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 ANSWER 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 

Associate General Counsel 

Mark.Arimoto@hawaiianair.com 

Hawaiian Airlines, Inc. 

P.O. Box 30008 

Honolulu, HI 96820-0008 

Jonathan B. Hill 

J. Parker Erkmann 

Brent Olson 

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 

bolson@dowlohnes.com 

Counsel for Hawaiian Airlines, Inc. 

September 6, 2012
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 1 of 35 

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 

______________________________) 

September 6, 2012 

CONSOLIDATED ANSWER OF HAWAIIAN AIRLINES, INC. 

DOT established this proceeding to update the record to reallocate a single slot 

pair for combination service between the United States and Tokyo International Airport 

(“Haneda”). In 2010, DOT awarded Haneda slot pairs to three carriers, Delta, American 

and Hawaiian. Each of these carriers has had the opportunity to demonstrate its 

respective commitment to Haneda service. 1 To determine which of the competing 

applications in this proceeding best serves the public interest, DOT must evaluate the 

carriers’ experience since U.S.-Haneda service began two years ago. That operating 

experience demonstrates that the gateways proposed by Delta, United and American have 

more than ample nonstop service from Tokyo to meet current and foreseeable demand, 

that gateways with a high proportion and high volume of Japanese originating traffic are 

                                                            

1

 Although DOT did not award a slot pair to United in the initial 2010 proceeding, DOT 

has ample evidence of how the market will react to the proposals of the alliance carriers. 

United’s alliance partner ANA received two Haneda slots, and JAL is serving the very 

HND-SFO route for which United has applied. The results of this mainland service are 

relevant to the evaluation of United’s proposal. 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 2 of 35 

most likely to succeed, and that only one U.S. carrier, Hawaiian, has demonstrated the 

ability and commitment to fully utilize the authority at issue. Consequently, the public 

interest will be best served by awarding the frequency to the proposed gateway that, as 

established by the experience of the past two years, will generate the greatest benefit to 

the United States. Any rigorous analysis of the available data leads to the inevitable 

conclusion that Hawaiian’s Kona-Haneda service is the best proposal for a number of 

reasons: 

 Kona is the only market proposed in this proceeding currently without nonstop 

service to Tokyo. See HA-2012A-201. 

 The Tokyo-Kona market is sufficiently large that it will significantly outperform 

all of the other Haneda gateways. See HA-2012A-203. 

 Of all the proposals in this proceeding, Hawaiian proposes to use the largest 

aircraft for its service. See HA-2012A-108, 109. 

 Of all the proposals in this proceeding, Kona will generate the most domestic 

economic growth and jobs. See HA-2012A-402, 404. 

By contrast, the competing applications of Delta, American and United are deeply 

flawed replicas of their initial 2010 applications. The renewed applications completely 

ignore the lessons learned over the past two years. Undaunted by its failure to make 

Detroit a successful gateway and having withdrawn its Detroit schedule from the GDSs 

prior to the DOT’s decision in this case, Delta again has asked for authority to operate 

from Haneda to Seattle, a smaller market with substantial preexisting service to Tokyo. 

American has again applied for Los Angeles, despite its current focus on restructuring its 

business and the fact that its proposed service duplicates underutilized Haneda service 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 3 of 35 

offered by both Delta and ANA. United has again asked for San Francisco, despite 

JAL’s existing, duplicative and underperforming Haneda service to the airport. The 

proposed city pairs already are saturated with abundant service provided by the members 

of the Star, Skyteam and oneworld alliances (collectively, the “alliance carriers”), two of 

whom operate in metal-neutral joint ventures from both of the Tokyo airports, Haneda 

and Narita Airport. 

The alliance carriers’ proposals are recipes for more failure. All the alliances 

maintain significant hubs at Narita and propose to serve mainland points on routes they 

already serve from Narita. They attempt to rationalize this duplicative service by 

promising a high volume of connecting traffic on the Haneda flights. HA-2012A-103. 

This formula has failed for two years, see HA-2012A-104, and the alliances fail to 

explain why the Department should expect a different result going forward. In contrast, 

Hawaiian began service as a new entrant independent of the alliances on a route 

consisting mostly of local traffic. Hawaiian has delivered continuous service and flown 

more passengers to and from Haneda than the rest of the U.S. carriers combined. HA2012A-103. 

It speaks volumes that none of the alliance carrier applications address the nearly 

two years of operating history between Haneda and the United States. Any examination 

of that operating history leads to an obvious conclusion – one carrier stands alone in its 

commitment to Haneda service, Hawaiian Airlines. See HA-2012A-105. Since 

becoming the first carrier to initiate service to Haneda, Hawaiian has operated its 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 4 of 35 

Haneda-Honolulu route continuously with load factors that far exceed those of other U.S. 

carriers awarded Haneda slots, see HA-2012A-311, and provided strong competition to 

Japanese carriers on its route. See HA-2012A-105.

This performance reflects not only Hawaiian’s commitment to growing its 

transpacific business, but also the fact that Hawaiian is wholly committed to Haneda. 

Unlike the alliances, Hawaiian does not have to balance its Haneda service with a 

preexisting and substantial investment at Narita. See HA-2012A-106 (depicting 

Hawaiian’s lack of Narita service). As a result, Hawaiian has made the most of its 

Haneda opportunity and flown its allocated frequencies, rather than squandering them 

like Delta and American. See HA-2012A-107 (documenting the failure of Delta and 

American to use their allocated Haneda frequencies a full 57 percent of the time). 

In addition, none of the other proposed gateways even approach the size of the 

Hawaii market, and, given that Tokyo-Kona has no nonstop service, Kona is the most 

under-served market proposed in this proceeding. See HA-2012A-202. Only Hawaiian’s 

Kona application will result in a significant influx of passengers and therefore tourist 

dollars into the U.S and Hawaii, creating over 1,400 U.S jobs, generating $74 million in 

new exports annually, increasing the U.S. GDP by $135 million annually and increasing 

aggregate U.S. household earnings by over $39 million annually. HA-2012A-402, 403, 

404, 405. These significant economic benefits will flow primarily to the State of Hawaii, 

where the Japanese originating passengers will stay and spend their money. Based on the 

operational track record, analysis of passenger demand and its impact on the economy, it 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 5 of 35 

is apparent that Hawaiian’s proposed service to Kona will be a commercial success and 

result in the greatest public interest benefits.

I. Hawaiian’s Proposed Service to Kona Provides the Greatest Public 

Interest Benefits. 

In announcing its tentative decision in 2010, DOT acknowledged that when it has 

“an opportunity to introduce or re-introduce service to an area that has long been 

unavailable to U.S. carriers, the Department has typically attempted, where possible, to 

satisfy diverse public interest objectives and needs in selecting carrier proposals for 

award of the available rights.” Order 2010-5-7 at 8 (citing 2007/2008 U.S.-Colombia 

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

In the 2010 Haneda proceeding, DOT concluded that: 

[T]he ability to allocate slot pairs to enable four daily U.S.-Haneda 

services, allows us to reintroduce convenient U.S.-Tokyo while 

address[ing] a variety of important public interest objectives. Specifically, 

we can introduce new competition in the U.S.-Tokyo market, address the 

need for U.S.-Haneda service in the largest mainland U.S.-Tokyo O&D 

markets, and enhance competition in the U.S.-Tokyo and U.S.-Asia 

markets.

See id. DOT’s evaluation of these public interest criteria should also reflect the nearly 

two years of operating experience at Haneda. As will be discussed below, that 

experience demonstrates that the amount of connecting service available has not been 

particularly important in the success of a particular Haneda gateway. Instead, success has 

been highly correlated with local market demand. The Department recognized this 

possibility when it initially awarded a slot pair to Delta’s Detroit service. At that time it 

expressed concern that the “Detroit-Tokyo local O&D market is the smallest proposed in 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 6 of 35 

this proceeding,” but concluded that “Delta would offer important service and 

competition benefits by providing connecting services at Detroit to the largest behindgateway catchment area in this proceeding.” Order 2010-5-7 at 10. The Department’s 

concerns about the size of the Detroit local market were well-founded, but the value of 

the connecting service has proven elusive, if not nonexistent. The Department 

commenced this proceeding when Delta abandoned its Detroit-Haneda service in large 

part because the connecting traffic promised by Delta never materialized. Further, as 

Exhibit HA-2012A-101 demonstrates, load factor on the Haneda service is highly 

correlated with the percentage of Tokyo originating passengers. Honolulu has by far the 

highest load factor at 78 percent and the highest share of Tokyo-originating passengers, 

while Detroit has the lowest load factor and lowest point of sale in Tokyo. See id. This 

result is intuitive, as the residents of Tokyo are most likely to appreciate and make 

purchase decisions based on the convenience of their downtown airport, Haneda. 

 Applying the Department’s established public interest criteria in this proceeding – 

especially in light of the last two years’ operating experience – will require the award of 

the Haneda frequency to Hawaiian. Hawaiian’s application is the only one that will: (1) 

create a new, viable, sustainable service; (2) reduce concentration in the markets between 

Japan and the United States and increase competition with the alliances; (3) strengthen a 

small competitor; (4) provide the greatest benefit to the economy of the U.S. and the state 

of Hawaii; and (5) avoid giving the effective benefit of the Haneda slots to the Japanese 

carriers. 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 7 of 35 

A. Hawaiian’s Proposed Kona Service Is the Best Use of the Sole 

Slot Pair Available in this Proceeding. 

Kona is the most underserved gateway proposed in this proceeding. Hawaii 

represents the largest travel market for the Japanese visitors to the U.S. In 2011, more 

Japanese visited Hawaii than visited the entire U.S. mainland combined. See Exhibit HA2012A-314, 315, 316. More specifically, Hawaii received twice the number of Japanese 

visitors as the two other proposed gateway states combined. See Exhibit HA-2012A-317, 

318. And 2012 promises to be even bigger, “[t]hrough May, the number of Japanese 

visitor arrivals to Hawaii has increased by more than 18%.”

2

 Despite the huge numbers 

of Japanese visiting Hawaii, Kona, the second-most popular destination after Honolulu, 

lacks nonstop service from Tokyo. Kona is the second largest market for travel between 

the U.S. and Japan without nonstop Tokyo service and the only market in this proceeding 

without nonstop service. See Exhibit HA-App2012-12; Exhibit HA-2012A-201. 

Hawaiian sees Kona as an overlooked opportunity to put this underutilized Haneda slot 

pair to its highest and best use rather than have it allocated to the alliance carriers who 

propose only to serve markets with abundant nonstop service to Tokyo. 

By any measure, Hawaii is the most important U.S.-Japan market. The TokyoHawaii O&D market is 63 percent larger than the next largest state, California, and more 

than 1396 percent larger than the State of Washington. Exhibit HA-2012A-307. 

Likewise, the number of Haneda-Hawaii onboard passengers is almost double the size of 

                                                            

2

  Ron Watanabe, Hawaii Hotter Than Ever for Travelers, HotelNewsNow.com (Sep. 4, 

2012) (available at: http://hotelnewsnow.com/Articles.aspx/8887/Hawaii-hotter-thanever-for-travelers) (emphasis added). 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 8 of 35 

California, the next largest state. See Exhibit HA-2012A-306. Indeed, the size of the 

Haneda-Hawaii O&D market is larger than all the other current U.S. gateways combined. 

See Exhibit-2012A-304. Hawaii has more Haneda onboard passengers than any other 

Haneda gateway, see HA-2012A-301, and the number of Haneda onboard passengers in 

Hawaii also exceeds the number of onboard passengers for all the other Haneda gateways 

combined. See Exhibit HA-2012A-302. This includes California – which already has 

the same number of Haneda frequencies as Hawaii – making the rationale for American’s 

and United’s proposals to put additional capacity into California markets difficult to 

comprehend. Perhaps most important, the market for service between Japan and Hawaii 

is growing, while that for service to the mainland is declining. See Exhibit HA-2012A305. 

Kona in particular is a strong market – the island of Hawaii is easily the secondmost visited destination by Japanese tourists in the state of Hawaii – with significant 

existing traffic between it and Tokyo. See Exhibit HA-2012A-206, 207. In fact, the ratio 

of passengers on the route to the number of nonstop frequencies serving the market 

(including the proposals in this proceeding), demonstrates that Kona is the most 

underserved route of all the proposed gateways in this proceeding. See Exhibit HA2012A-202. And with nonstop service, Hawaiian would expect this traffic to grow 

significantly as markets gaining nonstop service typically do. See Exhibit HA-2012A204. The resulting traffic on the HND-KOA route would amount to over 146,000 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 9 of 35 

passengers per year.3 See id. This projected traffic would compare favorably with 

Hawaiian’s successful Honolulu service, see Exhibit HA-2012A-205, and it exceeds the 

total of all existing mainland gateways that use a single-slot. See Exhibit HA-2012A203. 

Kona is the best option for the remaining slot pair. Awarding the last remaining 

slot pair to Hawaiian for its Kona service will satisfy demand not presently being met in 

the market place. Further, the demand for the route would overwhelmingly come from 

Japan. See HA-2012A-102 (stating that 97 percent of passengers are Japanese point of 

origin, the highest of any proposed gateway). And as the two years of operational 

experience at Haneda teaches, the routes with the highest percentage of Japaneseoriginating traffic are the ones that succeed. See Exhibit HA-2012A-101. Given 

Hawaiian’s successful experience with Haneda, Hawaiian expects similar results with its 

proposed Kona service. 

B. The Grant of Hawaiian’s Application to Serve Kona Will Reduce 

Concentration in Markets Dominated by the Three Global Alliances. 

Reducing the power of the alliance oligopoly should be one of the Department’s 

highest priorities in this proceeding. The grants of antitrust immunity that created the 

alliance oligopoly were conditioned on the United States and Japan entering into the 

Open Skies Agreement that made this proceeding possible. U.S.-Japan Alliance Case, 

                                                            

3

 The 146,000 number is very conservative because it is derived from data from the 12 

months ending February 2012. In the first six months of 2012, Japanese air visitors to 

Hawaii increased by 17 percent according to the Hawaii Department of Business, 

Economic Development and Tourism. In addition, Hawaiian has experienced an 18 

percent increase in HND passengers in the first 8 months of 2012. 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 10 of 35 

Order 2010-11-10, at 1 (Nov. 10, 2010). While Hawaiian fully supports the liberalization 

of the U.S.-Japan aviation relationship, the agreement was not without its countervailing 

effects. With the approval of the Open Skies Agreement, the resulting approval of the 

alliances left the U.S.-Japan markets highly concentrated. The Skyteam, Star and 

oneworld alliances (of which, respectively, Delta, United and American are members) 

control 97 percent of the U.S.-Tokyo frequencies, and 98 percent of capacity and 92 

percent of Tokyo-Honolulu frequencies. See Exhibit HA-2012A-501, 502, 505. Since 

2009, industry concentration in the U.S.–Tokyo market has almost doubled as measured 

by the Herfindahl-Hirsch Index (HHI).4

 Delta’s merger with Northwest made it the 

largest U.S flag carrier and the U.S. carrier with the most service to Japan. American and 

United have formed joint ventures with antitrust immunity with the two Japanese flag 

carriers. See Exhibit HA-2012A-506. Consolidation resulting in this level of 

concentration is presumed to enhance market power as to pricing and capacity.5

 

Ironically, each of the alliance carriers submitting applications in this proceeding 

assert that grant of its application is necessary to balance competition among the rival 

alliances. American 2012 Application, OST-2010-0018, at 3 (Aug. 27, 2012) (“To 

maximize alliance competition in the largest Mainland-Tokyo market that would result in 

                                                            

4

 The Herfindahl-Hirschman Index (“HHI”) is a measure of market concentration (based 

upon market shares) used commonly by the U.S. Department of Justice’s Antitrust 

Division and the Federal Trade Commission.  U.S. DOJ & FTC, Horizontal Merger 

Guidelines § 5 (Aug. 19, 2010).

5

 U.S. DOJ & FTC, Horizontal Merger Guidelines § 5.3 (Aug. 19, 2010). Although the 

Antitrust Division typically assesses the competitive effects of concentration on a citypair by city-pair basis, the significant increase in the HHIs for all U.S.-Tokyo markets 

illustrates the overall impact of the consolidation. 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 11 of 35 

the greatest benefit to the traveling public, American and Los Angeles should be selected 

in this proceeding.”); Delta 2012 Application, OST-2010-0018, at 1 (Aug. 27, 2012) 

(granting the application “will also enhance Delta’s competitiveness against the Star and 

oneworld alliance that dominate Haneda”); United 2012 Application, OST-2010-0018, at 

4 (Aug. 27, 2012) (“Awarding the available Tokyo Haneda slots to United would correct 

this imbalance [among U.S. carriers serving Tokyo], would finally provide for 

competitive parity among U.S. carriers at Tokyo Haneda and would offer nationwide 

public benefits . . . .”). These assertions fail to see the forest for the trees. By any metric 

service to Tokyo is dominated by the alliances and is highly concentrated. The three 

alliances control 97 percent of all Tokyo capacity, and the oneworld and Star alliance 

partners alone control 77 percent of departures at Haneda and 83 percent of capacity. 

HA-2012A-503, 504. 

Only the grant of Hawaiian’s application will serve to loosen the grip of the 

alliance oligopoly and reduce concentration. While the award of the one available slot 

pair to any of the other applicants would simply strengthen the alliances’ hold on the 

Japanese market, the grant of Hawaiian’s application would double its service to Tokyo. 

Although even Hawaii-Tokyo service would still be dominated by the alliances, see 

Exhibit HA-2012A-505 (depicting Hawaiian’s 8 percent share of Hawaii-Tokyo 

frequencies compared to the alliances’ 92 percent), it will give Hawaiian a stronger base 

from which to grow. Two years of operating experience since 2010 demonstrate that 

Hawaiian can, and will, take advantage of this opportunity. 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 12 of 35 

Indeed, in the 2010 proceeding, Hawaiian represented that the award of a Haneda 

frequency would allow it to establish a platform from which to grow. See Consolidated 

Reply of Hawaiian Airlines, Inc., OST-2010-0018, at 6-7 (Mar. 8, 2010). Hawaiian has 

delivered on that promise and initiated service in two additional Japanese markets with a 

third market to open later this year. Hawaiian also has expanded the breadth of its 

service in Japan by entering a procompetitive, yet not immunized, codeshare agreement 

with ANA, serving six destinations in Japan.6

 Moreover, Hawaiian’s willingness to 

compete with the alliance carriers between Tokyo and Honolulu has had procompetitive 

effects. Hawaiian’s service has stimulated significantly more traffic than the mainland 

routes to Tokyo from the United States. See Exhibit HA-2012A-320. In fact, Honolulu 

experienced more than two times the stimulation of all other gateways combined. See

Exhibit HA-2012A-321. Hawaiian, and Hawaiian only, can bring the benefits of 

increased competition to U.S.-Japanese markets. The public benefit of reducing this 

highly concentrated market is significant and Hawaiian should be given the opportunity 

to expand upon its successful platform through the award of an additional slot at Haneda. 

Delta has the temerity to suggest that it should be awarded the slots, in part, 

because it is without a Japanese alliance partner, arguing that grant of its application “will 

enhance Delta’s competitiveness against the Star and oneworld alliances that dominate 

Haneda by virtue of the protected incumbent hubs of their immunized Japanese alliance 

partners.” Delta Application at 1. Delta’s argument lacks the slightest bit of self-

                                                            

6

 These destinations include: Hiroshima, Kagoshima, Oita, Okinawa, Osaka-Itami and 

Sapporo-Chitose. 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 13 of 35 

awareness and should be given no weight. Through its acquisition of Northwest, Delta 

inherited its own incumbent position at Narita, where Delta is the largest foreign carrier. 

See Exhibit HA-2012A-802. Moreover, despite not having a Japanese alliance partner, 

the Skyteam alliance is a close second to the Star alliance in passengers and flights 

between Tokyo and the U.S. Exhibit HA-2012A-501, 502. And Delta is the single 

largest carrier between Tokyo and the U.S. See Exhibit HA-2012A-802. If DOT wants 

to address the problem of market concentration, its only choice is to award the available 

slot pair to Hawaiian. 

C. The Grant of Hawaiian’s Application Will Strengthen a Small 

Competitor. 

