BEFORE THE DEPARTMENT OF TRANSPORTATION OFFICE OF THE SECRETARY WASHINGTON, D.C.

____________________________________ ) Applications of ) ) HAWAIIAN AIRLINES, INC. ) ) Docket DOT - OST - 2010 - 0018 UNITED AIRLINES, INC. ) ) in the matter of 2010 U.S. - Haneda ) Combination S ervices ) Allocation Proceeding )

____________________________________ ) 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 Ben jamin Berlin 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 b berlin @dowlohnes.com Counsel for Hawaiian Airlines, Inc.

December 9 , 2013TABLE OF CONTENTS I. Nearly Three Years of Operational Data Demonstrates that Hawaiian’s Haneda - Honolulu Route Has Been By Far the Most Successful Route, Warranting an Award of Additional Service to Hawaii. ................................ ................... 7 A. Hawaiian Has Been the Most Reliable U.S. Carrier Operating at Haneda. ................. 7 B. Hawaiian’s Haneda Service Outperformed All Other U.S. Gateways. ........................ 8 C. Hawaiian Up - gauged the Airc raft It Flies on the Haneda Route, and Proposes to Fly the Largest Aircraft in this Proceeding. ................................ ............. 10 D. Hawaiian Used Its Haneda Service as a Launching Point for Expanded Service to Japan. ................................ ................................ ................................ .............. 12 E. Hawaiian’s Service Brought the Greate st Economic Benefit to the U.S. .................... 12 II. The Overwhelming Size of the Market Between Hawaii and Japan Warrants Additional Service to Haneda. ................................ ................................ ............................ 13 III. Hawaiian’s Proposed Service to Kona Provides the Greatest Public Interest Benefits. ................................ ................................ ................................ ................................ 22 A. Hawaiian’s Proposed Kona Service Is the Best Use of the Sole Slot Pair Available in this Proceeding. ................................ ................................ ........................... 24 B. The Initiation of Haneda - Kona Service Will Benefit the Economy of the United States and the State of Hawaii. ................................ ................................ ........... 28 C. The Grant of Hawaiian’s Application Will Strengthen a Small Competitor. ............ 31 D. The Grant of Hawaiian’s Application to Serve Ko na Will Reduce Concentration in Markets Dominated by the Three Global Alliances. ...................... 33 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. ................................ ................................ ................................ ... 35 IV. Hawaiian’s Proposed Service to Kona Is Superior to United’s Proposal. ..................... 37 A. United’s Proposed SFO Service is a Recipe for More Failure. ................................ .... 39 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 Highe st Tokyo - U.S. Market Share. ................................ ................................ .......... 40 C. Any Purported Benefit of Connecting Traffic at SFO is a Myth and Does Not Justify Awarding the Slot Pair to United. ................................ ................................ ...... 45V. Hawaiian Has a Unique Incentive to Make Its Haneda Service a Success. ................... 47 VI. Hawaiian Offers Superior Customer Service. ................................ ................................ .. 48 Conclusion ................................ ................................ ................................ ................................ ... 48DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 1 of 49 BEFORE THE DEPARTMENT OF TRANSPORTATION OFFICE OF THE SECRETARY WASHINGTON, D.C.

____________________________________ ) Applications of ) ) HAWAIIAN AIRLINES, INC. ) ) Docket DOT - OST - 2010 - 0018 UNITED AIRLINES, INC. ) ) in the matter of 2010 U.S. - Haneda ) Combination S ervices ) Allocation Proceeding )

____________________________________ ) December 9, 2013 CONSOLIDATED ANSWER OF HAWAIIAN AIRLINES, INC. In a series of proceedings to allocate slot pairs for combination service between the United Sta tes and Tokyo International Airport (“Haneda” or “HND”), the Department has sought to “award . . . limited Haneda slot opportunities” in a manner that “best serve[s] the public interest”. 1 In reallocating the single slot pair returned to the Department b y American Airlines in this proceeding, the Department now has the benefit of nearly three years of operating data to inform its consideration of which application to serve Haneda will generate the most public benefits. That information, along with analy sis of current market conditions, leaves no doubt that the application of Hawaiian Airlines, Inc. (“Hawaiian”) to serve Haneda from Kona, Hawaii will generate the most public benefits. 1 In re 2010 U.S. - Haneda Combination Services Allocation Proceeding, Docket DOT - OST 2010 - 0018, Order 2012 - 11 - 12, at 6 (Nov. 15, 2012) .DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 2 of 49 By any metric, Hawaiian’s Honolulu gateway has been by far the most su ccessful of all the U.S. carriers. Despite competition from the two incumbent Japanese carriers, Hawaiian’s Haneda service has been an unqualified success: • Hawaiian was the first U.S. carrie r to initiate service to Haneda; • Hawaiian has operated its Haneda - Honolulu route continuously with load factors that far exceed those of other U.S. carriers awarded Haneda slots , often at full capacity , see HA - 2013A - 202, 204, 407 (depicting a load factor of 95% or higher on 198 HA flights during the year ended Oct ober 31, 2013); • Hawaiian has flown more passengers to and from Haneda than any other U.S. carrier. HA - 2013A - 201; and • Hawaiian has maintained its service even through difficult circumstances, including during the 2011 tsunami and nuclear disaster. In contrast to other carriers, Hawaiian has fulfilled every promise that it has made to the Department and maximized the opportunity presented by the Department’s initial award. See HA - 2013A - 108. Indeed, Hawaiian has used the initial grant of Haneda slot s as a platform to expand service throughout Japan, taking advantage of the Open Skies agreement to provide new, competitive service between the two countries. Hawaiian’s track record compels confidence that Hawaiian will make the most of the reallocated Haneda frequency. In making its prior awards of Haneda slots, the Department has sought to promote “geographic diversity” by selecting “U.S. - Haneda gateways” operated by different carriers across the country. 2 The carriers awarded the slot pairs for mainl and service, however, have largely squandered the opportunity granted by the Department. In particular, carriers operating gateways located in the eastern half of the country have failed. Within 15 months of starting 2 Order 2012 - 11 - 12 at 6.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 3 of 49 service to Detroit, Delta applied to transfer the service to Seattle, 3 and now American Airlines has returned the slot pair allocated for its Haneda - JFK service. Meanwhile, airlines operating west coast gateways have struggled, and airlines have experienced low load factors, repeatedly cance lled service and down - gauged their aircraft. Now, United proposes San Francisco (“SFO”) service that is duplicative of existing service and duplicative of its own service from Narita International Airport (“Narita” or “NRT”) to both SFO and the service of its Star Alliance partner All Nippon Airways (“ANA”) to both SFO and nearby San Jose. United’s proposal urges the Department to insert more capacity into an already over - served market, where existing service is being withdrawn and down - gauged. In this p roceeding, the Department has the opportunity to reallocate a slot pair to a carrier that will maximize the public benefits by awarding a second frequency to Hawaiian. By selecting Hawaiian’s Kona application, the Department will facilitate the introduct ion of service to a new Haneda gateway and allow the introduction of service on the second largest O&D route without nonstop service from Tokyo. The resulting award will produce the most public benefits because it will stimulate Japanese - originating traff ic and bring more Japanese visitors to the United States. Those visitors will spend additional dollars. That spending will stimulate economic growth and lead to the creation of new U.S. jobs. This is in sharp contrast to United’s proposal, which relies t o a significant extent on U.S. - originating passengers from SFO. A rigorous analysis of th e available data leads to the inevitable conclusion t hat Hawaiian ’s Kona Haneda service is the best proposal for a number of reasons: 3 Motion of Delta Air Lines, Inc., Docket DOT - OST - 2010 - 0018 (July 30, 2012). During many of those 15 months, Delta did not operate the service. See HA - 2013A - 207.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 4 of 49
• Kona is the only market proposed in this proceeding currently without nonstop service to Haneda and is the second largest U.S. market that does not have nonstop service to Tokyo . See HA - 201 3 A - 5 0 0, 501, 502 . • The Tokyo - Kona market is sufficiently large tha t it will significantly outperform all of the mainland Haneda gateways. See HA - 2013A - 511, 512 . • Hawaiian’s proposed Kona service will generate 267% more U.S. visitors than United’s SFO service, s ee HA - 201 3 A - 613, and consequently generate the most domestic economic growth, s ee HA - 201 3 A - 616. Only Hawaiian’s Kona application will result in a commercially viable service that will stimulate traffic rather than simply reshuffle the already - abundant capacity from an over - served market. Based on the operational t rack record, analysis of passenger demand and its impact on the economy, it is apparent that Hawaiian’s proposed service to Kona will result in the greatest public interest benefits and, as is essential for any successful application, be a commercial succe ss. By contrast, United’s competing application is deeply flawed. Not only is its proposal duplicative of its own service to SFO from Narita, the HND - SFO route already is served by Japan Airlines (“JAL”), which struggles with low load factors and an abund ance of empty seats. See HA - 2013A - 408, 409. In fact, the market is so small and has so much existing capacity, that JAL down - gauged its aircraft to its smallest transpacific aircraft type (with a capacity of only 186 seats) in September 2013. See HA - 2013A - 410. Indeed, the Tokyo - SFO route is already saturated with abundant service. United and its alliance partner ANA currently serve the route 21 times per week with an additional 7 weekly frequencies to nearby San Jose.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 5 of 49 In the most recent Haneda slot allocation proceeding, the Department expressed reluctance about awarding a second slot pair for service to the State of Hawaii. 4 Given the overwhelming size of the Japan - Hawaii market compared to all other Japan - U.S. mainland markets and the failure of carriers to operate the mainland markets successfully, the Department should have no such reservations. See HA - 2013A - 306. Indeed, the size of the Hawaii - Tokyo market is nearly twice the size of the Tokyo - California market even though the two states h ave the same number of Haneda frequencies:

