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 

______________________________)

CONSOLIDATED REPLY OF HAWAIIAN AIRLINES, INC.

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 

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 

Lynn M. Deavers 

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

ldeavers@dowlohnes.com

Counsel for Hawaiian Airlines, Inc. 

March 8, 2010 
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 

______________________________)

CONSOLIDATED REPLY OF HAWAIIAN AIRLINES, INC.

Without exception, Hawaiian Airlines, Inc.’s (“Hawaiian”) proposal in this 

proceeding is criticized because it will carry primarily Japan-originating traffic and 

therefore is somehow a benefit to Japan and not to the United States. Likewise, other 

applicants claim Hawaiian should be relegated to providing charter service to Japan 

rather than scheduled service – this from four carriers who, together with their alliance 

partners, control 99% of the U.S.-Tokyo market even without any slot pairs from this 

proceeding. In fact, Hawaiian’s proposal is the only one that will bring significant 

revenue into the United States and create new jobs because it will bring high-spending 

Japanese travelers to a part of the country where they most want to visit, thereby creating 

jobs, infusing revenue into the United States and supporting the major industry of 

Hawaii, tourism. It also is the only proposal that will make progress toward ensuring 

meaningful competition exists in the U.S.-Tokyo market, if and when antitrust immunity 

is granted to American, Continental and United in their respective oneworld and Star 

alliances, a condition precedent to any U.S.-flag service to Haneda being permitted. The 

Department must not pass up this critical opportunity to promote independent U.S.-flag 
DOT-OST-2010-0018

Answer of Hawaiian Airlines, Inc. 

Page 2 of 18 

competition by introducing an award-winning new entrant into the scheduled passenger 

market at Haneda. 

Awarding more slot pairs to the four legacy network carriers, American, 

Continental,1

 Delta or United,2 at Hawaiian’s expense would run counter to the 

Department’s goal of choosing the proposals that maximize the public benefits and 

encouraging new entrant carriers. These carriers already have extensive direct and/or 

code-share service in the U.S.-Tokyo market. Moreover, since Japanese carriers will be 

obtaining slot pairs for service from Haneda as a result of the MOU, the alliance carriers 

in this proceeding are slated to obtain benefits from both sides of the Pacific. 

Only Hawaiian will offer the traveling public a new, exciting travel option 

between Honolulu and Tokyo with benefits that are not now available, and Hawaiian’s 

application does not benefit any foreign carrier. Hawaiian’s proposed twice-daily HNDHNL service is superior to other carriers’ proposals for the following reasons: 

 Unlike all other applicants, Hawaiian would be a new entrant to the U.S.-

Tokyo market and its proposal would not duplicate any of its existing service; 

 Hawaiian is the only applicant that is neither the largest U.S.-flag carrier in 

the U.S.-Japan market nor a member of a dominant alliance seeking antitrust 

immunity for operations with Japanese carriers; 

 Only Hawaiian’s proposed service would inject new competition into the 

U.S.-Tokyo market and prevent entrenched legacy network carriers and their 

alliance partners from increasing their combined 99% market share; 

 

1

 Where appropriate, “Continental” also refers to its wholly-owned subsidiary, 

Continental Micronesia. 

2

 Common names are used for airlines. 
DOT-OST-2010-0018

Answer of Hawaiian Airlines, Inc. 

Page 3 of 18 

 Because all of the other applicants would be competing against their existing 

service at Narita, only Hawaiian has a true incentive to make its proposed 

HND-HNL flights a success; 

 Hawaiian is the only applicant proposing new service from the largest U.S. 

gateway to Japan as its top priority; 

 Hawaiian’s proposed service will have a much greater economic impact on 

the State of Hawaii than the other applicants’ proposals will have on the states 

(or territory) of their proposed U.S. gateways; 

 Hawaiian’s proposed service will bring Japanese business and leisure travelers 

to Hawaii, resulting in a cash infusion into the United States, whereas the 

U.S.-originating passengers focused on by other applicants would drain U.S. 

dollars into Japan; 

 There is sufficient demand for Hawaiian’s two (2) proposed flights into 

Honolulu;

 Unlike other applicants, Hawaiian has demonstrated where its aircraft will 

come from and that its service can be operated with one (1) aircraft per 

rotation; 

 No other applicant can match Hawaiian’s financial health and its awardwinning customer service, with the best on-time performance and fewest 

mishandled bags for the past six (6) years; 

 Only Hawaiian’s application will offer travelers a free stopover at its 

origination point; and 

 Hawaiian is fully committed to initiating and maintaining its proposed service 

as the natural next step in its long-term business plan to expand its Pacific 

Rim presence. 

Because no other proposal can offer these benefits, Hawaiian should be the Department’s 

first choice for an allocation of slot pairs and should be awarded the two (2) slot pairs it 

requests.
DOT-OST-2010-0018

Answer of Hawaiian Airlines, Inc. 

Page 4 of 18 

I. The Department Must Choose Hawaiian Instead of Giving More to the 

“Haves” in This Proceeding. 

The Answers filed by American, Continental, Delta and United confirm what 

their Applications made clear: this proceeding is only about the “haves” attempting to 

“have more” while simultaneously excluding the sole “have not” – Hawaiian – from 

bringing new, independent competition to the U.S.-Tokyo market. Given that the 

effectiveness of the MOU is conditioned on the grant of antitrust immunity and the 

resulting consolidation into an oligopoly of three alliances, the Department’s only 

reasonable choice here is to award Hawaiian two (2) slot pairs to introduce new, 

independent competition to the U.S.-Tokyo market on a scale that provides meaningful 

competition in the largest U.S.-Japan market. 

a. To Ameliorate the Impact of the Grant of Antitrust Immunity, the 

Department Must Award Two Daily Slot Pairs to Hawaiian. 

The award of the Haneda slots in this proceeding cannot be separated from the 

Department’s consideration of the applications for antitrust immunity (“ATI 

Applications”) by Japanese airlines and their U.S. partners. The grant of the ATI 

Applications is a condition precedent to the draft MOU liberalizing the aviation 

relationship between Japan and the U.S. coming into effect.3

 Accordingly, members of 

the Star and oneworld alliances have submitted ATI Applications, which await action by 

 

3 See Letter from Keiji Takiguchi, Deputy Director – General Civil Av. Bur. of 

Japan, to John Byerly, Deputy Assistant Secretary for Transportation Affairs – U.S. Dep’t 

of State (Dec. 11, 2009). 
DOT-OST-2010-0018

Answer of Hawaiian Airlines, Inc. 

Page 5 of 18 

the Department.4

 If these applications are granted, the parties intend to coordinate their 

activities completely by, as the oneworld carriers state: “eliminating each carrier’s 

economic incentive to maximize its own revenue.”5 While the ATI applicants claim 

significant benefits from the “metal neutrality” of their proposed integration,6

 they cannot 

dispute that all competition among alliance partners will cease, leaving only three (3) 

competitors on routes between the U.S. and Japan. Indeed, two (2) of the applicants in 

this proceeding, Continental and United, should be viewed by the Department as the 

same carrier due to their participation in the Star Alliance and their mutually agreed-to 

ATI Application that touts the fact that, if granted, they will act as one (1) carrier.7

Given the sharp reduction in the number of competitors, it is imperative that the 

Department take all action necessary to preserve competition. Hawaiian’s Application in 

this proceeding gives the Department a one-time opportunity: by granting Hawaiian the 

two (2) daily slot pairs it has requested, the Department will facilitate not only the entry 

of a new competitor but one with a robust presence in the Tokyo market. The award of 

two (2) Haneda slot pairs will give Hawaiian the economies of scale that will enable it to 

 

4

 Joint Application of All Nippon Airways Co., Ltd., Continental Airlines, Inc. and 

United Air Lines, Inc., Docket OST-2009-0350 (Dec. 23, 2009) (“ANA/CO/UA 

Application”); Joint Application of American Airlines, Inc. and Japan Airlines Int’l Co., 

Ltd. for Antitrust Immunity, Docket OST-2010-0034 (Feb. 12, 2010) (“AA/JAL 

Application”). 

5

 AA/JAL Application at 7; see ANA/CO/UA Application at 12 (“joint venture 

partners [will] share common economic incentives to promote the interests of their 

alliance over their individual corporate interests”). 

6

 ANA/CO/UA Application at 12; AA/JAL Application at 7. 

7 See ANA/CO/UA Application at 12. 
DOT-OST-2010-0018

Answer of Hawaiian Airlines, Inc. 