The grant of Hawaiian’s application to serve Kona will also strengthen a small 

competitor. It is the long-standing policy of the Department and its forerunner agency, 

the Civil Aeronautics Board, that a primary factor in the Department’s public interest 

analysis is the strengthening of smaller carriers. See e.g., St. Louis-Southeast Service 

Case, 27 C.A.B. 342, 347 (“[T]he need of a smaller carrier for route strengthening has 

been, and should be, an important factor to be considered by us in selecting a carrier to 

provide needed service.”); c.f. Southwest-Northeast Service Case, 22 C.A.B. 973 (1955); 

New York-Florida Case, 24 C.A.B. 94 (1956). Recent proceedings confirm that the 

Department continues to weigh this factor heavily in its public interest analysis because 

strengthening smaller carriers remains the best way for the Department to enhance 

competition and reduce market concentration. 1998 U.S.-Brazil Combination Service 

Case, Order 98-12-33, at 8 (Dec. 29, 1998) (finding its selection of Continental would 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 14 of 35 

“enhance the ability of a relatively new Brazil entrant to compete and reduce 

concentration”); 2007/2008 U.S.-Columbia Combination Frequency Allocation 

Proceeding, Order 2008-5-27, at 8 (May 21, 2008) (finding that the allocation of 

frequencies to JetBlue and Spirit “would provide much needed competition in a 

frequency-limited U.S.-Columbia market that has not seen the entry of any new U.S. 

competitor since the year 2000.”) 

This principle strongly favors an award of the frequency to Hawaiian. The other 

applicants are all over 10 times the size of Hawaiian. See Exhibit HA-2012A-110. Of all 

the applicants in this proceeding, Hawaiian is the smallest competitor in the market for 

Tokyo-United States service by at least an order of magnitude. See Exhibit HA-2012A501, 502, 505. Despite Hawaiian’s small size, its track record in this proceeding 

demonstrates it is in the best position to maximize the benefit from the proposed slots. In 

2010, Hawaiian had no service to Japan at all. Upon receiving one HND slot pair, not 

only was Hawaiian able to operate the awarded route successfully, but it used this 

operating base to build a successful scheduled service franchise in Japan. Hawaiian’s 

success surpassed the Department’s aspirations in its 2010 Order: “Hawaiian’s entry into 

the Japanese market should be a positive development, in terms of offering greater choice 

to travelers as well as increased competition in the U.S.-Japan market.” Order 2010-5-7 

at 8. Hawaiian respectfully submits that DOT should recognize the success of its prior 

decision and build upon that success by awarding a second Haneda slot pair to Hawaiian 

to serve Kona. 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 15 of 35 

D. The Initiation of Haneda-Kona Service Will Benefit the Economy of 

the United States and the State of Hawaii. 

Because the preponderance of traffic on Hawaiian’s proposed Kona to Haneda 

service will be Japanese originating, Hawaiian’s proposal will bring the greatest 

economic benefit to the United States and the State of Hawaii. Unlike the other 

proposals, Hawaiian’s Kona service focuses on bringing in spending to Hawaii and the 

United States and not exporting that spending to Japan or other destination countries. 

Money spent in the United States, and more specifically on the island of Hawaii, by 

Japanese passengers is the functional equivalent of increased United States exports. 

Unlike other applicant carriers that will have a much more balanced distribution of 

Japanese and U.S. resident originating traffic, the passengers on Hawaiian’s flight 

represent a significant net inflow of currency into the United States and Hawaii. 

Hawaiian projects that its proposed Kona flight will result in more visitors to the 

U.S. and therefore in more economic growth than the other proposed gateways in this 

proceeding. Because service to Kona would introduce true nonstop service in a large 

O&D market, Hawaiian projects, on a very conservative basis, that it will stimulate a 

significant number of incremental Japanese visitors, 33,240, or more than 59 percent 

more than any other proposed gateway. See Exhibit HA-2012A-401. Because Japanese 

visitors to Hawaii spend more than Japanese who visit elsewhere in the United States (64 

percent more than the U.S. average and 35 percent more than Japanese visitors to 

California), Hawaiian’s Kona service will have an even larger economic impact. See 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 16 of 35 

Exhibits HA-2012A-402, 403, 404, 405, 406. Hawaiian projects that the proposed Kona 

service would result in $74 million additional dollars injected into the economy of 

Hawaii and the United States annually, more than two times higher than the impact of 

any other proposed gateway. See Exhibit HA-2012A-403. Accounting for typical 

economic multipliers, this incremental spending will result in an additional $135 million 

in U.S. GDP growth, more than 115 percent higher than any other proposed gateway. 

See Exhibit HA-2012A-404. This GDP growth will support an additional 1,400 U.S. 

jobs, nearly triple the next-highest gateway. See Exhibit HA-2012A-402. Those jobs 

will be in the State of Hawaii and mainly on the Big Island of Hawaii. 

This economic boon for the State of Hawaii and the United States is a significant 

public interest benefit unique to Hawaiian’s Kona application. See Order 2010-5-7 at 9 

(“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.”). 

E. Because Hawaiian Is Independent of the Major Alliances, the Grant 

of Hawaiian’s Application Will Benefit U.S. Flag Carriers Rather 

than Japanese Flag Carriers. 

Awarding the available pair of Haneda slots to Hawaiian is necessary to avoid 

handing control of the routes to the Japanese flag alliance partners of American and 

United. American and JAL are part of the oneworld alliance, which received antitrust 

immunity in 2010. U.S.-Japan Alliance Case, Order 2010-11-10. Likewise, ANA and 

United are part of the Star alliance, which also received antitrust immunity in 2010. Id. 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 17 of 35 

In touting the benefits of antitrust immunity, the applicants stated that the alliance would 

be structured to be “metal neutral,” meaning that alliance members would coordinate 

schedules and fares to act, for the purposes of the applicable routes, as a single carrier. 

Further, in granting the oneworld and Star applications for antitrust immunity, the 

Department found the “intended commercial effects of the[se] . . . joint venture 

agreements are similar to those resulting from a merger.” Id. at 3 (emphasis added). As a 

result, the award of the slot pair to United or American is the equivalent of returning it to 

the Japanese carriers ANA or JAL. 

Together the Star and oneworld alliances already dominate traffic between the 

U.S. and Japan. These two alliances already control 83 percent of all Haneda capacity. 

See Exhibit HA-2012A-504. And they control 62 percent of the traffic between the U.S. 

and Tokyo. See Exhibit HA-2012A-502. 

The Department and its colleagues at the State Department bargained hard to 

obtain the right for U.S. carriers to serve Haneda. The instant proceeding is the result of 

a compromise in the MOU by which four Haneda slot pairs were to be allocated to 

Japanese carriers and four were to be allocated to U.S. carriers for U.S. service. The 

DOT should not upset this balance by handing these valuable rights right back to the 

alliance partners of the Japanese carriers. The Star and oneworld alliances already hold 

five of the eight available slot pairs, and an award to either United or American would 

increase the share of these alliances to 75 percent. Not only are the Japanese carriers able 

to exercise some degree of control over the slots allocated to their alliance partners, but 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 18 of 35 

any profits earned on the routes are necessarily split pursuant to their respective joint 

venture agreements. 

II. Hawaiian’s Operational Experience Since the Department’s Initial 

Award of Haneda Slots in 2010 Demonstrates that It Is the Most Worthy 

Recipient of the One Available Slot Pair in 2012. 

Of the recipients of Haneda slots in the Department’s 2010 proceeding, Hawaiian 

has made the most productive use of these valuable rights. By any measure, Hawaiian’s 

Haneda service is the most successful of the four awarded in 2010. It leads all the other 

carriers in load factor, numbers of operations, passengers carried and traffic stimulated. 

Indeed, Hawaiian’s Honolulu to Haneda service is arguably the only successful Haneda 

route awarded in the 2010 proceeding. 

A. Hawaiian Has Been the Most Reliable U.S. Carrier Operating at Haneda. 

Hawaiian was the first carrier to initiate its Haneda service, beginning in 

November 2010. The other carriers requested extensions of the time to start their 

respective services. See Motion of Delta Air Lines, Inc. for a 30 Day Startup Extension, 

OST-2010-0018 (September 7, 2010); Motion of American Airlines, Inc. for 28-Day 

Start-up Extension (New York JFK – Tokyo Haneda), OST-2010-0018 (December 20, 

2010). Since initiating its service, Hawaiian has operated its service continuously, even 

through the tragic events of the Japanese earthquake, tsunami and associated nuclear 

disaster. See Exhibits HA-App2012-4, 5 , 6, 7. Indeed, in the year ended January 2012, 

Hawaiian conducted more operations on its Haneda-Honolulu route than any other 

carrier, including Japanese carriers, on their Haneda routes. See Exhibit HA-2012A-105. 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 19 of 35 

By contrast, other airlines have repeatedly halted service and requested waivers of the 90-

day dormancy condition. See, e.g., Exhibit HA-App2012-5; Motion of Delta Air Lines, 

Inc., OST-2010-0018 (June 3, 2011). 

B. Hawaiian Upgauged the Aircraft It Flies on the Haneda Route, While 

Delta Downgauged Its Aircraft. 

As promised in its application, Hawaiian increased the size of the aircraft it uses 

to serve Haneda. After initiating service with 264 seat B767s, Hawaiian began to fly 

A330-200s accommodating 294 passengers as these new aircraft were acquired and 

introduced into its fleet. In contrast, Delta, which promised to serve the route with a 

B747-400, downgauged its aircraft after only 32 flights, and now serves its LAX route – 

when it is serving it at all – with 40 percent less capacity then it proposed to the 

Department. See Exhibit HA-2012A-808. In fact, in the year ending February 2012, 

Delta only operated 51 percent of the seats it promised for LAX and only 19 percent of 

the seats it promised for DTW. See Exhibit HA-2012A-808. 

Delta’s decision to down-gauge was particularly remarkable because the 

Department expressly relied upon Delta’s representation that it would use B747-400s in 

making the original award to the Delta. See Order 2010-5-7 at 10 (“We tentatively find 

that Delta’s significant capacity advantage is particularly compelling at Los Angeles, 

clearly the largest Tokyo traffic generator of the proposed west coast gateways to 

Haneda.”); see id. (“Delta’s proposed use of B747 aircraft for its Detroit service would 

also maximize use of its hub gateway in serving Haneda, enabling it to accommodate 

traffic from both the Detroit-Tokyo local market and its catchment area”). Delta even 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 20 of 35 

chided Hawaiian for proposing to use a smaller aircraft. See Reply of Delta Air Lines, 

Inc., OST-2010-0018, 2 (March 8, 2010). Yet Delta’s service using B747s on its Detroit 

route lasted a month, and it cut capacity for its Los Angeles flight after a month as well. 

See Exhibit HA-2012A-807, 808. Ironically, Hawaiian has served more Haneda 

passengers with a single slot pair than Delta served with two Haneda slot pairs. See 

Exhibit HA-2012A-809 (depicting that the number of Haneda passengers carried by 

Hawaiian was 43 percent more than the amount carried by Delta to LAX and DTW 

combined). 

In its 2012 Application, Delta has proposed to serve Seattle using a B767-300 ER 

with only 225 seats, Delta’s smallest internationally-configured wide-body aircraft, see 

Delta 2012 Application at 5, nearly 70 fewer seats than the 294-seat A330-200s that 

Hawaiian proposes to use for its proposed Kona service. 

C. Hawaiian Used Its Haneda Service as a Launching Point for Expanded 

Service to Japan. 

Hawaiian, taking full advantage of the Open Skies Agreement, has not been 

content to simply operate the single successful route awarded to it between Haneda and 

Honolulu. Instead, it has seized the opportunity facilitated by the Department’s award of 

Haneda slots. For years, Hawaiian’s presence in Japan had been limited to charter 

service and the marketing of its Inter-Island services to tourists who traveled to Hawaii 

on other carriers. The introduction of Hawaiian’s Haneda service established it as a 

legitimate competitive provider of travel between Japan and the Hawaiian Islands. This 

increased awareness resulting from Hawaiian’s marketing efforts among the Japanese 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 21 of 35 

public and tour operators has facilitated Hawaiian’s introduction of its own services to 

additional cities in Japan, including Osaka, Fukuoka and beginning in November 2012, 

Sapporo-Chitose and free sale codeshare service with ANA to Hiroshima, Kagoshima, 

Oita, Okinawa, Osaka-Itami and Sapporo-Chitose.

D. As Hawaiian Predicted, Operation of the Alliance Carriers’ 2010 

Proposed Flights Required Capacity Reductions at Narita. 

The Haneda service offered by the other slot recipients – all of which have 

significant operations at Narita either individually or through their alliance partners – 

have largely cannibalized their existing Narita services. Exhibit HA-2012A-319. Indeed, 

in arguing for the allocation of two Haneda slots in the 2010 proceeding, Hawaiian 

predicted that the alliance carriers would be required to divert traffic from their Narita 

operations to support their otherwise unsustainable proposed Haneda services. See 

Consolidated Answer of Hawaiian Airlines, Inc., DOT-OST-2010-0018 (Mar. 1, 2010), 

at 11 (“Diversion of traffic . . . from these carriers’ existing service only threatens to 

weaken their service at Narita”). Specifically, Hawaiian predicted that: 

 Operation of American’s JFK flight would require Narita capacity reductions or a 

low load factor of 59 percent. See Exhibit HA-A-303 (March 1, 2010).

 Operation of Delta’s DTW flight would result in load factors of 64 percent, 

meaning that 32 percent of Delta’s NRT-DTW passengers would have to divert to 

the Haneda flight to achieve a 75 percent load factor. See Exhibit HA-A-514, 515 

(March 1, 2010).

 Operation of Delta’s LAX flight would result in load factors of 69 percent, 

meaning that 13 percent of Delta’s NRT-DTW passengers would have to divert to 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 22 of 35 

the Haneda flight to achieve a 75 percent load factor. See Exhibit HA-A-520, 521 

(March 1, 2010).7

With respect to Delta, these predictions proved to be overly optimistic, as it has failed to 

meet even these low projections despite flight cancellations. See HA-2012A-311. 

American only achieved its 72.9 percent load factor for its JFK service by cutting 

capacity through service cancellations. For the most recently reported 12-month period, 

American operated less than one third of the seats it promised in 2010. Exhibit HA2012A-703.

E. Hawaiian Delivered on its Promise to Stimulate New Traffic to Honolulu. 

In its 2010 Application, Hawaiian predicted that it would stimulate additional 

traffic on its proposed Honolulu to Haneda route. Hawaiian argued that its service would 

stimulate more traffic than any of the other carriers’ proposed services. See Answer of 

Hawaiian Airlines, Inc., OST-2010-0018, 17 (March 1, 2010); Exhibits HA-A-304, 404, 

507, 604. Not only did Hawaiian deliver on the pledge, but Hawaiian’s estimates proved 

to be very accurate. Hawaiian predicted that passenger traffic would grow by over 

72,000 passengers per year based on Hawaiian’s new flights between Haneda and 

Honolulu. The market actually grew by 227,626 passengers (Exhibit HA-2012A-320) 

with Hawaiian and two Japanese carriers on the route – an average increase of 75,875 per 

                                                            

7

 To the extent necessary Hawaiian requests that the Department take notice of the 

exhibits in this docket submitted by Hawaiian in the 2010 proceeding as they demonstrate 

the consistency and accuracy of Hawaiian’s position on the issue of the projected 

performance of the other carriers in that and this proceeding. Copies of all of Hawaiian’s 

2010 exhibits referenced in this answer are attached as Appendix A: Referenced 2010 

Exhibits. 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 23 of 35 

carrier. Honolulu performed better than any other gateway, and, indeed, more traffic was 

stimulated on the Honolulu route than on all the other Haneda gateways combined. See 

Exhibit HA-2012A-321.8

 

By contrast, the applications submitted by the other applicants ignore the lessons 

taught by the past two years of actual operations at Haneda. Instead, they continue to trot 

out the same arguments that the alliance carriers made in their 2010 applications (e.g., the 

importance of connecting service), even though the past two years have demonstrated 

that those arguments are without merit. See Part III, infra. 

F. Hawaiian’s Service Brought the Greatest Economic Benefit to the U.S. 

Hawaiian predicted that its proposed service would bring Japanese yen and 

therefore economic growth to the U.S. Again, Hawaiian delivered on its promises. 

Hawaiian carried more U.S.-bound passengers than any other U.S. carrier. See Exhibit 

HA-2012A-103. As discussed in section I.D., these additional visitors to Hawaii spent 

money and supported the economy of the United States and the State of Hawaii. In the 

2010 proceeding Hawaiian forecast the economic impact of the Honolulu service would: 

generate $57 million in new US exports annually; increase on the U.S. GDP by over $112 

million annually; increase U.S. household earnings by $30 million annually; and increase 

employment by 1200 jobs. HA-A-230, 231, 232, 233. The projected impact of the Kona 

service is comparable. See Section I.D, supra.

                                                            

8

 Exhibits HA-2012A-320 and 321 use adjusted MIDT passengers to reflect the total 

market size and therefore are comparable to Hawaiian’s 2010 forecasts. 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 24 of 35 

III. Hawaiian’s Proposed Service to Kona Is Superior to Other Carriers’ 

Proposals. 

Only Hawaiian’s proposed service to Kona will introduce nonstop service from 

Tokyo to a market that does not currently have it. In comparison, SEA, SFO and LAX 

have abundant service by alliance and other carriers. Exhibit HA-2012A-201. 

Hawaii and California both have Haneda service from three carriers (Japanese and 

U.S.) despite Hawaii having almost twice as many passengers. See Exhibit HA-2012A306, 309. Accordingly, Hawaii should get a fourth designation before California gets 

another one, especially since Hawaii’s three Haneda U.S./Japanese designations have 

generated more Haneda passengers than all five of the other Haneda designations 

combined. Exhibit HA-2012A-302, 304. 

The alliance carriers have announced service additions to Seattle, the San 

Francisco Bay Area and Southern California that further diminish any perceived need for 

more Tokyo capacity at those respective airports. ANA – and by extension its alliance 

partner United – is adding a new SEA flight and initiating service to San Jose, which is 

just 32 miles from SFO and within SFO’s catchment area. JAL – and by extension its 

alliance partner American – is adding a daily Tokyo-San Diego flight which will 

recapture passengers now supporting LAX flights. This additional service from the 

oneworld alliance undermines American’s case for its LAX application. 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 25 of 35 

A. Given the Abundant Existing Service to LAX, the Market Will Not 

Support American’s Proposed Additional Service. 

American’s proposal to serve LAX would put additional capacity into a market 

that already has it in abundance. The Tokyo-LAX market already is served by 67 weekly 

roundtrips, including Haneda service offered by both Delta and ANA. Exhibit HA2012A-201. A significant number of the total Tokyo-LAX capacity is offered by 

American and its alliance partner, JAL, which provide 14 of the weekly roundtrips. See 

Exhibit HA-2012A-710. Moreover, that service will come under additional pressure as 

JAL institutes four weekly roundtrips to nearby San Diego, increasing to daily in March 

2013. See Exhibit HA-2012A-712. In the face of this ample capacity, American 

proposes to increase capacity by 11 percent. Exhibit HA-2012A-707. The overall 

increase in capacity would be even higher if Delta decided to fulfill its 2010 HND 

commitment by using the larger aircraft it promised. In fact, the difference between 

Delta’s promised versus actual LAX-HND capacity equals 80 percent of the capacity 

American proposes to add to LAX. See Exhibit HA-2012A-708. 

The last two years of operating data for LAX-HND demonstrate that American’s 

service will have a low load factor, requiring capacity cuts or price increases to make the 

proposal a success. Delta, a comparable legacy hub carrier at LAX, attracted only 71.1 

percent of its Narita level of passengers. Assuming American will be able to achieve the 

same ratio as Delta, its projected load factor will be only 56 percent. HA-2012A-706. 

Even with a generous assumption of stimulation on this well-served route, the Tokyo 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 26 of 35 

market load factor will be only 73 percent with American service, which is significantly 

less than the American’s U.S.-Tokyo average of 79 percent. HA-2012A-711. 

American’s apparent concerns about capacity on this route are reflected in the fact 

that it proposes to use a 247-seat B777, see American Application Exhibit AA-102, 

which has 19 percent less capacity than the 294-seat A330-200 proposed by Hawaiian. 

See Exhibit HA-2012A-704. 

 American’s operating record at Haneda also suggests that the award of a second 

slot would be a waste of valuable resources. American has repeatedly canceled its 

Haneda service, doing so 77 percent of the time between January 2011 and May 2012. 

See Exhibit HA-2012A-702. As a result, through February 2012 Hawaiian has carried 

more than 4.8 times as many Haneda passengers as American. See Exhibit HA-2012A705. The precious U.S. carrier Haneda slots should be awarded to a carrier with the track 

record of delivering high-quality, consistent service with its allocated Haneda slots, and 

not a carrier with a track record of repeated cancellations. 

B. The Existing Excess Capacity on the Tokyo-San Francisco Route Is 

Further Reason Not to Award the One Available Haneda Slot to the 

Alliance with the Highest Tokyo-U.S. Market Share. 