4 See Order 2012 - 11 - 12 at 7 (“We tentatively find that the public interest would be better served by opening Haneda nonstop access to a new region of the country, the Pacific Northwest, than by allocating a fourth Haneda route to Hawaii.”).DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 6 of 49

HA - 2013A - 305. In this proceeding, awarding the available frequency to Hawaiian is necessary to achieve geographic balance. SFO already has Haneda service, while Kona does not. Moreover, four Haneda frequencie s (U.S. and Japanese carriers) already have been allocated to the west coast, including three to California alone, so the award of an additional frequency to theDOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 7 of 49 State of Hawaii, which is a larger market than California and Washington combined, see HA 2013 A - 306, is necessary to balance the supply of the available frequencies to the demand. I. Nearly Three Years of Operational Data Demonstrates that Hawaiian’s Haneda Honolulu Route Has Been By Far the Most Successful Route, Warranting an Award of Additional S ervice to Hawaii. 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. I t leads all the other carriers in load factor, numbers of operations, passengers carried and traffic stimulated. Indeed, Hawaiian arguably is the only carrier to operate the Haneda service awarded in this docket successfully. A. Hawaiian Has Been the Most R eliable U.S. Carrier Operating at Haneda. Hawaiian initiate d its Haneda service before any other U.S. carrier , beginning in Novembe r 2010 , three months prior to when the other U.S. carriers started their respective Haneda services. See HA - 2013A - 206. The remaining U.S. carriers requested extensions of the time to start their respective services. See Motion of Delta Air Lines, Inc. for a 30 Day Startup Extension, Docket DOT - OST - 2010 - 0018 (Sept. 7, 2010); Motion of American Airlines, Inc. for 28 - Day Sta rt - up Extension (New York JFK
– Tokyo Haneda), Docket DOT - OST - 2010 - 0018 (Dec. 20, 2010) . Since initiating its service, Hawaiian has operated its service continuously, even through out the tragic events of the Japanese earthquake, tsunami and associated nuc lear disaste r — in stark contrast to other U.S. carriers . See HA - 2013A - 207. Indeed, Hawaiian has conducted more operations on its Haneda - Honolulu route than any other U.S. carrier on theirDOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 8 of 49 Haneda routes. See HA - 201 3 A - 205. Only Hawaiian has stood up to the competition provided by the Japanese carriers by operating consistently and flying a competitive number of segments. See HA - 201 3 A - 204, 205. By contrast, o ther airlines have repeatedly halted service and requested w aivers of the 90 - day dormancy condition. See , e.g., Motion of Delta Air Lines, Inc., OST - 2010 - 0018 (June 3, 2011); Motion of American Airlines, Inc. for Dormancy Waiver, Docket DOT - OST - 2010 - 0018 (June 30, 2011). The failure of mainland - Haneda service has not been confined to one carrier, as both American’s service and Delta’s services have suffered setbacks in the form of no - op days, down - gauged aircraft and service suspensions. See HA - 2013A - 107. B. Hawaiian’s Haneda Service Outperformed All Other U.S. Gate ways. Hawaiian’s service from Honolulu to Haneda far out - performed other U.S. gateways. Hawaiian’s load factor of 84.7 percent for its Haneda service is the best of all U.S. flag carriers.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 9 of 49

HA - 2013 - 202 . The Honolulu - Haneda service has proven very pop ular, resulting in increased traffic from Tokyo and more increased traffic than any other gateway. See HA - 2013A - 203. Indeed, through April 2013, Hawaiian has carried more than 150,000 more passengers on its Honolulu route than the next - best performing U. S. gateway. See HA - 2013A - 201. By comparison, the U.S. flag mainland carriers have squandered their awarded frequencies, using them only 55% of the time
– compared to Hawaiian’s 100% utilization:DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 10 of 49

