BEFORE THE

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY

WASHINGTON, D.C. 

____________________________________

)

Motions and Applications of )

)

HAWAIIAN AIRLINES, INC. )

) Docket DOT-OST-2010-0018

AMERICAN AIRLINES, INC. )

)

in the matter of 2010 U.S.-Haneda )

Combination Services )

Allocation Proceeding )

____________________________________)

CONSOLIDATED REPLY OF HAWAIIAN AIRLINES, INC.

Communications with respect to this document should be addressed to:

Mark B. Dunkerley

President & Chief Executive Officer 

Peter Ingram

Executive Vice President and Chief

Commercial Officer

Hoyt H. Zia

Senior Vice President, General Counsel & 

Corporate Secretary

Hoyt.Zia@hawaiianair.com

Hawaiian Airlines, Inc.

P.O. Box 30008

Honolulu, HI 96820-0008

J. Parker Erkmann 

Jonathan B. Hill

Geoff Rapoport

Cooley LLP

1299 Pennsylvania Ave., NW

Suite 700

Washington, DC 20004

(202) 842-7800

(202) 842-7899 (fax)

jhill@cooley.com

perkmann@cooley.com

grapoport@cooley.com

Counsel for Hawaiian Airlines, Inc.

January 20, 2015
DOT-OST-2010-0018

2015 Reply of Hawaiian Airlines, Inc.

Page 1 of 16

BEFORE THE

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY

WASHINGTON, D.C. 

____________________________________

)

Motions and Applications of )

)

HAWAIIAN AIRLINES, INC. )

) Docket DOT-OST-2010-0018

AMERICAN AIRLINES, INC. )

)

in the matter of 2010 U.S.-Haneda )

Combination Services )

Allocation Proceeding )

____________________________________)

CONSOLIDATED REPLY OF HAWAIIAN AIRLINES, INC.

This proceeding presents the Department of Transportation (“Department” or “DOT”) 

with a policy choice. On the one hand, Hawaiian Airlines, Inc. (“Hawaiian”) has proposed a 

viable commercial service between Tokyo’s Haneda International Airport (“Haneda” or “HND”) 

and Kona International Airport (“Kona” or “KOA”) that has undisputed public interest benefits:

• Hawaiian’s Kona proposal will stimulate traffic growth in the Tokyo-Kona market, 

increasing the number of tourists visiting the United States and leading to more 

economic growth and jobs in the United States than any of the other proposals, see HA2015A-613-17, 620;

• Hawaiian will use the largest aircraft proposed in this proceeding and therefore fly the 

most capacity, see HA-2015A-113;

• Hawaiian has proposed to open a new Haneda gateway as opposed to gateways that have 

failed or are awash in service; and

• Hawaiian’s service will expand its competitive footprint against the major alliances.
DOT-OST-2010-0018

2015 Reply of Hawaiian Airlines, Inc.

Page 2 of 16

American Airlines (“American”) and Delta Air Lines (“Delta”), on the other hand, make 

arguments laced with economic jingoism that their proposed services would benefit more U.S. 

passengers than Hawaiian’s service. Besides being wrong about who benefits from foreign 

originating service, those services are not workable, redundant with existing Tokyo services and 

will provide minimal, if any, benefits to the United States. Delta’s Seattle service has proven to 

be a failure, and American proposes to inject more capacity into a market, Los Angeles (“LAX”),

that cannot absorb it. Indeed, by proposing to use the same flight numbers as its current LAXNarita (“NRT”) service for HND-LAX, American has foreshadowed that grant of its application 

will come at the expense of current service, undermining any potential incremental benefit of its 

proposal. 

Nevertheless, both Delta and American assert that the benefits of their connecting 

opportunities will save their respective proposals, but the benefits of their proposed connecting 

services for gateways to Haneda already have proven to be illusory See HA-2015R-109-11

(depicting minimal market impact of connecting services). Given the grave doubt concerning 

any public interest benefits from either of the alliance carriers’ proposals, the Department should 

select Hawaiian’s proposal to serve Kona so the Department can be assured that public interest 

benefits will result.

I. The Benefits of Foreign Originating Traffic Resulting from Hawaiian’s Proposal 

Outweigh the Benefits Proposed by American and Delta.

Delta and American would have the Department dismiss the benefits of Hawaiian’s 

application because “U.S. businesses should receive public interest priority over Japan’s 
DOT-OST-2010-0018

2015 Reply of Hawaiian Airlines, Inc.

Page 3 of 16

tourists.”1

 This line of argument is fundamentally misguided. As a threshold matter, both 

American and Delta have argued that the Department should favor particular U.S. business 

interests while ignoring the Administration’s tourism policy and the Department’s broader public 

interest mandate. The facts are that the greatest beneficiaries of Hawaiian’s proposal will be

U.S. businesses and workers. Indeed, American’s and Delta’s argument to elevate their

particular business interests above the public at large and without any attempt to quantify the 

benefits finds no support in the statute or Department policy. See 49 U.S.C. § 40101; see HA2015R-108. 