Page 6 of 18 

establish a foothold in the Tokyo market from which to grow and compete with the 

alliance carriers. While Hawaiian believes the award of one (1) slot pair would allow it 

to operate a profitable route, the award of two (2) will allow Hawaiian to build the scale 

necessary to provide a meaningful competitive alternative to the dominant alliance 

carriers.8 Only if the Department awards Hawaiian both pairs of slots that it seeks can 

the Department credibly claim (if it ultimately grants the ATI Applications) that it has 

done everything within its authority to preserve competition between the United States 

and Japan. 

b. The Department Must Select Hawaiian to Preserve Independent, 

Non-Alliance Competition in the U.S.-Tokyo Market. 

Even aside from the implication of antitrust immunity for American/JAL and 

Continental/United/ANA, none of the other applicants in this proceeding should be 

awarded any slot pairs at Hawaiian’s expense because they are all key members of 

powerful alliances with control over 99% of current U.S.-Tokyo flights. See Exhibit HAA-101. All other applicants already have not only substantial direct U.S.-Tokyo service 

but also code-share service through their alliances with foreign carriers. See, e.g.,

Exhibits HA-A-101-23. 

As described in Hawaiian’s Answer, this proceeding presents the ongoing issue of 

increasing market control and domination by four (4) U.S. carriers that are members of 

powerful worldwide alliances. International markets are becoming increasingly 

 

8

 At the outset, Hawaiian only will compete with carriers on the Tokyo-Honolulu 

route. This is appropriate because Honolulu is by far the largest U.S. gateway for Tokyo 

traffic. See Exhibits HA-A-201, 211-18.
DOT-OST-2010-0018

Answer of Hawaiian Airlines, Inc. 

Page 7 of 18 

consolidated into alliance services, with a growing concentration of market share held by 

SkyTeam, Star and oneworld. By obtaining more slot pairs, and the possible antitrust 

immunity for American, Continental and United, together with the immunized SkyTeam 

alliance for Delta, these carriers would only further contribute to the consolidation of the 

U.S.-Tokyo market. With the four (4) slot pairs allocated to Japanese carriers, the Star 

and oneworld Alliances (which include American, Continental and United) are poised to 

receive all eight (8) slot pairs. Given the dominant positions in the U.S.-Japan market 

held by both the alliance carriers (U.S. and Japanese) as well as Delta, Hawaiian’s 

request for two (2) of the eight (8) slots in this market is entirely reasonable. 

Hawaiian is the only independent new entrant that will serve the largest U.S.-

Tokyo and U.S.-Japan market with award-winning service.9

 The Department has stated 

that “where a new entrant carrier contest[s] the direct-carrier authority application of an 

airline already providing code-share service . . . the greater public benefits would result 

 

9

 The Department has repeatedly confirmed the importance of new entrants in 

international markets to increase competition and bring new service options to 

consumers. See New York/Newark-Cancun Combination Serv. Proceeding, Order 2006-

9-8, at 8 (awarding JetBlue primary authority because it would offer “important new 

entrant benefits”); 2007/2008/2009 U.S.-China Air Sers. and Combination Frequency 

Allocation Proceeding, Order 2007-9-25, at 8 (Docket OST-2007-28567) (awarding 

Delta certificate authority because, as a new entrant, it would expand service options and 

promote competition); 2005 Los Angeles-Mexico City Combination Serv. Proceeding,

Final Order 2005-5-1, at 6 (Docket OST-2005-20406) (awarding Alaska Airlines primary 

authority because it would “bring new service options to consumers, and a competitive 

impetus to incumbents to improve their service offerings” as a new entrant); 2004 U.S.-

Mexico Combination Serv. Proceeding, Order to Show Cause 2004-12-8, at 8 (Docket 

OST-2004-18692) (awarding Frontier Airlines primary authority because, as a new 

entrant, it would provide consumers with more flight and service options than they would 

otherwise receive). 
DOT-OST-2010-0018

Answer of Hawaiian Airlines, Inc. 

Page 8 of 18 

from our selection of the new entrant carrier.” 2005 Los Angeles-Mexico City 

Combination Service Proceeding, Final Order 2005-5-1, at 6 (Docket OST-2005-20406); 

see also Los Angeles-San Jose del Cabo Exemption Proceeding, Order 2001-1-11, at 7 

(Docket OST-2001-8361). Despite arguing to the contrary here, American itself made 

this argument in the Los Angeles-San Jose del Cabo Exemption Proceeding, in which it 

asserted that United was in effect an incumbent in the market by virtue of its code-share 

arrangement with Mexicana. See Order 2001-1-11, at 5.10 This same reasoning applies 

with equal force here. None of the proposals of American, Continental and United, 

which have code-share arrangements with incumbent Japanese carriers at Haneda,11

should be selected at Hawaiian’s expense.12 If Hawaiian’s proposal is not selected here 

 

10 See also 1999 U.S.-Brazil Combination Serv. Case, Order 2000-12-2 (Docket 

OST-99-6284) (rejecting United’s Los Angeles-Sao Paulo request where United already 

served the market by code-sharing with Varig); U.S.-Turkey Third-Country Codeshare 

Opportunities, Order 2000-7-25 (Docket OST-2000-7184) (tentatively denying limitedentry rights to American in light of its code-share arrangement with Turkish Airlines); 

1999 U.S.-France Combination Serv. Frequency Allocation Proceeding, Order 98-10-21 

(Dockets OST-98-3756, 3757, 3872, 3931, 3932, 3933, 4614) (denying limited-entry 

rights to Delta in light of Delta’s code-share arrangement with Air France). 

11 Continental will begin code-sharing with ANA on its U.S.-Japan flights on or 

about March 28, 2010. See Applications of All Nippon Airways Co., Ltd., Colgan Air, 

Inc., Continental Airlines, Inc. & Continental Micronesia, Inc., at 4 (Docket OST-2009-

0344); Notice of Action Taken (Docket OST-2009-0344). 

12 In its Answer, American points to circumstances where the Department awarded 

limited route authority to carriers with code-share relationships with foreign homeland 

carriers. Answer of American Airlines, Inc. at 10-11. None of that authority supports the 

award of slots to the oneworld or Star Alliance carriers in this proceeding. First, none of 

the cases cited by American involved an award of authority to the partner of a carrier in 

an immunized alliance, as would any award to the oneworld or Star Alliance carriers. 

Second, the orders cited by American were based on circumstances unique to those 
DOT-OST-2010-0018

Answer of Hawaiian Airlines, Inc. 

Page 9 of 18 

for an award of two (2) slot pairs, what hope do other independent U.S. carriers have of 

being able to compete with the huge alliance carriers in limited-entry international 

markets? 

c. Delta, the Largest U.S.-Tokyo and U.S.-Japan Carrier, Should Not 

Receive Any Slot Pairs at Hawaiian’s Expense. 

Delta should not receive any slot pairs at Hawaiian’s expense, given that Delta is 

the world’s largest air carrier and the largest U.S.-flag carrier serving the U.S.-Tokyo and 

U.S.-Japan markets. See Exhibits HA-A-501-02. In its Answer, Delta acknowledged 

that Hawaiian should receive one (1) slot pair for its HND-HNL service to combat the 

power of the alliance carriers. See Answer of Delta Air Lines, Inc. at 3 n.2 & 19-20. But 

Delta’s assertion that Hawaiian should receive no more than one (1) slot pair, and that 

 

particular applications that are inapplicable here. See 2007-2008 U.S.-Colombia 

Combination Frequency Allocation Proceeding, Order 2008-5-27 (May 21, 2008) 

(awarding Delta authority because it would provide “first-ever U.S.-flag direct carrier 

services”); U.S.-France Combination Servs. Proceeding, Order 1999-8-24 (Aug. 27, 

1999) (awarding authority because carrier was the only one proposing to initiate service 

to a new market); Los Angeles-Puerto Vallarta Combination Servs. Proceeding, Order 

2006-6-25 (June 22, 2006) (awarding authority to only carrier proposing daily year-round 

service); U.S.-China Combination and All-Cargo Frequency Allocation Proceeding,

Order 2007-2-10 (Feb. 8, 2007) (awarding authority to carrier offering to provide service 

to largest U.S. gateway without such service). None of the circumstances in this 

proceeding warrant overturning the Department’s strong preference for awarding limited 

entry authority to new entrants. See 2009 U.S.-Brazil Combination Frequency 

Proceeding, Order 2009-3-14, at 7-8 (Mar. 20, 2009) (“We have stated in previous carrier 

selection proceedings that, when rights for U.S. air carriers become available in 

restrictive markets, one of our primary goals has been to enhance competition by creating 

opportunities for new entrant carriers to gain market access.”). 
DOT-OST-2010-0018

Answer of Hawaiian Airlines, Inc. 

