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, 2013
 

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) 

 In light of American Airlines, Inc.’s decision to terminate its New York (JFK)-Tokyo 

Haneda service as of December 1, 2013, thus freeing up an additional frequency for US carriers 

to operate to Tokyo’s Haneda airport, Hawaiian Airlines, Inc. (“Hawaiian”) respectfully submits 

this Application for the allocation of a slot pair for daily scheduled combination services at 

Tokyo International Airport (“Haneda”).1 Hawaiian proposes to institute service to and from 

Kona International Airport, Kona, Hawaii (“Kona”). Kona is the second largest O & D market 

without direct service.2

OPENING STATEMENT

 Through this application Hawaiian seeks to expand and strengthen its already successful 

entry into the U.S.-Japan combination service market. In the 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 filed 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 authority
DOT-OST-2010-0018 

Application of Hawaiian Airlines, Inc. 

Page 2 of 12 

that the award of Haneda slots was an integral part of its plan to become an important new 

competitor in Japan. Since the award of the initial Honolulu-Haneda slot pair, Hawaiian has 

delivered on those promises. Since 2010, Hawaiian has initiated direct service from Honolulu to 

Tokyo Haneda, Osaka-Kansai, Sendai, Fukuoka, and Sapporo-Chitose. Hawaiian also offers 

codeshare service with ANA to Hiroshima, Kagoshima, Oita, Okinawa, Osaka-Itami and 

Sapporo-Chitose. Hawaiian’s initiation of service between Kona and Haneda will insure 

maximum utilization of the limited frequencies available 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 airport, Haneda. Based upon the data available, 

Hawaiian’s present Haneda service has generated more traffic than any other authorized 

destination. Kona will provide the same highest and 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 continuation of a logical and carefully thought-out 

expansion of service, consistent with Hawaiian’s business plan of establishing itself as a major 

air carrier in the Pacific. Hawaiian 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 service to the continental United States, Hawaiian now 

serves destinations in Japan, South Korea, Tahiti, American Samoa, Australia, New Zealand, and 

Taiwan, and has announced service to China. Initiating highly-demanded service from Haneda 
DOT-OST-2010-0018 

Application of Hawaiian Airlines, Inc. 

Page 3 of 12 

to Kona is a natural progression in the execution of Hawaiian’s business strategy. Hawaiian has 

consistently and repeatedly requested 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 logical response to a destination 

that has always experienced strong and reliable passenger demand, maximizing the benefits for 

the traveling public, Hawaii and the United States. 

Hawaiian’s longstanding commitment to the Japanese market facilitated the success of its 

first Haneda service. Its current service between Haneda and Honolulu has been the most 

successful service of all gateways approved in the 2010 proceeding. As Hawaiian predicted in 

the 2010 proceeding, traffic between Honolulu and Tokyo has increased by significantly more 

than any other route awarded in that proceeding. Hawaiian’s initial confidence and resulting 

success is based in substantial part on Hawaiian’s long-standing and deep ties to the Japanese 

market. During the 1980s and early 1990s, Hawaiian was the largest provider 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 maintains a Japanese language website.4

 

Hawaiian’s proposed service to Kona also, uniquely, will infuse much-needed additional 

spending by foreign nationals into Hawaii’s tourism-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 Airlines, DOT-OST-2010-0018, (Mar. 1, 2010), at 1-2, 4; 

Consolidated Reply of Hawaiian Airlines, 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 Hawaiian Airlines, Inc. 

Page 4 of 12 

economic impact on Hawaii’s economy of Hawaiian’s service will be significant due to 

increased spending in the Hawaiian Islands by Japanese tourists. Unlike the other proposal to 

date that focuses on U.S. originating traffic, Hawaiian’s Japanese originating 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 export US dollars and 

spending to a foreign country. 

Hawaiian has discussed its service proposals with representatives of its major Japanese 

travel partners; based on its present 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, uninterrupted performance of the Haneda-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 aircraft. 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 strength, Hawaiian is well-positioned to inaugurate new service to Kona 

from Haneda as part of its successful and growing Asian network. 
DOT-OST-2010-0018 

Application of Hawaiian Airlines, Inc. 

Page 5 of 12 

Public Interest 

 The primary public interest benefits resulting 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 popular gateway for Japanese passengers; (2) 

increasing competition and reducing market concentration through a smaller and independent 

U.S. competitor with the operational and financial strength to mount and sustain service in the 

market against significantly larger U.S. and foreign carriers; (3) ensuring that the benefits of the 

frequency available are not essentially given to Japanese carriers that operate under antitrust 

immunity with their United States partners, such as United and its Star Alliance partner, All 

Nippon Airways (who already provides service between the U.S. and Haneda via LAX), and (4) 

leveraging the economic benefit that Hawaiian’s Japan-originating passengers bring in both 

business and leisure spending to the State of Hawaii and the U.S., whereas other carrier services 

dependent on U.S. originating traffic takes spending out of the U.S. economy. As noted in the 

Opening Statement, Hawaiian’s initiation of service 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 for the past nine (9) years with 

a proposal that maximizes the utilization of the frequency available. 

