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 Lo hnes 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, 2012BEFORE 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 upg raded the size of its aircraft

providing service in the Haneda market . Also from the onset of th is route selection proceeding

,

Hawaiian has asked f or 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

Haw aiian 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

“s election 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 sel e ction of Delta’s

Detroit proposal would provide Haneda service to the largest behind

- gatewa y 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

. S hould 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 ga teway. 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 OS T

- 2010

- 0018

.

2proceeding 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.

3CERTIFICATE 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 6 th 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

____________________________