HA - 2013A - 208 . To the extent the Department considers co mmitment to Haneda service in its decision making, that factor tips heavily in favor of Hawaiian. C. Hawaiian Up - gauged the Aircraft I t Flies on the Haneda Route , and Proposes to Fly the Largest Aircraft in this Proceeding. As promised in its initial application, Hawaiian increased the size of the aircraft it uses to serve Haneda. After initiating service with 264 - seat aircraft , Hawaiian began to fly 294 - seat aircraft as these larger airplanes were acquired and introduced into its fleet. For its prop osed Kona service, Hawaiian also proposes to use its larger airplane, the largest proposed in this proceeding. In contrast, United has proposed to initiate service on its SFO - HND route with anDOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 11 of 49 aircraft that seats only 268, which is approximately 10% small er than Hawaiian’s proposal. See HA - 2013A - 111. Tellingly, United’s application states that it already has plans to down - gauge to smaller 219 - seat aircraft as they are incorporated into United’s fleet, in apparent recognition that the SFO - TYO market alre ady has too much capacity. See United Application at 3 n.4. Accounting for this proposed capacity reduction, Hawaiian has proposed to introduce 34 percent more long - term capacity than United. Hawaiian Will Provide 34% More Long - Term Haneda Capacity Tha n United

HA - 2013A - 112.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 12 of 49 D. Hawaiian Used I ts 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, i t 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 touri sts 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. Th e increased awareness resulting from Hawaiian’s marketing efforts among the Japanese public and tour operators has facilitated Hawaiian’s introduction of its own services to additional cities in Japan, including Osaka, Fukuoka, Sendai and Sapporo Chitose and free sale codeshare service with ANA to Hiroshima, Kago shima, Oita, Okinawa, Osaka - Itami and Sapporo - Chitose. E. Hawaiian’s Service Brought the Greatest Economic Benefit to the U.S. Hawaiian predicted in both prior proceedings in this docket that its proposed service would bring Japanese yen and therefor e econom ic 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 HA - 201 3 A - 608 . Unlike U.S. - originating services and United’s proposed SFO service, these additional visitors to Hawaii spent money and supported the economy of the United States and the State of Hawaii. Hawaiian’s Haneda flight accounted for $365.1 million in U.S. exports, more than twice the second - highest Haneda gateway, see HA - 2013A - 610; accounted for overDOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 13 of 49 $657 million in U.S. gross domestic product, more than 110 percent higher than the second highest Haneda gateway, see HA - 2013A - 6 11; and generated more than $195 million in U.S. household earnings, more than double the second highest Haneda gateway. See HA - 2013A - 612. This economic boost accounted for nearly 3,000 U.S. jobs, which is double the second highest Haneda gateway. See HA - 2013A - 609. The projected impact of the Kona service is comparable. See Section III.B , infra. II. The Overwhelming Size of the Market Between Hawaii and Japan Warrants Additional Service to Haneda. Although Hawaii is a small state geographically, it is by far the largest travel market between Japan and the United States. Quite simply, the Japanese visit Hawaii in droves. For m any years, Hawaii has been the preferred destination for Japanese visitors. See HA - 2013A 602. Demand is so high that more Japanese visit Hawaii than visit the rest of the U.S. combined.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 14 of 49

HA - 2013A - 603 . Moreover, Japanese continue to visit Hawaii in in creasing numbers
– 20 percent more Japanese tourists visited Hawaii in 2012 than in 2011. See HA - 2013A - 604. The same cannot be said of visitors to the rest of the U.S., as Hawaii attracted three times as many new Japanese visitors in 2012 as the rest of the United States combined:DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 15 of 49

HA - 2013A - 605. This gap promises to widen, as the rate of growth of Japanese visitors to Hawaii exceeded the rate of growth for the mainland U.S. See HA - 2013A - 606. No other state comes close to the popularity of Hawaii, as Hawaii attracted nearly three times as many visitors as the second most popular state, California. See HA - 2013A - 607. Even considering the passenger market overall, Hawaii is the la rgest U.S. - Japan market, s ee HA - 2013A - 301, and it is increasing. See HA - 2013A - 302. The size of the Japan - Hawaii market also is reflected in the size of the Tokyo - Hawaii market. The Tokyo - Hawaii O&D market is much larger than the next - largest state, Cal ifornia.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 1 6 of 49

HA - 2013A - 306. Even though California has been allocated the same number of Haneda frequencies as Hawaii, the Hawaii - Tokyo O&D market is nearly twice the size of California. See HA - 2013A - 303, 305. The Hawaii - Tokyo market is even larger rela tive to California than it was during the last Haneda proceeding. See HA - 2013A - 304 (90 percent larger this time compared to 63 percent larger last time). The widening chasm between the size of the Tokyo Hawaii and Tokyo - California markets is attributabl e to the fact that Hawaii - Tokyo traffic isDOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 17 of 49 growing at a much faster rate than Tokyo - mainland traffic. See HA - 2013A - 307 (17.8 percent for Hawaii compared to 8.6 percent for California). The size of the Hawaii - Japan market is again reflected in the performance of the U.S. - Haneda gateways. Hawaii is, by far, the largest Haneda gateway. See HA - 2013A - 308. Despite the fact that Hawaii has three Haneda frequencies, Hawaii has almost as many Haneda gateway passengers as the five mainland gateways combin ed. See HA - 2013A - 309. And the Hawaii Haneda O&D market with three frequencies is 13 percent larger than all other states combined with 5 frequencies:DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 18 of 49

HA - 2013A - 310. Indeed, the Hawaii - Haneda O&D market is nearly twice the second - largest U.S. state, Cal ifornia
– even though Hawaii and California have the same number of Haneda frequencies. See HA - 2013A - 311.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 19 of 49

