi cial notice of these and all ot her Orders finding Hawaiian ready,DOT-OST-2010-0018 Application of Hawa iian Airlines, Inc. Page 7 of 12 willing and able to provide scheduled foreign ai r transportation of persons, property and mail, pursuant to Rule 24 of its Rules of Practice.
4. Hawaiian is fit, and expects to remain fit, to provide scheduled foreign air transportation of persons, prope rty and mail to and from th e United States and Japan. 5. Hawaiian proposes to initiate daily nons top flights between Haneda and Kona. A total of seven (7) round-trip frequencies will be used each week with se rvice between Kona and Haneda. Service would begin on a date specifie d by the Department, so long as such a date provides reasonable opportunity fo r advance selling of the new se rvice. Hawaiian proposes that service should begin on or about April 1, 2014. Hawaiian intends to operate its proposed flights with Airbus 330-200 aircraft. 5 Each flight will have 294 seat s, 18 seats in First Class, and 276 seats in Coach. The route maps and correspond ing flight schedules proposed by Hawaiian for each daily slot pair to Haneda are set forth in Exhibits HA-App2013-1 and HA-App2013-2.
6. This application is consistent with the Memorandum of U nderstanding (“MOU”) initialed by the United States and Japan on or about December 11, 2009. The Open Skies Agreement entered into effect on November 13, 2010.
7. The grant of a slot pair to Hawaiian for se rvice from Haneda to Kona will inject new competition into the Tokyo market from Hawaii and build upon Hawaiian’s already successful service from Haneda to Honolulu. Kona is a large market for Japanese tourists and Hawaiian already has a strong pres ence in Tokyo and across Japan.

5 Given Hawaiian’s financial st rength, Hawaiian has ordered a nd is receiving new Airbus 330- 200 aircraft. To date, Hawaiian operates 13 A330- 200 aircraft, and will take delivery of 9 more A330 aircraft during the next two years, bringing to 22 its total of wide-body aircraft by 2015.DOT-OST-2010-0018 Application of Hawa iian Airlines, Inc. Page 8 of 12
8. Of the three U.S. carrier routes awarde d slot pairs in the 2010 Haneda slot allocation proceeding, Hawaiian’s Honolulu service has been by far the most, if not the only, successful route. Not only was Hawaiian the fi rst recipient of Haneda authority to initiate service, but it has flown the route continuously si nce its launch, even in the aftermath of the tragic earthquake and tsunami in 2011 as promised to DOT in its applicati on. In fact, with only one route, it has carried more passengers betw een the U.S. and Tokyo Haneda than any other U.S. carrier (including Delta wi th its two awarded routes). Since starting service, Hawaiian upgraded its aircraft used on the route from a B767-300ER to an A330-200 as it promised in its original application. Moreover, Hawaiian’s service has stimulat ed traffic between Honolulu and Tokyo significantly more than the other carriers’ routes have between their origin markets and Tokyo. Unlike Delta, and American, Hawaiian has ke pt its promises made and run its service as stated in its application. Delta has moved one of its services from Detro it to Seattle and now is operating service at less than 7 days a week frequency. Ameri can is dropping its New York service entirely. Delta’s other Haneda servi ce (LAX) has been operated with significantly smaller aircraft than originally proposed and has been subjected to numerous days without nonstop service.
9. The award of American’s frequencies to Hawaiian will insure the highest and best use of these scarce resources fo r the benefit of the traveling public and the economic benefit of the State of Hawaii and the United States. This service meets the demand for the largest international origin market to Kona, which is Tokyo, as well as the seco nd-largest destination market from Tokyo without non-stop service. Fo r Japanese travelers, access to Kona is only available through Honolulu; as such, the availabi lity of direct service will be attractive to Japanese-originating tourists. Hawaiian’s extensive Neighbor Isla nd schedule would allowDOT-OST-2010-0018 Application of Hawa iian Airlines, Inc. Page 9 of 12 Haneda passengers arriving in Kona easy and fr equent access to Hawaii’s nearby destinations. Through providing a valuable new entry point fo r Japanese-originating travelers, Hawaiian’s new Kona service will help promote the U.S. e xport of tourism and further stimulate Hawaii’s tourism-based economy. Service Proposal Hawaiian proposes to initiate daily nons top year-round flights between Tokyo Haneda, Japan and Kona, Hawaii. Hawaiian will initiate service on or about 90 days following issuance of the final order, or on approximately April 1, 2014, which will provide sufficient time to presell the service. The aircraft would depart K ona at 17:50 local (May th rough October) and arrive in Haneda at 22:00 +1 day. On the return trip, the aircraft would depart at 23:55 and arrive in Kona at 12:50 on the same day. Owing to wi nter head winds there would be a slight seasonal variation in the timing of the Kona service. For the period November to Ap ril, the aircraft would depart Kona at 17:35 and arrives at Haneda at 22:00 +1 day. The return would depart Haneda at 23:55 and arrive at Kona at 12:45 on the same day. All departure and arrival times stated herein are local. Route maps and proposed schedules, includ ing inter-island connections, are set forth in Exhibit HA-App2013-1, 2. Hawaiian will use newly acquired, state-of-the-art A330-200 airc raft with 294 total seats (18 Business Class “J” seats and 276 Economy “Y” seats). Hawaiian will also offer attractive connecting service to enhance it s proposed service offering. Hawaiian will offer its Neighbor Hawaiia n Island connecting servic e to all passengers. In addition, Hawaiian will offer passengers the o pportunity to stopover without charge in Kona or Honolulu when traveling in either direction, giving its cust omers the option to break theirDOT-OST-2010-0018 Application of Hawa iian Airlines, Inc. Page 10 of 12 flight in Hawaii before continuing on to Japan or to additional points in the continental United States. Hawaiian will increase connective capacity for passengers on its Haneda-Kona service to other Neighbor Hawaiian Islands by upgrading at l east one flight a day from Kona to Honolulu to a wide-body aircraft. Current Service to Tokyo Hawaiian currently provides daily direct service between Honolulu and Tokyo, Haneda, seven days a week. 6 It does not offer code-share service to Tokyo. Availability of Aircraft Hawaiian presently has 13 new A330-200 aircraft , with a 14th aircraft scheduled to arrive in 2013 and 5 more deliveries scheduled in 2014. Hawaiian proposes to use an A330-200 aircraft made available by the deliveries sl ated for early 2014 for its Kona-Haneda route. Hawaiian has taken delivery of 13 A330-200 airc raft using lease fina ncing and/or debt financing and will acquire additional aircraft using conventional financing or leases. In 2017, Hawaiian will begin taking delivery of A350-800s, which may be used on the Kona-Haneda route in the future. All of Hawaiia n’s aircraft are compliant with FAR Part 36. Annual Fuel Consumption Hawaiian estimates that the proposed daily service between Kona and Haneda using its A330 aircraft will consume approximately 10,600,000 USG per year. Hawaiian does not anticipate that the institu tion of its proposed flights will resu lt in a near-term annual net fuel