 Based upon its present service, its traffic studies and the response it has received from the 

Japanese travel trade to the possibility of Hawaiian’s implementation of the additional service to 

Kona, Hawaiian believes there is sufficient demand by Japanese tourists to support separate daily 

flights between Haneda and Honolulu and Kona. Hawaiian has carefully considered whether 

two daily Haneda flights could be successfully maintained. Although it is in part a consequence 
DOT-OST-2010-0018 

Application of Hawaiian Airlines, Inc. 

Page 6 of 12 

of time restrictions imposed at Haneda for international flights, operating two flights with the 

proposed schedules would have significant appeal to travelers in the market. Travelers in Japan 

could depart for the airport 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 trip, travelers could spend a full day in Kona or 

Honolulu and return home in time 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 service, 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 Hawaiian fit to provide 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 Department 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 official notice of these and all other Orders finding Hawaiian ready, 
DOT-OST-2010-0018 

Application of Hawaiian Airlines, Inc. 

Page 7 of 12 

willing and able to provide scheduled foreign air 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, property and mail to and from the United States and Japan. 

5. Hawaiian proposes to initiate daily nonstop flights between Haneda and Kona. A 

total of seven (7) round-trip frequencies will be used each week with service between Kona and 

Haneda. Service would begin on a date specified by the Department, so long as such a date 

provides reasonable opportunity for advance selling of the new service. 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 seats, 18 seats in First Class, and 276 

seats in Coach. The route maps and corresponding 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 Understanding (“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 service 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 presence in Tokyo and across Japan. 

                                                            

5

 Given Hawaiian’s financial strength, Hawaiian has ordered and 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 Hawaiian Airlines, Inc. 

Page 8 of 12 

8. Of the three U.S. carrier routes awarded 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 first recipient of Haneda authority to initiate 

service, but it has flown the route continuously since its launch, even in the aftermath of the 

tragic earthquake and tsunami in 2011 as promised to DOT in its application. In fact, with only 

one route, it has carried more passengers between the U.S. and Tokyo Haneda than any other 

U.S. carrier (including Delta with 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 stimulated 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 kept its promises made and run its service as 

stated in its application. Delta has moved one of its services from Detroit to Seattle and now is 

operating service at less than 7 days a week frequency. American is dropping its New York 

service entirely. Delta’s other Haneda service (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 for 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 second-largest destination 

market from Tokyo without non-stop service. For Japanese travelers, access to Kona is only 

available through Honolulu; as such, the availability of direct service will be attractive to 

Japanese-originating tourists. Hawaiian’s extensive Neighbor Island schedule would allow 
DOT-OST-2010-0018 

Application of Hawaiian Airlines, Inc. 

Page 9 of 12 

Haneda passengers arriving in Kona easy and frequent access to Hawaii’s nearby destinations. 

Through providing a valuable new entry point for Japanese-originating travelers, Hawaiian’s 

new Kona service will help promote the U.S. export of tourism and further stimulate Hawaii’s 

tourism-based economy. 

Service Proposal 

Hawaiian proposes to initiate daily nonstop 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 Kona at 17:50 local (May through 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 winter head winds there would be a slight seasonal variation 

in the timing of the Kona service. For the period November to April, 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, including inter-island connections, are set forth in 

Exhibit HA-App2013-1, 2. 

Hawaiian will use newly acquired, state-of-the-art A330-200 aircraft with 294 total seats 

(18 Business Class “J” seats and 276 Economy “Y” seats). 

Hawaiian will also offer attractive connecting service to enhance its proposed service 

offering. Hawaiian will offer its Neighbor Hawaiian Island connecting service to all passengers. 

In addition, Hawaiian will offer passengers the opportunity to stopover without charge in Kona 

or Honolulu when traveling in either direction, giving its customers the option to break their 
DOT-OST-2010-0018 

Application of Hawaiian 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 least 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 slated for early 2014 for its Kona-Haneda route. 

Hawaiian has taken delivery of 13 A330-200 aircraft using lease financing 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 Hawaiian’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 institution of its proposed flights will result 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 departs 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 Hawaiian 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 distance 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 frequencies, a requirement to 

institute service by a date specified by the Department. 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 the flight, such as April 1, 2014. 

Hawaiian was not only the first carrier to initiate service to Haneda in 2010, unlike other 

carriers in this proceeding it maintained the level of that service throughout the period following 

the earthquake and tsunami and, as promised, substituted 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/Wk
CERTIFICATE 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