Page 10 of 18 

Delta should receive the remaining three (3) slot pairs,13 is short-sighted. Delta has a 

large hub at Narita and is well-established as the largest U.S. carrier in the U.S.-Tokyo 

and U.S.-Japan markets. Delta seeks three (3) slot pairs in this proceeding merely to 

insulate itself from new competition in those markets, not to bring the public any 

particular benefits. Given Delta’s dominant position and its already extensive service in 

the U.S.-Tokyo market, it should not receive any slot pairs before Hawaiian is awarded 

the two (2) slot pairs it requests. 

II. Hawaiian Needs Two Slot Pairs to Compete Optimally at Haneda with the 

Incumbent Carriers in the U.S.-Tokyo Market. 

Hawaiian needs two (2) slot pairs to compete with the oligopoly that currently 

exists. As explained by Mark Dunkerley, Hawaiian’s President and Chief Executive 

Officer, the alliance carriers’ control at Narita has made initiating service at that airport 

all but impossible for a new entrant like Hawaiian. See Exhibit HA-R-101 (Statement of 

Mark Dunkerley, President and Chief Executive Officer, Hawaiian Airlines, Inc.). As a 

result, the availability of slot pairs at Haneda is a unique opportunity to facilitate the 

establishment of a new, independent competitor serving the U.S.-Tokyo market. 

Although the current dearth of service by non-alliance U.S. carriers in the U.S.-Tokyo 

market cannot be completely alleviated by awarding two (2) slot pairs to an independent 

carrier, Hawaiian’s two (2) daily flights will be a critical step in that direction. It is 

imperative that Hawaiian be awarded both slot pairs it requests so that it has the 

 

13 In its Answer, Delta stated that it would not object to Hawaiian receiving one (1) 

slot pair for HND-HNL service, with backup authority on that route given to Delta. See

Answer of Delta Air Lines, Inc. at 3 n.2. 
DOT-OST-2010-0018

Answer of Hawaiian Airlines, Inc. 

Page 11 of 18 

economies of scale to compete with and offer a robust alternative to the powerful alliance 

carriers.

 Hawaiian will use its two (2) slot pairs to serve Honolulu, the largest U.S. 

gateway from Tokyo and from Japan.14 See Exhibits HA-A-201, 206-10. As described 

in its Answer, Honolulu also is the largest O&D passenger market to and from Tokyo, 

and Hawaii is the largest O&D passenger market to and from Japan. See Exhibits HA-A211-18. Honolulu has more Japan gateway passengers than all of the other applicants’ 

first-choice U.S. gateways combined. See Exhibit HA-A-204.15

 Because Honolulu is over twice as large as all of the other first-choice U.S. 

gateways proposed in this proceeding, a decision by the Department to award Hawaiian 

two (2) slot pairs to serve that large market before it awards any other slot pairs is more 

than reasonable. See Exhibits HA-R-108-12. Honolulu is over two (2) times the size of 

 

14 Despite Continental’s claim that Guam is the largest U.S. gateway from Japan, by 

combining Guam with Saipan, it is clear that Honolulu is the largest individual U.S. 

gateway. Continental’s charts combining Saipan and even Honolulu, both connections to 

Guam, as part of its Guam gateway, for comparison to Honolulu, are misleading. See

Exhibits CO-A-115-16. Continental is undoubtedly aware that connecting traffic is not 

counted when measuring the size of an individual U.S. gateway. Moreover, 

Continental’s proposed HNL-GUM-HND service would add over eight (8) hours of 

additional travel time for an HNL-HND roundtrip passenger compared to Hawaiian’s 

nonstop proposal. See Exhibit HA-R-107. 

15 Hawaiian is the only carrier that will offer a free stopover for travelers on its 

proposed routing. Hawaiian’s experience in serving Australia provides it a unique 

perspective into the nature of both business and leisure travelers between the U.S. 

mainland and points in the far Pacific – many travelers choose to break the long trip with 

an extended stopover in Hawaii. To accommodate these wishes, Hawaiian offers its 

passengers to and from Sydney a free stopover in Honolulu, an option that is extremely 

popular. Hawaiian will offer this same option to all passengers on its flights to and from 

Haneda. No other applicant in this proceeding will offer this unique benefit to travelers 

on its proposed routes. 
DOT-OST-2010-0018

Answer of Hawaiian Airlines, Inc. 

Page 12 of 18 

United’s proposed gateway, SFO, almost three (3) times the size of American’s first 

choice gateway, JFK, five (5) times the size of Delta’s first-choice gateway, SEA, and 

over ten (10) times the size of Continental’s first-choice gateway, EWR. Id. Because 

Honolulu is more than double the size of the next-largest first-choice gateway proposed 

in this proceeding, the Department should award two (2) slot pairs to serve that market 

before any others. 

Hawaiian’s application may be the last chance the Department has to introduce an 

independent new entrant of this type into the U.S.-Tokyo market. Hawaiian is unique 

because it has a base in Hawaii, the top destination for Japanese travelers, and it proposes 

service to Honolulu, the strongest U.S.-Tokyo point. There is ample local traffic to 

support Hawaiian’s two proposed HND-HNL flights. Any future proposals are likely to 

come from carriers proposing service to Tokyo from their hubs, which would represent a 

weaker option because the amount of local traffic would be lower. This is because such a 

carrier would be reliant on flow over its hub, in competition with all of the other carriers 

in this proceeding which, given their collective market share, would be a daunting 

prospect. That new entrant would not have the strength that Hawaiian has in Honolulu, 

the largest U.S. gateway to Japan. 

Although other applicants scoff at Hawaiian’s proposal to initiate two (2) daily 

flights at similar times, those comments ignore the time restrictions the MOU imposes on 

the slot pairs available in this proceeding. When the artificial restrictions associated with 

the slot pairs imposed by Japan are ameliorated as international operations at Haneda 

increase, Hawaiian anticipates that it will separate the departure time of the two (2) 

proposed flights with one (1) leaving earlier in the evening from Haneda. The present 
DOT-OST-2010-0018

Answer of Hawaiian Airlines, Inc. 

Page 13 of 18 

proposal for both flights reflects the reality of operational restrictions imposed on all U.S. 

carriers.

III. Hawaiian’s Proposal Will Serve the Public Interest by Benefiting the 

United States Economy, Whereas the Other Applicants’ Proposals Will 

Primarily Benefit Those Applicants Themselves. 

Hawaiian’s proposal to institute two (2) daily passenger flights between Haneda 

and Honolulu would bring more benefits to the public than any of the other proposals. In 

addition to serving the largest U.S. gateway from Tokyo, Hawaiian’s proposed service 

will have a greater economic impact upon its destination, the State of Hawaii, than any of 

the other proposals will have on the states (or territory) of their destinations. See Exhibits 

HA-A-227-38. Unlike the other proposals which are focused on taking U.S. travelers and 

money out of the United States to Japan, Hawaiian expects its twice-daily HND-HNL 

service to bring mostly Japan-originating traffic to the United States, where those 

travelers will spend money and infuse much-needed dollars into the United States and 

into Hawaii’s tourism-based economy. See Exhibit HA-A-228. As discussed in its 

Answer, using standard and accepted multipliers, Hawaiian’s two (2) proposals, 

essentially a U.S. export, will bring in over $110 million in new revenue to the United 

States, resulting in a $219 million increase in the U.S. Gross Domestic Product (“GDP”), 

a $62 million increase in U.S. household earnings annually, and the creation of nearly 

2,500 U.S. jobs. See Exhibits HA-A-235-38. 

No other carrier has even suggested that its proposal will create any jobs or infuse 

revenue into the U.S. economy. That is because the U.S.-originating passengers focused 

on by other applicants will drain dollars out of the United States, sending dollars and jobs 

to Japan. The primary interests served by those proposals are the interests of the 
DOT-OST-2010-0018

Answer of Hawaiian Airlines, Inc. 

Page 14 of 18 

applicants themselves. In these tough economic times, the Department must choose to 

benefit the United States and its economy as its first priority, rather than the corporate 

interests of American, Continental, Delta and United. 

IV. Other Applicants’ Assertions That Hawaiian Should Take Other 

Opportunities to Serve Tokyo, Without Gaining Entry to Haneda, Are 

Disingenuous and Misguided. 