First, contrary to the arguments of Delta and American, the largest beneficiaries of 

Hawaiian’s service will be U.S. businesses and workers, not the Japanese businesses and workers 

benefited by Delta’s and American’s proposals. Delta and American would prefer that the 

Department ignore the stated policy of the Obama Administration encouraging tourism, which 

recognizes the significant economic power of the tourist dollars that Hawaiian would bring to the 

United States. Due to multiplier effects, the value to the U.S. economy extends far beyond the 

dollars spent by the tourists themselves.

 1

 Consolidated Answer of Delta Air Lines, Inc., DOT-OST-2010-0018 (Jan. 12, 2015), 

hereinafter “Delta Answer”, at 9; see also Consolidated Answer of American Airline, Inc., DOTOST-2010-0018 (Jan. 12, 2015), hereinafter “American Answer”, at 10 (“As a result, Japanese 

travelers, not U.S. travelers, will be the overwhelming beneficiaries of any Hawaiian Haneda 

service to Kona”). 
DOT-OST-2010-0018

2015 Reply of Hawaiian Airlines, Inc.

Page 4 of 16

See HA-2015R-101. Because Hawaiian’s proposal will stimulate much more traffic than Delta’s 

and American’s service and Japanese tourists spend more money when they visit Hawaii than 

when they visit the mainland U.S.,

2 the economic impact of Hawaiian’s service will be much 

greater. See HA-2015R-116. Hawaiian’s Kona flight will have a much more significant impact 

on U.S. gross domestic product than American’s flight. See HA-2015R-103 ($117 million per 

year for Hawaiian’s compared to $34 million for American’s). This additional spending would 

create nearly 1,000 more U.S. jobs than American’s proposal.

 2 See Exhibit HA-2015A-601.
DOT-OST-2010-0018

2015 Reply of Hawaiian Airlines, Inc.

Page 5 of 16

See HA-2015R-102. Given the dearth of traffic on Delta’s proposed Seattle service, the results 

tilt even more heavily in Hawaiian’s favor. Hawaiian’s service will increase U.S. GDP by 15 

times the amount of Delta’s proposal, see HA-2015R-105, with a similar disproportionate impact 

on U.S. jobs.
DOT-OST-2010-0018

2015 Reply of Hawaiian Airlines, Inc.

Page 6 of 16

See HA-2015R-104. Perhaps, being aware of the futility of comparison, Delta and American do 

not even attempt to estimate the economic impact of their services. See HA-2015R-108.
DOT-OST-2010-0018

2015 Reply of Hawaiian Airlines, Inc.

Page 7 of 16

Second, promotion of the tourism and the economic benefits that derive therefrom is a 

stated goal of the Obama Administration. As pointed out in Hawaiian’s answer, the promotion 

of tourism is a Presidential level economic priority.3

 Not only has the President given personal 

attention to this issue within the last year, the Department has recognized the importance of 

promoting tourism and economic growth in this very proceeding when it awarded Hawaiian its 

first Haneda slot pair:

However, we tentatively find that, in addition to the service and competitive 

benefits outlined above, Hawaiian’s service would benefit the local Hawaiian 

economy. Tourism is the dominant industry in the local economy, and Japanoriginating visitors comprise a significant percentage of travelers to Hawaii. The 

Department has previously found benefit to the Hawaiian economy to be an 

affirmative public interest factor worthy of decisional weight in our regulatory 

proceedings. We tentatively find such weight fully warranted in light of the facts 

presented.

See DOT Order 2010-5-7 (May 7, 2010), at 9 (emphasis added) (citing Expanded Air Services at 

Hawaii International Airports, Order 99-12-10, issued December 10, 1999). In light of the 

Department’s precedent and the Administration’s tourism policy, Hawaiian’s public interest 

benefits cannot and should not be dismissed. With the comparative lack of benefits in the 

competing proposals, the record before the Department overwhelmingly favors Hawaiian’s 

application. See HA-2015R-108, 116. 

B. American’s and Delta’s Proposed Services Lack Public Interest Benefits.

While Hawaiian’s public interest benefits have been quantified and not refuted, the 

alliance carriers offer only vague promises of connecting service and traffic projections that have 

 3

 Consolidated Answer of Hawaiian Airlines, Inc., DOT-OST-2010-0018 (Jan. 12, 2015), 

hereinafter “Hawaiian Answer”, at 29-30.
DOT-OST-2010-0018

2015 Reply of Hawaiian Airlines, Inc.

Page 8 of 16

been proven wrong in prior proceedings and will not materialize after this proceeding.

4

 While 

both American and Delta claim that their services will benefit a wider geographic area with a 

larger population than Hawaii because of their supposed connecting services, the truth is that the 

impact of these purported “connections” will be minimal.