San Francisco is a poor candidate for an award of the Haneda slot pair available in 

this proceeding. Like other markets in this proceeding, the Tokyo-San Francisco market 

already has abundant service. The alliance carriers currently offer 40 weekly roundtrips 

to San Francisco. See Exhibit HA-2012A-201. United’s application acknowledges the 

overabundance of capacity in only committing to “continue to operate at least one daily 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 27 of 35 

Tokyo flight year round if awarded the requested Tokyo Haneda Slots.” United 

Application at 2 fn. 4. Operating one daily flight would actually be less than its current 

service to Tokyo. See Exhibit HA-2012A-906. United and its Star Alliance partner ANA 

offer 21 of those roundtrips and propose to introduce 5 more roundtrips to San Jose, well 

within the SFO catchment area. See Exhibit HA-2012A-909, 914. Thus, United has 

requested the award of a frequency on a route where it and its alliance partner already 

possess a dominant 60 percent market share. See Exhibit HA-2012A-908. The Star 

Alliance also has the largest Tokyo-U.S. market share. See id. Awarding the slot pair to 

United serves to put capacity where it is not needed and grant additional authority to the 

dominant carriers in the market. Indeed, the award to United would completely 

undermine the public interest goal of “enhance[ing] competition in the U.S.-Tokyo 

market while failing to achieve the goal of “address[ing] the need for U.S.-Haneda 

service in the largest mainland U.S.-Tokyo O&D markets,” given the existing surplus of 

HND-SFO service. Order 2010-5-7 at 8. 

The SFO-HND route has existing service from JAL and that service has not been 

successful. JAL’s service has been plagued by unused capacity and a surplus of seats. 

See HA-2012A-903. JAL’s SFO service has the lowest load factor of any Haneda 

gateway besides Delta’s failed Detroit service, see Exhibit HA-2012A-904, and JAL’s 

SFO service has underperformed the predecessor NRT service that the Haneda service 

replaced. See Exhibit HA-2012A-907. United’s response to all this excess capacity in 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 28 of 35 

the Tokyo-Bay Area market is to propose increasing it by up to 33 percent.9 See Exhibit 

HA-2012A-910. It should also be noted that in 2010 United said that “San Francisco and 

Detroit would serve a comparable number of local plus connecting passengers.” Exhibit 

HA2012A-905. Given United’s own previous analysis, San Francisco service would be a 

failure. 

The Tokyo-San Francisco market is simply not large enough to accommodate 

United’s proposed service additions. Even accounting for stimulation, which standard 

QSI analysis suggests will be under 50,000 annual passengers, the estimated load factor 

for all carriers will be 66 percent. See Exhibits HA-2012A-912, 913. This is not 

sufficient to sustain current service without significant price increases. See id. The 

logical conclusion to be drawn from the limited “commitment” to continue the service, is 

that United will cut existing Narita service or only operate the precious Haneda slots 

seasonally. See Exhibit HA-2012A-906. Moreover, United’s intention to cut capacity is 

further demonstrated by its proposal to use a 268-seat B777-200, see United Application 

Exhibit UA-113, which is 10 percent smaller than the 294-seat A330-200 proposed by 

Hawaiian. See Exhibit HA-2012A-902. While United’s candor in admitting that the 

SFO market cannot bear both its existing Narita-SFO service and its proposed Haneda 

service is admirable, the public interest requires an award that will increase service, and 

not merely shift it. 

                                                            

9

 United does suggest it would reduce capacity to accommodate the Haneda flight. 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 29 of 35 

C. The Seattle Market Is Not Large Enough to Support Delta’s Proposed 

Service. 

The Seattle market is also simply not large enough to support Delta’s proposed 

Haneda service. Even though the market currently is served by 21 weekly roundtrips 

provided by Delta, United and ANA from Narita, the market has fewer Japanese point-ofsale passengers than does Kona, which has no nonstop service. See Exhibit HA-2012A810. Indeed, in the 2010 proceeding, the Department concluded that the Seattle market 

was too small to support an award of a Haneda slot. See Order 2010-5-7 at 10 (awarding 

slots to serve LAX because it is “significantly larger than both the San Francisco-Tokyo 

and Seattle-Tokyo markets”). Nothing has changed. Seattle is still too small to support 

more service and, like Detroit, will not be rescued by connecting service from Delta, 

Alaska or anyone else. 

The 2010 award of a Haneda slot pair to Delta’s proposed Detroit service was 

predicated upon its superior connecting options, yet it failed. Now Delta asserts that it 

can succeed in Seattle with only half the connecting opportunities of Delta’s failed 

Detroit service. See Exhibit HA-2012A-805, 806. This claim is dubious given Delta’s 

Haneda operating history and the overlapping nature of the proposed connections with 

Delta’s existing service. Of the 62 U.S. points Delta proposes to connect to Haneda 

through Seattle, eighteen (or approximately 29 percent of them) overlap with the 

connecting destinations Delta promised to link in its original Detroit application, see 

Delta 2010 Application, at DL-117; Delta Application, Exhibit DL-401, 402, 403, 

meaning that Delta is promising to do better with many of the same connections that it 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 30 of 35 

proposed for its failed Detroit service. Moreover, most of the Detroit connections flew 

on Delta’s own metal (as opposed to Alaska’s aircraft under its current proposal) which 

allowed for easier control of ticket prices and scheduling. The proposed connections also 

are generally of shorter stage lengths from DTW than from Seattle. The Seattle 

connections will also undermine Delta’s LAX service. Of the top O&D cities on Delta’s 

LAX-HND flight, 11 of them (or approximately 20 percent) are also cities Delta is 

promising to link to Haneda through Seattle.10 Consequently, Delta will, at best, dilute its 

existing service to make Seattle work, and, at worst, dilute both flights, increasing the 

chance that LAX and SEA will suffer the same fate as Delta’s Detroit service. 

This proposal is especially suspect in light of the abundant and increasing TokyoSeattle service. The combined effect of ANA’s new Seattle service and Delta’s proposal 

will be to increase capacity on the route by 71 percent. See Exhibit HA-2012A-812. In 

light of the fact that the market has decreased since 2009, it cannot absorb that capacity. 

See Exhibit HA-2012A-813. Even accounting for stimulation, which standard QSI 

analysis suggests will be a paltry 40,000 annual passengers, the estimated load factor for 

all carriers in the Tokyo market will be 59 percent. See Exhibit HA-2012A-815, 816. 

This is far below Delta’s standard for Tokyo-U.S. flights, see Exhibit HA-2012A-816, 

and is below the low bar of 60 percent set by Delta’s failed Detroit-Haneda service. See 

Exhibit HA-2012A-101. 

                                                            

10 The overlapping gateways are LAS, JFK, SFO, SAN, MCO, ATL, PHX, DTW, SEA, 

SLC, MSP, MIA.
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 31 of 35 

The aircraft selection decisions of both Delta and ANA acknowledge that the 

Seattle market will not support the influx of capacity. ANA has announced that, after 

beginning its Seattle service with a B777, it will downgauge to the smaller B787 aircraft. 

See Exhibit HA-2012A-811. Having proposed to serve the market with a 298 seat A330 

in 2010, Delta now offers a 225 seat B767-300 ER, which is not only the smallest aircraft 

in Delta’s international fleet but the smallest aircraft proposed in this proceeding. See

HA-2012A-109. In fact, Hawaiian’s proposed A330-200 will provide 31 percent more 

capacity than Delta’s proposed B767-300ER. See id. 

Delta, evidently not learning from its Detroit experience, has again proposed a 

recipe for another failed Haneda route. Its record of using these scarce resources is not 

impressive. In 2011, Delta failed to operate more than half its allocated Haneda slots. 

See Exhibit HA-2012A-802. Delta’s performance was so poor that it actually flew fewer 

passengers to and from Haneda than Hawaiian, despite having twice the number of slots 

and proposing to use much larger aircraft. See Exhibit HA-2012A-809. This 

performance should not be rewarded, and the single slot pair available in this proceeding 

should be awarded to the most consistent operator at Haneda, Hawaiian. 

IV. Hawaiian Has a Unique Incentive to Make Its Haneda Service a Success. 

Unlike the other carriers in this proceeding, Hawaiian has no investment in 

operations and facilities at Narita. Narita is dominated by the alliance carriers, which 

have huge commitments to that airport. United and ANA operate 43 segments from 

Narita, including 21 weekly frequencies to San Francisco. See Exhibit HA-2012A-901. 
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 32 of 35 

Delta operates 20 segments from Narita, including 7 weekly frequencies to Seattle. See 

Exhibit HA-2012A-801. American and JAL operate 37 segments at Narita, including 14 

weekly frequencies to LAX. See Exhibit HA-2012A-701. As a result, Hawaiian has a 

unique incentive to invest in and develop its Haneda service and can entirely focus its 

efforts in Tokyo there without worrying about cannibalizing a Narita hub. 

The conflicting incentives of the other carriers in this proceeding have plagued 

their respective Haneda services. Exhibit HA-2012A-319. In fact, the fear of diversion 

from existing Narita services has likely been a major contributor to the periodic 

suspensions of all the mainline routes from the alliance carriers. 

Because Hawaiian only operates at Haneda, it has a powerful incentive to 

promote, sell and operate its service at the airport. As a result, its service is additive to 

the capacity of the Tokyo-U.S. market, which has led to an expanding Tokyo-Honolulu 

market and a superior operating record at Haneda. 

V. Hawaiian Offers Superior Customer Service. 

Hawaiian’s application also best satisfies the public interest because its customer 

service is superior to the other applicants in this proceeding. Indeed, Hawaiian 

consistently outperforms the alliance carriers on important customer service metrics. In 

2011, Hawaiian again led the industry in on-time arrivals. See Exhibit HA-2012A-602. 

This represents the eighth year in a row that Hawaiian has led this category. See Exhibit 

HA-2012A-606. Hawaiian also bests the other applicants in the rate of mishandled bags, 

see Exhibit HA-2012A-603, and has done so for a number of years. See Exhibit HA-
DOT-OST-2010-0018 

2012 Answer of Hawaiian Airlines, Inc. 

 Page 33 of 35 

2012A-607. By a substantial margin, Hawaiian has the lowest rate of passengers 

involuntarily denied boarding. See Exhibit HA-2012A-604 (depicting Delta’s rate as 

nearly 3 times Hawaiian’s rate and United and American more than 8 times Hawaiian’s 

rate). Hawaiian’s superior service manifests itself in a primary indicator of customer 

satisfaction – fewest customer complaints. In 2011, Hawaiian’s customer complaint rate 

was only half that of second-best Delta and a third of United’s rate. See Exhibit HA2012A-605. Again, this represented the eighth year in a row that Hawaiian has 

outperformed the other applicants in this proceeding. See Exhibit HA-2012A-608. 

Hawaiian has achieved this performance while growing its business and as the other 

carriers in this proceeding have cut capacity. See Exhibits HA-2012App-21; HA-2012A601. 

Conclusion 

 As set forth in this Consolidated Answer, the public interest will be best served by 

the award of Delta’s currently abandoned Haneda frequency to Hawaiian Airlines. Kona 

is the only market presented to the Department without nonstop service. Selection of 

Kona as the fourth route to Haneda will insure that the valuable frequency is put to the 

highest and best use, that the public receives the most benefit and that the Department 

 
w

ca

will not be ag

arriers failed

gain faced w

d to deliver o

 

 

 

 

ith the prosp

on their prom

pect of re-liti

mises. 

 Resp

Jona

J. Pa

Bren

 Dow

1200

Suit

Was

(202

(202

jhill

perk

bols

 Cou

2012 Answ

igating a rou

pectfully sub

athan B. Hill

arker Erkma

nt Olson 

w Lohnes PL

0 New Hamp

te 800 

shington, DC

2) 776-2000

2) 776-4725 

l@dowlohne

kmann@dow

son@dowloh

unsel for Haw

DOT

wer of Hawai

ute proceedin

bmitted, 

l

ann 

LLC 

mpshire Ave.,

C 20036 

(fax) 

es.com 

wlohnes.com

hnes.com

waiian Airlin

-OST-2010-

iian Airlines

Page 34

ng because 

, NW 

m

nes, Inc. 

-0018 

s, Inc. 

of 35 
DOT-OST-2O10-0018

2012 Answer of Hawaiian Airlines, Inc.

Page 35 of35

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Consolidated Answer of Hawaiian

Airlines, Inc. was served this 6th day of September 2012 viaemail transmission or U.S.

mail on the following:

Carl.nelson(@.aa.com

Iìobert.wirick@aa.com

Francis.heil@aa.com

James.kalei gh@aa. corn

Marshal L sinick@squiresanders. com

Eclrvard. sauer@scl ui resanders. com

Sascha.vanderbel len@de lta.com

J e11. mor gan fg)delta. com

Sametta. c.barnett(@delta.com

Tim.OMalleyl@alph.olq

Dan.weiss@united.com

Steve.rnon'i sse)r@united. com

Jonathan. I inde@united.com

rbkeiner@crowell.com

lhalloway@cromwell. com

gmurphy@crorvell.com

esta. rosenberg@dot. gov

brett.kruger@dot.gov

urskllg,ìstate.gov

john.allen@faa.gov

W i I I iam. stall in gs@usdo_i . gov

i nf b l@,ai rlineinf'o. com

Ambassador Ichiro Fuj isaki

Embassy of Japan

2520 Massachusetts Ave., NW

Washington, DC 20008
INDEX OF EXHIBITS

Exhibit Number Description No. of Pages

Exhibit HA-2012A-101 Haneda Success is Highly Correlated to Tokyo 

Originating Passengers

1

Exhibit HA-2012A-102 Kona Has the Highest Percentage of Point of 

Origin Tokyo Passengers

1

Exhibit HA-2012A-103 Carrier Size and Dominance Has Not Been a Good 

Predictor of Haneda Success

1

Exhibit HA-2012A-104 The Other Applicants Are Proposing Service 

Eerily Similar to Services That Have Failed at 

Other Mainland Gateways

1

Exhibit HA-2012A-105 Only Hawaiian Has Stood Up to Strong Japanese 

Competition

1

Exhibit HA-2012A-106 Only Hawaiian Can Prioritize Its Haneda Service 1

Exhibit HA-2012A-107 Hawaiian Operated All of Its Awarded 

Frequencies While U.S. Mainland Carriers 

Squandered 57% of Their Awarded U.S. – Haneda 

Frequencies

1

Exhibit HA-2012A-108 Hawaiian Will Operate the Largest Aircraft 1

Exhibit HA-2012A-109 Hawaiian Will Provide 10% - 31% More Haneda 

Capacity Than the Other Applicants

1

Exhibit HA-2012A-110 The Other Applicant Carriers Are 11 to 16 Times 

as Large as Hawaiian

1

Exhibit HA-2012A-201 Kona is the Only New Tokyo Gateway Proposed 

in This Proceeding

1

Exhibit HA-2012A-202 Kona is the Most Underserved Tokyo Market 1
Exhibit HA-2012A-203 Kona Will Outperform Current Single-Slot 

Mainland Gateways to Haneda

1

Exhibit HA-2012A-204 Kona Will Generate Over 146,000 Onboard 

Passengers

1

Exhibit HA-2012A-205 Kona Has the Potential to Produce Similar 

Onboard Passenger Numbers to HA’s Successful 

HNL-HND Service

1

Exhibit HA-2012A-206 The Big Island Is the 2nd Most Visited Island in 

Hawaii for Japanes

1

Exhibit HA-2012A-207 13% of Japanese Visitors to Hawaii Visited Kona 

and the Big Island

1

Exhibit HA-2012A-301 Hawaii is the Largest U.S. - Haneda Gateway and 

Generates the Most Haneda O&D Passengers

1

Exhibit HA-2012A-302 Hawaii Has More Haneda Gateway and More 

Haneda O&D Passengers Than All the Other U.S. 

- Haneda Gateways Combined

1

Exhibit HA-2012A-303 Hawaii is the Largest U.S. - Haneda Gateway and 

Generates the Most Haneda O&D Passengers

1

Exhibit HA-2012A-304 Hawaii Has More Haneda Gateway and More 

Haneda O&D Passengers Than All the Other U.S. 

- Haneda Gateways Combined

1

Exhibit HA-2012A-305 The Hawaii – Tokyo Market Is Growing While the 

Mainland-Tokyo Market is Shrinking

1

Exhibit HA-2012A-306 The Hawaii-Tokyo O&D Market Is Much Larger 

than the Size of the Second Largest U.S. State

1

Exhibit HA-2012A-307 The Hawaii-Tokyo O&D Market is 63% Larger 

Than California and Over 1000% Larger Than 

Washington State

1

Exhibit HA-2012A-308 Hawaii Has 47% More Tokyo Passengers Than the 

Other Two Proposed Gateway States Combined

1
Exhibit HA-2012A-309 The Hawaii-Haneda O&D Market Size is Nearly 

Two Times the Size of the Second Largest U.S. 

State

1

Exhibit HA-2012A-310 Despite the Tsunami Impacted Travel and 

Significant Capacity Additions, the Hawaii-Tokyo 

Market Maintained Strong Load Factors

1

Exhibit HA-2012A-311 The Three Highest Haneda Carrier Load Factor 

Segments Were All From Hawaii

1

Exhibit HA-2012A-312 Hawaii Had the Highest Tokyo Point of Origin 

Percentage of All Haneda Gateways

1

Exhibit HA-2012A-313 Hawaii is the Most Underserved Tokyo Market 1

Exhibit HA-2012A-314 Hawaii is the Most Popular U.S. Destination for 

Japanese Visitors and Has Been the Preferred 

Destination for Japanese Visitors Since 2001

1

Exhibit HA-2012A-315 Hawaii is the Most Popular U.S. Destination for 

Japanese Visitors and Has Been the Preferred 

Destination for Japanese Visitors Since 2001

1

Exhibit HA-2012A-316 More Japanese Tourists Visit Hawaii Than Visit 

the Entire U.S. Mainland

1

Exhibit HA-2012A-317 Hawaii Has Over Two Times the Japanese Visitors 

to California and Nearly Twenty Times the 

Japanese Visitors to Washington

1

Exhibit HA-2012A-318 Hawaii Has Twice the Number of Japanese 

Visitors as the Other Proposed Gateway States 

Combined

1

Exhibit HA-2012A-319 All Three Mainland Gateway Carriers Experienced 

Significant Diversion From Their NRT Flights

1

Exhibit HA-2012A-320 HNL-HND Service Generated 227,626 New 

Tokyo O&D Passengers

1

Exhibit HA-2012A-321 HNL-HND Service Has Generated More New 

Tokyo O&D Passengers Than All The Other U.S. 