HA - 2013A - 311. Honolulu, with three Haneda frequencies, generated significantly more (31 percent) Haneda O&D passengers than the other five U.S. - Ha neda gateways combined. See HA 2013A - 312. The size of the Hawaii - Japan market is evident in other metrics as well. The Hawaii Haneda market experiences a much higher load factor than does the comparable mainlandDOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 20 of 49 gateways. See HA - 2013A - 405, 412. Indeed, all three of the highest Haneda carrier load factors were from Hawaii. See HA - 2013A - 406. The inevitable conclusion is that Hawaii needs another Haneda gateway, while California does not. Indeed, the average number of passenge rs per designation is much higher than the service to the U.S. mainland, meaning that Hawaii is drastically underserved from Haneda compared to California.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 21 of 49 HA - 2013A - 401. And the Hawaii - Tokyo market in general is underserved compared to California, as Hawaii has a much higher number of weekly passengers per flight than does California. See HA - 2013A - 305. In contrast to the mainland Haneda gateways, the introduction of Haneda - Hawaii service stimulated growth in traffic rather than the diversion of traffi c from Narita. The introduction of Haneda service at Honolulu resulted in significant traffic growth; 353,422 more passengers flew to Honolulu in the year ended September 2013 than flew in calendar year 2009. See HA - 2013A 402. This performance blew away the other U.S. gateways, which saw little, if any, additional traffic growth.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 22 of 49 HA - 2013A - 403. The traffic growth in Honolulu was higher than the rest of the U.S. - Haneda gateways combined by approximately a factor of nearly four. See HA - 2013A - 403. Remar kably, traffic between SFO and Tokyo actually declined during this period, which does not bode well for United’s application. See HA - 2013A - 402. Instead, the traffic U.S. carriers flew to their U.S. - Haneda gateways was the result of diversion from carrier s’ operations at Narita. See HA 2013A - 413. The stimulation that will result from additional service to Hawaii, rather than the diversion of existing Narita traffic, is a primary reason for granting Hawaiian’s application. III. 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 sati sfy diverse public interest objectives and needs in selecting carrier proposals for award of the available rights.” In re 2010 U.S. - Haneda Combination Services Allocation Proceeding, Docket DOT - OST - 2010 - 0018, Order 2010 - 5 - 7 , at 8 (May 7, 2010) (citing 2007 /2008 U.S. - Colombia Combination Frequency Allocation Proceeding , Order 2008 - 5 - 27, issued May 21, 2008). With nearly three years of operating experience for U.S. carriers at Haneda, the Department has developed a sharper focus for this proceeding: Our principal objective in this proceeding will be to maximize public benefits. In this regard, we will consider which proposal will most likely result in service that best meets the needs of the traveling and shipping public. We will also consider the effec ts of the applicants’ service proposals on the overall competitiveDOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 23 of 49 environment, including effects on the market structure and on competition in the U.S. - Japan market. In addition, we will consider other factors historically used for carrier selection, whe re relevant. In re 2010 U.S. - Haneda Combination Services Allocation Proceeding, Docket DOT - OST - 2010 - 0018, Order 2013 - 11 - 9, at 2 (Nov. 14, 2013). The Department has focused its analysis on the market’s demand for Haneda service and the award’s impact on competition. Under this standard, only one proposal can be selected
— Hawaiian’s Kona application. As Hawaiian’s rigorous analysis of three years of operating data will demonstrate, Hawaiian’s proposal is the only one in this proceeding that is commerciall y viable. Market experience demonstrates that the amount of connecting service available has not been particularly important in the success o f a particular Haneda gateway. Instead , success has been highly correlated with local market demand . See HA - 20 13A - 103. As Exhibit HA - 2013A 10 2 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 81 percent and the highest share of Tokyo - originating passengers, while San Francisco has the lowest load factor and the lowe st point of sale in Tokyo , other than American’s abandoned JFK service . See HA 2013A - 102. 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, Ha neda. Moreover, local market demand is strong, as Kona is the largest local market without nonstop service proposed in this proceeding with 98 percent of the traffic originating locally. See HA 2013A - 105.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 24 of 49 Hawaiian ’s proposed service to Kona will satis fy the Department’s criteria and “maximize public benefits” for the following reasons: (1) Hawaiian’s application is the only one that will create a new, sustainable service ; (2) Hawaiian’s application will provide the greatest benefit to the economy of the U.S. and the state of Hawaii ; ( 3 ) The award to Hawaiian will fulfill the Department’s statutory mandate to strengthen a small competitor ; (4) Hawaiian’s expanded service will reduce concentration in the markets between Japan and the United States and increase competition with the alliances; and (5) The award to Hawaiian will avoid giving the effective benefit of the Haneda slots to the Japanese carriers. A. Hawaiian’s Proposed Kona Service Is the Best Use of the Sole Slot Pair Available in this Proceedin g. Kona is the most underserved gateway proposed in this proceeding. Hawaii represents the largest travel market for the Japanese visitors to the U.S. Despite the huge numbers of Japanese visiting Hawaii, Kona, the second - most popular destination after Honolulu, lacks nonstop service from Tokyo. In addition to being the only market in this proceeding without nonstop service, Kona is the second largest market for travel between the U.S. and Japan and the second largest Japan point of sale market without nonstop Tokyo service. See HA - 2013A - 501, 502, 503. Indeed, Kona is a larger market than thirteen markets with Tokyo nonstop service. See HA - 2013A - 504. Hawaiian sees Kona as an overlooked opportunity to put this underutilizedDOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 25 of 49 Haneda slot pair to its highest and best use rather than have it allocated to serve a market already awash in nonstop service to Tokyo
– with a stunning 40 roundtrips per week. See HA - 2013A 501. Kona in particular is a strong market
– the island of Hawaii is e asily the second - most visited destination by Japanese tourists in the state of Hawaii
– with significant existing traffic between it and Tokyo. See HA - 2013A - 505. Like Honolulu, the traffic is overwhelmingly Japanese originating. See HA - 2013A - 504. Nearl y 14 percent of Japanese tourists visit the Big Island of Hawaii. See HA - 2013A - 507. Moreover, the number of Japanese visitors to the Big Island is growing faster than the visitors to all the other Hawaiian Islands. See HA - 2013A - 506 . In fact, the Big Is land, which lacks nonstop service , already attracts more Japanese visitors than the Bay Area with 6 daily nonstops.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 26 of 49

HA - 2013A - 5 09. And with nonstop service, Hawaiian would expect this traffic to grow significantly as markets gaining nonstop service typ ically do. See HA - 2013A - 613. Hawaiian projects that the Kona service will bring in 267 percent more visitors than SFO. See id . But even before accounting for growth, Hawaiian estimates that the resulting traffic on the HND KOA route would amount to ove r 160,000 onboard passengers per year. See HA - 2013A - 510. This projected traffic would be comparable to Hawaiian’s successful Honolulu service, as depicted in the chart below:DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 27 of 49

HA - 2013A - 511. The anticipated Kona traffic would exceed the total of all exi sting mainland gateways that use a single Haneda - slot. See HA - 2013A - 512. Awarding this slot pair to Hawaiian for its Kona service will satisfy demand not presently being met in the market place. Given Hawaiian’s successful experience with Haneda, Haw aiian expects similar results for its proposed Kona service where Hawaiian anticipates that Kona will outperform all the current or previous mainland gateways to Haneda. See HA - 2013A - 513. Given the track record of other Haneda gateways and SFO in particu lar, the Department mustDOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 28 of 49 conclude that the award of an available slot pair to Hawaiian will result in the most public benefits. B. 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 - Haneda service will be Japanese originating, Hawaiian’s proposal will bring the greatest economic benefit to the United States and the S tate of Hawaii. Unlike United’s SFO proposal, Hawaiian’s Kona serv ice 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 fun ctional equivalent of increased U.S. exports . See HA - 2013A - 106. Unlike United, which will have a comparatively 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 . See HA - 2013A 105. 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, 39,798, or nearly four times United’s proposed gatewa y. See HA - 2013A - 613, 621.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 29 of 49

HA - 2013A - 613. Japanese visitors spend a significant amount of money during their trips, so Hawaiian’s Kona service will have a significant economic impact. See HA - 2013A - 601. Hawaiian projects that the proposed Kona servic e would result in $75.4 million additional dollars injected into the economy of Hawaii and the United States annually, nearly three times higher than the impact of the other proposed gateway. See HA - 2013A - 615.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 30 of 49