1. American’s Claims of Public Interest Benefits Are Exaggerated.

American’s argument that its public interest benefits will exceed Hawaiian’s proposed 

benefits comes down to the fact that it proposes to offer more connections and therefore provide 

service to a wider geographic area.5

 This is an apples-to-oranges comparison between 

Hawaiian’s strong local service offering6 and the promise of connecting service offered by 

American. The problem with American’s argument is that experience has demonstrated that 

connections over the mainland U.S.-Haneda gateways have a minimal market impact, averaging 

less than 3% market share of the Tokyo markets served. See HA-2015R-109. That performance 

will not improve for American’s HND-LAX service. As shown in HA-2015R-110, American’s 

total market share in connecting markets over LAX will average only 2.2%.

 4

 Hawaiian Answer at 39-40, 49.

5

 See American Answer at 10. 

6

 American makes an analogy between Hawaiian’s proposal and JAL’s former nonstop service 

in only one direction between Narita and Kona. American Answer at 11. The comparison is 

inapt. Not only will Hawaiian’s service originate from the preferred gateway to Hawaii

(Haneda), see HA-2015A-213, but Hawaiian proposes nonstop service in both directions and,

unlike JAL, offers an extensive schedule of flights within Hawaii to provide for multi-destination 

vacations. Moreover, the evidence is overwhelming that Hawaiian’s proposed service will 

generate more public interest benefits than American’s redundant proposal and Delta’s failed 

service. See, e.g., HA-2015R-116. 
DOT-OST-2010-0018

2015 Reply of Hawaiian Airlines, Inc.

Page 9 of 16

See HA-2015R-111. American’s LAX proposal offers few unique connections. On those 

unduplicated routes, American would have far less traffic than the local O&D in Hawaiian’s 

proposed Haneda-Kona route. See HA-2015R-112 (showing that HND-KOA will have three 

times as many Tokyo MIDT passengers and thirty times more Haneda MIDT passengers than 

American’s unduplicated connections). The fact is that the impact of American’s proposal on its 

claimed larger service area will be miniscule, while the grant of Hawaiian’s application would be 

a meaningful boost to the economy of the Hawaiian Islands. HA-2015R-106-07.
DOT-OST-2010-0018

2015 Reply of Hawaiian Airlines, Inc.

Page 10 of 16

American’s service is not needed and therefore will not deliver the promised benefits. 

With 14 weekly Haneda frequencies offered by Delta and ANA and 56 weekly round trips

overall, LAX is well served from Tokyo. See Hawaiian Answer at 44-45. Adding more capacity

will result in lower load factors than Delta’s failed Seattle service.

7 American’s superfluous 

additional capacity simply will make the market uneconomic. American’s only alternative, 

which they recognized by using the same flight numbers for their present Narita service and their 

proposed Haneda service, is to cut its Narita service, eliminating any incremental benefit to 

American’s proposed service. 

2. Delta’s Seattle Service Does Not and Will Not Provide Meaningful 

Public Interest Benefits.

Delta responded to Hawaiian’s application by making the structural argument that the 

State of Hawaii should not receive another Haneda frequency over its Seattle service. See Delta 

Answer at 9. Instead, Delta believes it should retain the Seattle frequency to preserve connecting 

opportunities for the small number of passengers in the Pacific Northwest region. See id. at 2. 

But allowing Delta to retain the frequency will only result in public interest benefits if Delta 

actually flies the route and passengers actually board the aircraft when it does. So far, Delta has 

been unwilling to fly the route, and the passengers have not used the service on the few 

occasions Delta has flown it.8

 

 7

 See HA-2015A-930 (forecasting lower load factors than Delta’s failed service )

8

 See HA-2015A-1002 (depicting Delta’s choosing not to operate 248 available HND-SEA 

flights); HA-2015A-1004 (depicting Seattle-Haneda load factor lower than the other failed 

Haneda routes).
DOT-OST-2010-0018

2015 Reply of Hawaiian Airlines, Inc.

Page 11 of 16

Although Delta argues that investments in its Seattle hub will save the Seattle-Haneda 

service, that growth will not make a difference. First, as discussed in Hawaiian’s Answer, the 

additional flights Delta has added to Seattle will not significantly increase the number of 

connections or passengers on the routing. See Hawaiian Answer at 37. As with American’s 

proposal, the connecting traffic is too small to have any impact on load factors to Haneda. See 

HA-2015R-109, 111. Second, even assuming rapid growth at Delta’s Seattle hub, the HND-SEA 

traffic will trail HND-KOA by a large margin. Indeed, the number of onboard passengers would 

have to increase 139% to equal Hawaiian’s HND-KOA traffic forecast, which seems unlikely 

when Delta’s Answer bragged that its summer-season performance “improved by 54% percent

year-over-year.”9

 Delta has no smaller aircraft to fly this route than it presently uses and 

therefore the route cannot succeed.

 9

 Delta Answer at 3 (emphasis in original). Delta’s 2014-15 winter season performance will 

undoubtedly decline, as it has cancelled all but 17 flights.
DOT-OST-2010-0018

2015 Reply of Hawaiian Airlines, Inc.

Page 12 of 16

HA-2015R-115. The Department should award the frequency to the proposed market where it is 

needed10 instead of keeping it in a market that just has not worked. 