– HND Gateways Combined

1
Exhibit HA-2012A-401 Hawaiian’s Proposed Kona Flight Will Bring in 

59% More Incremental U.S. Visitors Than the 

Second Highest Proposed Gateway

1

Exhibit HA-2012A-402 Hawaiian’s Proposed Kona Flight Will Create 

Over 1,400 U.S. Jobs, Over Two and a Half Times 

the Second Highest Gateway

1

Exhibit HA-2012A-403 Hawaiian’s Proposed Kona Flight Will Bring in 

$73.8 Million in New U.S. Exports Annually, 

Over Two Times the Second Highest Gateway

1

Exhibit HA-2012A-404 Hawaiian’s Proposed Kona Flight Will Increase 

U.S. GDP by $135 Million Annually, Over 115% 

More Than the Second Highest Gateway

1

Exhibit HA-2012A-405 Hawaiian’s Proposed Kona Flight Will Increase 

Aggregate U.S. Household Earnings by $39 

Million Annually, More Than Double the Second 

Highest Gateway

1

Exhibit HA-2012A-406 Japanese Visitors to Hawaii Spend 64% More 

Than the U.S. Average and 35% More Than 

Japanese Visitors to California

1

Exhibit HA-2012A-407 Explanation of Economic Impact Method 1

Exhibit HA-2012A-408 Calculation of Stimulation 2

Exhibit HA-2012A-409 Calculation of Incremental Japanese Visitors 1

Exhibit HA-2012A-501 The Star/Oneworld/Skyteam Oligopoly Dominates 

Current U.S. – Tokyo Frequencies (Current 

Schedules) 

2

Exhibit HA-2012A-502 The Star/Oneworld/Skyteam Oligopoly Dominates 

the U.S. – Tokyo Passenger Market (YE February 

2012) 

2

Exhibit HA-2012A-503 American’s ATI Partner, JAL, and United’s ATI 

Partner, ANA, Control 77% of All Departures at 

Haneda (Current Schedules)

1

Exhibit HA-2012A-504 American’s ATI Partner, JAL, and United’s ATI 

Partner, ANA, Control 83% of Haneda Capacity 

(Current Schedules)

1
Exhibit HA-2012A-505 The Star/Oneworld/Skyteam Oligopoly Controls 

92% of Current Hawaii – Tokyo Frequencies 

(Current Schedules)

2

Exhibit HA-2012A-506 ATI and Mergers Have Increased U.S. – Tokyo 

Market Concentration to an Alarming Level

2 – Missing 

Page 2 of 2

Exhibit HA-2012A-601 Hawaiian is Growing Its Capacity While All Other 

Applicant Carriers are Shrinking

1

Exhibit HA-2012A-602 Hawaiian Has the Best On-Time Performance of 

All Large U.S. Airlines

1

Exhibit HA-2012A-603 Hawaiian’s Mishandled Bags Rate is Lower Than 

All Other Applicant Carriers

1

Exhibit HA-2012A-604 Hawaiian’s Denied Boardings Rate is Lower Than 

All Other Applicant Carriers

1

Exhibit HA-2012A-605 Hawaiian’s Complaint Rate is Lower Than All 

Other Applicant Carriers

1

Exhibit HA-2012A-606 Hawaiian Has Consistently Achieved the Best OnTime Performance in the Industry1

Exhibit HA-2012A-607 Hawaiian Has Consistently Outperformed the 

Other Applicant Carriers in Terms of Mishandled 

Bags

1

Exhibit HA-2012A-608 Hawaiian Has Consistently Outperformed the 

Other Applicant Carriers in Terms of Customer 

Complaints

1

Exhibit HA-2012A-701 AA/JL Has a Huge Commitment to Narita 1

Exhibit HA-2012A-702 From January 2011 to May 2012 American Did 

Not Operate 796 or 77% of Its Awarded Haneda

Flights 

1

Exhibit HA-2012A-703 American Operated Less Than 1/3 of the Flights it 

Proposed 

1

Exhibit HA-2012A-704 Hawaiian Will Provide 19% More Annual Seats 

Than American

1
Exhibit HA-2012A-705 Hawaiian Carried 4.8 Times as Many Haneda 

Passengers as American

1

Exhibit HA-2012A-706 If American’s Haneda Service Follows a Pattern 

Similar to Delta at LAX, Its Haneda Load Factor 

Would be Below 60%

1

Exhibit HA-2012A-707 American Proposes an 11% Increase in LAX-TYO 

Seats

1

Exhibit HA-2012A-708 Almost 80% of American’s Proposed LAX-HND 

Capacity Could be Offset by Delta Fulfilling Its 

2010 LAX-HND Commitment

1

Exhibit HA-2012A-709 LAX is Not Large Enough to Support More 

Haneda Service

1

Exhibit HA-2012A-710 Using Standard DOT QSI Stimulation 

Methodology American’s LAX Proposal Would 

Generate Only 57,608 New Passengers

1

Exhibit HA-2012A-711 LAX is Not Large Enough to Support More 

Haneda Service (Includes Stimulation)

1

Exhibit HA-2012A-712 American and JAL Already Operate 14 Weekly 

Roundtrips Between LAX and Tokyo

1

Exhibit HA-2012A-801 Delta Has a Huge Commitment to Narita 1

Exhibit HA-2012A-802 Delta Has 47 More Weekly U.S. – Tokyo Flights 

Than the Second Largest Carrier

1

Exhibit HA-2012A-803 In 2011 Delta Did Not Operate 780 or 53% of Its 

Awarded Haneda Flights

1

Exhibit HA-2012A-804 Hawaiian Will Provide at Least 30% More Annual 

Seats Than Delta

1

Exhibit HA-2012A-805 Delta Failed at DTW With 106 Connecting Points 

and Will Fail Again at SEA With Only 62 

Connecting Points

1
Exhibit HA-2012A-806 In 2010 Delta Said DTW Would Have About 

Twice as Many Connecting Points Within 10% 

Circuity as SEA 

1

Exhibit HA-2012A-807 Delta Did Not Fulfill Its LAX Aircraft Promise 1

Exhibit HA-2012A-808 Delta Did Not Honor Its 2010 Proposed Number 

of Annual Seats

1

Exhibit HA-2012A-809 Hawaiian With Only One Haneda Slot 

Transported 43% More Haneda Passengers Than 

Delta With Two Haneda Slots

1

Exhibit HA-2012A-810 Despite Not Having Nonstop Service to Tokyo, 

Kona Has More Point of Origin Japan Passengers 

Than Seattle Which Already Enjoys Three Daily 

Nonstops

1

Exhibit HA-2012A-811 ANA Has Already Added Capacity to the SEA –

Tokyo Market and Is Switching to the 

Significantly Smaller 787 Because It Does Not See 

the Market as Large Enough For a Larger Aircraft

1

Exhibit HA-2012A-812 SEA – TYO Seats Would Increase by 71% With 

Proposed Delta and New ANA Service

1

Exhibit HA-2012A-813 Despite the Fact That SEA-TYO Has Lost 2% of 

Its Traffic, DL Proposes to Increase Capacity by 

71%

1

Exhibit HA-2012A-814 SEA is Not Large Enough to Support HND 

Service

1

Exhibit HA-2012A-815 Using Standard DOT QSI Stimulation 

Methodology Delta’s SEA Proposal Would 

Generate Only 40,454 New Passengers

1

Exhibit HA-2012A-816 Even With an Optimistic Estimate of Stimulation, 

SEA is Not Large Enough to Support HND 

Service

1

Exhibit HA-2012A-901 UA/NH Has a Huge Commitment to Narita 1

Exhibit HA-2012A-902 Hawaiian Will Provide at Least 10% More Annual 

Seats Than United

1
Exhibit HA-2012A-903 SFO-HND Operated With Over 67,000 Empty 

Seats

1

Exhibit HA-2012A-904 Only the Failed DTW Route Had a Lower HND 

Load Factor Than SFO

1

Exhibit HA-2012A-905 United’s 2010 Assessment of SEA and DTW 

Shows That SFO Would be a Failure on the Scale 

of the DTW Fiasco

1

Exhibit HA-2012A-906 United’s Application Suggests It is Considering 

Reducing SFO-NRT Service or Only Operating 

HND Seasonally

1

Exhibit HA-2012A-907 JAL Has Been Struggling Since Switching Its SFO 

Service to Haneda

1

Exhibit HA-2012A-908 The Star Alliance Already Has Both the Largest 

SFO – Tokyo Share and the Largest U.S. to Tokyo 

Share

1

Exhibit HA-2012A-909 The SFO Bay Area is Getting New Nonstop 

Tokyo Service – United’s ATI Partner ANA is 

Adding SFO Bay Area Service in Early 2013

1

Exhibit HA-2012A-910 With Proposed United And New ANA Service, 

Bay Area– TYO Seats Would Increase 33%

1

Exhibit HA-2012A-911 The Bay Area is Not Large Enough to Support 

More Haneda Service

1

Exhibit HA-2012A-912 Using Standard DOT QSI Stimulation 

Methodology United’s Bay Area Proposal Would 

Generate Only 49,640 New Passengers

1

Exhibit HA-2012A-913 Even With an Optimistic Estimate of Stimulation, 

the Bay Area is Not Large Enough to Support 

More Haneda Service

1

Exhibit HA-2012A-914 If United Cuts Its NRT-SFO Capacity, Its ATI 

Partner Will Still Be in the Market

1

Appendix A Referenced 2010 Exhibits 13
EXHIBITS OF HAWAIIAN AIRLINES
100 SERIES
100 Series Exhibits

• Haneda Success is Highly Correlated with Tokyo Originating Passengers (Exhibit 101)

• Kona Has the Highest Percentage of Point of Origin Tokyo Passengers (Exhibit 102)

• Carrier Size and Dominance Has Not Been a Good Predictor of Haneda Success (Exhibit 103)

• The Other Applicants Are Proposing Service Eerily Similar to Services That Have Failed at 

Other Mainland Gateways (Exhibit 104)

• Only Hawaiian Has Stood Up to Strong Japanese Competition (Exhibit 105)

• Only Hawaiian Can Prioritize Its Haneda Service (Exhibit 106)

• Hawaiian Operated All of Its Awarded Frequencies While U.S. Mainland Carriers 

Squandered 57% of Their Awarded U.S. – Haneda Frequencies (Exhibit 107)

• Hawaiian Will Operate the Largest Aircraft (Exhibit 108)

• Hawaiian Will Provide 10% - 31% More Haneda Capacity Than the Other Applicants

(Exhibit 109)

• The Other Applicant Carriers Are 11 to 16 Times as Large as Hawaiian (Exhibit 110)

Exhibit HA-2012A-100

Docket OST-2010-0018

Page 1 of 1
HANEDA SUCCESS IS HIGHLY CORRELATED WITH 

TOKYO ORIGINATING PASSENGERS

78%

74%

70%

62%

60%

50%

55%

60%

65%

70%

75%

80%

85%

90%

95%

100%

50% 60% 70% 80% 90% 100%

Load Factor

1/ Point of Origin refers to the place where a passenger begins his or her trip. 

Source: U.S. DOT, T-100 Data and MIDT data via Travelport.

DTW

SFO

LAX

JFK

HNL

% Point of Origin Tokyo

Correlation Between Point of Origin 

Tokyo/1 and Load Factor = 0.91

Exhibit HA-2012A-101

Docket OST-2010-0018

Page 1 of 1
KONA HAS THE HIGHEST PERCENTAGE 

OF POINT OF ORIGIN TOKYO PASSENGERS

97%

72%

66%

60%

73%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

KOA LAX SFO SEA Mainland

U.S.

Average

% Point of Origin Tokyo – YE June 2012

Source: MIDT via Travelport.

Exhibit HA-2012A-102

Docket OST-2010-0018

Page 1 of 1
CARRIER SIZE AND DOMINANCE HAS NOT BEEN

A GOOD PREDICTOR OF HANEDA SUCCESS

Operated NRT

Service

Member of 

Alliance with 

Access to Large 

Volume of Consistent

Legacy

Carrier

Mainland

U.S. Point

from Proposed 

Gateway

Major Investment 

at NRT

Connecting 

Passengers

HND

Service

Haneda Gateway

Passengers Carried

DL- DTW YES YES YES YES YES NO 35,812

DL- LAX YES YES YES YES YES NO 105,556

AA- JFK YES YES YES YES YES NO 42,526

HA - HNL NO NO NO NO NO YES 202,722

Exhibit HA-2012A-103

Docket OST-2010-0018

Page 1 of 1
THE OTHER APPLICANTS ARE PROPOSING SERVICE EERILY

SIMILAR TO SERVICES THAT HAVE FAILED 

AT OTHER MAINLAND GATEWAYS

Requires Large 

Volume of Periodic

Operated NRT

Service

Member of 

Alliance with 

Connecting 

Passengers

Point of 

Origin

Suspension 

of

Legacy

Carrier

Mainland

U.S. Point

from Proposed 

Gateway

Major Investment 

at NRT

to Make HND Flight 

Viable

Japan 

Over 90%

HND

Service

2010 Awards

DL- DTW YES YES YES YES YES NO YES

DL- LAX YES YES YES YES YES NO YES

AA- JFK YES YES YES YES YES NO YES

Proposals

AA-LAX YES YES YES YES YES NO

DL-SEA YES YES YES YES YES NO

UA-SFO YES YES YES YES YES NO

Exhibit HA-2012A-104

Docket OST-2010-0018

Page 1 of 1
ONLY HAWAIIAN STOOD UP TO STRONG JAPANESE COMPETITION

731 731 730

699 697

572

218

189

0

100

200

300

400

500

600

700

800

HA-HNL JL-SFO JL-HNL NH-LAX NH-HNL DL-LAX AA-JFK DLDTW

U.S.-HND Flights – 12 Months Ended February 2012

Source: U.S. DOT, T-100 Data.

U.S. Flag

Japan Flag

Exhibit HA-2012A-105

Docket OST-2010-0018

Page 1 of 1
183

126

28

0

0

20

40

60

80

100

120

140

160

180

200

Delta United American Hawaiian

687

444

382

0

0

100

200

300

400

500

600

700

Star oneworld Sky

Team

Hawaiian

Weekly Roundtrip Flights to/from NRT

Source: Innovata schedule for the week of August 13, 2012. 

By Carrier By Alliance

ONLY HAWAIIAN CAN PRIORITIZE ITS HANEDA SERVICE

Exhibit HA-2012A-106

Docket OST-2010-0018

Page 1 of 1
Hawaiian

Source: U. S. DOT T-100 data, CY 2011.

Exhibit HA-2012A-107

Docket OST-2010-0018

Page 1 of 1

Available 

Frequencies 

Used

43%

Available 

Frequencies 

Not Used

57%

Mainland Carriers

Available 

Frequencies 

Used

100%

HAWAIIAN OPERATED ALL OF ITS AWARDED FREQUENCIES

WHILE U.S. MAINLAND CARRIERS SQUANDERED 

57% OF THEIR AWARDED U.S. – HANEDA FREQUENCIES
HAWAIIAN WILL OPERATE THE LARGEST AIRCRAFT 

268

247

225

294

0

20

40

60

80

100

120

140

160

180

200

220

240

260

280

300

Proposed Aircraft Size

Hawaiian United American Delta

(A330) (777) (777) (767)

Exhibit HA-2012A-108

Docket OST-2010-0018

Page 1 of 1

Note: Assumes all carriers operate the aircraft types and the number of flights in their proposals. 

Only Hawaiian has operated the number of flights and aircraft it committed to in its original HND proposal.

Source: Applications.
195,640

180,310

164,250

214,620

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

200,000

220,000

Annual Seats Based on Proposals

Hawaiian United American Delta

(A330) (777) (777) (767)

+10% +19% +31%

HAWAIIAN WILL PROVIDE 10% - 31% 

MORE HANEDA CAPACITY THAN THE OTHER APPLICANTS

Exhibit HA-2012A-109

Docket OST-2010-0018

Page 1 of 1

Note: Assumes all carriers operate the aircraft types and the number of flights in their proposals. 

Only Hawaiian has operated the number of flights and aircraft it committed to in its original HND proposal.

Source: Applications.
4,834

3,386

315

5,158

0

1,000

2,000

3,000

4,000

5,000

6,000

System Available Seat Miles per Week (Millions)

Source Innovata Schedule Data, week of August 13, 2012.

United Delta American Hawaiian

THE OTHER APPLICANT CARRIERS ARE 11 TO

16 TIMES AS LARGE AS HAWAIIAN

Exhibit HA-2012A-110

Docket OST-2010-0018

Page 1 of 1

Times as

Large as HA: 16x 15x 11x
200 SERIES:

KONA IS THE BEST USE OF THE U.S.’s 4TH HANEDA FREQUENCY
200 Series Exhibits

KONA IS THE BEST USE OF THE U.S.’s 4TH HANEDA FREQUENCY

• Kona Is the Only New Tokyo Gateway Proposed in This Proceeding (Exhibit 201)

• Kona Is the Most Underserved Tokyo Market (Exhibit 202)

• Kona Will Outperform Current Single-Slot Mainland Gateways to Haneda (Exhibit 

203)

• Kona Will Generate Over 146,000 Onboard Passengers (Exhibit 204)

• Kona Has the Potential to Produce Similar Onboard Passenger Numbers to HA’s 

Successful HNL-HND Service (Exhibit 205)

• The Big Island Is the 2nd Most Visited Island in Hawaii for Japanese (Exhibit 206)

• 13% of Japanese Visitors to Hawaii Visited Kona and the Big Island (Exhibit 207)

Exhibit HA-2012A-200

Docket OST-2010-0018

Page 1 of 1
KONA IS THE ONLY NEW TOKYO GATEWAY

PROPOSED IN THIS PROCEEDING

SFO Bay 

Area

LAX

KOA

TYO

SEA

Source: Innovata Schedule Data, Week of August 13, 2012 and announced service.

Exhibit HA-2012A-201

Docket OST-2010-0018

Page 1 of 1

67

40

21

0

0

10

20

30

40

50

60

70

80

LAX SFO Bay Area SEA KOA

Current and Announced Roundtrips per Week
KONA IS THE MOST UNDERSERVED TOKYO MARKET

NOTE: Includes an adjustment to MIDT to reflect direct bookings. For purposes of comparability HA has used DL’s 35% MIDT adjustment 

factor. Numbers do not include stimulation. SFO includes bay area airports (SJC and OAK).

Source: Innovata Schedule Data, Week of August 13, 2012 and proposed; MIDT, YE June 2012 via Travelport.

107

86

71

39

0

20

40

60

80

100

120

KOA LAX SFO SEA

Roundtrip

Passengers

per week : 748 6,392 3,345 1,091

Roundtrip and 

proposed 

flights per week : 7 74 47 28 

107 86 71 39 

YE June 2012 Tokyo MIDT Passengers per Flight

Exhibit HA-2012A-202

Docket OST-2010-0018

Page 1 of 1
146,351

111,152

39,284

33,616

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

KOA Proposed SFO - Actual JFK - Actual DTW - Actual

HND Onboard Passengers –

12 Months Ended February 2012 and Proposed for KOA

1/ Does not include expected growth to 2012. Hawaiian’s HND service is up 18% in the first 8 months of 2012.

Source: U.S. DOT, T-100 Data and Exhibit HA-2012A-204.

Exhibit HA-2012A-203

Docket OST-2010-0018

Page 1 of 1

KONA WILL OUTPERFORM CURRENT SINGLE-SLOT 

MAINLAND GATEWAYS TO HANEDA

/1
KONA WILL GENERATE OVER 146,000 ONBOARD PASSENGERS

YE Feb. 2012 HNL-TYO Onboard Passengers

Ratio of KOA-TYO to HNL-TYO When KOA Had 

Nonstop Service /1

HA HND-KOA Onboard Passengers Before Growth

1/ KOA share calculated using CY 2009 data (the last full calendar year with daily nonstop service) from NRT-KOA when JAL operated nonstop 

service.

2/ 146,351 is equivalent to 44% share of Japan- Big Island Visitors.

Source: U.S. DOT, T-100 Data and MIDT.

1,829,384

8%

146,351

Exhibit HA-2012A-204

Docket OST-2010-0018

Page 1 of 1

/2
Source: U.S. DOT, T-100 Data, YE February 2012 and Exhibit HA-2012A-204.

146,351

160,732

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

KOA HNL

Tokyo to Hawaii Annual Onboard Passengers

91%

Exhibit HA-2012A-205

Docket OST-2010-0018

Page 1 of 1

The Hawaii Department of Business, Economic Development and

Tourism reported a 17% increase in Japanese air visitors for the first

six months of 2012. KOA and HNL passengers levels can be expected

to be significantly higher in 2012, subject to capacity limitations.

Hawaiian’s HND traffic is up 18% in the first 8 months of 2012.

KONA HAS THE POTENTIAL TO PRODUCE SIMILAR ONBOARD 

PASSENGER NUMBERS TO HA’S SUCCESSFUL HNL-HND SERVICE
THE BIG ISLAND IS THE 2nd MOST 

VISITED ISLAND IN HAWAII FOR JAPANESE

165,250

63,683

23,571

1,193,378

0

50,000

100,000

150,000

200,000

250,000

300,000

O'ahu Big Island Maui County Kaua'i

Japan Visitors to Hawaii

1/ The Big Island refers to Hawaii Island where Kona is located.

Source: State of Hawaii Department of Business, Economic Development, and Tourism, 2011 Annual Visitor Research Report.

Exhibit HA-2012A-206

Docket OST-2010-0018

Page 1 of 1

• 165,250 visitors is equivalent to 330,500 O&D passengers or 453

passengers per day each way.

• The Hawaii Department of Business, Economic Development

and Tourism reported a 17% increase in Japanese air visitors

for the first six months of 2012.

/1
Big Island

13.3%

Other Hawaii

86.7%

13% OF JAPANESE VISITORS TO HAWAII 

VISITED KONA AND THE BIG ISLAND

Distribution of Japanese Visitors to Hawaii

Total 2011 Japanese Visitors: 1,241,805

Total 2011 Hawaii-Japan Onboard Passengers: 2,465,668

Source: State of Hawaii Department of Business, Economic Development, and Tourism, 2011 Annual Visitor Research Report.