HA - 2013A - 615. Accounting for typical econo mic multipliers, this incremental spending will result in an additional $135.6 million in U.S. GDP growth, more than four times United’s proposed service. See HA - 2013A - 616. This GDP growth will support an additional 1,393 U.S. jobs, more than quadruple U nited’s proposal. See HA - 2013A - 614. Moreover, aggregate U.S.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 31 of 49 household earnings will increase by over $40.3 million annually, again more than quadruple the estimated benefit of United’s SFO proposal. See HA - 2013A - 617. 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.”). C. The Grant of Hawaiian’s Application Will Strengthen a Small Competitor. The grant of Hawaiian’s application to serve Kona also will strengthen a small competitor. The transportation code mandates that the Secretary’s public interest determinations consider “ the continued strengthening of small air carriers to ensure a more effective a nd competitive airline industry.” 49 U.S.C. § 40101(a)(13). This statutory obligation has been incorporated into the long - standing policy of the Department and its forerunner agency , the Civil Aeronautics Board. 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 compet ition and reduce market concentration. 1998 U.S. - Brazil Combination Service Case , Order 98 - 12 - 33, at 8 (Dec. 29, 1998) (finding its selection ofDOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 32 of 49 Continental would “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 marke t that has not seen the entry of any new U.S. competitor since the year 2000 .” ) T his principle strongly favors an award of the frequency to Hawaiian. By comparison, United is 15 times the size of Hawaiian. See HA - 2013A - 11 3. Also unlike United, Hawaiian is not affiliated with any major alliance. United and its immunized Star Alliance partner ANA overwhelm Hawaiian’s 7 weekly flights from Tokyo to the United States, flying 182 weekly round trips or 26 times more service from Tokyo than Hawaiian offers. See HA - 2013A - 701. 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 Haneda slot pair, Hawaiian not only operate d 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 en try 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 D epartment should recogniz e the wisdom in its prior decision and build upon that success by award ing a second H aneda slot pair to Hawaiian to serve Kona .DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 33 of 49 D. 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 priorit ies in this proceeding. The grants of antitrust immunity that created the alliance oligopoly were conditioned on the United States and Japan entering into the O pen S kies A greement that made the initial allocation of Haneda slots possible. U.S. - Japan Alliance Case , 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 o neworld alliances (of which, respectively, Delta, Unite d and American are members) control 9 8 percent of the U.S. - Tokyo frequencies , 98 percent of passengers and 92 percent of Tokyo - Honolulu frequencies . See HA - 2013A - 703, 705, 708. United’s Star Alliance and the oneworld alliance are nearly as dominant at Ha neda, where they control 77 percent of the departures. See HA - 2013A - 706, 707. Of the two alliances, the United’s Star Alliance partner ANA is by far the dominant with 49 percent of Haneda capacity. See HA - 2013A - 706. Since 2009, industry concentration in the U.S.
– Tokyo market has more than doubled as measured by the Herfindahl - Hirsch Index (HHI), including a 463 point increase (16 percent) just since the last Haneda case. 5 See HA - 2013A - 708, 709. Delta’s merger with N orthwest made it 5 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. D OJ & FTC , Horizontal Merger Guidelines § 5 (Aug . 19, 2010) .DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 34 of 49 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 HA - 2013A - 707. Consolidation resulting in t his level of concentration is presumed to enhance market power as to pricing and capacity . 6 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 s lot pair to any of the other applicants would simply strengthen the alliances ’ hold on the Japanese market, the grant of Hawaiian ’s application wou l d double its service to Tokyo. Although even Hawaii - Tokyo service would still be dominated by the alliances , see Exhibit HA - 2013A - 707 (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. Three years of operating ex perience since 2010 demonstrate that Hawaiian can, and will, take advantage of this opportunity. 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 four additional Japanese markets. Hawaiian also has expanded the breadth of its service in Japan by entering a procom petitive, yet not immunized, codeshare

6 U.S. D OJ & F TC , Horizontal Merger Guidelines § 5.3 (Aug. 19, 2010). Although the Antitrust Division typically assesses the competitive effects of concentration on a city - pair 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 2013 Answer of Hawaiian Airlines, Inc. Page 35 of 49 agreement with ANA, serving six destinations in Japan. 7 Moreover, Hawaiian’s willingness to compete with the alliance carriers between Tokyo and Honolulu has had procompetitive effects. Hawaiian’s service has result ed in significantly more traffic than the mainland routes to Tokyo from the United States . See HA - 2013A - 402. In fact, Honolulu generated approximately four times the passengers than all other gateways combined. See HA - 2013A - 403. Hawaiian , and not Unite d, can bring the benefits of increased competition to U.S. - Japanese market s. United proposes to introduce additional service on a market that it, together with ANA, already dominates with a 80 percent market share. 8 See HA - 2013A - 1 11. 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 H aneda . By any measure, Hawaiian is a much smaller carrier but with a track record of operating to Haneda that is worthy of an additional opportunity from the Department. E. Because Hawaiian I s Independent of the Major Alliances, the Grant of Hawaiian’s Application Will Benefit U.S. Flag Carriers Rather than Japanese Flag Car riers. 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. - 7 These destinations include: Hiroshima, Kagoshima, Oita, Okinawa, Osaka - Itami and Sapporo Chitose. 8 Because JAL took down its NRT - SFO service when it established HND - SFO , JAL was le ft with a single poor - performing daily service to the Bay Area. United’s proposed introduction of HND - SFO service thre atens to drive JAL from the market entirely, eliminating all competition between Tokyo and the Bay Area.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 36 of 49 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. 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 oneworl d 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 p air to United is the equivalent of returning it to the Japanese carriers ANA . 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 comprom ise 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 . The Star and oneworld alliances already hold five of the eight available slot pairs. The Department should take the o pportunity to restore the balance contemplated by the MOU, rather than handing these valuable rights right back to the alliance partner of ANA . Not only are the Japanese carriers able to exercise some degree of control over the slots allocated to their al liance partners, but any profits earned on the routes are necessarily split pursuant to their respective joint venture agreements. An award to United would perpetuate this concentration whereas an award to Hawaiian would be an important step towards prote cting U.S. operating rights.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 37 of 49 IV. Hawaiian’s Proposed Service to Kona I s Superior to United’s Proposal. Only Hawaiian’s proposed service to Kona will introduce nonstop service from Tokyo to a market that does not currently have it. In comparison, SFO ha s abundant service from both the oneworld and Star alliance . See HA - 2013A - 501. Hawaii and California both have Haneda service from three carriers (Japanese and U.S.) despite Hawaii having almost twice as many passengers. See HA - 2013A - 30 5, 310 .DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 38 of 49

HA - 2013A - 311. Accordingly, Hawaii should get a fourth designation before California gets another one, especia lly because Hawaii’s three Haneda designations have generated almost as many Haneda passengers as all five of the other Haneda designations combin ed. See HA 201 3A - 309 .DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 39 of 49 A. United’s Proposed SFO Service is a Recipe for More Failure. In proposing to serve SFO from Haneda, United is offering a recipe that repeatedly has proven to be commercially infeasible. United is a legacy carrier proposing to serve a mainland U.S. point it already serves from Narita, where the proposal depends on a significant volume of U.S. originating traffic rather than Japanese - originating traffic.