 10 See HA-2015R-113 (demonstrating that even before stimulation KOA is underserved relative 

to LAX and SEA).
DOT-OST-2010-0018

2015 Reply of Hawaiian Airlines, Inc.

Page 13 of 16

II. The Availability of the Customs & Border Patrol/Federal Inspection Service Facility 

in Kona Will Not Delay the Start of Hawaiian’s Proposed Service.

American makes much ado about the U.S. Customs and Border Protection (“CBP”) and 

Federal Inspection Service (“FIS”) facilities at Kona. Hawaiian is well aware of this issue, but it 

will not prevent Hawaiian from commencing service in a timely manner. The facility that had 

been used at Kona to support JAL’s flights remains in place. Moreover, Hawaiian has received 

pledges of support from both state and federal officials to both reopen the necessary facilities in 

the short term and provide a long-term solution.11 Hawaiian therefore has every expectation that 

it will operate nonstop service to Kona within 90 days after the receiving the award from the 

Department.12

 11 See Gov. David Ige, Letter to Hon. Anthony Foxx, (Jan. 9, 2015) (attached as HA-2015R117) (“My administration will work with our partners in the federal government to ensure that 

Kona International Airport will be ready to receive these passengers when Hawaiian initiates” 

Haneda-Kona service); Sen. Brian Schatz, Letter to Hon. Anthony Foxx (Jan. 16, 2015) (attached 

as HA-2015R-118) (“The State of Hawaii and Hawaii County continue to take steps to reiterate 

their commitment to resuming international operations at Kona. . . . I remain committed to 

ensuring that CBP continues to engage with the State and Hawaii County.”); Rep. Tulsi Gabbard, 

Letter to Hon. Anthony Foxx (Jan. 12, 2015) (attached as HA-2015R-119) (“CBP was located [at 

KOA] just a few years ago..., infrastructure that remains today. Hawaiian’s Congressional 

delegation has been aggressively working to re-establish this CBP presence and the major factor 

preventing serious engagement by CBP is the lack of international flights and demand for CBP 

presence at [KOA]. . . . [R]eallocation of these slots to Hawaiian Airlines would precipitate a 

quick resolution to this issue.”); Rep. Mark Takai, Letter to Hon. Anthony Foxx, (Jan. 9, 2015) 

(attached as HA-2015R-120); Mayor Billy Kenoi, Letter to Hon. Anthony Foxx, (Jan. 9, 2015) 

(attached as HA-2015R-121). These officials have identified the reopening of Kona as an 

international gateway as a key to alleviating congestion at the overburdened HNL CBP/FIS 

facility, improving the travel experience for all international visitors to Hawaii. See HA-2015R117-18.

12 As shown by its actions in this proceeding, Hawaiian believes strongly that air carriers 

awarded Haneda authority should meet their commitments, including compliance with the 90-

day start up condition. Indeed, Hawaiian started service using its first Haneda slot early and has 

flown the route continuously, while others failed to do so. Hawaiian fully expects to commence 

service as proposed. If, for any reason, the temporary unavailability of the CBP/FIS facility in 
DOT-OST-2010-0018

2015 Reply of Hawaiian Airlines, Inc.

Page 14 of 16

In addition, Hawaiian submits that the Department cannot, as a matter of policy, use the 

temporary lack of staffing at any CBP/FIS facility as a decisional factor in limited entry route 

proceedings. Any carrier, like Hawaiian in this proceeding, proposing service to an airport 

currently without international service is in a classic Catch-22. CBP is not likely to staff a 

facility at an airport without international service. If the Department views the current lack of 

staffing as decisional, then any application to initiate international service would be ineligible for 

an award. Any such categorical exclusion would be contrary to the Department’s mandate in the 

Federal Aviation Act to encourage new entry into air transportation markets13 and would serve to 

limit unjustly the expansion of international services. Instead, the Department should make the 

award based on the relative strength of the different proposed services.

III. Only Hawaiian Proposes to Compete Against the Alliance Carriers.

Although Delta’s Answer discusses the importance of promoting inter-alliance 

competition, see Delta Answer at 7, Hawaiian respectfully submits that its status as the only 

nonaligned carrier is a major distinguishing characteristic of its application. Especially as the 

U.S.-Japan immunized joint ventures have forged their ties, it is more important than ever that 

the Department fulfill its responsibility to strengthen smaller air carriers. Through hard work 

and a willingness to undertake risk, Hawaiian has carved out a niche by catering to leisure 

 

Kona were to prevent Hawaiian from complying with the 90-day startup condition, Hawaiian 

would be willing, after consulting with the Department, to stop at HNL so passengers could clear 

customs before proceeding to Kona. This procedure would be temporary, lasting only until the 

Kona CBP/FIS facility is fully operational. For departing flights, Hawaiian would fly directly to 

HND with no need for a stop at HNL.