Exhibit HA-2012A-207

Docket OST-2010-0018

Page 1 of 1
300 SERIES:

HAWAII IS THE MOST

IMPORTANT U.S. – JAPAN MARKET
300 Series Exhibits

HAWAII IS THE MOST IMPORTANT U.S. – JAPAN MARKET

• Hawaii Is the Largest U.S. - Haneda Gateway and Generates the Most Haneda O&D 

Passengers (Exhibits 301 and 303)

• Hawaii Has More Haneda Gateway and More Haneda O&D Passengers Than All the 

Other U.S. - Haneda Gateways Combined (Exhibits 302 and 304)

• The Hawaii – Tokyo Market Is Growing While the Mainland-Tokyo Market is 

Shrinking (Exhibit 305)

• The Hawaii-Tokyo O&D Market Is Much Larger than the Size of the Second Largest 

U.S. State (Exhibit 306)

• The Hawaii-Tokyo O&D Market Is 63% Larger Than California and Over 1000% 

Larger Than Washington State (Exhibit 307)

• Hawaii Has 47% More Tokyo Passengers Than the Other Two Proposed Gateway States 

Combined (Exhibit 308)

• The Hawaii-Haneda O&D Market Size Is Nearly Two Times the Size of the Second 

Largest U.S. State (Exhibit 309)

• Despite the Tsunami Impact on Travel and Significant Capacity Additions, the HawaiiTokyo Market Maintained Strong Load Factors (Exhibit 310)

• The Three Highest Haneda Carrier Load Factor Segments Were All From Hawaii

(Exhibit 311)

• Hawaii Had the Highest Tokyo Point of Origin Percentage of All Haneda Gateways

(Exhibit 312)

• Hawaii Is the Most Underserved Tokyo Market (Exhibit 313)

• Hawaii Is the Most Popular U.S. Destination for Japanese Visitors and Has Been the 

Preferred Destination for Japanese Visitors Since 2001 (Exhibits 314 and 315)

• More Japanese Tourists Visit Hawaii Than Visit the Entire U.S. Mainland (Exhibit 316)

• Hawaii Has Over Two Times the Japanese Visitors to California and Nearly Twenty 

Times the Japanese Visitors to Washington (Exhibit 317)

• Hawaii Has Twice the Number of Japanese Visitors as the Other Proposed Gateway 

States Combined (Exhibit 318)

• All Three Mainland Gateway Carriers Experienced Significant Diversion From Their 

NRT Flights (Exhibit 319)

• HNL-HND Service Generated 227,626 New Tokyo O&D Passengers (Exhibit 320)

• HNL-HND Service Has Generated More New Tokyo O&D Passengers Than All The 

Other U.S. – HND Gateways Combined (Exhibit 321)

Exhibit HA-2012A-300

Docket OST-2010-0018

Page 1 of 1
HAWAII IS THE LARGEST U.S. - HANEDA GATEWAY

443,860

215,518

111,152

39,284 33,616

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

450,000

500,000

HNL LAX SFO JFK DTW

HND Onboard Passengers – 12 Months Ended February 2012

Source: U.S. DOT, T-100 Data.

Exhibit HA-2012A-301

Docket OST-2010-0018

Page 1 of 1
HAWAII HAS MORE HANEDA GATEWAY PASSENGERS 

THAN ALL THE OTHER U.S. - HANEDA GATEWAYS COMBINED

443,860

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

450,000

500,000

HNL ALL Other Gateways

DTW

JFK

LAX

399,570

SFO

HND Onboard Passengers – 12 Months Ended February 2012

Source: U.S. DOT, T-100 Data.

Exhibit HA-2012A-302

Docket OST-2010-0018

Page 1 of 1

Current Designations: 3 5
HAWAII GENERATES THE MOST HANEDA O&D PASSENGERS

353,140

118,845

78,567

26,825

4,233

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

HNL LAX SFO JFK DTW

MIDT Local Passengers – 12 Months Ended June 2012

Exhibit HA-2012A-303

Docket OST-2010-0018

Page 1 of 1

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

Source: MIDT, via Travelport.
HAWAII GENERATES MORE HANEDA O&D PASSENGERS 

THAN ALL THE OTHER U.S. - HANEDA GATEWAYS COMBINED

353,140

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

HNL ALL Other Gateways

DTW

JFK

LAX

228,470

SFO

MIDT Local Passengers – 12 Months Ended June 2012

Exhibit HA-2012A-304

Docket OST-2010-0018

Page 1 of 1

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

Source: MIDT, via Travelport.
THE HAWAII – TOKYO MARKET IS GROWING WHILE

THE MAINLAND-TOKYO MARKET IS SHRINKING

8%

-4%

-10%

-8%

-6%

-4%

-2%

0%

2%

4%

6%

8%

10%

Hawaii - Tokyo Mainland - Tokyo

% Onboard Passenger Change 2009-2011

Source: U.S. DOT, T-100 Data.

Exhibit HA-2012A-305

Docket OST-2010-0018

Page 1 of 1
THE HAWAII-TOKYO O&D MARKET IS 

MUCH LARGER THAN THE SECOND LARGEST U.S. STATE

793,773

326,558

94,183 88,841 87,748

1,295,832

86,634 86,201

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

Hawaii

California

New York

Illinois

Florida

Nevada

Washington

Texas

YE June 2012 Tokyo MIDT Passengers

Exhibit HA-2012A-306

Docket OST-2010-0018

Page 1 of 1

Hawaii Has Almost Twice the Tokyo 

Passengers as California with the 

Same Number of Designations

Current HND

Designations: 3 3 1

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

Source: MIDT, via Travelport.
THE HAWAII-TOKYO O&D MARKET IS 63% LARGER THAN CALIFORNIA 

AND OVER 1000% LARGER THAN WASHINGTON STATE

793,773

86,634

1,295,832

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

YE June 2012 Tokyo MIDT Passengers

Hawaii California Washington

+63%

+1396%

Exhibit HA-2012A-307

Docket OST-2010-0018

Page 1 of 1

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

Source: MIDT, via Travelport.
HAWAII HAS 47% MORE TOKYO PASSENGERS THAN 

THE OTHER TWO PROPOSED GATEWAY STATES COMBINED

1,295,832

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

Hawaii Other Proposed Gateway

States

California

880,407

Washington

YE June 2012 Tokyo MIDT Passengers 

+47%

Exhibit HA-2012A-308

Docket OST-2010-0018

Page 1 of 1

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

Source: MIDT, via Travelport.
THE HAWAII-HANEDA O&D MARKET SIZE IS NEARLY 

TWO TIMES THE SIZE OF THE SECOND LARGEST U.S. STATE

204,154

33,318 22,028 10,803 4,722

381,085

3,670 3,392 3,181 2,093

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

450,000

Hawaii

California

New York

Nevada

Florida

Michigan

Massachusetts

Texas

Arizona

Georgia

YE June 2012 HND MIDT Passengers

Hawaii Has Almost Twice the 

HND Passengers as 

California with the Same 

Number of Designations

Exhibit HA-2012A-309

Docket OST-2010-0018

Page 1 of 1

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

Source: MIDT, via Travelport.

Current HND

Designations: 3 3 1
DESPITE THE TSUNAMI IMPACT ON TRAVEL AND SIGNIFICANT 

CAPACITY ADDITIONS, THE HAWAII-TOKYO MARKET

MAINTAINED STRONG LOAD FACTORS

84% 81%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

2010 2011

HNL- Tokyo Load Factor 

Source: U.S. DOT, T-100 Data.

Exhibit HA-2012A-310

Docket OST-2010-0018

Page 1 of 1
THE THREE HIGHEST HANEDA CARRIER LOAD FACTOR 

SEGMENTS WERE ALL FROM HAWAII

78.8% 78.1%

76.8%

73.6% 72.7%

67.9%

60.3%

62.3%

50%

55%

60%

65%

70%

75%

80%

85%

HNL-JL HNL-HA HNL-NH JFK-AA LAX-NH LAX-DL SFO-JL DTW-DL

Load Factor – 12 Months Ended February 2012

Source: U.S. DOT, T-100 Data.

Exhibit HA-2012A-311

Docket OST-2010-0018

Page 1 of 1

0%
HAWAII HAD THE HIGHEST TOKYO POINT OF ORIGIN

PERCENTAGE OF ALL HANEDA GATEWAYS

96%

73% 72%

66%

55%

0%

20%

40%

60%

80%

100%

120%

HNL JFK LAX SFO DTW

% Point of Origin Tokyo Passengers – YE June 2012

Source: MIDT via Travelport.

Exhibit HA-2012A-312

Docket OST-2010-0018

Page 1 of 1
HAWAII IS THE MOST UNDERSERVED TOKYO MARKET

185

90

40

0

20

40

60

80

100

120

140

160

180

200

Hawaii California Washington

Tokyo YE June 2012 MIDT per Flight

Exhibit HA-2012A-313

Docket OST-2010-0018

Page 1 of 1

Roundtrip

Passengers

per week : 16,821 10,303 1,125

Flights per

Week Including 

Proposals: 91 114 28

185 90 40

NOTE: Includes an adjustment to MIDT to reflect direct bookings. For purposes of comparability HA has used DL’s 35% MIDT adjustment 

factor. Numbers do not include stimulation. 

Source: Innovata Schedule Data, Week of August 13, 2012 and proposed; MIDT, YE June 2012 via Travelport.
HAWAII IS THE MOST POPULAR

U.S. DESTINATION FOR JAPANESE VISITORS

• Hawaii has been the most popular destination for Japanese 

visitors since 2001

• In 2011, more Japanese traveled overseas to Hawaii (39.1%) 

than to all mainland destinations combined (38.8%)

• Hawaii was the top destination for both first-time and repeat 

visitors

Source: U.S. Department of Commerce Office of Travel and Tourism Industries, 2011 Market Profile: Japan; 

Exhibit HA-2012A-314

Docket OST-2010-0018

Page 1 of 1
HAWAII HAS BEEN THE PREFERRED DESTINATION FOR 

JAPANESE VISITORS SINCE 2001

39%

41%

43%

41% 41%

39% 38%

41%

39%

0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

50%

2001 2002 2003 2004 2005 2006 2007 2009 2011

Share of Japanese Travelers to the U.S. Visiting Hawaii

(Multiple Answers Allowed)

Source: U.S. Department of Commerce Office of Travel and Tourism Industries, 2011 Market Profile: Japan

Exhibit HA-2012A-315

Docket OST-2010-0018

Page 1 of 1
MORE JAPANESE TOURISTS VISIT HAWAII 

THAN VISIT THE ENTIRE U.S. MAINLAND

Source: U.S. Department of Commerce Office of Travel and Tourism Industries, 2011 Market Profile: Japan.

1,271,000 1,260,000

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

Hawaii U.S. Mainland

2011 Japanese Visitors to U.S. Destinations

Exhibit HA-2012A-316

Docket OST-2010-0018

Page 1 of 1
HAWAII HAS OVER TWO TIMES THE JAPANESE VISITORS TO CALIFORNIA 

AND NEARLY TWENTY TIMES THE JAPANESE VISITORS TO WASHINGTON

1,271

549

65

0

200

400

600

800

1,000

1,200

1,400

Hawaii California Washington

2011 Visitors to U.S. Destinations (Millions)

Hawaii Relative Size: 2.32x 19.55x

Note: Includes multiple destinations.

Source: U.S. Department of Commerce Office of Travel and Tourism Industries, 2011 Market Profile: Japan.

Exhibit HA-2012A-317

Docket OST-2010-0018

Page 1 of 1

Hawaii Has Over Twice the 

Japanese Visitors as 

California with the Same 

Number of Designations
HAWAII HAS TWICE THE NUMBER OF JAPANESE VISITORS 

AS THE OTHER PROPOSED GATEWAY STATES COMBINED

1,271

0

200

400

600

800

1,000

1,200

1,400

Hawaii Other Proposed Gateway

States

California

614

Washington

2.1 x

2011 Visitors to U.S. Destinations (Millions)

Note: Includes multiple destinations.

Source: U.S. Department of Commerce Office of Travel and Tourism Industries, 2011 Market Profile: Japan.

Exhibit HA-2012A-318

Docket OST-2010-0018

Page 1 of 1
-21,718 -21,418

-38,234

-45,000

-40,000

-35,000

-30,000

-25,000

-20,000

-15,000

-10,000

-5,000

0

DL-DTW AA-JFK DL-LAX

Change in NRT Onboard Passengers –

12 Months Ended February 2012 Compared to 12 Months Before HND Service Began

Source: U.S. DOT, T-100 Data.

Exhibit HA-2012A-319

Docket OST-2010-0018

Page 1 of 1

ALL THREE MAINLAND GATEWAY CARRIERS 

EXPERIENCED SIGNIFICANT DIVERSION FROM THEIR NRT FLIGHTS
HNL-HND SERVICE GENERATED 227,626 NEW TOKYO O&D PASSENGERS

227,626

55,617

34,304

9,673 6,494

0

50,000

100,000

150,000

200,000

250,000

HNL LAX JFK SFO DTW

Change in Tokyo* Adjusted/1 MIDT Passengers CY 2009 /2-YE June 2012

1/ Includes an adjustment to MIDT to reflect direct bookings. For purposes of comparability HA has used DL’s 35% MIDT adjustment factor. 

2/ CY 2009 was the base year from the first HND case.

* Tokyo includes NRT and HND.

Source: MIDT via Travelport. 

Exhibit HA-2012A-320

Docket OST-2010-0018

Page 1 of 1
227,626

0

50,000

100,000

150,000

200,000

250,000

HNL ALL Other Gateways

DTW

JFK

LAX

106,087

SFO

Exhibit HA-2012A-321

Docket OST-2010-0018

Page 1 of 1

Change in Tokyo* Adjusted/1 MIDT Passengers CY 2009 /2-YE June 2012

HNL-HND SERVICE HAS GENERATED MORE NEW TOKYO O&D

PASSENGERS THAN ALL THE OTHER U.S. - HND GATEWAYS COMBINED

1/ Includes an adjustment to MIDT to reflect direct bookings. For purposes of comparability HA has used DL’s 35% MIDT adjustment factor. 

2/ CY 2009 was the base year from the first HND case.

* Tokyo includes NRT and HND.

Source: MIDT via Travelport. 
400 SERIES:

ECONOMIC IMPACT
400 Series Exhibits

ECONOMIC IMPACT

• Hawaiian’s Proposed Kona Flight Will Bring in 59% More Incremental U.S. Visitors 

Than the Second Highest Proposed Gateway (Exhibit 401)

• Hawaiian’s Proposed Kona Flight Will Create Over 1,400 U.S. Jobs, Over Two and a 

Half Times the Second Highest Gateway (Exhibit 402)

• Hawaiian’s Proposed Kona Flight Will Bring in $73.8 Million in New U.S. Exports 

Annually, Over Two Times the Second Highest Gateway (Exhibit 403)

• Hawaiian’s Proposed Kona Flight Will Increase U.S. GDP by $135 Million Annually, 

Over 115% More Than the Second Highest Gateway (Exhibit 404)

• Hawaiian’s Proposed Kona Flight Will Increase Aggregate U.S. Household Earnings by 

$39 Million Annually, More Than Double the Second Highest Gateway (Exhibit 405)

• Japanese Visitors to Hawaii Spend 64% More Than the U.S. Average and 35% More 

Than Japanese Visitors to California (Exhibit 406)

• Explanation of Economic Impact Method (Exhibit 407)

• Calculation of Stimulation (Exhibit 408)

• Calculation of Incremental Japanese Visitors (Exhibit 409)

Exhibit HA-2012A-400

Docket OST-2010-0018

Page 1 of 1
HAWAIIAN’S PROPOSED KONA FLIGHT WILL BRING IN 

59% MORE INCREMENTAL U.S. VISITORS THAN THE 

SECOND HIGHEST PROPOSED GATEWAY

33,240

20,903

17,250

13,109

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

KOA LAX SFO SEA

Source: Exhibit HA-2012A-409.

Forecast Incremental Japanese Visitors from Proposed Service

Exhibit HA-2012A-401

Docket OST-2010-0018

Page 1 of 1
HAWAIIAN’S PROPOSED KONA FLIGHT WILL CREATE

OVER 1,400 U.S. JOBS, OVER TWO AND A HALF TIMES

THE SECOND HIGHEST GATEWAY

0

200

400

600

800

1,000

1,200

1,400

1,600

 KOA LAX SFO SEA 

Direct Jobs Induced Jobs 1,429

552

432

341

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

Exhibit HA-2012A-402

Docket OST-2010-0018

Page 1 of 1

Note: Induced estimates calculated using standard multipliers from the U.S. Bureau of Economic Analysis.

Source: U.S. Bureau of Economic Analysis RIMS II Multipliers; Exhibits HA-2012A-407-409.
HAWAIIAN’S PROPOSED KONA FLIGHT WILL BRING IN

$73.8 MILLION IN NEW U.S. EXPORTS ANNUALLY, 

OVER TWO TIMES THE SECOND HIGHEST GATEWAY

$73.8

$30.9

$25.7

$17.8

$0.0

$10.0

$20.0

$30.0

$40.0

$50.0

$60.0

$70.0

$80.0

KOA LAX SFO SEA

Annual Spending (Exports) of Incremental Japanese 

Visitors to the U.S. (Millions)

Note: Expenditures calculated using average expenditures per visitor x estimated incremental Japanese visitors.

Exhibit HA-2012A-403

Docket OST-2010-0018

Page 1 of 1

Source: Exhibits HA-2012A-407-409.
HAWAIIAN’S PROPOSED KONA FLIGHT WILL INCREASE

U.S. GDP BY $135 MILLION ANNUALLY, 

OVER 115% MORE THAN THE SECOND HIGHEST GATEWAY

$0.0

$20.0

$40.0

$60.0

$80.0

$100.0

$120.0

$140.0

$160.0

KOA LAX SFO SEA

Direct Spending Induced Impacts $135.0

$62.7

$50.1

$4.8

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

Exhibit HA-2012A-404

Docket OST-2010-0018

Page 1 of 1

Note: Induced estimates calculated using standard multipliers from the U.S. Bureau of Economic Analysis.

Source: U.S. Bureau of Economic Analysis RIMS II Multipliers; Exhibits HA-2012A-407-409.
HAWAIIAN’S PROPOSED KONA FLIGHT WILL INCREASE AGGREGATE U.S. 

HOUSEHOLD EARNINGS BY $39 MILLION ANNUALLY, 

MORE THAN DOUBLE THE SECOND HIGHEST GATEWAY

Total Earnings Impact of Incremental Japanese Visitors to the U.S.

Note: Induced estimates calculated using standard multipliers from the U.S. Bureau of Economic Analysis.

Source: U.S. Bureau of Economic Analysis RIMS II Multipliers; Exhibits HA-2012A-407-409.

$0.0

$5.0

$10.0

$15.0

$20.0

$25.0

$30.0

$35.0

$40.0

$45.0

KOA LAX SFO SEA

Direct Spending Induced Impacts

$39.0

$17.1

$13.5

$9.8

Exhibit HA-2012A-405

Docket OST-2010-0018

Page 1 of 1
JAPANESE VISITORS TO HAWAII SPEND 64% MORE THAN THE

U.S. AVERAGE AND 35% MORE THAN JAPANESE VISITORS TO CALIFORNIA

$1,643

$1,355

$2,219

$0

$200

$400

$600

$800

$1,000

$1,200

$1,400

$1,600

$1,800

$2,000

$2,200

$2,400

Hawaii California U.S. Average

Note: Includes spending by Japanese Visitors at destination. 

Source: U.S. Department of Commerce Office of Travel and Tourism Industries, 2011 Market Profile: Japan; 

Overseas And Mexican Visitors To California (2010), Visit California, October 2011 (updated to 2011 using GDP price deflator;

2011 Annual Visitor Research Report, State of Hawaii, Department of Business, Economic Development & Tourism;

Japanese Spending in U.S. per Visitor

Exhibit HA-2012A-406

Docket OST-2010-0018

Page 1 of 1
EXPLANATION OF ECONOMIC IMPACT METHOD

• Direct Japanese Visitor Expenditures were broken down into 

expense type from Three Sources: 

• KOA: State of Hawaii, Department of Business, 

Economic Development & Tourism, 2011 Annual Visitor 

Research Report;

• LAX/SFO: Visit California, Overseas And Mexican 

Visitors To California (2010), October 2011 (updated to 

2011 using GDP price deflator); 

• SEA/Connecting Passengers: U.S. Department of 

Commerce Office of Travel and Tourism Industries, 2011 

Market Profile: Japan.

• Multiplied Japanese Visitor Expenditures broken down by 

expense type by the estimated incremental Japanese Visitors

for each market (See Exhibits HA-2012A-408-409). 

• To calculate induced impacts that estimate the multiplier effects 

of new spending on the U.S. economy, we obtained official 

metropolitan area output, earnings and employment multipliers 

broken down by industry from the U.S. Bureau of Economic 

Analysis’ RIMS II database. For local visitors, we used 

multipliers specific to Hawaii or the metropolitan area. For 

connecting visitors, we used multipliers based on the Seattle 

MSA.

Exhibit HA-2012A-407

Docket OST-2010-0018

Page 1 of 1
CALCULATION OF STIMULATION

Exhibit HA-2012A-408

Docket OST-2010-0018

Page 1 of 2

KONA

1 YE Feb. 2012 HNL-TYO Onboard Passengers 1,829,384

2 KOA Share of NRT-KOA When Both HNL and KOA Had Nonstop Service 8%

3 Estimated KOA Passengers With Service 146,351

4 Current Unadjusted MIDT KOA-TYO 57,641

Adjustment Factor to Account for Direct 

Bookings /1 0.35

5 Adjusted KOA-TYO Passengers 77,815

6 Stimulated passengers 68,536 ( Row 3 - Row 5)

1/ For purposes of comparability HA has used DL’s 35% MIDT adjustment factor. 
CALCULATION OF STIMULATION

(A) Year Ended Feb. 2012 scheduled passenger service only from U.S. DOT, T-100 Data.

(B) (A) plus 1 new daily flight. For SFO Bay Area ANA-SJC service is 5 roundtrips per week.

(C) (B)/(A) -1

(D) Uses standard DOT QSI formula: Stimulation = ((Future Flights/Current Flights)/(0.3741 + 0.5561(Future Flights/Current Flights)))/1.075. 