HA - 2013A - 104. This is the formula that Delta and American already have tried, but they have failed. In contrast, Hawaiian has proposed to serve a route without nonstop service from Tokyo with significant Japanese - originating traffic to a non - mainland point on a route Hawaiian does not serve from Narita. As will be demonstrated be low, Hawaiian’s proposal is distinct in this proceeding in that it is a commercially feasible proposal.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 40 of 49 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 Hi ghest Tokyo - U.S. Market Share. San Francisco is a poor candidate f or an award of the Haneda slot pair available in this proceeding. Like other markets with Haneda service, the Tokyo - San Francisco market already has abundant service. The alliance carriers currently offer 40 weekly roundtrips to San Francisco. See HA - 2013A - 501. United’s application acknowledges the overabundance of capacity in only committing to “ continue to operate at least one daily Tokyo Narita 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 HA - 2013A - 905. United and its Star Alliance partner ANA offer 21 of those weekly roundtrips and recent ly introduced 7 more weekly roundtrips to San Jose, which is well within the SFO catchment area. S ee HA - 2013A - 905. The market - based decisions of carriers currently serving the Bay Area from Tokyo demonstrate that the market cannot support additional capa city. See HA - 2013A - 114 . ANA has added service to SJC, rather than SFO. Id. Delta has announced that it will drop SFO NRT in March of 2014, after 20 years of nonstop service. Id. JAL shifted its SFO - NRT service to HND rather than add capacity at SFO an d down - gauged to a smaller aircraft. Id. United’s application strongly suggests that its new service, if approved, will shift SFO capacity from NRT to HND. See HA - 2013A - 114 . Indeed, in the year ended April 2013, the alliance carriers flew an astonishing 150,000 empty seats between Tokyo and San Francisco:DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 41 of 49

HA - 2013A - 912. Thus, United has requested the award of a frequency on a route where, after Delta’s withdrawal of its NRT - SFO service, it and its alliance partner already possess a dominant 80 percent m arket share of the weekly roundtrip flights between SFO and Tokyo and a 43 percent market share of weekly roundtrip flights between the United States and Tokyo. See HA - 2013A 11 1. 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 theDOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 42 of 49 dominant alliance in the market. Indeed, the award to United would completely undermine the public interest goal of “enhance[ing] competit ion 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 2013A - 409 . JAL’s SFO service has the lowest load factor of any Haneda gateway bes ides Delta’s failed Detroit service and American’s abandoned JFK service, s ee HA - 2013A - 412. In fact, given its poor performance, JAL down - gauged to its smallest transpacific aircraft type, which carries only 186 passengers, in September 2013. See HA - 2013 A - 410. And United has proposed a schedule that would merely duplicate the existing JAL service. See HA - 2013A - 907. In this struggling Bay Area - Tokyo market, United has made the nonsensical proposal to increase capacity 20 to 24 percent: 9

9 United does suggest it would reduce capacity to accommodate the Haneda flight.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 43 of 49

HA - 2013A - 911 . The Tokyo - San Francisco market is simply not large enough to accommodate United’s proposed service additions. Given the average United U.S. - Tokyo average load factor, this is not sufficient to sustain current service without significant price increases . Moreover, the commercial infeasibility of United’s HND - SFO service is further demonstrated by its proposal to use a 268 - seat aircraft, see United Application Exhibit UA - 113, which is 10 percent smaller than the 294 - seat aircraft proposed by Hawaiian. See HA - 2013A 111. It also proposes to down - gauge its service once a 219 - seat aircraft becomes widely available in its fleet, meaning that Hawaiian has proposed to introduce 34 percent more capacity into the Japan - U.S. market. See HA - 2013A - 112. While Uni ted’s candor in admitting that theDOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 44 of 49 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, not merely shift it. Taking into account these fa ctors, United’s proposal has the makings of a fiasco similar to Delta’s failure in Detroit. In 2010, United predicted that “San Francisco and Detroit would serve a comparable number of local plus connecting passengers.” Consolidated Answer of United Air Lines, Inc., Docket DOT - OST - 2010 - 0018, Exhibit UA - A - 17 (Mar. 1, 2010). Like Delta’s Detroit service, United’s 2013 proposal relies extensively on connecting traffic with very few local passengers.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 45 of 49 HA - 2013A - 906. Given United’s own prior analysis and the operational data, the Department should expect another service failure should it award the available Haneda slot pair to United. C. Any Purported Benefit of Connecting Traffic at SFO is a Myth and Does Not Justify Awarding the Slot Pair to United. Unit ed’s Answer, as did its Application, will undoubtedly tout the benefits of the connections available at its SFO hub. These benefits are illusory and will not withstand scrutiny. While it is undeniable that United has a network that connects to SFO, the d ata demonstrates that the connecting traffic is likely to be so minimal that it should not figure in the Department’s analysis. As an initial matter, United has proposed relatively few connections with minimal incremental benefit to the traveling public. United’s proposed service offers few noncircuitous round trips. See HA - 2013A - 908. These connections are of little benefit because Delta already offers Haneda connections from SEA and LAX to most of the interior U.S. points that United proposes to serve , see id. , resulting in few connections that are unique to United’s SFO application. See HA - 2013A - 909. More important than the small number of unique connections, the demand for service to those connecting points is so minimal as to be practically nonexi stent. See id. In the last year, only 7,313 passengers flew to all of those connecting cities. See HA 2013A - 909. This astonishingly low number is only 4 .6 percent of the capacity that United proposes to add to the already - saturated SFO - HND market on a l ong - term basis. See HA 2013A - 112. To put the number in perspective, Kona currently has nearly three times the amount of HND traffic than all of United’s proposed connections combined.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 46 of 49

HA - 2013A - 910 . Given the over - capacity in the SFO - HND market and the negligible traffic that will flow over those connecting markets, United’s proposal and its connecting service will not result in any meaningful public benefits. In contrast, Hawaiian’s Kona application depends on the strength of the local market. Three y ears of operational experience at Haneda demonstrate that the success depends on the size of the O&D market, and the carriers that have proposed gateways reliant on connecting traffic have failed. Unlike SFO with United’s proposed duplicative capacity add ition, the KonaDOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 47 of 49 market stands on its own as a viable local market with sufficient traffic and demand to result in a sustainable, thriving service. V. Hawaiian Has a Unique Incentive to Make I ts 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 carrie r s , which have huge commitments to that airport . United and ANA operate 45 segments from Narita, in cluding 21 weekly frequencies to San Francisco. See HA - 2013A - 901, 905. 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 Narit a hub . See HA - 2013A - 109. The conflicting incentives of Delta and American have plagued their respective Haneda services. See HA - 2013A - 413. In fact, the fear of diversion from existing Narita services has likely been a major contributor to the periodic s uspensions of all the mainline routes from the alliance carriers. With the substantial investment of United’s alliance partner ANA at Narita, United will be similarly conflicted. Because Hawaiian only operates at Haneda, it has a powerful incentive to p romote, 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.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 4 8 of 49 VI. Hawaiian Offers Superior C ustomer 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 United on a plethora of important customer service metrics. In t he year ending August 2013, Hawaiian again led its legacy airline competitors in on - time arrivals. See HA - 2013A - 801. Hawaiian has led this category for 9 years running. See HA - 2013A - 805. Hawaiian also bests United in the rate of mishandled bags, see HA - 2013A - 802, and has done so for the last 9 years. See HA - 2013A - 806. By a substantial margin, Hawaiian has a much lower rate of passengers denied boarding. See HA - 2013A - 803 (depicting United’s rate more than 4 times Hawaiian’s rate). Hawaiian’s superior service manifests itself in a primary indicator of customer satisfaction