13 See 49 U.S.C. § 40101(a) (13) (requiring the Department to consider “encouraging entry into 

air transportation markets by new and existing air carriers” in its public interest analysis).
DOT-OST-2010-0018

2015 Reply of Hawaiian Airlines, Inc.

Page 15 of 16

travelers. Its aircraft are configured to serve leisure passengers comfortably while providing 

exceptional value and high-quality service. In doing so, Hawaiian has expanded its international 

service greatly and gained a foothold in the markets between Hawaii and Japan, which are

dominated by the major alliances. The U.S.-Japan alliances carry many advantages, including 

incumbency, sheer size, and the ability to coordinate planning, pricing and schedules. Hawaiian, 

having none of these advantages, is up for the fight but submits that the Federal Aviation Act and 

Department policies that provide for immunization of the alliances also require that the 

Department ensure a level playing field for nonaligned smaller carriers. See Hawaiian Answer at 

54-57. In a situation like this where a nonaligned smaller carrier with an unblemished record of 

fulfilling its commitments proposes a service that will generate superior public benefits, 

including more traffic, higher load factors and greater economic benefits, the Department should 

award to frequency to the smaller carrier, Hawaiian Airlines.
Conclusion 

DOT-OST-201 0-0018 

2015 Reply of Hawaiian Airlines, Inc. 

Page 16 of 16 

As set forth in this Reply, the public interest will be best served by reallocating Delta's 

Haneda slot pair to Hawaiian Airlines' for its proposed Kona service. 

Dated: January 20, 2015 

Respectfully submitted, 

J. Parker Erkmann 

Jonathan B. Hill 

Geoff Rapoport 

Cooley LLP 

1299 Pennsylvania Ave., NW 

Suite 700 

Washington, DC 20004 

(202) 842-7800 

(202) 842-7899 (fax) 

perkmann@cooley.com 

jhill@cooley.com 

grapoport@cooley. com 

Counsel for Hawaiian Airlines, Inc. 
CERTIFICATE OF SERVICE 

I hereby certify that a copy of the foregoing Consolidated Reply of Hawaiian Airlines, 

Inc. was served this 201

h day of January 2015 via email transmission or U.S. mail on the 

following: 

rnegan.lawrence@alaskaair. corn 

J eremy.Ross@alaskaair. corn 

kyle.levine@alaskaair.corn 

dheffernan@cozen.corn 

abigail.donovan@aa.corn 

francis.heil@aa.corn 

howard.kass@aa.corn 

robert. wirick@aa. com 

sascha. vanderbellen@delta.corn 

chris. walker@delta.com 

dan. weiss@united.com 

Thornas.bolling@united.corn 

steve.rnoiTissey@united.com 

gmurphy@crowell.com 

englets@state. gov 

finstonma@state.gov 

urskr@state. gov 

cristinasa@state. gov 

info@airlineinfo. com 

Ambassador Kenichiro Sasae 

Embassy of Japan 

2520 Massachusetts Ave., NW 

Washington, DC 20008 

charles.hmmicutt@thompsonhine.com 

patricia.snyder@thompsonhine.com 

seth.waxrnan@wilmerhale.com 

sseiden@crowell.corn 

robert.finamore@dot. gov 

brett.kruger@dot. gov 

paul. gretch@dot. gov 

todd.homan@dot. gov 

brian.hedberg@dot.gov 

peter .irvine@dot. gov 

john.s.duncan@faa.gov 

glindsey@lawa.org 

ej ames@jamhoff.corn 

ishiwata.k@pmiseattle.org 

safora.i@portseattle.org 

Mike.Donatelli@alpa. org 

!A4-=C .bn, -z! 

Erin Combs 
REPLY

EXHIBITS OF HAWAIIAN AIRLINES
TABLE OF CONTENTS

Exhibit R-101 – Japanese Visitors Create Sales, Jobs and Earnings for U.S.

Exhibit R-102 – Hawaiian’s Kona Flight Will Create Over 1,100 U.S. Jobs, Over Four Times 

American’s LAX Proposal 

Exhibit R-103 – Hawaiian’s Kona Flight Will Increase U.S. GDP by $117 Million, Over Three 

Times American’s LAX Proposal

Exhibit R-104 – Hawaiian’s Kona Flight Will Create Over 1,100 U.S. Jobs, Over Fifteen Times 

Delta’s SEA Proposal 

Exhibit R-105 – Hawaiian’s Kona Flight Will Increase U.S. GDP by $117 Million, Fifteen Times 

Delta’s SEA Proposal

Exhibit R-106 – Economic Impact on the State of Hawaii Will be Significant

Exhibit R-107 – Any Economic Impact for AA’s Proposed Service will be Hardly Noticed

Exhibit R-108 – American and Delta Provided No Evidence of Economic Impact of Their Services

Exhibit R-109 – The Proposed Connections on Past HND Awards Have Average Less than 3% 

Share of Tokyo Markets

Exhibit R-110 – American’s Total Market Size of Connecting Markets is not Meaningful when its 

Markets Share is Less than 3%

Exhibit R-111 – American’s Proposed LAX-HND Service Would Carry Less than 2.5% of 