The assertions by other applicants that Hawaiian should serve Tokyo via Narita or 

charter flights, instead of gaining access to Haneda through an award of slot pairs in this 

proceeding, are specious. All of the applicants in this proceeding know that Haneda is 

preferable to Narita and scheduled service is preferable to charter flights for U.S.-Tokyo 

operations. As an independent new entrant in the U.S.-Tokyo market, Hawaiian could 

not effectively compete at Narita, where the other applicants and their alliance partners 

control 99% of the operations. Indeed, that is why the re-opening of Haneda is such a 

unique opportunity for the Department to foster the entry of an independent competitor. 

Likewise, as the other applicants are undoubtedly aware, charter flights are a 

much less desirable option, with a cumbersome approval process, short term grants of 

authority, and a connotation of temporary operations. These suggestions merely reflect 

the selfish mentality of the “haves” in this proceeding, trying to keep the sole “have not” 

from gaining any meaningful access to the U.S.-Tokyo market. It is disingenuous and 

misguided to suggest these consolation prizes are sufficient, and it is telling that the other 

applicants only suggested these options for Hawaiian and not any of the other carriers in 

this proceeding. Hawaiian respectfully submits that, given the already formidable 

presence of the alliance carriers in the U.S.-Japan market, those carriers should initiate 

their own charter operations rather than pursue slot pairs at Haneda. They are free to 
DOT-OST-2010-0018

Answer of Hawaiian Airlines, Inc. 

Page 15 of 18 

comply with the independent insurance requirements, the filing of Charter Prospectuses 

and Passenger Agreements, and escrow requirements as they suggest Hawaiian can do. 

The other carriers’ position clearly smacks of trying to keep the “have nots” out of the 

“haves’” playpen. 

V. Hawaiian Is Committed to Instituting and Maintaining its Proposed HNDHNL Service. 

If awarded the two (2) slot pairs it requests, Hawaiian will successfully institute 

and maintain service to Haneda from Honolulu. As explained by Mr. Dunkerley, 

Hawaiian’s application represents the next logical step in its business plan of establishing 

itself as a major air carrier in the Pacific. See Exhibit HA-R-101. Initiating two (2) daily 

passenger flights to Japan is a natural progression in the execution of Hawaiian’s 

business strategy, and Hawaiian is fully committed to its proposed HND-HNL service. 

Id. Mr. Dunkerley has expressed his personal commitment to initiating and maintaining 

Hawaiian’s proposed twice-daily service to Haneda. Id.

Other applicants’ references to the alleged failure of Hawaiian to serve Japan in 

the past are misleading and irrelevant. The issues raised against Hawaiian are twenty 

(20) years old. In 1991, Hawaiian began service to Fukuoka and subsequently the 

Department approved the sale of that route to Northwest. See Order 91-4-1. Following 

the 1998 Japan route proceeding, the approval of Hawaiian’s Maui-Narita service was 

delayed for nearly a year after the award of other routes in that proceeding due to pending 

litigation between environmental plaintiffs and the Department over the planned 

extension of the runway at Kahului Airport. See Order 98-3-15, Order 99-4-4. And once 

final Department approval was given for that route, Hawaiian’s timely application for 
DOT-OST-2010-0018

Answer of Hawaiian Airlines, Inc. 

Page 16 of 18 

slots at Narita was denied by Japan’s Ministry of Transport. Due to these setbacks and 

economic considerations related to the Asian economy at that time, Hawaiian sought a 

delay in its start date for service, as had all of the other recipients of route authority in the 

1998 proceeding, American, Continental and TWA. See Notice of Action Taken, Docket 

OST-98-3419 (Jan. 14, 2000). Ultimately, the Maui runway extension necessary to 

support Hawaiian’s service to Narita was never built. When Hawaiian realized that it 

would not be able to institute its planned Maui-Narita service, it voluntarily returned its 

authority to the Department so that it could be allocated elsewhere. 

As Mr. Dunkerley explains, these past events occurred in different times, and they 

are irrelevant here. See Exhibit HA-R-101. All other applicants in this proceeding have 

failed to start, discontinued, or delayed service on dozens of international routes, see

Exhibit HA-R-102-06, and therefore their claims as to Hawaiian’s prior service awards 

should be given no weight.16 As it has consistently stated throughout this proceeding, 

Hawaiian is fully committed to successfully initiating and maintaining both of its 

proposed HND-HNL flights. 

CONCLUSION 

Hawaiian is the only carrier that would be a true independent new entrant to the 

U.S.-Tokyo market. All of the other applicants already have extensive direct and/or 

code-share service to Tokyo, and their selection for slot pairs at Hawaiian’s expense 

would merely be more of the same, benefiting the Star, SkyTeam and oneworld Alliances 

 

16 The other applicants also have discontinued direct service on routes in deference 

to service operated by their immunized alliance partners on those routes. 
DOT-OST-2010-0018

Answer of Hawaiian Airlines, Inc. 

Page 17 of 18 

in which they are members, rather than the public. With antitrust immunity for 

American/JAL and Continental/United/ANA, the U.S.-Tokyo market will be further 

consolidated and those applicants will have incredible advantages. Only Hawaiian’s 

proposal will bring an independent new competitor to this market. 

Hawaiian’s proposed twice-daily HND-HNL flights also would provide the 

greatest public benefits, bringing new revenue to the United States and creating 2,500 

new jobs. No other proposal comes close to offering such benefits. 

As explained by Mr. Dunkerley, Hawaiian is fully committed to instituting and 

maintaining its proposed service. This is the next step in Hawaiian’s plan to expand its 

presence along the Pacific Rim. And no other carrier can match Hawaiian’s awardwinning service, which Hawaiian will bring to this market. 

INDEX OF EXHIBITS

Exhibit Number Description Page

Exhibit HA-R-101 Statement of Mark Dunkerley 1 

Exhibit HA-R-102 American Has Discontinued/Failed to Start 5 

 Authorized Service on 88 International Routes 

 Since 1990 

Exhibit HA-R-103 Continental/Continental Micronesia Has 6 

 Discontinued/Failed to Start Authorized Service 

 on 60 International Routes Since 1990 

Exhibit HA-R-104 Delta Has Discontinued/Failed to Start 7 

 Authorized Service on 93 International Routes 

 Since 1990 

Exhibit HA-R-105 Northwest Has Discontinued/Failed to Start 8 

 Authorized Service on 46 International Routes 

 Since 1990 

Exhibit HA-R-106 United Has Discontinued/Failed to Start 9 

 Authorized Service on 66 International Routes 

 Since 1990 

Exhibit HA-R-107 Continental Micronesia’s HNL-GUM-HND 10 

 Service Would Add Over 3,000 Miles 

 and 8 Hours in Elapsed Time for a HNL-HND 

 Roundtrip Passenger Compared to Hawaiian’s 

 Nonstop Proposal 

Exhibit HA-R-108 HNL Is Over Two Times the Size of Any Other 11 

 Applicant’s First Choice Gateway 

Exhibit HA-R-109 HNL Is Over Two Times the Size of United’s 12 

 First Choice Gateway 

Exhibit HA-R-110 HNL Is Almost Three Times the Size of 13 

 American’s First Choice Gateway 

Docket OST-2010-0018 
INDEX OF EXHIBITS

Exhibit Number Description Page

Exhibit HA-R-111 HNL Is Five Times the Size of Delta’s 14 

 First Choice Gateway 

Exhibit HA-R-112 HNL Is Over Ten Times the Size of Continental’s 15 

 First Choice Gateway 

Docket OST-2010-0018 
STATEMENT OF MARK DUNKERLEY

PRESIDENT AND CHIEF EXECUTIVE OFFICER 

HAWAIIAN AIRLINES, INC. 

 On behalf of Hawaiian Airlines, Inc. (“Hawaiian”), I submit this statement to 

underscore the importance of the Haneda route to Hawaiian and our commitment to 

delivering the highest quality service in competition with the combined might of the 

alliance carriers. As our submissions in this proceeding demonstrate, Hawaiian’s service 

to Haneda with two daily flights will deliver the greatest benefits to the traveling public 

in the form of vigorous and uncompromising competition and to the United States more 

generally through the promotion of exports, the stimulation of the domestic economy and 

the creation of jobs. No combination of slot pair grants to the alliance carriers (all of the 

other applicants in this proceeding) come close to matching the benefits that will flow 

from the granting of two slot pairs to Hawaiian. Furthermore, because the 

implementation of the Memorandum of Understanding (“MOU”) between the United 

States and Japan is conditioned on the grant of antitrust immunity to certain alliance 

carriers, the Department’s review of the applications before it should be undertaken in the 

context of there being eight slot pairs to be distributed (four by the United States and four 

by Japan). This is because it is in the very nature of an immunized alliance that the 

economic rights of one alliance member are shared with the other alliance participants 

and vice versa. We take no issue with the alliances themselves; we merely believe that 

the pie of opportunity for which the Star and oneworld alliance carriers are vying is 

defined as much by the availability of slot pairs available to their Japanese partners as it 

is by the U.S. allotment. Put more bluntly, American, Continental and United’s “wants” 

can be satisfied as easily in the distribution of slot pairs by the Government of Japan as 

by DOT. 