– fewer customer complaints. In year - to - date 2013, Hawaiian’s customer complaint rate was much lower than United’s rate. See HA - 2013A - 804. Again, this represents the ninth year in a row that Hawaiian has outperformed United. See HA - 2013A - 807. Conclusion As set forth in this Answer, the public interest will be best served by the award of American’s currently abandoned Haneda slot pair to Hawaiian Airlines. Kona is the only mark et presented to the Department without nonstop service and the only gateway proposed in this proceeding that will result in a viable commercial service rather than a subsequent return or request to transfer the award.DOT - OST - 2010 - 0018 2013 Answer of Hawaiian Airlines, Inc. Page 49 of 49 Respectfully submitted,
Jonathan B. Hill J. Parker Erkmann Benjamin Berlin Dow Lohnes LLP 1200 New Hampshire Ave., NW Suite 800 Washington, DC 20036 (202) 776 - 2000 (202) 776 - 4725 (fax) jhill@dowlohnes.com perkmann@dowlohnes.com b berlin@dowlohnes.com Counsel for Hawaiian Airlines, Inc.C ERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Answer of Hawaiian Airlines, Inc. was served this 9 th day of Dec ember 201 3 via email transmission or U.S. mail on the following: megan.lawrence@alaskaair.com kyle.levine@alaskaair.com francis.heil@aa.com Robert.wirick@aa.com sascha.vanderbellen@delta.com chris.walker@delta.com dan.weiss@united.com Thomas.bolling@united.com steve.morrissey@united.com lhalloway@crowell.com gmurphy@crowell.com howard.kass@usairways.com benjamin.slocum@usairways.com marshall.s inick@squiresanders.com esta.rosenberg@dot.gov robert.finamore@dot.gov brett.kruger@dot.gov paul.gretch@dot.gov todd.homan@dot.gov john.s.duncan@faa.gov urskr@state.gov cristinasa@state.gov info@airlineinfo.com Ambassador Kenichiro Sasae Embassy of Japan 2520 Massachusetts Ave., NW Washington, DC 20008

_ /s/

__________________________ Benjamin Berlin

### ANSWER EXHIBITS OF HAWAIIAN AIRLINES

### TABLE OF CONTENTS Series 100 Summary Exhibits 200 Hawaiian Has Earned a Second Haneda Frequency 300 Hawaii is the Most Important U.S. – Japan Market 400 Hawaii Needs More Haneda Capacity – SFO Does Not 500 Kona is the Best Use of the U.S.’s 4 th Haneda Frequency 600 Economic Impact 700 Alliance Carriers Dominate the Tokyo Market 800 Hawaiian’s Record of Outstanding Performance 900 Answer to UA

### 100 SERIES: SUMMARY EXHIBITS

### 100 Series Exhibits Exhibit HA-2013A-100 Docket OST-2010-0018 Page 1 of 1

• Carrier Size and Dominance Has Been a P oor Predictor of Haneda Success (Exhibit 101) • High Tokyo Point-of-Sale is a Strong Pred ictor of U.S.-Haneda Success (Exhibit 102) • High Tokyo Point-of-Sale is a Strong Predictor of Sustained and Stable U.S.-Haneda Service (Exhibit 103) • United is Proposing Service Eerily Similar to Services That Have Failed at Other Mainland Gateways (Exhibit 104) • Kona Has a Tokyo Point of Origin That is Consistent With Success (Exhibit 105) • Japanese Originating Passengers Are Far More Valuable to the U.S. Economy Than U.S. Originating Passengers (Exhibit 106) • Mainland-Haneda Service Has Been a Recipe For Failure For U.S. Legacy Carriers (Exhibit 107) • Hawaiian Kept Its Haneda Route Case Commitments (Exhibit 108) • Haneda Service is Far More Important to Hawa iian Than it is to United/Star (Exhibit 109) • The Star Alliance Already Has Both the Larges t SFO – Tokyo Share and the Largest U.S. to Tokyo Share (Exhibit 110) • Hawaiian Will Operate the Larg est Aircraft (Exhibit 111) • Hawaiian Will Provide 34% More Long-Term Haneda Capacity Than United (Exhibit 112) • United is 15 Times as Large as Hawaiian (Exhibit 113) • Real World Route Decisions Demonstrate That SFO Cannot Support More Tokyo Capacity (Exhibit 114)

### CARRIER SIZE AND DOMINANCE HAS BEEN A POOR PREDICTOR OF HANEDA SUCCESS
Operated NRT Member of Alliance Heavy Big 3 Carrier Mainland U.S. Gateway Service from Proposed Gateway with Major Investment at NRT Reliance on Connecting Passengers Consistent Daily HND Service Haneda Gateway Passengers

Carried /1 HA - HNL NO NO NO NO NO YES 410,699 DL- LAX YES YES YES YES YES NO 257,264 AA- JFK YES YES YES YES YES NO 153,617 DL- DTW YES YES YES YES YES NO 87,864 DL - SEA YES YES YES YES YES NO /2 NA Exhibit HA-2013A-101 Docket OST-2010-0018 Page 1 of 1

1/ U.S. DOT, T-100 Data, November 2010-April 2013 2/ According to current schedule data, DL is operat ing less than daily service from September-February.

### HIGH TOKYO POINT-OF-SALE IS A STRONG PREDICTOR OF U.S.-HANEDA SUCCESS



### 75% 66% 70% 81%
65% 50% 55% 60% 65% 70% 75% 80% 85% 90% 95% 100%

50% 60% 70% 80% 90% 100% Cumulative Load Factor

1/ Point of Origin refers to the place where a passenger begins his or her trip. * Includes HND and NRT. Source: U.S. DOT, T-100 Data, November 2010-Apr il 2013 and MIDT data via Travelport, YE September 2013. 

### SFO JFK HNL

% Point of Origin Tokyo* 

### Correlation Between Point of Origin /1 

### Tokyo * 

### and Load Factor = 0.93 Exhibit HA-2013A-102 Docket OST-2010-0018 Page 1 of 1



### LAX
DTW

### HIGH TOKYO POINT-OF-SALE IS A STRONG PREDICTOR OF SUSTAINED AND STABLE U.S.-HANEDA SERVICE

84%

52%

30% 100%

30% 40% 50% 60% 70% 80% 90% 100%

30% 40% 50% 60% 70% 80% 90% 100% % of Authorized Flights Oper ated for U.S. Flag Carriers

1/ Point of Origin refers to the place where a passenger begins his or her trip. * Includes HND and NRT. Note: The period analyzed is from January 2011-April 2013. Source: U.S. DOT, T-100 Data, YE Apr. 2013 and MIDT data via Travelport, YE September 2013. 