Passengers in its Proposed Connecting Markets – Very Similar to Previous HND

Routes

Exhibit R-112 – Kona Has Over Three Times As Many Tokyo Passengers and Over 30 Times As 

Many HND Passengers as All of American’s Unduplicated Roundtrip Points 

Behind LAX

Exhibit R-113 – Even Before Stimulation, KOA is Underserved Relative to LAX and SEA

Exhibit R-114 – Forecast American LAX Passengers Will Have to be 76% Higher to Equal 

Forecast Hawaiian KOA-HND Levels

Page 1 of 2
TABLE OF CONTENTS

Exhibit R-115 – Actual SEA-HND Passengers Will Have to More than Double to Equal Forecast 

Hawaiian KOA-HND Levels

Exhibit R-116 – Hawaiian’s KOA-HND Economic Impact to the U.S. is the Largest by Far: The 

U.S. Will Lose $83 Million in Sales if American is Selected and Over $100 Million 

in Sales if Delta Keeps SEA

Exhibits R-117-R-121 – Letters of Support

Page 2 of 2
JAPANESE VISITORS CREATE JOBS
JAPANESE VISITORS CREATE

SALES, JOBS AND EARNINGS FOR THE U.S.

Exhibit HA-2015R-101

Docket OST-2010-0018

Page 1 of 1

Japanese 

Visitors...

Spend Money

in the U.S. and...

Create

Sales, Jobs 

and 

Earnings in

The U.S.

Japanese Visitors to the U.S.

U.S. Visitors to Japan

Spend Money in Japan

And Create Sales, Jobs and Earnings in Japan

Source: Graphic from http://www.whytourismmatters.com.
HAWAIIAN’S KONA FLIGHT WILL CREATE

OVER 1,100 U.S. JOBS, OVER FOUR TIMES AMERICAN’S LAX PROPOSAL

Total Employment Impact of Japanese Visitors to the U.S.

Exhibit HA-2015R-102

Docket OST-2010-0018

Page 1 of 1

HA-KOA 1,151 U.S. Jobs AA-LAX 259 U.S. Jobs 

Source: Exhibits HA-2015A-614. Note that Hawaiian estimated AA LAX-HND economic impacts. AA has claimed no new jobs.
HAWAIIAN’S KONA FLIGHT WILL INCREASE U.S. GDP 

BY $117 MILLION, OVER THREE TIMES AMERICAN’S LAX PROPOSAL

Annual Incremental GDP Impact of Japanese Visitors to the U.S. (Millions)

Exhibit HA-2015R-103

Docket OST-2010-0018

Page 1 of 1

$$$$$$$$$$

$$$$$$$$$$

$$$$$$$$$$

$$$$$$$$$$

$$$$$$$$$$$

$$$$$$$$$$$

$$$$$$$$$$$

$$$$$$$$$$$

$$$$$$$$$$$

$$$$$$$$$$$

$$$$$$$$$$$

$$$

$$$

$$$

$$$

$$$

$$$

$$$

$$$

$$$

$$$

$$$$

HA-KOA +117 Million GDP AA-LAX +34 Million GDP

$ = $1 Million

Source: Exhibits HA-2015A-616. Note that Hawaiian estimated AA LAX-HND economic impacts. 
HAWAIIAN’S KONA FLIGHT WILL CREATE

OVER 1,100 U.S. JOBS, OVER FIFTEEN TIMES DELTA’S SEA PROPOSAL

Total Employment Impact of Japanese Visitors to the U.S.

Exhibit HA-2015R-104

Docket OST-2010-0018

Page 1 of 1

HA-KOA 1,151 U.S. Jobs DL-SEA 75 U.S. Jobs 

Source: Exhibits HA-2015A-614. Note that Hawaiian estimated DL SEA-HND economic impacts. DL has claimed no new jobs.
HAWAIIAN’S KONA FLIGHT WILL INCREASE U.S. GDP 

BY $117 MILLION, FIFTEEN TIMES DELTA’S SEA PROPOSAL

Incremental GDP Impact of Japanese Visitors to the U.S. (Millions)

Exhibit HA-2015R-105

Docket OST-2010-0018

Page 1 of 1

$$$$$$$$$$

$$$$$$$$$$

$$$$$$$$$$

$$$$$$$$$$

$$$$$$$$$$$

$$$$$$$$$$$

$$$$$$$$$$$

$$$$$$$$$$$

$$$$$$$$$$$

$$$$$$$$$$$

$$$$$$$$$$$

$

$

$

$

$

$

$

$

HA-KOA +117 Million GDP DL SEA +8 Million GDP

$ = $1 Million

Source: Exhibits HA-2015A-616. Note that Hawaiian estimated DL SEA-HND economic impacts. 
ECONOMIC IMPACT ON THE STATE

OF HAWAII WILL BE SIGNIFICANT

Exhibit HA-2015R-106

Docket OST-2010-0018

Page 1 of 1

Annual 

Economic

Impact /1

$84 per Resident per Year

1/ From Exhibit HA-2015A-614.