Initiating Honolulu-Haneda Service is a Core Element of Hawaiian’s Business Plan 

 Since I became President of Hawaiian in 2003, we have embarked on a plan of 

controlled growth and operational excellence. This plan has begun to pay dividends to all 

of Hawaiian’s stakeholders – our passengers, employees and shareholders, and the State 

of Hawaii and the U.S. economy generally. We are consistently the top performer in 

Department-measured performance statistics. We also are the only carrier in this 

proceeding that has had a positive profit margin over the past five years. Our financial 

performance has strengthened Hawaiian’s balance sheet and provided the resources for us 

to explore growth opportunities. 

Exhibit HA-R-101 

Docket OST-2010-0018 

Page 1 of 4 

Page 1
To execute Hawaiian’s plan for controlled growth, we have sought to expand into 

markets all around the Pacific Rim. We have initiated and continue to operate long haul 

service to Australia, Tahiti, and the Philippines. We also continue to provide long haul 

essential air service to American Samoa. We serve ten destinations on the U.S. mainland. 

Given Hawaii’s close ethnic and cultural ties to Japan and our longstanding sales 

presence in Japan for our inter-Hawaiian Island service, service to Japan is the next 

logical step in our growth. We have studied the opportunity to serve the HonoluluHaneda route intensely, and we firmly believe the business case strongly supports a 

twice-daily service. Hawaii is the largest and most preferred destination for Japanese 

travelers, and our discussions with Japanese tour operators have confirmed our belief that 

our request for two daily slot pairs is modest given not only the size of the market, but 

also the dominance of the applicants in U.S.-Tokyo air travel. Between the U.S. and 

Japanese slot pairs that will be awarded – a total of eight slot pairs – Hawaiian’s request 

for two is modest given the competitive environment that will face a new entrant such as 

Hawaiian, where the other applicants and their alliance partners control nearly 100 

percent of the U.S.-Japan market. 

Given our financially sound position, we are the only carrier that has expanded its 

operations in the last year and we have on order nine Airbus 330 aircraft, the first three of 

which will be added to our fleet in 2010. These aircraft are perfectly suited to our 

proposed service, both to Asia and the U.S. mainland. Suggestions that we should 

purchase larger aircraft for this service are fatuous – acquiring one or two copies of an 

aircraft type not otherwise in a carrier’s fleet has been tried a couple of times before and 

as everyone in the industry knows, has each time been shown to be a costly mistake 

outside the bounds of commercial feasibility. 

Hawaiian’s Application Provides the Greatest Public Benefit 

 Because Hawaiian’s proposed service will have the greatest economic impact, the 

grant of Hawaiian’s application will provide the greatest benefits to the public. Visitors 

from abroad are an export of the United States. They spend money on goods and services 

produced and provided by Americans and as such they have a greater beneficial 

economic value to our economy than do U.S. residents who travel overseas. It is 

precisely because the majority of the traffic on Hawaiian’s proposed services is Japanoriginating that our proposals are superior in terms of domestic economic stimulus than 

the proposals of the other applicants. If encouraging economic growth and the creation 

of U.S. jobs is an objective of the U.S. Government in awarding the available slot pairs, 

then permitting Hawaiian to operate twice daily flights between Honolulu and Haneda 

would be the best use of this economic opportunity. That some carriers and their allies 

argue that the larger share of Japan-originating traffic to be carried on Hawaiian is a 

Exhibit HA-R-101 

Docket OST-2010-0018 

Page 2 of 4 

Page 2
negative consideration evidences a fundamental failure to appreciate the nature of how 

money spent on travel affects the economy laced, perhaps, with a touch of protectionism. 

The Award to Hawaiian of Two Daily Slot Pairs Will Combat the Consolidation 

Resulting from the Grant of Antitrust Immunity to the Alliance Carriers 

The other applicants in this proceeding and their alliance partners already exercise 

near-complete control over the U.S.-Tokyo market. Because the grant of antitrust 

immunity to certain alliance carriers is a condition of the MOU that has made the Haneda 

slots available, the integration of the alliance members on U.S.-Japan routes will be all 

but complete. Collectively, the Star, oneworld and SkyTeam carriers serve nearly 100 

percent of the traffic between the United States and 

Japan. 

The alliance carriers’ control of Narita warrants the award of two daily slot pairs 

to Hawaiian. The alliance carriers’ collective control over Narita has made initiating 

service at that airport all but impossible for a new entrant. The availability of slot pairs at 

Haneda therefore is a unique opportunity to facilitate the establishment of a new 

competitor serving the U.S.-Tokyo market. While we believe the award of one slot pair 

would be a successful enterprise for our company, the Department should award 

Hawaiian both pairs of slots it seeks if the Department truly wants to establish an 

alternative to the alliance carriers. 

Hawaiian’s Prior Service to Japan 

 Finally, I must address comments made by two other applicants in this proceeding 

concerning Hawaiian’s prior service to Japan. In our Reply, we list the routes the other 

applicants have failed to initiate or sustain within the last twenty years. The issues raised 

against Hawaiian are ten and twenty years old and are not relevant to this proceeding. 

Following the 1990 route proceeding, Hawaiian did start service to Fukuoka and 

subsequently the Department approved the sale of that route to Northwest by Order 91-4-

3. Following the 1998 route proceeding, Hawaiian’s Maui-Narita route approval was 

delayed several months from the award of other routes to our opponents in this 

proceeding due to ongoing litigation between environmental plaintiffs and the 

Department over the runway extension planned at Maui Airport. When final approval for 

the airport extension was finally received, despite Hawaiian’s timely application for slots 

at Narita, the Ministry of Transport in Japan denied Hawaiian’s request for slots. 

Hawaiian was not alone in seeking a delay, as the other applicants in that route 

proceeding, American, Continental and TWA, also requested delays in start dates. 

Ultimately, the Maui runway needed to support Hawaiian’s service to Narita was never 

built. Given those facts, Hawaiian notified the Department of its decision not to start that 

service and voluntarily returned the frequencies to the Department. 

Exhibit HA-R-101 

Docket OST-2010-0018 

Page 3 of 4 

Page 3
 

Hawaiian is fully committed to the use of two slot pairs at Haneda and is prepared 

to commence both flights should the Department award two slot pairs to Hawaiian. 

 Respectfully submitted, 

 

 Mark B. Dunkerley 

 

President and Chief Executive Officer 

 Hawaiian Airlines, Inc. 

Exhibit HA-R-101 

Docket OST-2010-0018 

Page 4 of 4 

Page 4
AMERICAN HAS DISCONTINUED/FAILED TO START 

AUTHORIZED SERVICE ON 88 INTERNATIONAL ROUTES SINCE 1990

Exhibit HA-R-102

Docket OST-2010-0018

Page 1 of 1

Note: May include routes that were discontinued and are now operated by an immunized alliance partner.

Source: U.S. DOT, T-100 Data, via Data Base Products; OAG; and DOT filings.