(E) Year Ended Feb. 2012 scheduled passenger service only from U.S. DOT, T-100 Data.

(F) (E) x (D)

(A) (B) (C) (D) (E) (F)

Current Proposed Current Stimulated

Annual Annual QSI Onboard Onboard

Between TYO and: Flights Flights % Change Stimuation Passengers Passengers

Los Angeles (LAX) 6,320 7,005 11.6% 4.4% 1,309,284 57,608

SFO Bay Area - With ANA Service /1 3,181 3,701 16.3% 6.0% 659,580 39,575

SFO Bay Area - With ANA and UA Service 3,701 4,431 19.7% 7.1% 699,155 49,640

Seattle (SEA) - With ANA Service /2 1,411 2,141 51.7% 15.9% 306,178 48,682

Seattle (SEA) - With ANA and DL Service 2,141 2,871 34.1% 11.4% 354,860 40,454

1/ ANA announced SJC-NRT service (5 RTs per week) is factored in before adding in UA proposed service.

2/ New ANA SEA service is factored in before adding in DL proposed service.

Exhibit HA-2012A-408

Docket OST-2010-0018

Page 2 of 2

MAINLAND GATEWAYS
CALCULATION OF INCREMENTAL JAPANESE VISITORS

1/ For connecting passengers, used the U.S. mainland average Point-of-Orgin Japan %.

(A) From Exhibit HA-2012A-408.

(B) From YE June 2012 MIDT via TravelPort. For UA, AA, and DL uses NRT service excluding beyond NRT to calculate.

(C) From YE June 2012 MIDT via TravelPort. For UA, AA, and DL uses NRT service excluding beyond NRT to calculate.

(D) From YE June 2012 MIDT via TravelPort.

(E) From YE June 2012 MIDT via TravelPort.

(F) (A) x (B) x (D) / 2.

(G) (A) x (C) x (E) / 2.

(H) (F) + (G)

(A) (B) (C) (D) (E) (F) (G) (H)

Local Connecting Total 

Stimulated % Local % Connecting Point-of-Origin Japan % Roundtrips Roundtrips Japanese

Passengers Passengers Passengers Local Connecting/1 (Visitors) (Visitors) Visitors

Kona 68,536 100% 0% 97% 0.0% 33,240 0 33,240

Los Angeles 57,608 43% 57% 72% 73% 8,918 11,985 20,903

SFO Bay Area 49,640 50% 50% 66% 73% 8,191 9,059 17,250

Seattle 40,454 63% 37% 60% 73% 7,646 5,463 13,109

Exhibit HA-2012A-409

Docket OST-2010-0018

Page 1 of 1
500 SERIES:

ALLIANCE CARRIERS DOMINATE THE TOKYO MARKET
500 Series Exhibits

ALLIANCE CARRIERS DOMINATE THE TOKYO MARKET

• The Star/Oneworld/Skyteam Oligopoly Dominates Current U.S. – Tokyo Frequencies 

(Current Schedules) (Exhibit 501)

• The Star/Oneworld/Skyteam Oligopoly Dominates the U.S. – Tokyo Passenger Market 

(YE February 2012) (Exhibit 502)

• American’s ATI Partner, JAL, and United’s ATI Partner, ANA, Control 77% of All 

Departures at Haneda (Current Schedules) (Exhibit 503)

• American’s ATI Partner, JAL, and United’s ATI Partner, ANA, Control 83% of Haneda

Capacity (Current Schedules) (Exhibit 504)

• The Star/Oneworld/Skyteam Oligopoly Controls 92% of Current Hawaii – Tokyo 

Frequencies (Current Schedules) (Exhibit 505)

• ATI and Mergers Have Increased U.S. – Tokyo Market Concentration to an Alarming 

Level (Exhibit 506)

Exhibit HA-2012A-500

Docket OST-2010-0018

Page 1 of 1
THE STAR/ONEWORLD/SKYTEAM OLIGOPOLY DOMINATES

CURRENT U.S. – TOKYO FREQUENCIES

(CURRENT SCHEDULES)

105

152

168

0

20

40

60

80

100

120

140

160

180

Star SkyTeam oneworld Nonaligned

Weekly Roundtrip Flights Between the U.S. and Tokyo

Source: Innovata schedule for the week of August 13, 2012.

Exhibit HA-2012A-501

Docket OST-2010-0018

Page 1 of 2

(UA) (DL) (AA) (HA)

11

Hawaiian (7)

Others (4)
THE STAR/ONEWORLD/SKYTEAM OLIGOPOLY CONTROLS 

97% OF CURRENT U.S. – TOKYO FREQUENCIES

(CURRENT SCHEDULES)

Star

38%

SkyTeam

35%

oneworld

24%

Hawaiian

2%

Other 

Nonaligned

1%

Distribution of Current U.S. – Tokyo Flights by Alliance

Source: Innovata schedule for the week of August 13, 2012.

Exhibit HA-2012A-501

Docket OST-2010-0018

Page 2 of 2

Nonaligned = 3%
3,132

2,906

1,945

161

0

500

1,000

1,500

2,000

2,500

3,000

3,500

Star SkyTeam oneworld Hawaiian

THE STAR/ONEWORLD/SKYTEAM OLIGOPOLY DOMINATES THE

U.S. – TOKYO PASSENGER MARKET

(YE FEBRUARY 2012)

Annual Onboard Passengers (000’s)

Source: U. S. DOT T-100 data, YE February 2012. Subsidiary carriers are included with the parent carrier.

Exhibit HA-2012A-502

Docket OST-2010-0018

Page 1 of 2

(UA) (DL) (AA) (HA)
THE STAR/ONEWORLD/SKYTEAM OLIGOPOLY CONTROLS

98% OF ALL U.S. – TOKYO GATEWAY-TO-GATEWAY PASSENGERS

(YE FEBRUARY 2012)

Star

38%

SkyTeam

36%

oneworld

24%

Hawaiian

2%

Distribution of Annual U.S. – Tokyo Onboard Passengers by Alliance

Source: U. S. DOT T-100 data, YE February 2012. Subsidiary carriers are included with the parent carrier.

Exhibit HA-2012A-502

Docket OST-2010-0018

Page 2 of 2
ANA

43%

JAL

34%

Others

23%

AMERICAN’S ATI PARTNER, JAL, AND UNITED’S ATI PARTNER, ANA, 

CONTROL 77% OF ALL DEPARTURES AT HANEDA

(CURRENT SCHEDULES)

Distribution of Current HND Flights Operated

Source: Innovata schedule for the week of August 13, 2012.

Exhibit HA-2012A-503

Docket OST-2010-0018

Page 1 of 1
ANA

49%

JAL

34%

Others

17%

AMERICAN’S ATI PARTNER, JAL, AND UNITED’S ATI PARTNER, ANA, 

CONTROL 83% OF HANEDA CAPACITY

(CURRENT SCHEDULES)

Distribution of Current HND Seats

Source: Innovata schedule for the week of August 13, 2012.

Exhibit HA-2012A-504

Docket OST-2010-0018

Page 1 of 1
29 28

21

7

0

5

10

15

20

25

30

SkyTeam oneworld Star Hawaiian

THE STAR/ONEWORLD/SKYTEAM OLIGOPOLY CONTROLS 

92% OF CURRENT HAWAII – TOKYO FREQUENCIES

(CURRENT SCHEDULES)

Weekly Roundtrip Flights Between Hawaii and Tokyo

Source: Innovata schedule for the week of August 13, 2012.

Exhibit HA-2012A-505

Docket OST-2010-0018

Page 1 of 2

(DL) (AA) (UA) (HA)
SkyTeam

34%

oneworld

33%

Star

25%

Hawaiian

8%

THE STAR/ONEWORLD/SKYTEAM OLIGOPOLY CONTROLS 

92% OF CURRENT HAWAII – TOKYO FREQUENCIES

(CURRENT SCHEDULES)

Distribution of Current Hawaii – Tokyo Flights by Alliance

Source: Innovata schedule for the week of August 13, 2012.

Exhibit HA-2012A-505

Docket OST-2010-0018

Page 2 of 2
1,516

1,683

2,858

0

500

1,000

1,500

2,000

2,500

3,000

2009 2010 YE Feb 2012

ATI AND MERGERS HAVE INCREASED U.S. – TOKYO 

MARKET CONCENTRATION TO AN ALARMING LEVEL

U.S. – Tokyo HHI Based on Onboard Passengers

Source: U. S. DOT T-100 data; U.S. Department of Justice, Horizontal Merger Guidelines, April 2010.

Exhibit HA-2012A-506

Docket OST-2010-0018

Page 1 of 1

Note: HHI, or Herfindahl-Hirschman Index is a measure of market concentration (based on market shares) used 

commonly by the Department of Justice. Markets with HHIs between 1500 and 2500 are considered 

“Moderately Concentrated”. Markets with HHIs above 2500 are considered “Highly Concentrated”. The U.S.-

Tokyo market has been transformed from Moderately Concentrated to Highly Concentrated.
600 SERIES:

HAWAIIAN’S RECORD OF OUTSTANDING PERFORMANCE
600 Series Exhibits

HAWAIIAN’S RECORD OF OUTSTANDING PERFORMANCE

• Hawaiian Is Growing Its Capacity While All Other Applicant Carriers Are Shrinking 

(Exhibit 601)

• Hawaiian Has the Best On-Time Performance of All Large U.S. Airlines (Exhibit 602)

• Hawaiian’s Mishandled Bags Rate Is Lower Than All Other Applicant Carriers (Exhibit 

603)

• Hawaiian’s Denied Boardings Rate Is Lower Than All Other Applicant Carriers

(Exhibit 604)

• Hawaiian’s Complaint Rate Is Lower Than All Other Applicant Carriers (Exhibit 605)

• Hawaiian Has Consistently Achieved the Best On-Time Performance in the Industry

(Exhibit 606)

• Hawaiian Has Consistently Outperformed the Other Applicant Carriers in Terms of 

Mishandled Bags (Exhibit 607)

• Hawaiian Has Consistently Outperformed the Other Applicant Carriers in Terms of 

Customer Complaints (Exhibit 608)

Exhibit HA-2012A-600

Docket OST-2010-0018

Page 1 of 1
HAWAIIAN IS GROWING ITS CAPACITY WHILE

ALL OTHER APPLICANT CARRIERS ARE SHRINKING

Source: Innovata Schedule Data.

26

-3 -3

-6

-20

-15

-10

-5

0

5

10

15

20

25

30

Year Over Year % Change in Systemwide Available Seat Miles

(August 2012 compared to August 2011)

Exhibit HA-2012A-601

Docket OST-2010-0018

Page 1 of 1

United American Delta

Hawaiian
HAWAIIAN HAS THE BEST ON-TIME

PERFORMANCE OF ALL LARGE U.S. AIRLINES

Source: U.S. DOT, Air Travel Consumer Report, page 5, February 2012.

92.8

82.3 80.2 77.8

0

10

20

30

40

50

60

70

80

90

100

Hawaiian Delta United American

CY 2011 Percentage of On-Time Arrivals

Rank: 1 5 7 11 

Exhibit HA-2012A-602

Docket OST-2010-0018

Page 1 of 1
HAWAIIAN’S MISHANDLED BAGS RATE IS LOWER

THAN ALL OTHER APPLICANT CARRIERS

Source: U.S. DOT, Air Travel Consumer Report, page 31, February 2012.

2.6 2.7

3.6 3.7

0.0

0.5

1.0

1.5

2.0

2.5

3.0

3.5

4.0

Hawaiian Delta American United

CY 2011 Number of Mishandled Bags per 1,000 Passengers

Rank: 4 5 9 11

Exhibit HA-2012A-603

Docket OST-2010-0018

Page 1 of 1
HAWAIIAN’S DENIED BOARDINGS RATE IS LOWER

THAN ALL OTHER APPLICANT CARRIERS

Source: U.S. DOT, Air Travel Consumer Report, page 34, February 2012.

0.11

0.31

0.92

1.01

0.00

0.20

0.40

0.60

0.80

1.00

1.20

Hawaiian Delta American United

CY 2011 Number of Denied Boardings per 10,000 Passengers

Rank: 2 3 9 12

Exhibit HA-2012A-604

Docket OST-2010-0018

Page 1 of 1
HAWAIIAN’S COMPLAINT RATE IS LOWER

THAN ALL OTHER APPLICANT CARRIERS

Source: U.S. DOT, Air Travel Consumer Report, page 47, February 2012.

0.70

1.23

1.46

2.21

0.00

0.50

1.00

1.50

2.00

2.50

Hawaiian Delta American United

CY 2011 Number of Complaints per 100,000 Enplanements

Rank: 4 11 13 16

Exhibit HA-2012A-605

Docket OST-2010-0018

Page 1 of 1
HAWAIIAN HAS CONSISTENTLY ACHIEVED THE BEST 

ON-TIME PERFORMANCE IN THE INDUSTRY

On-Time Performance Rank

Source: U.S. DOT, Air Travel Consumer Reports 2004-2011.

Exhibit HA-2012A-606

Docket OST-2010-0018

Page 1 of 1

Ranking 2004 2005 2006 2007 2008 2009 2010 2011

1 HA HA HA HA HA HA HA HA

2

3 UA

4

5 DL DL

6 UA DL

7 UA

8 UA AA UA

9 AA

10 AA UA DL

11 DL AA

12 DL

13 AA UA

14

15 DL

16 DL AA

17 AA UA

18

19 AA
HAWAIIAN HAS CONSISTENTLY OUTPERFORMED THE 

OTHER APPLICANT CARRIERS IN TERMS OF MISHANDLED BAGS

Baggage Mishandling Rank

Exhibit HA-2012A-607

Docket OST-2010-0018

Page 1 of 1

Ranking 2004 2005 2006 2007 2008 2009 2010 2011

1 HA HA HA

2 HA HA HA HA

3

4 HA

5 DL

6

7 UA

8 UA UA UA UA

9 AA

10 UA DL

11 AA AA AA AA UA AA UA

12 DL AA DL DL DL AA

13

14 DL DL

15

16

17

18

19

Note: The lower the ranking the fewest number of mishandled bags per passenger.

Source: U.S. DOT, Air Travel Consumer Reports 2004-2011.
HAWAIIAN HAS CONSISTENTLY OUTPERFORMED THE 

OTHER APPLICANT CARRIERS IN TERMS OF CUSTOMER COMPLAINTS

Note: The lower the ranking the fewest number of complaints per passenger.

Source: U.S. DOT, Air Travel Consumer Reports 2004-2011.

Customer Complaints Rank

Exhibit HA-2012A-608

Docket OST-2010-0018

Page 1 of 1

Ranking 2004 2005 2006 2007 2008 2009 2010 2011

1

2 HA HA HA

3 HA HA HA

4 AA HA

5 UA UA AA

6 UA UA

7 AA AA AA DL

8

9 AA UA

10 UA HA

11 DL

12 DL

13 AA

14 DL DL DL AA

15

16 DL UA

17 UA

18 DL

19
700 SERIES:

ANSWER TO AMERICAN
700 Series Exhibits

ANSWER TO AMERICAN

• AA/JL Has a Huge Commitment to Narita (Exhibit 701)

• From January 2011 to May 2012 American Did Not Operate 796 or 77% of Its Awarded 

Haneda Flights (Exhibit 702)

• American Operated Less Than 1/3 of the Flights it Proposed (Exhibit 703)

• Hawaiian Will Provide 19% More Annual Seats Than American (Exhibit 704)

• Hawaiian Carried 4.8 Times as Many Haneda Passengers as American (Exhibit 705)

• If American’s Haneda Service Follows a Pattern Similar to Delta at LAX, Its Haneda

Load Factor Would be Below 60% (Exhibit 706)

• American Proposes an 11% Increase in LAX-TYO Seats (Exhibit 707)

• Almost 80% of American’s Proposed LAX-HND Capacity Could be Offset by Delta 

Fulfilling Its 2010 LAX-HND Commitment (Exhibit 708)

• LAX is Not Large Enough to Support More Haneda Service (Exhibit 709)

• Using Standard DOT QSI Stimulation Methodology American’s LAX Proposal Would 

Generate Only 57,608 New Passengers (Exhibit 710)

• LAX is Not Large Enough to Support More Haneda Service (Includes Stimulation)

(Exhibit 711)

• American and JAL Already Operate 14 Weekly Roundtrips Between LAX and Tokyo

(Exhibit 712)

Exhibit HA-2012A-700

Docket OST-2010-0018

Page 1 of 1
AA/JL HAS A HUGE COMMITMENT TO NARITA

AA/JL’s 37 Narita Segments - 384 Weekly Departures

Bangkok (BKK)

Beijing (PEK)

Boston (BOS)

Chicago-O'Hare (ORD)

Dalian (DLC)

Dallas/Fort Worth (DFW)

Delhi (DEL)

Frankfurt (FRA)

Fukuoka (FUK)

Guam (GUM)

Guangzhou (CAN)

Hanoi (HAN)

Ho Chi Minh City (SGN)

Hong Kong (HKG)

Honolulu/Oahu (HNL)

Jakarta (CGK)

Kaohsiung (KHH)

Kuala Lumpur (KUL)

London-Heathrow (LHR)

Los Angeles (LAX)

Manila (MNL)

Moscow (DME)

Nagoya (NGO)

New York-JFK (JFK)

Okinawa (OKA)

Osaka-Itami (ITM)

Palau (ROR)

Paris-De Gaulle (CDG)

Pusan (PUS)

San Diego (SAN)*

Sapporo (CTS)

Seoul (ICN)

Shanghai (PVG)

Singapore (SIN)

Sydney, NS (SYD)

Taipei (TPE)

Vancouver (YVR)

Source: Innovata schedule for the week of August 13, 2012 plus announced service (*).

OKA OKA OKA

FUK FUK FUK

FRA FRA FRA

LHR LHR LHR

KHH KHH KHH

MNL MNL MNL

HKG HKG HKG

CAN CAN CAN

HAN HAN HAN

BKK BKK BKK

NGO NGO NGO

ITMITMITM

CTS CTS CTS

NRT NRT PVG PVG PVG

ICN ICN ICN ICN

BOS BOS BOS

SAN SAN SAN

DLC DLC DLC LAX LAX LAX

PEK PEK PEK

CGK CGK CGK

KUL KUL KUL

ORD ORD ORD

DFW DFW DFW

GUM GUM SGN SGN SGN

ROR ROR ROR

DME DME DME

JFK JFK JFK

YVR YVR YVR

PUS PUS PUS

CDG CDG CDG

HNL HNL HNL

SINSIN SINSIN

DEL DEL DEL

SYD SYD SYD

TPE TPE TPE

Exhibit HA-2012A-701

Docket OST-2010-0018

Page 1 of 1
0

10

20

30

40

50

60

70

Jan-11

Feb-11

Mar-11

Apr-11

May-11

Jun-11

Jul-11

Aug-11

Sep-11

Oct-11

Nov-11

Dec-11

Jan-12

Feb-12Mar-12

Apr-12

May-12

FROM JANUARY 2011 TO MAY 2012 AMERICAN DID

NOT OPERATE 796 or 77% OF ITS AWARDED HANEDA FLIGHTS

American HND Designated Flights Not Operated

Source: U. S. DOT T-100 data.

Exhibit HA-2012A-702

Docket OST-2010-0018

Page 1 of 1
AMERICAN OPERATED LESS 

THAN 1/3 OF THE FLIGHTS IT PROPOSED

Source: U.S. DOT, T-100 Data: DOT -OST -2010-0018, Exhibit AA-102.

180,310

53,410

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

200,000

220,000

Proposed JFK Actual JFK YE February 2012

AA HND Seats

Exhibit HA-2012A-703

Docket OST-2010-0018

Page 1 of 1
HAWAIIAN WILL PROVIDE 19% 

MORE ANNUAL SEATS THAN AMERICAN

247

294

0

20

40

60

80

100

120

140

160

180

200

220

240

260

280

300

Proposed Seats per Aircraft

Hawaiian American 

(A330) (777) 

+19%

+34,310 Annual Seats 

Exhibit HA-2012A-704

Docket OST-2010-0018

Page 1 of 1

Note: Assumes all carriers operate the aircraft types and the number of flights in their proposals. 

Only Hawaiian has operated the number of flights and aircraft it committed to in its original HND proposal.

Source: Applications.
HAWAIIAN CARRIED 4.8 TIMES AS MANY

HANEDA PASSENGERS AS AMERICAN

Source: U.S. DOT, T-100 Data.

202,772

42,526

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

200,000

220,000

Hawaiian American

HND Onboard Passengers 16 Months Ended February 2012

4.8 X

Exhibit HA-2012A-705

Docket OST-2010-0018

Page 1 of 1
IF AMERICAN’S HANEDA SERVICE FOLLOWS

A PATTERN SIMILAR TO DELTA AT LAX, ITS HANEDA

LOAD FACTOR WOULD BE BELOW 60%

Delta

Note: Load Factor for AA calculated assuming its 247 proposed seats.