2/ From Consolidated Answer of American Airlines, Inc. page 10.

$117 Million

Hawaii 

Population/2

1.4 Million
ANY ECONOMIC IMPACT FOR AA’S 

PROPOSED SERVICE WILL BE HARDLY NOTICED

Exhibit HA-2015R-107

Docket OST-2010-0018

Page 1 of 1

Annual 

Economic

Impact /1

$0.88 per California Resident per Year

$0.17 per U.S. Community Resident per Year

1/ From Exhibit HA-2015A-614.

2/ From Consolidated Answer of American Airlines, Inc page 10.

$34 Million

California

Population/2

38.8 Million

American’s Claimed 

Served

Communities’

Population/2

194.6 Million
AMERICAN AND DELTA PROVIDED 

NO EVIDENCE OF ECONOMIC IMPACT OF THEIR SERVICES

$117

$0

$20

$40

$60

$80

$100

$120

$140

HA KOA-HND AA LAX-HND DL SEA-HND

Annual Economic Impact (U.S. GDP/Sales) - Millions

No Evidence

Supplied

Exhibit HA-2015R-108

Docket OST-2010-0018

Page 1 of 1

No Evidence

Supplied

Note: American and Delta have not provided economic impact estimates. Hawaiian estimated their economic impact using the same method as 

KOA. See Exhibits HA-2015A-613-622. 

Source: Exhibit HA-2015A-616.
AMERICAN’S LARGE PASSENGER POOL IN CONNECTING MARKETS 

HAS NEGLIGIBLE VALUE AND NEGLIGIBLE MARKET SHARE
THE PROPOSED CONNECTIONS ON PAST HND AWARDS

HAVE AVERAGED LESS THAN 3% SHARE OF TOKYO MARKETS

% of Tokyo Passengers in Originally Proposed Connecting Markets Using HND Flights

Source: Exhibit HA-2015A-16-19.

Via DL LAXHND

2.4%

Via Other 

Routings

97.6%

Via DL SEAHND

1.6%

Via Other 

Routings

98.4%

Via AA JFKHND

2.9%

Via Other 

Routings

97.1%

Exhibit HA-2015R-109

Docket OST-2010-0018

Page 1 of 1
AMERICAN’S TOTAL MARKET SIZE OF CONNECTING MARKETS 

IS NOT MEANINGFUL WHEN ITS MARKET SHARE IS LESS THAN 3%

1/ Includes all 32 of AA’s proposed connections.

2/ Uses historical HND case adjustment factor for direct booking of 1.35.

3/ From Exhibit HA-2015A-927.

Tokyo MIDT Passengers

AA Claimed LAX-HND Connecting Market /1 (YE September 2014)

New York Kennedy (JFK) 310,428

San Francisco (SFO) 218,184

Las Vegas (LAS) 102,490

Chicago O'Hare (ORD) 99,459

Boston (BOS) 73,005

Washington Dulles (IAD) 65,412

San Diego (SAN) 59,879

Orlando (MCO) 55,689

San Jose (SJC) 42,278

Atlanta (ATL) 39,483

Houston Intercontinental (IAH) 38,258

Dallas/Ft. Worth (DFW) 35,392

Denver (DEN) 22,513

Miami (MIA) 19,862

Phoenix (PHX) 18,625

Salt Lake City (SLC) 16,791

Nashville (BNA) 15,529

Philadelphia (PHL) 10,933

Austin (AUS) 9,746

Tampa (TPA) 6,785

Charlotte (CLT) 6,707

San Antonio (SAT) 6,072

Sacramento (SMF) 3,319

Tucson (TUS) 3,134

El Paso (ELP) 2,301

Reno (RNO) 1,753

West Palm Beach (PBI) 1,409

Eugene (EUG) 1,218

Fresno (FAT) 1,139

Monterey (MRY) 455

Total -Unadjusted 1,288,248

Total - Adjusted /2 1,739,135

Forecast AA-HND-LAX Connecting Passengers /3 38,720

AA HND-LAX Share of Tokyo 2.2%

Exhibit HA-2015R-110

Docket OST-2010-0018

Page 1 of 1
AMERICAN’S PROPOSED LAX-HND SERVICE

WOULD CARRY LESS THAN 2.5% OF PASSENGERS IN ITS PROPOSED 

CONNECTING MARKETS – VERY SIMILAR TO PREVIOUS HND ROUTES

2.4% 1.6% 2.9% 2.2%

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

80.0%

90.0%

100.0%

Via DL LAX-HND Via DL SEA-HND Via AA JFK-HND Forecast AA

LAX-HND

% of Tokyo Passengers in Originally Proposed Connecting Markets Using HND Flights

Source: Exhibit HA-2015A-17-19 and HA-2015R-104.