Route Discontinued Since 1990 Count Route Discontinued Since 1990 Count

Antigua (ANU) - New York Kennedy (JFK) 1 Hamilton (BDA) - New York LaGuardia (LGA) 45

Antigua (ANU) - Raleigh/Durham (RDU) 2 Hamilton (BDA) - Raleigh/Durham (RDU) 46

Aruba (AUA) - San Juan, Puerto (SJU) 3 Honolulu (HNL) - Sydney (SYD) 47

Auckland (AKL) - Honolulu (HNL) 4 La Paz (LPB) - Miami (MIA) 48

Barranquilla (BAQ) - Miami (MIA) 5 London (LGW) - St. Louis (STL) 49

Birmingham (BHX) - Chicago O'Hare (ORD) 6 London (LHR) - Philadelphia (PHL) 50

Bogota (BOG) - New York Kennedy (JFK) 7 Los Angeles (LAX) - San Jose (SJO) 51

Boston (BOS) - Cancun (CUN) 8 Manchester (MAN) - Miami (MIA) 52

Boston (BOS) - Manchester (MAN) 9 Mexico City (MEX) - San Antonio (SAT) 53

Boston (BOS) - Montego Bay (MBJ) 10 Miami (MIA) - Monterrey (MTY) 54

Boston (BOS) - Port Au Prince (PAP) 11 Miami (MIA) - Vancouver (YVR) 55

Boston (BOS) - Shannon (SNN) 12 Milan (MXP) - Chicago O'Hare (ORD) 56

Brussels (BRU) - Dallas/Ft. Worth (DFW) 13 Montego Bay (MBJ) - St. Louis (STL) 57

Buenos Aires (EZE) - Chicago O'Hare (ORD) 14 Monterrey (MTY) - Chicago O'Hare (ORD) 58

Cancun (CUN) - Raleigh/Durham (RDU) 15 Moscow (DME) - Chicago O'Hare (ORD) 59

Cancun (CUN) - St. Louis (STL) 16 Munich (MUC) - Chicago O'Hare (ORD) 60

Caracas (CCS) - Ft. Lauderdale (FLL) 17 Nagoya (NGO) - Chicago O'Hare (ORD) 61

Chicago O'Hare (ORD) - Berlin (TXL) 18 Nashville (BNA) - London (LGW) 62

Chicago O'Hare (ORD) - London (STN) 19 Nashville (BNA) - Toronto (YYZ) 63

Chicago O'Hare (ORD) - Puerto Vallarta (PVR) 20 Nassau (NAS) - Raleigh/Durham (RDU) 64

Chicago O'Hare (ORD) - Shannon (SNN) 21 New York Kennedy (JFK) - Kingston (KIN) 65

Chicago O'Hare (ORD) - Winnipeg (YWG) 22 New York Kennedy (JFK) - Lima (LIM) 66

Chicago O'Hare (ORD) - Zurich (ZRH) 23 New York Kennedy (JFK) - London (LGW) 67

Cozumel (CZM) - Miami (MIA) 24 New York Kennedy (JFK) - London (STN) 68

Cozumel (CZM) - Raleigh/Durham (RDU) 25 New York Kennedy (JFK) - Lyon (LYS) 69

Curacao (CUR) - New York Kennedy (JFK) 26 New York Kennedy (JFK) - Nassau (NAS) 70

Curacao (CUR) - San Juan, Puerto (SJU) 27 New York Kennedy (JFK) - Port of Spain (POS) 71

Dallas/Ft. Worth (DFW) - Lima (LIM) 28 New York Kennedy (JFK) - Puerto Plata (POP) 72

Dallas/Ft. Worth (DFW) - Manchester (MAN) 29 New York Kennedy (JFK) - Vancouver (YVR) 73

Dallas/Ft. Worth (DFW) - Osaka (KIX) 30 New York LaGuardia (LGA) - Nassau (NAS) 74

Dallas/Ft. Worth (DFW) - Puebla (PBC) 31 Newark (EWR) - London (LHR) 75

Dallas/Ft. Worth (DFW) - Zurich (ZRH) 32 Newark (EWR) - Santo Domingo (SDQ) 76

Dusseldorf (DUS) - Chicago O'Hare (ORD) 33 Paris (CDG) - Los Angeles (LAX) 77

Frankfurt (FRA) - Miami (MIA) 34 Paris (CDG) - San Jose (SJC) 78

Frankfurt (FRA) - New York Kennedy (JFK) 35 Paris (ORY) - Raleigh/Durham (RDU) 79

Ft. Lauderdale (FLL) - Kingston (KIN) 36 Raleigh/Durham (RDU) - St. Maarten (SXM) 80

Ft. Lauderdale (FLL) - San Jose (SJO) 37 San Jose (SJC) - Taipei (TPE) 81

Ft. Lauderdale (FLL) - Santo Domingo (SDQ) 38 San Jose (SJC) - Vancouver (YVR) 82

Glasgow (GLA) - Chicago O'Hare (ORD) 39 Sao Paulo (GRU) - Orlando (MCO) 83

Grand Cayman (GCM) - New York Kennedy (JFK) 40 St. Louis (STL) - Vancouver (YVR) 84

Grand Cayman (GCM) - Raleigh/Durham (RDU) 41 Stockholm (ARN) - Chicago O'Hare (ORD) 85

Guadalajara (GDL) - Los Angeles (LAX) 42 Tampa (TPA) - Toronto (YYZ) 86

Guatemala (GUA) - Los Angeles (LAX) 43 Tokyo (NRT) - San Jose (SJC) 87

Hamilton (BDA) - Boston (BOS) 44 Tokyo (NRT) - Seattle (SEA) 88

Page 5
CONTINENTAL/CONTINENTAL MICRONESIA

HAS DISCONTINUED/FAILED TO START 

AUTHORIZED SERVICE ON 60 INTERNATIONAL 

ROUTES SINCE 1990

Exhibit HA-R-103

Docket OST-2010-0018

Page 1 of 1

Route Discontinued Since 1990 Count Route Discontinued Since 1990 Count

Auckland (AKL) - Honolulu (HNL) 1 Honolulu (HNL) - Nagoya (NGO) 31

Bridgetown (BGI) - Newark (EWR) 2 Honolulu (HNL) - Sydney (SYD) 32

Brisbane (BNE) - Guam (GUM) 3 Honolulu (HNL) - Tokyo (NRT) 33

Brisbane (BNE) - Honolulu (HNL) 4 Honolulu (HNL) - Vancouver (YVR) 34

Brownsville (BRO) - Mexico City (MEX) 5 Houston Intercontinental (IAH) - Montreal (YUL) 35

Cali (CLO) - Houston Intercontinental (IAH) 6 Houston Intercontinental (IAH) - Punta Cana (PUJ) 36

Cancun (CUN) - New Orleans (MSY) 7 Johnston Island, U.S. T (JON) - Majuro (MAJ) 37

Caracas (CCS) - Newark (EWR) 8 Koror, Palau Isl (ROR) - Taipei (TPE) 38

Cebu (CEB) - Guam (GUM) 9 London (LGW) - Miami (MIA) 39

Cologne (CGN) - Newark (EWR) 10 Manila (MNL) - Saipan, Mariana Isl (SPN) 40

Denpasar (DPS) - Koror, Palau Isl (ROR) 11 Mexico City (MEX) - Mission/McAllen (MFE) 41

Denver (DEN) - London (LGW) 12 Mexico City (MEX) - San Antonio (SAT) 42

Dusseldorf (DUS) - Newark (EWR) 13 Mexico City (MEX) - San Diego (SAN) 43

El Paso (ELP) - Mexico City (MEX) 14 Nagoya (NGO) - Saipan, Mariana Isl (SPN) 44

Fukuoka (FUK) - Saipan, Mariana Isl (SPN) 15 Newark (EWR) - Calgary (YYC) 45

Guam (GUM) - Hong Kong (HKG) 16 Newark (EWR) - Freeport (FPO) 46

Guam (GUM) - Kaohsiung (KHH) 17 Newark (EWR) - Guayaquil (GYE) 47

Guam (GUM) - Noumea (NOU) 18 Newark (EWR) - Kingston (KIN) 48

Guam (GUM) - Okinawa (OKA) 19 Newark (EWR) - Rio De Janeiro (GIG) 49

Guam (GUM) - Ponape (PNI) 20 Newark (EWR) - Santiago (SCL) 50

Guam (GUM) - Seoul (SEL) 21 Newark (EWR) - Santiago (STI) 51

Guam (GUM) - Sydney (SYD) 22 Osaka (KIX) - Saipan, Mariana Isl (SPN) 52

Guam (GUM) - Taipei (TPE) 23 Paris (CDG) - Cleveland (CLE) 53

Guatemala (GUA) - Los Angeles (LAX) 24 Saipan, Mariana Isl (SPN) - Taipei (TPE) 54

Guayaquil (GYE) - Houston Intercontinental (IAH) 25 Sapporo (CTS) - Saipan, Mariana Isl (SPN) 55

Guayaquil (GYE) - Miami (MIA) 26 Sendai (SDJ) - Saipan, Mariana Isl (SPN) 56

Hamilton (BDA) - New York LaGuardia (LGA) 27 Seoul (SEL) - Saipan, Mariana Isl (SPN) 57

Hong Kong (HKG) - Saipan, Mariana Isl (SPN) 28 Spokane (GEG) - Vancouver (YVR) 58

Honolulu (HNL) - Manila (MNL) 29 St. Croix, Virgin Isl (STX) - St. Maarten (SXM) 59

Honolulu (HNL) - Melbourne (MEL) 30 Tokyo (NRT) - Seattle (SEA) 60

Note: May include routes that were discontinued and are now operated by an immunized alliance partner.

Source: U.S. DOT, T-100 Data, via Data Base Products; OAG; and DOT filings.