Source: U.S. DOT, T-100 Data and MIDT.

180 253 71.1%

YE Feb. 2012 LAX 

Onboard Passenger per Flight

HND NRT

HND as % 

of NRT

AA YE Feb. 2012 LAX-NRT Onboard Passengers per Flight 194

AA HND Onboard Passengers per Flight @ 71.1% (DL Ratio) 138

Estimated AA HND Load Factor 55.9%

Exhibit HA-2012A-706

Docket OST-2010-0018

Page 1 of 1
AMERICAN PROPOSES AN 11% INCREASE IN LAX-TYO SEATS

LAX – TYO Annual Seats

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

1,600,000

1,800,000

2,000,000

Current Seats - YE Feb. 2012 Current Plus Proposed Service

1,882,648

1,702,338

+11%

Source: U. S. DOT T-100 data, YE Feb. 2012 and Innovata schedule data.

Exhibit HA-2012A-707

Docket OST-2010-0018

Page 1 of 1
ALMOST 80% OF AMERICAN’S PROPOSED LAX-HND CAPACITY COULD BE 

OFFSET BY DELTA FULFILLING ITS 2010 LAX-HND COMMITMENT

Source: U.S. DOT, T-100 Data: Docket OST-2010-0018, Exhibit DL-ANS-201.

.

180,310

142,716

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

200,000

220,000

AA Proposed LAX Seats Additional DL Seats If DL

Fulfilled 2010 Commitment /1

Exhibit HA-2012A-708

Docket OST-2010-0018

Page 1 of 1

1/ Delta proposed 294,190 seats in 2010. It operated 151,474 seats in YE February 2012. The difference is 142,716. 
LAX IS NOT LARGE ENOUGH TO SUPPORT MORE HANEDA SERVICE

Load Factor (%)

77%

70%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Latest TYO-LAX Annual - All Carriers After Adding AA Proposed Service

Departures

Onboard Passengers

Seats

Load Factor

6,320

1,309,284

1,702,338

77%

7,050

1,309,284

1,882,648

70%

Source: U. S. DOT T-100 data, YE Feb. 2012 and Innovata schedule data.

Exhibit HA-2012A-709

Docket OST-2010-0018

Page 1 of 1
USING STANDARD DOT QSI STIMULATION METHODOLOGY AMERICAN’S

LAX PROPOSAL WOULD GENERATE ONLY 57,608 NEW PASSENGERS

Stimulated Passengers

57,608

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

80,000

90,000

100,000

LAX

YE Feb. 2012 Flights

YE Feb. 2012 Onboard Passengers

Proposed Flights

Total Proposed Flights

% Increase in Flights

Indicated Stimulation %/1

Stimulated Passengers

6,320

1,309,284

730

7,050

11.6%

4.4%

57,608

With Proposed

AA Service

1/ Exhibit HA-2012A-408, page 2.

Source: U. S. DOT T-100 data, YE Feb. 2012 and Innovata schedule data.

Exhibit HA-2012A-710

Docket OST-2010-0018

Page 1 of 1
LAX IS NOT LARGE ENOUGH TO SUPPORT MORE HANEDA SERVICE

(Includes Stimulation)

Load Factor(%)

73%

79%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

TYO After Adding More LAX-HND

Service and Stimulation - All

Carriers

AA U.S. Tokyo Average

1/ See Exhibit HA-2012A-408, page 2. 

Departures

Onboard Passengers (Incl. Stimulation)/1

Seats

TYO Load Factor – All Carriers

6,320

1,366,892

1,882,648

73%

Source: U. S. DOT T-100 data, YE Feb. 2012 and Innovata schedule data.

Exhibit HA-2012A-711

Docket OST-2010-0018

Page 1 of 1
AMERICAN AND JAL ALREADY OPERATE 14 WEEKLY

ROUNDTRIPS BETWEEN LAX AND TOKYO

American

JAL

Source: Innovata Schedule Data, Week of August 13, 2012.

7

7

14

Note: JAL Will Add 4 Weekly Roundtrips to Southern California (via

San Diego) in December 2012 increasing to daily in March 2013 which

will recapture passengers currently driving from San Diego to LAX

and reduce passengers available to support additional LAX capacity.

LAX-TYO

Current Weekly 

Roundtrip Flights

Exhibit HA-2012A-712

Docket OST-2010-0018

Page 1 of 1
800 SERIES:

ANSWER TO DELTA
800 Series Exhibits

ANSWER TO DELTA

• Delta Has a Huge Commitment to Narita (Exhibit 801)

• Delta Has 47 More Weekly U.S. – Tokyo Flights Than the Second Largest Carrier 

(Exhibit 802)

• In 2011 Delta Did Not Operate 780 or 53% of Its Awarded Haneda Flights (Exhibit 803)

• Hawaiian Will Provide at Least 30% More Annual Seats Than Delta (Exhibit 804)

• Delta Failed at DTW With 106 Connecting Points and Will Fail Again at SEA With 

Only 62 Connecting Points (Exhibit 805)

• In 2010 Delta Said DTW Would Have About Twice as Many Connecting Points Within 

10% Circuity as SEA (Exhibit 806)

• Delta Did Not Fulfill Its LAX Aircraft Promise (Exhibit 807)

• Delta Did Not Honor Its 2010 Proposed Number of Annual Seats (Exhibit 808)

• Hawaiian With Only One Haneda Slot Transported 43% More Haneda Passengers 

Than Delta With Two Haneda Slots (Exhibit 809)

• Despite Not Having Nonstop Service to Tokyo, Kona Has More Point of Origin Japan 

Passengers Than Seattle Which Already Enjoys Three Daily Nonstops (Exhibit 810)

• ANA Has Already Added Capacity to the SEA – Tokyo Market and Is Switching to the 

Significantly Smaller 787 Because It Does Not See the Market as Large Enough For a 

Larger Aircraft (Exhibit 811)

• SEA – TYO Seats Would Increase by 71% With Proposed Delta and New ANA Service 

(Exhibit 812)

• Despite the Fact That SEA-TYO Has Lost 2% of Its Traffic, DL Proposes to Increase 

Capacity by 71% (Exhibit 813)

• Sea is Not Large Enough to Support HND Service (Exhibit 814)

• Using Standard DOT QSI Stimulation Methodology Delta’s SEA Proposal Would 

Generate Only 40,454 New Passengers (Exhibit 815)

• Even With an Optimistic Estimate of Stimulation, SEA is Not Large Enough to Support 

HND Service (Exhibit 816)

Exhibit HA-2012A-800

Docket OST-2010-0018

Page 1 of 1
DELTA HAS A HUGE COMMITMENT TO NARITA

Delta’s 20 Narita Segments – 182 Weekly Departures

Atlanta (ATL)

Bangkok (BKK)

Beijing (PEK)

Detroit (DTW)

Guam (GUM)

Hong Kong (HKG)

Honolulu/Oahu (HNL)

Los Angeles (LAX)

Manila (MNL)

Minneapolis/St. Paul (MSP)

New York-JFK (JFK)

Palau Island (ROR)

Portland (PDX)

Saipan (SPN)

San Francisco (SFO)

Seattle (SEA)

Seoul (ICN)

Shanghai (PVG)

Singapore (SIN)

Taipei (TPE)

SPN SPN SPN

NRT NRT

SFO SFO SFO

SEA SEA SEA

ATL ATL ATL

DTW

GUM GUM

ROR ROR ROR

LAX LAX LAX

JFK JFK JFK

PDX PDX PDX

HKG HKG HKG

ICN ICN ICN

BKK BKK BKK

HNL HNL HNL

PEK PEK PEK

SINSIN SINSIN

MNL MNL MNL

MSP MSP MSP

PVG PVG PVG

TPE TPE TPE

Source: Innovata schedule for the week of August 13, 2012.

Exhibit HA-2012A-801

Docket OST-2010-0018

Page 1 of 1
DELTA HAS 47 MORE WEEKLY U.S. – TOKYO FLIGHTS THAN

THE SECOND LARGEST CARRIER 

138

91

70

63

35

8 777 6 4

0

20

40

60

80

100

120

140

160

DL UA JL NH AA KE CI HA SQ OZ MH

U.S.-Tokyo Weekly Flights – August 2012

Source: Innovata Schedule Data, week of August 13, 2012.

Exhibit HA-2012A-802

Docket OST-2010-0018

Page 1 of 1
0

20

40

60

80

100

120

140

Jan11Feb11Mar11Apr11May11Jun11Jul11Aug11Sep11Oct11Nov11Dec11

IN 2011 DELTA DID NOT OPERATE 780 

OR 53% OF ITS AWARDED HANEDA FLIGHTS

Delta HND Designated Flights Not Operated

Source: U. S. DOT T-100 data.

Exhibit HA-2012A-803

Docket OST-2010-0018

Page 1 of 1
HAWAIIAN WILL PROVIDE AT LEAST 30% 

MORE ANNUAL SEATS THAN DELTA

225

294

0

20

40

60

80

100

120

140

160

180

200

220

240

260

280

300

Proposed Seats per Aircraft

Hawaiian Delta 

(A330) (767) 

+30%

+50,370 Annual Seats 

Exhibit HA-2012A-804

Docket OST-2010-0018

Page 1 of 1

Note: Assumes all carriers operate the aircraft types and the number of flights in their proposals. 

Only Hawaiian has operated the number of flights and aircraft it committed to in its original HND proposal.

Source: Applications.
DELTA FAILED AT DTW WITH 106 CONNECTING POINTS AND WILL FAIL 

AGAIN AT SEA WITH ONLY 62 CONNECTING POINTS

In 2010 Delta Said:

In 2012 Delta Says:

Exhibit HA-2012A-805

Docket OST-2010-0018

Page 1 of 1
IN 2010 DELTA SAID DTW WOULD HAVE ABOUT TWICE AS MANY 

CONNECTING POINTS WITHIN 10% CIRCUITY AS SEA

Exhibit HA-2012A-806

Docket OST-2010-0018

Page 1 of 1
DELTA DID NOT FULFILL ITS LAX AIRCRAFT PROMISE

In February 2010 Delta Said:

In May 2010,the Department relied on Delta’s Proposal:

“Through utilization of B747 aircraft, Delta would inject more capacity into the U.S.-Tokyo

market than the other west coast services proposed by the applicants. We tentatively find that Delta’s significant capacity 

advantage is particularly compelling at Los Angeles... Thus, Delta’s proposed Los Angeles-Haneda service would 

provide passengers the largest capacity in this large market to offer a practical alternative service option to the existing 

Narita services available from Los Angeles.” - Order 2010-5-7, p. 10

Delta Actually Operated:

• B 747 service for only 32 days (11 in February 2011 and 21 in March 2011)

• Between November 2010 and December 2011 Delta operated

• 189 days with no service

• 205 days with smaller aircraft

Exhibit HA-2012A-807

Docket OST-2010-0018

Page 1 of 1
DELTA DID NOT HONOR ITS 2010 PROPOSED NUMBER OF ANNUAL SEATS

55,782

294,190

151,474

294,190

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

200,000

220,000

240,000

260,000

280,000

300,000

Delta DTWHND 2010

Proposal /1

Actual DTWHND YE Feb

2012

Delta LAXHND 2010

Proposal /1

Actual LAXHND YE Feb

2012

Delta Promised and Actual Annual HND Seats

1/ From Docket OST-2010-0018,Exhibit DL-ANS-201.

Exhibit HA-2012A-808

Docket OST-2010-0018

Page 1 of 1
HAWAIIAN WITH ONLY ONE HANEDA SLOT TRANSPORTED 43% MORE 

HANEDA PASSENGERS THAN DELTA WITH TWO HANEDA SLOTS

Source: U.S. DOT, T-100 Data.

202,772

141,368

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

200,000

220,000

Hawaiian Delta Total (2 Designations)

HND Onboard Passengers 16 Months Ended February 2012

+43%

Exhibit HA-2012A-809

Docket OST-2010-0018

Page 1 of 1
DESPITE NOT HAVING NONSTOP SERVICE TO TOKYO,

KONA HAS MORE POINT OF ORIGIN JAPAN PASSENGERS THAN SEATTLE, 

WHICH ALREADY ENJOYS THREE DAILY NONSTOPS

50,525

56,127

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

45,000

50,000

55,000

60,000

KOA SEA

YE June 2012 Tokyo MIDT Point of Origin Japan 

Exhibit HA-2012A-810

Docket OST-2010-0018

Page 1 of 1

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

Source: MIDT, via Travelport.
ANA HAS ALREADY ADDED CAPACITY TO THE SEA – TOKYO MARKET AND 

IS SWITCHING TO THE SIGNIFICANTLY SMALLER 787 BECAUSE IT DOES 

NOT SEE THE MARKET AS LARGE ENOUGH FOR A LARGER AIRCRAFT

Exhibit HA-2012A-811

Docket OST-2010-0018

Page 1 of 1
SEA – TYO SEATS WOULD INCREASE BY 71%

WITH PROPOSED DELTA AND NEW ANA SERVICE 

SEA – TYO Annual Seats

0

100,000

200,000

300,000

400,000

500,000

600,000

700,000

800,000

Current Seats - YE Feb. 2012 Current Plus Proposed and New ANA

Service

674,608

394,690

+71%

1/ ANA begins service with a 777 but downsizes to a 787 with 158 seats in October 2012. 

Source: U. S. DOT T-100 data, YE Feb. 2012 and Innovata schedule data.

New ANA 787 

Nonstop /1

Proposed

Delta

Exhibit HA-2012A-812

Docket OST-2010-0018

Page 1 of 1
DESPITE THE FACT THAT SEA-TYO HAS LOST 2% OF ITS TRAFFIC,

DL PROPOSES TO INCREASE CAPACITY BY 71%

-2%

71%

-10%

0%

10%

20%

30%

40%

50%

60%

70%

80%

2009-YE Jan. 2012 Change in

Onboard Passengers

Proposed Increase in Capacity

with ANA and DL Haneda

Proposal

Source: U.S. DOT, T-100 Data.

Exhibit HA-2012A-813

Docket OST-2010-0018

Page 1 of 1
SEA IS NOT LARGE ENOUGH TO SUPPORT HND SERVICE

78%

46%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Latest NRT-SEA Annual - All Carriers TYO After Adding DL and NH SEA-HND

Departures

Onboard Passengers

Seats

Load Factor

1,411

306,178

395,018

78%

2,871

306,178

674,608

45%

Source: U. S. DOT T-100 data, YE Feb. 2012 and Innovata schedule data.

Exhibit HA-2012A-814

Docket OST-2010-0018

Page 1 of 1

Load Factor (%)
USING STANDARD DOT QSI STIMULATION METHODOLOGY DELTA’S

SEA PROPOSAL WOULD GENERATE ONLY 40,454 NEW PASSENGERS

Stimulated Passengers

40,454

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

80,000

90,000

100,000

SEA

YE Feb. 2012 Flights

YE Feb. 2012 Onboard Passengers

Proposed Flights

Total Proposed Flights

% Increase in Flights

Indicated Stimulation %/1

Stimulated Passengers

1,411

306,178

730

2,141

51.7%

15.9%

48,682

2,141

354,860

730

2,871

34.1%

11.4%

40,454

SEA with NH

SEA with DL

and NH

Source: U. S. DOT T-100 data, YE Feb. 2012 and Innovata schedule data.

Exhibit HA-2012A-815

Docket OST-2010-0018

Page 1 of 1

1/ Exhibit HA-2012A-408, page 2.
EVEN WITH AN OPTIMISTIC ESTIMATE OF STIMULATION, SEA IS NOT 

LARGE ENOUGH TO SUPPORT HND SERVICE

Load Factor(%)

59%

82%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

TYO After Adding SEA-HND and

Stimulation - All Carriers

DL U.S. Tokyo Average

1/ See Exhibit HA-2012A-408, page 2. Includes both ANA and DL service.

Departures

Onboard Passengers (Incl. Stimulation)/1

Seats

TYO Load Factor – All Carriers

2,871

395,314

674,608

59%

Source: U. S. DOT T-100 data, YE Jan. 2012 and Innovata schedule data.

Exhibit HA-2012A-816

Docket OST-2010-0018

Page 1 of 1
900 SERIES:

ANSWER TO UA
900 Series Exhibits

ANSWER TO UNITED

• UA/NH Has a Huge Commitment to Narita (Exhibit 901)

• Hawaiian Will Provide at Least 10% More Annual Seats Than United (Exhibit 902)

• SFO-HND Operated With Over 67,000 Empty Seats (Exhibit 903)

• Only the Failed DTW Route Had a Lower HND Load Factor Than SFO (Exhibit 904)

• United’s 2010 Assessment of SFO and DTW Shows That SFO Would Be a Failure on the 

Scale of the DTW Fiasco (Exhibit 905)

• United’s Application Suggests It Is Considering Reducing SFO-NRT Service or Only 

Operating HND Seasonally (Exhibit 906)

• JAL Has Been Struggling Since Switching Its SFO Service to Haneda (Exhibit 907)

• The Star Alliance Already Has Both the Largest SFO – Tokyo Share and the Largest 

U.S. to Tokyo Share (Exhibit 908)

• The SFO Bay Area Is Getting New Nonstop Tokyo Service – United’s ATI Partner ANA 

is Adding SFO Bay Area Service in Early 2013 (Exhibit 909)

• With Proposed United And New ANA Service, Bay Area– TYO Seats Would Increase 

33% (Exhibit 910)

• The Bay Area is Not Large Enough to Support More Haneda Service (Exhibit 911)

• Using Standard DOT QSI Stimulation Methodology United’s Bay Area Proposal Would 

Generate Only 49,640 New Passengers (Exhibit 912)

• Even With an Optimistic Estimate of Stimulation, the Bay Area Is Not Large Enough to 

Support More Haneda Service (Exhibit 913)

• If United Cuts Its NRT-SFO Capacity, Its ATI Partner Will Still Be in the Market

(Exhibit 914)

Exhibit HA-2012A-900

Docket OST-2010-0018

Page 1 of 1
UA/NH HAS A HUGE COMMITMENT TO NARITA

UA/NH’s 43 Narita Segments - 504 Weekly Departures

Bangkok (BKK)

Beijing (PEK)

Chengdu (CTU)

Chicago-O'Hare (ORD)

Dalian (DLC)

Denver (DEN)*

Frankfurt (FRA)

Fukuoka (FUK)

Guam (GUM)

Guangzhou (CAN)

Hangzhou (HGH)

Hiroshima (HIJ)

Ho Chi Minh City (SGN)

Hong Kong (HKG)

Honolulu/Oahu (HNL)

Houston (IAH)

Jakarta (CGK)

Komatsu (KMQ)

London-Heathrow (LHR)

Los Angeles (LAX)

Manila (MNL)

Mumbai/Bombay (BOM)

Munich (MUC)

Nagoya (NGO)

New York-JFK (JFK)

Newark (EWR)

Niigata (KIJ)

Okinawa (OKA)

Osaka-Itami (ITM)

Paris-De Gaulle (CDG)

Qingdao (TAO)

San Francisco (SFO)

San Jose (SJC)*

Sapporo (CTS)

Seattle (SEA)

Sendai (SDJ)

Seoul (ICN)

Shanghai (PVG)

Shenyang (SHE)

Singapore (SIN)

Taipei (TPE)

Washington-Dulles (IAD)

Xiamen (XMN)

NGO NGO NGONRT NRT

SDJ SDJ SDJ

HIJ HIJ HIJ HIJ

KMQ KMQ KMQ

FUK FUK FUKITMITM

OKA OKA OKA

ICN ICN ICN ICN KIJ KIJ KIJ KIJ

SGN SGN SGN

BKK BKK BKK

TAO TAO TAO

DLC DLC DLC

PEK PEK PEK

CTU CTU CTU

SHE SHE SHE

IADIADIADIAD

EWR EWEWRRRRRR

HGH HGH HGH CAN CAN CAN

SJC SJC SJC

SFO SFO SFO

LAX LAX LAX

XMN XMN XMN

HKG HKG HKG

CTS CTS CTS

FRA FRA FRA

MUC MUC MUC

LLLLLLLHR HRHRHR

ORD ORD ORD

GUM GUM

IAHIAHIAHIAH

JFJFJFJFJFKKKKKKKKK

SEA SEA SEA CCCCDG CDG DG

HNL HNL HNL

SINSIN SINSIN

BOM BOM

CGK CGK CGK

MNL MNL MNL

PVG PVG PVG

TPE TPE TPE

DEN DEN DEN

Source: Innovata schedule for the week of August 13, 2012 plus announced service (*).

Exhibit HA-2012A-901

Docket OST-2010-0018

Page 1 of 1
HAWAIIAN WILL PROVIDE AT LEAST 10% 

MORE ANNUAL SEATS THAN UNITED

268

294

0

20

40

60

80

100

120

140

160

180

200

220

240

260

280

300

Proposed Seats per Aircraft

Hawaiian United 

(A330) (777) 

+10%

+18,980 Annual Seats

Exhibit HA-2012A-902

Docket OST-2010-0018

Page 1 of 1

Note: Assumes all carriers operate the aircraft types and the number of flights in their proposals. 