6 Hawaiian’s present service departs Honolulu at 18:30 and arrives Haneda 22:05+1 day and departs Haneda at 23:55 and arrives Honolulu at 12:25 (May through October). During the winter (November through April), the aircraft de parts Honolulu at 17:40 and arrives Haneda at 22:05 +1 day, and departs Haneda at 23: 55 +1 day and arrives Honolulu at 11:35.DOT-OST-2010-0018 Application of Hawa iian Airlines, Inc. Page 11 of 12 increase of 10 million gallons or more as there will be net reduction of approximately 6.2 million gallons of fuel consumed due to the shorter dist ance to Kona from Haneda as compared to New York. Hawaiian has been given assurance through its fuel suppliers, Cosmo in Haneda and Chevron in Kona, that sufficient fuel to operate the proposed flights will be available at both airports. Start of Service Hawaiian will accept, as it did in the first allocation of frequencie s, a requirement to institute service by a date specified by the Depa rtment. It would be Hawaiian’s recommendation that the Department specify a date of no earlier than 90 days after issuance of the final order and allow sufficient time to pre-sell th e flight, such as April 1, 2014. Hawaiian was not only the first carrier to init iate service to Haneda in 2010, unlike other carriers in this proceeding it maintained the leve l of that service througho ut the period following the earthquake and tsunami and, as promised, s ubstituted its new A330-200 aircraft for the B767- 300ER aircraft as those new aircraft went into service. This is in sharp contrast to the other carriers such as Delta and American that have terminated, moved service or sharply reduced it during this period.DOT-OST-201 0-0018 Application of Hawaiian Airlines, Inc. Page 12 of 12

For the foregoing reasons, Hawaiian respectfully requests that the Department award it a second daily slot pair to operate daily combination service between Haneda and Kona, Hawaii as
set forth herein.

. Parker Erkmann Benjamin M. Berlin Dow Lohnes PLLC 1200 New Hampshire Ave., NW Suite 800 Washington, DC 20036 (202) 776-2000 (202) 776-4 725 (fax) jhill@dowlohnes.com perkmann@dow lohnes.com bberlin@dowlohnes.com Counsel tor Hawaiian Airlines, Inc.



# J

### HAWAIIAN PROPOSED NONSTOP SERVICE BETWEEN KONA AND HANEDA Exhibit HA-App2013-1 Docket OST-2010-0018 Page 1 of 1

4,008 Miles Tokyo (HND)

Kona (KOA)

### HAWAIIAN AIRLINES’ PROPOSED KOA – HND NONSTOP SERVICE Airbus 330-200 Aircraft Exhibit HA-App2013-2 Docket OST-2010-0018 Page 1 of 1

Summer 9:10


### 2200 +1

1735 TOKYO (HND)

KONA (KOA) Summer 7:55 

### 2355

1250 Winter

9:25 Winter 7:50


### 2355

1245 HA 432

Daily HA 431 Daily



### 2200 +1

1750

Note: All Times Local. Season Elapsed Time Flight Freq/WkCERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing Application of Hawaiian Airlines, Inc. for Service Between Kona, Hawai'i and Tokyo, Japan (Haneda Airport) was served this 24th day of October, 2013 via email transmission or U.S. mail on the following: megan.lawrence@alaskaair.com kyle.Jevine@alaskaair.com francis.heil@aa.com will_ris@amrcorp.com sascha.vanderbellen@delta.com sametta.c.barnett@delta.com chris.walker@delta.com dan.weiss@united.com steve.monissey@united.com lhalloway@crowell.com gmurphy@crowell.com howard.kass@usairways.com benjamin.slocum@usairways.com esta.rosenberg@dot.gov robert.finamore@dot.gov brett.kruger@dot.gov paul.gretch@dot.gov jolm.s.duncan@faa.gov urskr@state.gov info@airlineinfo.com
Ambassador Kenichiro Sasae Embassy of Japan 2520 Massachusetts Ave., NW Washington, DC 20008

Benjamin M. Berlin