Page 6
DELTA HAS DISCONTINUED/FAILED TO START 

AUTHORIZED SERVICE ON 93 INTERNATIONAL ROUTES SINCE 1990

Exhibit HA-R-104

Docket OST-2010-0018

Page 1 of 1

Route Discontinued Since 1990 Count Route Discontinued Since 1990 Count

Acapulco (ACA) - Dallas/Ft. Worth (DFW) 1 Fukuoka (FUK) - Portland (PDX) 48

Amsterdam (AMS) - Cincinnati (CVG) 2 Guatemala (GUA) - New York Kennedy (JFK) 49

Anchorage (ANC) - Hong Kong (HKG) 3 Hamburg (HAM) - New York Kennedy (JFK) 50

Anchorage (ANC) - Seoul (SEL) 4 Helsinki (HEL) - New York Kennedy (JFK) 51

Atlanta (ATL) - Calgary (YYC) 5 Hong Kong (HKG) - Los Angeles (LAX) 52

Atlanta (ATL) - Dakar (DKR) 6 Las Vegas (LAS) - Calgary (YYC) 53

Atlanta (ATL) - Edinburgh (EDI) 7 London (LGW) - Miami (MIA) 54

Atlanta (ATL) - Hamburg (HAM) 8 Los Angeles (LAX) - Calgary (YYC) 55

Atlanta (ATL) - Istanbul (IST) 9 Los Angeles (LAX) - Ixtapa (ZIH) 56

Atlanta (ATL) - Ixtapa (ZIH) 10 Los Angeles (LAX) - Managua (MGA) 57

Atlanta (ATL) - Leon-Guanajuato (BJX) 11 Los Angeles (LAX) - Mazatlan (MZT) 58

Atlanta (ATL) - Merida (MID) 12 Los Angeles (LAX) - Mexico City (MEX) 59

Atlanta (ATL) - Nice (NCE) 13 Los Angeles (LAX) - Nagoya (NGO) 60

Atlanta (ATL) - Pointe A Pitre (PTP) 14 Los Angeles (LAX) - Taipei (TPE) 61

Atlanta (ATL) - Port of Spain (POS) 15 Los Angeles (LAX) - Vancouver (YVR) 62

Atlanta (ATL) - Shanghai (PVG) 16 Mazatlan (MZT) - Phoenix (PHX) 63

Atlanta (ATL) - Sal (SID) 17 Miami (MIA) - Montreal (YUL) 64

Atlanta (ATL) - Seoul (ICN) 18 Miami (MIA) - Toronto (YYZ) 65

Atlanta (ATL) - Shannon (SNN) 19 Montego Bay (MBJ) - Philadelphia (PHL) 66

Atlanta (ATL) - Vienna (VIE) 20 Nagoya (NGO) - Portland (PDX) 67

Mumbai (BOM) - New York Kennedy (JFK) 21 New York Kennedy (JFK) - Bucharest (OTP) 68

Boston (BOS) - Halifax (YHZ) 22 New York Kennedy (JFK) - Liberia (LIR) 69

Boston (BOS) - London (LGW) 23 New York Kennedy (JFK) - Lisbon (LIS) 70

Boston (BOS) - Montreal (YUL) 24 New York Kennedy (JFK) - Munich (MUC) 71

Boston (BOS) - Nassau (NAS) 25 New York Kennedy (JFK) - Nassau (NAS) 72

Buffalo (BUF) - Toronto (YYZ) 26 New York Kennedy (JFK) - Panama City (PTY) 73

Cincinnati (CVG) - Frankfurt (FRA) 27 New York Kennedy (JFK) - San Jose (SJO) 74

Cincinnati (CVG) - London (LGW) 28 New York Kennedy (JFK) - Stuttgart (STR) 75

Cincinnati (CVG) - Montego Bay (MBJ) 29 New York Kennedy (JFK) - Vienna (VIE) 76

Cincinnati (CVG) - Montreal (YUL) 30 New York Kennedy (JFK) - Warsaw (WAW) 77

Cincinnati (CVG) - Munich (MUC) 31 New York LaGuardia (LGA) - Montreal (YUL) 78

Cincinnati (CVG) - Nassau (NAS) 32 Newark (EWR) - Frankfurt (FRA) 79

Cincinnati (CVG) - Rome (FCO) 33 Orlando (MCO) - Nassau (NAS) 80

Cincinnati (CVG) - San Jose Del Cabo (SJD) 34 Orlando (MCO) - Paris (ORY) 81

Cincinnati (CVG) - Vancouver (YVR) 35 Oslo (FBU) - New York Kennedy (JFK) 82

Cincinnati (CVG) - Zurich (ZRH) 36 Paris (CDG) - New York Kennedy (JFK) 83

Dallas/Ft. Worth (DFW) - Frankfurt (FRA) 37 Phoenix (PHX) - Puerto Vallarta (PVR) 84

Dallas/Ft. Worth (DFW) - Mexico City (MEX) 38 Pittsburgh (PIT) - Toronto (YYZ) 85

Denver (DEN) - Calgary (YYC) 39 Portland (PDX) - Seoul (SEL) 86

Edinburgh (EDI) - New York Kennedy (JFK) 40 Portland (PDX) - Taipei (TPE) 87

Frankfurt (FRA) - Los Angeles (LAX) 41 Portland (PDX) - Vancouver (YVR) 88

Frankfurt (FRA) - Miami (MIA) 42 Salt Lake City (SLC) - Edmonton (YEG) 89

Frankfurt (FRA) - Orlando (MCO) 43 Salt Lake City (SLC) - Toronto (YYZ) 90

Frankfurt (FRA) - San Francisco (SFO) 44 San Francisco (SFO) - Vancouver (YVR) 91

Frankfurt (FRA) - Washington Dulles (IAD) 45 Stockholm (ARN) - Atlanta (ATL) 92

Ft. Lauderdale (FLL) - Nassau (NAS) 46 Tampa (TPA) - Toronto (YYZ) 93

Ft. Lauderdale (FLL) - Santo Domingo (SDQ) 47

Note: May include routes that were discontinued and are now operated by an immunized alliance partner.

Source: U.S. DOT, T-100 Data, via Data Base Products; OAG; and DOT filings.

Page 7
NORTHWEST HAS DISCONTINUED/FAILED TO START 

AUTHORIZED SERVICE ON 46 INTERNATIONAL ROUTES SINCE 1990

Exhibit HA-R-105

Docket OST-2010-0018

Page 1 of 1

Note: May include routes that were discontinued and are now operated by an immunized alliance partner.

Source: U.S. DOT, T-100 Data, via Data Base Products; OAG; and DOT filings.

Route Discontinued Since 1990 Count Route Discontinued Since 1990 Count

Amsterdam (AMS) - Hartford (BDL) 1 Guam (GUM) - Seoul (SEL) 24

Amsterdam (AMS) - Miami (MIA) 2 Guam (GUM) - Taipei (TPE) 25

Amsterdam (AMS) - Philadelphia (PHL) 3 Hong Kong (HKG) - Minneapolis/St. Paul (MSP) 26

