BEFORE THE

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY

WASHINGTON, D.C.

______________________________

)

2010 U.S.- Haneda Combination )

Services Allocation Proceeding ) Docket DOT-OST-2010-0018

______________________________)

ANSWER OF HAWAIIAN AIRLINES, INC.

TO MOTION OF DELTA AIR LINES, INC.

Communications with respect to this document should be addressed to:

Mark B. Dunkerley

President & Chief Executive Officer 

Hoyt H. Zia

Senior VP, General Counsel &

Corporate Secretary

Hoyt.Zia@hawaiianair.com

Mark K. Arimoto

Assistant General Counsel

Mark.Arimoto@hawaiianair.com

Hawaiian Airlines, Inc.

P.O. Box 30008

Honolulu, HI 96820-0008

Jonathan B. Hill

J. Parker Erkmann

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

Counsel for Hawaiian Airlines, Inc.

August 6, 2012
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C. 

_____________________________ 

)

2010 U.S. - Haneda Combination )

Services Allocation Proceeding ) Docket DOT-OST-2010-0018

______________________________)

ANSWER OF HAWAIIAN AIRLINES, INC.

TO MOTION OF DELTA AIR LINES, INC.

Uniquely among the carriers approved to provide service between the United States and 

Tokyo’s Haneda Airport (“Haneda”), Hawaiian Airlines, Inc. (“Hawaiian”), was not only the 

first carrier to start service under Order 2010-7-2 (“the Order”) to Haneda, but Hawaiian was the 

only carrier that continued that service undiminished and uninterrupted following the earthquake 

and tsunami. Hawaiian also has taken full advantage of the US/Japan Bilateral Agreement by 

starting additional service to Fukuoka, Hiroshima, Kagoshika, Oita, Okinawa, Osaka and 

Sapporo, Japan and, as it promised in its application, has upgraded the size of its aircraft 

providing service in the Haneda market. Also from the onset of this route selection proceeding,

Hawaiian has asked for a second frequency.

1

 Against this backdrop Hawaiian finds Delta’s 

 1 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. 
request to move its Detroit service to Seattle without merit and completely counter to the 

carefully crafted distribution of frequencies established by DOT in the Order.

In granting Delta two of the four frequencies (Los Angeles and Detroit) DOT stated 

“selection of Delta’s Los Angeles proposal and American’s New York (JFK) proposal would 

provide Haneda service to the two largest mainland U.S.-Tokyo markets and selection of Delta’s 

Detroit proposal would provide Haneda service to the largest behind-gateway catchment area in 

the proceeding through a proven hub. These selections fulfill important and diverse public 

interest objectives.” Order at 7. The granting of Delta’s present request to move from its Detroit 

hub, that it represented to DOT would provide well established and dependable benefits, would 

undo the carefully crafted distribution of frequencies set forth in the Order.2

Hawaiian remains committed to increasing its frequencies to Haneda. Should a new 

selection proceeding be initiated, Hawaiian will actively participate to win that second 

frequency. 

Delta’s request to move its Detroit service should be denied, as should American’s 

request to allow it the freedom to serve Haneda from any gateway. DOT should initiate a 

 2 American Airline’s “me too” pleading filed in this docket would further clearly undermine that 

balance established by DOT and should not be granted. See Answer of American Airlines, Inc. 

dated July 31, 2012 Docket OST-2010-0018.

2
proceeding to reallocate the frequency given Delta’s determination that its awarded operating 

rights are no longer viable. 

Respectfully submitted,

Jonathan B. Hill

J. Parker Erkmann

Counsel for Hawaiian Airlines, Inc.

3
CERTIFICATE OF SERVICE

A copy of the foregoing Answer of Hawaiian Airlines, Inc. to Motion of Delta Air Lines, 

Inc. was served via email transmission this 6th day of August, 2012 on the following persons:

carl.nelson@aa.com

francis.heil@aa.com

Robert.wirick@aa.com

Dan.weiss@united.com

Thomas.bolling@united.com

Howard.kass@usairways.com

Benjamin.slocum@usairways.com

Paul.gretch@dot.gov

Keith.glatz@dot.gov

Esta.rosenberg@dot.gov

Todd.homan@dot.gov

urskr@state.gov

Eugene_alford@ita.doc.gov

info@airlineinfo.com

lhalloway@crowell.com

gmurphy@crowell.com

Hershel.kamen@united.com

Jonathan.linde@united.com

Sascha.vanderbellen@delta.com

____________________________