Only Hawaiian has operated the number of flights and aircraft it committed to in its original HND proposal.

Source: Applications.
SFO-HND OPERATED WITH OVER 67,000 EMPTY SEATS

111,152

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

200,000

Onboard Passengers Seats Offered by JAL

JAL SFO-HND Passengers and Seats – 12 Months Ended February 2012

Source: U.S. DOT, T-100 Data.

178,484

67,332

Empty

Seats

SFO-HND Averaged 92 Empty Seats per Flight

Exhibit HA-2012A-903

Docket OST-2010-0018

Page 1 of 1
ONLY THE FAILED DTW ROUTE

HAD A LOWER HND LOAD FACTOR THAN SFO

78.8% 78.1% 76.8%

73.6% 72.7%

67.9%

62.3% 60.3%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

HNL-JL HNL-HA HNL-NH JFK-AA LAX-NH LAX-DL SFO-JL DTWDL

Load Factor – 12 Months Ended February 2012

Source: U.S. DOT, T-100 Data.

Exhibit HA-2012A-904

Docket OST-2010-0018

Page 1 of 1
UNITED’S 2010 ASSESSMENT OF SFO AND DTW SHOWS THAT SFO WOULD 

BE A FAILURE ON THE SCALE OF THE DTW FIASCO

Exhibit HA-2012A-905

Docket OST-2010-0018

Page 1 of 1
UNITED’S APPLICATION SUGGESTS IT IS CONSIDERING REDUCING 

SFO-NRT SERVICE OR ONLY OPERATING HND SEASONALLY

1/ From Innovata schedule data. The average is 1.6 because it operates 2 frequencies in the Summer months and 1 of the rest.

“United currently operates two daily flights during the summer

between San Francisco and Tokyo Narita and one daily flight

during the winter. United would continue to operate at least one

daily Tokyo flight year round if awarded the requested Tokyo

Haneda Slots.” – United Application at page 2, footnote 4.

Emphasis Added.

United CY 2012 Scheduled SFO- NRT Average Daily Departures /1: 1.6

United’s SFO- Tokyo commitment if it is awarded SFO-HND: 1.0 

Exhibit HA-2012A-906

Docket OST-2010-0018

Page 1 of 1
0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

Jul-09

Sep-09

Nov-09

Jan-10

Mar-10

May-10

Jul-10

Sep-10

Nov-10

Jan-11

Mar-11

May-11

Jul-11

Sep-11

Nov-11

Jan-12

JAL HAS BEEN STRUGGLING SINCE 

SWITCHING ITS SFO SERVICE TO HANEDA

JAL SFO-NRT Load Factor

Source: U. S. DOT T-100 data.

1 of 16 Months with Load 

Factor Over 70%

(Ave. = 62%)

15 of 16 Months with 

Load Factor Over 70%

(Ave. = 76%)

JAL SFO-HND Load Factor

JAL Moves Its 

SFO Service to HND

Exhibit HA-2012A-907

Docket OST-2010-0018

Page 1 of 1
60%

20% 20%

0% 0%

0%

10%

20%

30%

40%

50%

60%

70%

Star

SkyTeam

oneworld

Hawaiian

Nonaligned

THE STAR ALLIANCE ALREADY HAS BOTH THE LARGEST

SFO – TOKYO SHARE AND THE LARGEST U.S. TO TOKYO SHARE

38%

35% 34%

2% 1%

0%

10%

20%

30%

40%

50%

Star

SkyTeam

oneworld

Hawaiian

Nonaligned

Share of Weekly Roundtrip Flights 

Between SFO and Tokyo

Source: Innovata schedule for the week of August 13, 2012. 

Share of Weekly Roundtrip Flights 

Between the U.S. and Tokyo

Exhibit HA-2012A-908

Docket OST-2010-0018

Page 1 of 1
THE SFO BAY AREA IS GETTING NEW NONSTOP 

TOKYO SERVICE – UNITED’S ATI PARTNER ANA IS ADDING 

SFO BAY AREA SERVICE IN EARLY 2013

“United currently operates two daily flights during the summer between 

San Francisco and Tokyo Narita and one daily flight during the winter. 

United would continue to operate at least one daily Tokyo flight year 

round if awarded the requested Tokyo Haneda Slots.” – United 

Application at page 2, footnote 4. Emphasis Added.

United CY 2012 Scheduled SFO- NRT Average Daily Departures /1: 1.6

United’s SFO- Tokyo commitment if it is awarded SFO-HND: 1.0 

Exhibit HA-2012A-909

Docket OST-2010-0018

Page 1 of 1
WITH PROPOSED UNITED AND NEW ANA SERVICE,

BAY AREA– TYO SEATS WOULD INCREASE 33%

Bay Area – TYO Annual Seats

0

100,000

200,000

300,000

400,000

500,000

600,000

700,000

800,000

900,000

1,000,000

1,100,000

1,200,000

Current Seats - YE Jan. 2012 Current Plus Proposed and

New ANA Service

1,130,258

852,458

+33%

1/ ANA begins SJC – NRT service with a 787 for 5 days a week in January of 2013. 

Source: U. S. DOT T-100 data, YE Jan. 2012 and Innovata schedule data.

New ANA Nonstop 

to SJC /1

Proposed

United

Note: All United stimulation and seat analyses assume the it will not reduce capacity to 1 daily Tokyo 

flight. If it does do this its stimulated passengers will be lower.

Exhibit HA-2012A-910

Docket OST-2010-0018

Page 1 of 1
THE BAY AREA IS NOT LARGE ENOUGH 

TO SUPPORT MORE HANEDA SERVICE

Load Factor (%)

77%

58%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Latest TYO-Bay Area Annual - All

Carriers

TYO After Adding UA and NH Bay

Area-TYO

Departures

Onboard Passengers

Seats

Load Factor

3,181

659,580

852,458

77%

4,431

659,580

1,130,258

58%

Source: U. S. DOT T-100 data, YE Feb. 2012 and Innovata schedule data.

Exhibit HA-2012A-911

Docket OST-2010-0018

Page 1 of 1
USING STANDARD DOT QSI STIMULATION METHODOLOGY UNITED’S

BAY AREA PROPOSAL WOULD GENERATE ONLY 49,640 NEW PASSENGERS

Stimulated Passengers

49,640

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

80,000

90,000

100,000

Bay Area

YE Feb. 2012 Flights

YE Feb. 2012 Onboard Passengers

Proposed Flights

Total Proposed Flights

% Increase in Flights

Indicated Stimulation %/1

Stimulated Passengers

3,181

659,580

520

3,701

16.3%

6.0%

39,575

3,701

699,155

730

4,431

19.7%

7.1%

49,640

Bay Area with NH

Bay Area with UA

and NH

Source: U. S. DOT T-100 data, YE Feb. 2012 and Innovata schedule data.

Exhibit HA-2012A-912

Docket OST-2010-0018

Page 1 of 1

1/ Exhibit HA-2012A-408, page 2.
EVEN WITH AN OPTIMISTIC ESTIMATE OF STIMULATION, THE 

BAY AREA IS NOT LARGE ENOUGH TO SUPPORT MORE HANEDA SERVICE

Load Factor(%)

66%

81%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

TYO After Adding More Bay Area -

HND Service and Stimulation - All

Carriers

UA U.S. Tokyo Average

1/ See Exhibit HA-2012A-408, page 2. Includes both ANA and UA service.

Departures

Onboard Passengers (Incl. Stimulation)/1

Seats

TYO Load Factor – All Carriers

4,431

748,795

1,130,258

66%

Source: U. S. DOT T-100 data, YE Feb. 2012 and Innovata schedule data.

Exhibit HA-2012A-913

Docket OST-2010-0018

Page 1 of 1
IF UNITED CUTS ITS NRT-SFO CAPACITY, 

ITS ATI PARTNER WILL STILL BE IN THE MARKET

United

ANA

Source: Innovata Schedule Data, Week of August 13, 2012.

14

7

21

Note: ANA Will Add 5 Weekly Roundtrips to San Jose In 

January 2013. This service will recapture passengers 

currently driving from the San Jose Area.

SFO-TYO

Current Weekly 

Roundtrip Flights

Exhibit HA-2012A-914

Docket OST-2010-0018

Page 1 of 1
Appendix A
EACH OF HAWAIIAN’S PROPOSED HNL FLIGHTS WILL BRING IN

OVER $50 MILLION IN NEW U.S. EXPORTS ANNUALLY, 

OVER 70% MORE THAN THE SECOND HIGHEST GATEWAY

Exhibit HA-A-230

Docket OST-2010-0018

Page 1 of 1

$56.7

$53.3

$30.5 $28.9

$21.5 $21.0 $20.4 $18.3 $17.7

$0.0

$10.0

$20.0

$30.0

$40.0

$50.0

$60.0

HNL

Flight 1

HNL

Flight 2

DTW LAX JFK SFO GUM SEA EWR

Annual Spending (Exports) of Incremental Japanese 

Visitors to the U.S. (Millions)

Note: Expenditures calculated using average expenditures per visitor x estimated incremental Japanese visitors.

Source: U.S. Department of Commerce Office of Travel and Tourism Industries, 2008 Market Profile: 

Japan; Guam Visitors Bureau, Japan Visitor Tracker Exit Profile FY 2008 Data Aggregation; 

State of Hawaii Department of Business, Economic Development, and Tourism, 

2008 Annual Visitor Research Report; Exhibits HA-A-801 and 803. Page 83
EACH OF HAWAIIAN’S PROPOSED HNL FLIGHTS WILL INCREASE

U.S. GDP BY OVER $105 MILLION ANNUALLY, 

OVER 70% MORE THAN THE SECOND HIGHEST GATEWAY

Exhibit HA-A-231

Docket OST-2010-0018

Page 1 of 1

$0.0

$20.0

$40.0

$60.0

$80.0

$100.0

$120.0

HNL

Flight 1

HNL

Flight 2

LAX DTW JFK SFO GUM SEA EWR

Direct Spending Induced Impacts

$112.8

$105.9

$62.0 $60.6

$43.5 $42.1 $40.6 $37.0 $35.9

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

Note: Induced estimates calculated using standard multipliers from the U.S. Bureau of Economic Analysis (See Exhibit HA-A-801)

Source: U.S. Bureau of Economic Analysis RIMS II Multipliers;

U.S. Department of Commerce Office of Travel and Tourism Industries, 2008 Market Profile: Japan; 

Guam Visitors Bureau, Japan Visitor Tracker Exit Profile FY 2008 Data Aggregation; 

State of Hawaii Department of Business, Economic Development, and Tourism, 2008 Annual Visitor Research Report. Page 84
EACH OF HAWAIIAN’S PROPOSED HNL FLIGHTS WILL INCREASE U.S. 

HOUSEHOLD EARNINGS BY OVER $30 MILLION ANNUALLY, 

NEARLY DOUBLE THE SECOND HIGHEST GATEWAY

Exhibit HA-A-232

Docket OST-2010-0018

Page 1 of 1

$0.0

$5.0

$10.0

$15.0

$20.0

$25.0

$30.0

$35.0

HNL

Flight 1

HNL

Flight 2

DTW LAX JFK GUM SFO SEA EWR

Direct Earnings Induced Earnings $32.1

$30.1

$16.5

$11.8 $11.6 $10.9 $10.1 $9.8

$16.3

Total Earnings Impact of Incremental Japanese Visitors to the U.S.

Note: Induced estimates calculated using standard multipliers from the U.S. Bureau of Economic Analysis (See Exhibit HA-A-801)

Source: U.S. Bureau of Economic Analysis RIMS II Multipliers;

U.S. Department of Commerce Office of Travel and Tourism Industries, 2008 Market Profile: Japan; 

Guam Visitors Bureau, Japan Visitor Tracker Exit Profile FY 2008 Data Aggregation; 

State of Hawaii Department of Business, Economic Development, and Tourism, 2008 Annual Visitor Research Report. Page 85
EACH OF HAWAIIAN’S PROPOSED HNL FLIGHTS WILL CREATE

OVER 1,100 U.S. JOBS, DOUBLE THE SECOND HIGHEST GATEWAY

Exhibit HA-A-233

Docket OST-2010-0018

Page 1 of 1

0

200

400

600

800

1,000

1,200

1,400

HNL

Flight 1

HNL

Flight 2

DTW LAX GUM JFK SFO SEA EWR

Direct Jobs Induced Jobs 1,269

1,191

586

543

459

404

364 364

333

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

Page 86

Note: Induced estimates calculated using standard multipliers from the U.S. Bureau of Economic Analysis (See Exhibit HA-A-801)

Source: U.S. Bureau of Economic Analysis RIMS II Multipliers;

U.S. Department of Commerce Office of Travel and Tourism Industries, 2008 Market Profile: Japan; 

Guam Visitors Bureau, Japan Visitor Tracker Exit Profile FY 2008 Data Aggregation; 

State of Hawaii Department of Business, Economic Development, and Tourism, 2008 Annual Visitor Research Report.
JFK IS NOT LARGE ENOUGH TO SUPPORT HND SERVICE

WITHOUT REDUCING SERVICE TO NRT OR 

CHARGING MUCH HIGHER PRICES

Load Factor (%)

74%

59%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Latest JFK-NRT Annual After Adding JFK-HND

Departures

Onboard Passengers

Seats

Load Factor

2,805

538,753

729,419

74%

3,535

538,753

909,729

59%

Source: U.S. DOT T-100 data, YE August 2009, via Data Base Products and Exhibit AA-102.

Exhibit HA-A-303

Docket OST-2010-0018

Page 1 of 1

Page 96
USING STANDARD DOT QSI STIMULATION METHODOLOGY HA’S FIRST 

CHOICE HNL PROPOSAL WILL STIMULATE 49% MORE NEW PASSENGERS 

THAN AMERICAN’S FIRST CHOICE JFK PROPOSAL

Stimulated Passengers

72,952

48,817

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

45,000

50,000

55,000

60,000

65,000

70,000

75,000

80,000

85,000

90,000

95,000

100,000

HNL JFK

+49%

YE August 2009 Flights

YE August 2009 Onboard Passengers

Proposed Flights

Total Proposed 2010 Flights

% Increase in Flights

Indicated Stimulation %/1

Stimulated Passengers

5,940

1,583,197

730

6,670

12.3%

4.6%

72,952

2,805

538,753

730

3,535

26.0%

9.1%

48,817

HNL JFK

1/ Exhibit HA-A-802.

Source: U.S. DOT T-100 data, YE August 2009, via Data Base Products and Exhibit AA-102.

Exhibit HA-A-304

Docket OST-2010-0018

Page 1 of 1

Page 97
USING STANDARD DOT QSI STIMULATION METHODOLOGY HA’S FIRST 

CHOICE HNL PROPOSAL WILL STIMULATE 87% MORE NEW PASSENGERS 

THAN CONTINENTAL’S FIRST CHOICE EWR PROPOSAL

Stimulated Passengers

72,952

38,938

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

45,000

50,000

55,000

60,000

65,000

70,000

75,000

80,000

85,000

90,000

95,000

100,000

HNL EWR

+87%

YE August 2009 Flights

YE August 2009 Onboard Passengers

Proposed Flights

Total Proposed 2010 Flights

% Increase in Flights

Indicated Stimulation %/1

Stimulated Passengers

5,940

1,583,197

730

6,670

12.3%

4.6%

72,952

714

152,709

728.8

1,443

102.1%

25.5%

38,938

HNL EWR

1/ Exhibit HA-A-802.

Source: U.S. DOT T-100 data, YE August 2009, via Data Base Products and Exhibit CO-114.

Exhibit HA-A-404

Docket OST-2010-0018

Page 1 of 1

Page 114
USING STANDARD DOT QSI STIMULATION METHODOLOGY HA’S FIRST 

CHOICE HNL PROPOSAL WILL STIMULATE 52% MORE NEW PASSENGERS 

THAN DELTA’S FIRST CHOICE SEA PROPOSAL

Stimulated Passengers

72,952

47,926

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

45,000

50,000

55,000

60,000

65,000

70,000

75,000

80,000

85,000

90,000

95,000

100,000

HNL SEA

+52%

YE August 2009 Flights

YE August 2009 Onboard Passengers

Proposed Flights

Total Proposed 2010 Flights

% Increase in Flights

Indicated Stimulation %/1

Stimulated Passengers

5,940

1,538,197

730

6,670

12.3%

4.6%

72,952

1,485

313,579

730

2,215

49.2%

15.3%

47,926

HNL SEA

1/ Exhibit HA-A-802.

Source: U.S. DOT T-100 data, YE August 2009, via Data Base Products and Exhibits DL-105-106.

Exhibit HA-A-507

Docket OST-2010-0018

Page 1 of 1

Page 134
DTW IS NOT LARGE ENOUGH TO SUPPORT HND SERVICE

WITHOUT REDUCING SERVICE TO NRT OR 

CHARGING MUCH HIGHER PRICES

(Includes Stimulation)

Load Factor (%)

64%

82%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

After Adding DTW-HND and Stimulation DL U.S. Tokyo Average

1/ See Exhibit HA-A-513.

Source: U.S. DOT T-100 data, YE August 2009, via Data Base Products and Exhibits DL-105-106.

Departures

Onboard Passengers (Incl. Stimulation)/1

Seats

Load Factor

2,045

526,615

823,977

64%

Exhibit HA-A-514

Docket OST-2010-0018

Page 1 of 1

Page 141
DELTA’S DTW – HND PROPOSAL WILL REQUIRE 

32% OF CURRENT DTW – NRT PASSENGERS TO SHIFT TO HND

Proposed Additional Seats

Passengers Required for 75% Load Factor

Indicated DOT QSI Stimulation/1

Passenger Diversion Required

Current NRT Passengers (T-100)

Diversion from NRT Required for 75% Load Factor

294,190

220,643

75,618

145,025

450,997

32.2%

Source: U.S. DOT T-100 data, YE August 2009, via Data Base Products and Exhibits DL-114-115.

1/ Exhibit HA-A-802

Exhibit HA-A-515

Docket OST-2010-0018

Page 1 of 1

Note: Using a 75% load factor is conservative and was selected for purposes of uniformity. Most markets 

would require higher load factors which would increase the amount of diversion needed and self diversion.

Page 142
LAX IS NOT LARGE ENOUGH TO SUPPORT HND SERVICE

WITHOUT REDUCING SERVICE TO NRT OR 

CHARGING MUCH HIGHER PRICES

(Includes Stimulation)

Load Factor (%)

69%

82%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

After Adding LAX-HND and Stimulation DL U.S. Tokyo Average

1/ See Exhibit HA-A-519.

Source: U.S. DOT T-100 data, YE August 2009, via Data Base Products and Exhibits DL-105-106.

Departures

Onboard Passengers (Incl. Stimulation)/1

Seats

Load Factor

5,776

1,291,687

1,884,899

69%

Exhibit HA-A-520

Docket OST-2010-0018

Page 1 of 1

Page 147
DELTA’S LAX – HND PROPOSAL WILL REQUIRE 

13% OF CURRENT LAX – NRT PASSENGERS TO SHIFT TO HND

Proposed Additional Seats

Passengers Required for 75% Load Factor

Indicated DOT QSI Stimulation/1

Passenger Diversion Required

Current NRT Passengers (T-100)

Diversion from NRT Required for 75% Load Factor

294,190

220,643

65,697

154,945

1,225,990

12.6%

Source: U.S. DOT T-100 data, YE August 2009, via Data Base Products and Exhibits DL-123-124.

1/ Exhibit HA-A-802

Exhibit HA-A-521

Docket OST-2010-0018

Page 1 of 1

Note: Using a 75% load factor is conservative and was selected for purposes of uniformity. Most markets 

would require higher load factors which would increase the amount of diversion needed and self diversion.

Page 148
USING STANDARD DOT QSI STIMULATION METHODOLOGY HA’S FIRST 

CHOICE HNL PROPOSAL WILL STIMULATE 41% MORE NEW PASSENGERS 

THAN UNITED’S SFO PROPOSAL

Stimulated Passengers

72,952

51,844

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

45,000

50,000

55,000

60,000

65,000

70,000

75,000

80,000

85,000

90,000

95,000

100,000

HNL SFO

+41%

YE August 2009 Flights

YE August 2009 Onboard Passengers

Proposed Flights

Total Proposed 2010 Flights

% Increase in Flights

Indicated Stimulation %/1

Stimulated Passengers

5,940

1,583,197

730

6,670

12.3%

4.6%

72,952

3,647

720,705

730

4,377

20.0%

7.2%

51,844

HNL SFO

1/ See Exhibit HA-A-802.

Source: U.S. DOT T-100 data, YE August 2009, via Data Base Products and Exhibit UA-2.

Exhibit HA-A-604

Docket OST-2010-0018

Page 1 of 1

Page 160