Exhibit HA-2015R-111

Docket OST-2010-0018

Page 1 of 1
KONA HAS OVER THREE TIMES AS MANY TOKYO PASSENGERS 

AND OVER 30 TIMES AS MANY HND PASSENGERS AS 

ALL OF AMERICAN’S UNDUPLICATED ROUNDTRIP POINTS BEHIND LAX

YE September 2014 Tokyo 

MIDT Passengers

56,767

18,119

0

10,000

20,000

30,000

40,000

50,000

60,000

KOA

Exhibit HA-2015R-112

Docket OST-2010-0018

Page 1 of 1

Total of All AA 

Proposed “New” 

Roundtrip Points 

Behind LAX

1/ See Exhibits HA-2015A-922-924 for more detail on these markets. All connections use a reasonable maximum connect time of 4 hours.

Note: MIDT sample has not been expanded to account for direct bookings and does not reflect total market size.

Source: Exhibits HA-2015A-922-924 and MIDT via Travelport.

YE September 2014 HND

MIDT Passengers

24,463

746

0

5,000

10,000

15,000

20,000

25,000

30,000

KOA Total of All AA 

Proposed “New” 

Roundtrip Points 

Behind LAX

American’s unduplicated connecting markets are AUS, SAT and 

ELP. These are the three proposed AA roundtrip connections to 

HND that are not currently offered by any other carrier./1 
KOA IS THE MOST UNDERSERVED AND WILL

GENERATE MORE PASSENGERS THAN LAX OR SEA
EVEN BEFORE STIMULATION KOA 

IS UNDERSERVED RELATIVE TO LAX AND SEA

66

43

81

0

10

20

30

40

50

60

70

80

90

KOA LAX SEA

YE September 2014 Tokyo* MIDT Passengers per Flight

YE Q3 2014 Passengers 

 Before Stimulation: 58,757 443,032 96,034

YE Q3 2014 Flights Scheduled

Flights Including Proposed: 730 6,757 2,225

Passengers per Flight: 81 66 43 

* Includes HND and NRT.

Note: MIDT sample has not been expanded to account for direct bookings and reflects relative but not total market size.

Source: MIDT, via Travelport. 

Exhibit HA-2015R-113

Docket OST-2010-0018

Page 1 of 1

(Without Any Nonstop Service) (With Nonstop Service) (With Nonstop Service)
FORECAST AMERICAN LAX PASSENGERS WILL HAVE TO BE

76% HIGHER TO EQUAL FORECAST HAWAIIAN KOA-HND LEVELS

91,044

160,602

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

Forecast HA KOA-HND Forecast AA LAX-HND

Forecast HND Passengers

Source: Hawaiian Answer Exhibits.

+69,558

+76%

From: 

Exhibit HA-2015A-508

From: 

Exhibit HA-2015A-927

Exhibit HA-2015R-114

Docket OST-2010-0018

Page 1 of 1
ACTUAL SEA-HND PASSENGERS WILL HAVE TO MORE

THAN DOUBLE TO EQUAL FORECAST HAWAIIAN KOA-HND LEVELS

67,274

160,602

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

Forecast HA KOA-HND Actual YE June 2014 SEA-HND

Forecast HND Passengers

Source: Hawaiian Answer Exhibits.

+93,328

+139%

From: 

Exhibit HA-2015A-508

From: 

U.S. DOT, T-100

Exhibit HA-2015R-115

Docket OST-2010-0018

Page 1 of 1
HAWAIIAN’S KOA-HND ECONOMIC IMPACT TO 

THE U.S. IS THE LARGEST BY FAR:

THE U.S. WILL LOSE $83 MILLION IN SALES IF AMERICAN

IS SELECTED AND OVER $100 MILLION IN SALES IF DELTA KEEPS SEA

$34

$8

$117

$0

$20

$40

$60

$80

$100

$120

$140

HA KOA-HND AA LAX-HND DL SEA-HND

Annual Economic Impact (U.S. GDP/Sales) - Millions

Note: American and Delta have not provided economic impact estimates. Hawaiian estimated their economic impact using the same method as 

KOA. See Exhibits HA-2015A-613-622. 

Source: Exhibit HA-2015A-616.

-$83 Million

Exhibit HA-2015R-116

Docket OST-2010-0018

Page 1 of 1

-$109 Million
LETTERS OF SUPPORT
Exhibit HA-2015R-117

Docket OST-2010-0018

Page 1 of 1

Exhibit HA-2015R-117

Docket OST-2010-0018

Page 1 of 2
Exhibit HA-2015R-117

Docket OST-2010-0018

Page 2 of 2
Exhibit HA-2015R-118

Docket OST-2010-0018

Page 1 of 2
Exhibit HA-2015R-118

Docket OST-2010-0018

Page 2 of 2
Exhibit HA-2015R-119

Docket OST-2010-0018

Page 1 of 2
Exhibit HA-2015R-119

Docket OST-2010-0018

Page 2 of 2
Exhibit HA-2015R-120

Docket OST-2010-0018

Page 1 of 1
Exhibit HA-2015R-121

Docket OST-2010-0018

Page 1 of 2
Exhibit HA-2015R-121

Docket OST-2010-0018

Page 2 of 2