Anchorage (ANC) - Seoul (SEL) 4 Hong Kong (HKG) - Seattle (SEA) 27

Boston (BOS) - Copenhagen (CPH) 5 Honolulu (HNL) - Nagoya (NGO) 28

Boston (BOS) - Frankfurt (FRA) 6 Honolulu (HNL) - Seoul (SEL) 29

Boston (BOS) - Glasgow (GLA) 7 Honolulu (HNL) - Sydney (SYD) 30

Boston (BOS) - Glasgow (PIK) 8 Las Vegas (LAS) - Tokyo (NRT) 31

Boston (BOS) - London (LGW) 9 London (LGW) - Minneapolis/St. Paul (MSP) 32

Boston (BOS) - Paris (CDG) 10 London (LHR) - Seattle (SEA) 33

Brussels (BRU) - Detroit (DTW) 11 Los Angeles (LAX) - Seoul (SEL) 34

Cancun (CUN) - Tampa (TPA) 12 Los Angeles (LAX) - Taipei (TPE) 35

Detroit (DTW) - Beijing (PEK) 13 Memphis (MEM) - Puerto Vallarta (PVR) 36

Detroit (DTW) - Calgary (YYC) 14 Milwaukee (MKE) - Toronto (YYZ) 37

Detroit (DTW) - Dusseldorf (DUS) 15 Minneapolis/St. Paul (MSP) - Oslo (OSL) 38

Detroit (DTW) - Milan (MXP) 16 Montego Bay (MBJ) - Tampa (TPA) 39

Detroit (DTW) - Osaka (KIX) 17 New York Kennedy (JFK) - Osaka (OSA) 40

Fukuoka (FUK) - Guam (GUM) 18 Osaka (KIX) - Los Angeles (LAX) 41

Fukuoka (FUK) - Honolulu (HNL) 19 Osaka (KIX) - Minneapolis/St. Paul (MSP) 42

Grand Cayman (GCM) - Memphis (MEM) 20 Paris (CDG) - Detroit (DTW) 43

Grand Cayman (GCM) - Miami (MIA) 21 Seattle (SEA) - Seoul (SEL) 44

Guam (GUM) - Manila (MNL) 22 Spokane (GEG) - Vancouver (YVR) 45

Guam (GUM) - Okinawa (OKA) 23 Tokyo (NRT) - Chicago O'Hare (ORD) 46

Page 8
UNITED HAS DISCONTINUED/FAILED TO START 

AUTHORIZED SERVICE ON 66 INTERNATIONAL ROUTES SINCE 1990

Exhibit HA-R-106

Docket OST-2010-0018

Page 1 of 1

Route Discontinued Since 1990 Count Route Discontinued Since 1990 Count

Acapulco (ACA) - Los Angeles (LAX) 1 Los Angeles (LAX) - San Jose (SJO) 34

Auckland (AKL) - Honolulu (HNL) 2 Los Angeles (LAX) - San Salvador (SAL) 35

Auckland (AKL) - Los Angeles (LAX) 3 Los Angeles (LAX) - Seoul (SEL) 36

Belo Horizonte (CNF) - Miami (MIA) 4 Mexico City (MEX) - Miami (MIA) 37

Boston (BOS) - London (LHR) 5 Miami (MIA) - Panama City (PTY) 38

Buenos Aires (EZE) - Chicago O'Hare (ORD) 6 Miami (MIA) - San Jose (SJO) 39

Buenos Aires (EZE) - Miami (MIA) 7 Miami (MIA) - San Salvador (SAL) 40

Buenos Aires (EZE) - New York Kennedy (JFK) 8 Miami (MIA) - Santiago (SCL) 41

Caracas (CCS) - Miami (MIA) 9 Nagoya (NGO) - San Francisco (SFO) 42

Caracas (CCS) - New York Kennedy (JFK) 10 New York Kennedy (JFK) - London (LHR) 43

Chicago O'Hare (ORD) - Seoul (SEL) 11 New York Kennedy (JFK) - Port of Spain (POS) 44

Denver (DEN) - Frankfurt (FRA) 12 New York Kennedy (JFK) - Tokyo (NRT) 45

Dusseldorf (DUS) - Chicago O'Hare (ORD) 13 Newark (EWR) - London (LHR) 46

Dusseldorf (DUS) - Washington Dulles (IAD) 14 Newark (EWR) - Tokyo (NRT) 47

Frankfurt (FRA) - Los Angeles (LAX) 15 Orlando (MCO) - Mexico City (MEX) 48

Glasgow (GLA) - Washington Dulles (IAD) 16 Osaka (KIX) - Chicago O'Hare (ORD) 49

Grand Cayman (GCM) - Miami (MIA) 17 Osaka (KIX) - Los Angeles (LAX) 50

Guadalajara (GDL) - San Francisco (SFO) 18 Paris (CDG) - Los Angeles (LAX) 51

Guam (GUM) - Osaka (KIX) 19 Paris (CDG) - San Francisco (SFO) 52

Guatemala (GUA) - Chicago O'Hare (ORD) 20 Rio De Janeiro (GIG) - Miami (MIA) 53

Guatemala (GUA) - Los Angeles (LAX) 21 Rio De Janeiro (GIG) - New York Kennedy (JFK) 54

Guatemala (GUA) - Miami (MIA) 22 San Francisco (SFO) - Guangzhou (CAN) 55

Hamilton (BDA) - Chicago O'Hare (ORD) 23 San Francisco (SFO) - Taipei (TPE) 56

Hamilton (BDA) - Washington Dulles (IAD) 24 Sao Paulo (GRU) - Los Angeles (LAX) 57

Hong Kong (HKG) - Los Angeles (LAX) 25 Sao Paulo (GRU) - Miami (MIA) 58

Hong Kong (HKG) - New York Kennedy (JFK) 26 Sao Paulo (GRU) - New York Kennedy (JFK) 59

Hong Kong (HKG) - Seattle (SEA) 27 Seattle (SEA) - Vancouver (YVR) 60

Honolulu (HNL) - Osaka (KIX) 28 Spokane (GEG) - Calgary (YYC) 61

Honolulu (HNL) - Seoul (SEL) 29 Washington Dulles (IAD) - Milan (MXP) 62

Honolulu (HNL) - Taipei (TPE) 30 Washington Dulles (IAD) - Nassau (NAS) 63

Lima (LIM) - Miami (MIA) 31 Washington Dulles (IAD) - San Jose (SJO) 64

London (LHR) - Miami (MIA) 32 Washington Dulles (IAD) - San Salvador (SAL) 65

London (LHR) - Seattle (SEA) 33 Washington Dulles (IAD) - Vancouver (YVR) 66

Note: May include routes that were discontinued and are now operated by an immunized alliance partner.

Source: U.S. DOT, T-100 Data, via Data Base Products; OAG; and DOT filings.

Page 9
CONTINENTAL MICRONESIA’S HNL-GUM-HND SERVICE WOULD ADD 

OVER 3,000 MILES AND 8 HOURS IN ELAPSED TIME

FOR A HNL-HND ROUNDTRIP PASSENGER COMPARED 

TO HAWAIIAN’S NONSTOP PROPOSAL

(Reply to CO-A-116)

Exhibit HA-R-107

Docket OST-2010-0018

Page 1 of 1

HA’s Proposed HNL-HND Nonstop

CO’s Proposed HNL-GUM-HND Connecting Service

Additional Time for CO’s Proposal

Note: Winter Schedules Are Used.

Source: Exhibit HA-App-2, Exhibit CO-124-CO-125, Official Airline Guide, schedules for the week of February 8, 2010.

16:15

24:50

8:35

Roundtrip

Elapsed Time

Additional Miles for CO HNL-GUM-HND Connecting Service: 3,010

% Circuity: 39%

Page 10
HNL IS OVER TWO TIMES THE SIZE OF 

ANY OTHER APPLICANT’S FIRST CHOICE GATEWAY

1.58

0.72

0.54

0.31

0.15

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.4

1.6

1.8

HNL SFO JFK SEA EWR

Tokyo Onboard Passengers of First Choice Gateways (Millions)

Source: U. S. DOT T-100 data, YE August 2009, via Data Base Products.

Exhibit HA-R-108

Docket OST-2010-0018

Page 1 of 1

Honolulu Relative Size: 2.2x 2.9x 5.0x 10.4x

Page 11
HNL IS OVER TWO TIMES THE SIZE OF

UNITED’S FIRST CHOICE GATEWAY

1.58

0.72

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.4

1.6

1.8

HNL SFO

Tokyo Onboard Passengers of First Choice Gateways (Millions)

Source: U. S. DOT T-100 data, YE August 2009, via Data Base Products.

Exhibit HA-R-109

Docket OST-2010-0018

Page 1 of 1

2.2x

Page 12
HNL IS ALMOST THREE TIMES THE SIZE OF

AMERICAN’S FIRST CHOICE GATEWAY

1.58

0.54

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.4

1.6

1.8

HNL JFK

Source: U. S. DOT T-100 data, YE August 2009, via Data Base Products.

Exhibit HA-R-110

Docket OST-2010-0018

Page 1 of 1

2.9x

Tokyo Onboard Passengers of First Choice Gateways (Millions)

Page 13
HNL IS FIVE TIMES THE SIZE OF

DELTA’S FIRST CHOICE GATEWAY

1.58

0.31

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.4

1.6

1.8

HNL SEA

Source: U. S. DOT T-100 data, YE August 2009, via Data Base Products.

Exhibit HA-R-111

Docket OST-2010-0018

Page 1 of 1

5.0x

Tokyo Onboard Passengers of First Choice Gateways (Millions)

Page 14
HNL IS OVER TEN TIMES THE SIZE OF

CONTINENTAL’S FIRST CHOICE GATEWAY

1.58

0.15

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.4

1.6

1.8

HNL EWR

Source: U. S. DOT T-100 data, YE August 2009, via Data Base Products.

Exhibit HA-R-112

Docket OST-2010-0018

Page 1 of 1

10.4x

Tokyo Onboard Passengers of First Choice Gateways (Millions)

Page 15