### DL-DTW AA-JFK HA-HNL

% Point of Origin Tokyo* 

### Correlation Between Point of Origin /1 

### Tokyo * 

### and Authorized Flights Operated = 0.87 Exhibit HA-2013A-103 Docket OST-2010-0018 Page 1 of 1



### DL-LAX

### UNITED IS PROPOSING SERVICE EERILY SIMILAR TO SERVICES THAT HAVE FAILED AT OTHER MAINLAND GATEWAYS Operated NRT Service Member of Alliance with Original Proposal Dependent on Significant Volume Point of Origin Periodic Suspension Legacy Carrier Mainland U.S. Point from Proposed Gateway Major Investment at NRT of Connecting Passengers Japan Over 90% of 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 DL-SEA YES YES YES YES YES NO ? Proposal UA-SFO YES YES YES YES YES NO Exhibit HA-2013A-104 Docket OST-2010-0018 Page 1 of 1

### KONA HAS A TOKYO POINT OF ORIGIN THAT IS CONSISTENT WITH SUCCESS

98%
66% 67%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

KOA SFO Mainland U.S. Average % Point of Origin Tokyo* – YE September 2013

* Includes HND and NRT. Source: MIDT via Travelport. Exhibit HA-2013A-105 Docket OST-2010-0018 Page 1 of 1

### JAPANESE ORIGINATING PASSENGERS ARE FAR MORE VALUABLE TO THE U.S. ECONOMY TH AN U.S. ORIGINATING PASSENGERS

$1,171

$0 $0 $200 $400 $600 $800 $1,000 $1,200 $1,400

Japan Originating Passengers U.S. Originating Passengers Exhibit HA-2013A-106 Docket OST-2010-0018 Page 1 of 1



### Average Spending in U.S.

Sources: U.S. Department of Commerce Office of Tr avel and Tourism Industries, 2012 Market Profile: Japan.

### MAINLAND-HANEDA SERVICE HAS BEEN A RECIPE FOR FAILURE FOR U.S. LEGACY CARRIERS Mainland Gateways Awarded Exhibit HA-2013A-107 Docket OST-2010-0018 Page 1 of 1

Original Proposal Real World Results DTW
LAX
JFK
SEA Daily B747 Daily B747 Daily B777 Daily B767 • Service started 94 days late • Aircraft downgraded to smaller B777 in July 2011 • 475 noop days 2010-2012 • All service suspended in Sept. 2012
• Service started 94 days late • Aircraft downgraded to smaller B777 in June 2011 • Aircraft downgraded to smaller A330 in Nov. 2011 • Aircraft downgraded to sm aller B767 in April 2013 • 129 noop days since 2010
• Service started 93 days late • Suspended JFK-NRT service concurrently with HND start • 405 noop days January 2011 to April 2013 • All service suspended in Nov. 2013
• Proposed A330 aircraft in first Haneda case • Instituted service with smaller B767 • Service downgraded to less than daily Oct. 2013 to Feb. 2014

### HAWAIIAN KEPT ITS HANEDA ROUTE CASE COMMITMENTS Exhibit HA-2013A-108 Docket OST-2010-0018 Page 1 of 1



### • Hawaiian started HND service before any other U.S. flag carrier. (Exhibit A-207) • Hawaiian is the only U.S. flag carrier that has provided uninterrupted service to HND. (Exhibit A-207) • Hawaiian proposed A330 aircraft and Hawaiian operates A330 aircraft. • Hawaiian operated all of its awar ded frequencies. (Exhibit A-207) • Hawaiian transported 156,733 passenge rs in its first full year of service (Exhibit A-512) and 181,379 passengers in the latest reported T-100 data.143 112

26 0 0 20 40 60 80 100 120 140 160

Delta United American Hawaiian 699 478 322
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 November 4, 2013. By Carrier By Alliance 

### HANEDA SERVICE IS FAR MORE IMPORTANT TO HAWAIIAN THAN IT IS TO UNITED/STAR Exhibit HA-2013A-109 Docket OST-2010-0018 Page 1 of 180%

0% 20% 0% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90%

S t

a

r S k

y T

e

a

m / 1 o n e

w

o

r l d H a

w

a i i a

n 

### THE STAR ALLIANCE ALREADY HAS BOTH THE LARGEST SFO – TOKYO SHARE AND THE LARGEST U.S. TO TOKYO SHARE

43% 28% 27%
2% 0% 10% 20% 30% 40% 50%

S t

a

r S k

y T

e

a

m o n

e

w

o

r l d H a

w

a i i a

n Share of Weekly Roundtrip Flights Between SF Bay Area and Tokyo*

* Includes HND and NRT. 1/ Excludes DL’s recently cancelled NRT service. Source: Innovata schedule for the week of November 4, 2013. Share of Weekly Roundtrip Flights Between the U.S. and Tokyo* Exhibit HA-2013A-110 Docket OST-2010-0018 Page 1 of 1

### HAWAIIAN WILL OPERATE THE LARGEST AIRCRAFT

268 219 294

0 20 40 60 80 100 120 140 160 180 200 220 240 260 280 300 Proposed Aircraft Size



### Hawaiian (KOA) (A330) Exhibit HA-2013A-111 Docket OST-2010-0018 Page 1 of 1

Source: Applications. 

### United (SFO) Short-Term (B777) United (SFO) Long-Term (B787)159,870 214,620

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 WILL PROVIDE 34% MORE LONG-TERM HANEDA CAPACITY THAN UNITED Exhibit HA-2013A-112 Docket OST-2010-0018 Page 1 of 1

Source: Applications. 

### Hawaiian (A330) United Long-Term (B787) +34%318 4,703

0 1,000 2,000 3,000 4,000 5,000 6,000 System Available Seat Miles per Week (Millions)

Note: American includes US Airways. Source Innovata Schedule Data, week of November 4, 2013. 

### United Hawaiian UNITED IS 15 TIMES AS LARGE AS HAWAIIAN Exhibit HA-2013A-113 Docket OST-2010-0018 Page 1 of 1

Times as

Large as HA: 15x 

### American and Delta are 15 times and 13 times, respectively, as large as Ha waiian and were unable to sustain HND service at th eir awarded gateways

### REAL WORLD ROUTE DECISI ONS DEMONSTRATE THAT SFO CANNOT SUPPORT MORE TOKYO CAPACITY Exhibit HA-2013A-114 Docket OST-2010-0018 Page 1 of 1



### • ANA added flights at SJC rather than SFO • DL scheduled to drop all SFO- NRT flights in March 2014 after over 20 years of nonstop service • JAL simply shifted its SFO-NRT flight to HND rather than add SFO capacity. In September 2013 it switched to its smallest transpacific aircraft • UA’s application suggests it t oo will simply shift SFO capacity from NRT to HND

### 200 SERIES: HAWAIIAN HAS EARNED A SECOND HANEDA FREQUENCY

### 200 Series Exhibits HAWAIIAN HAS EARNED A SECOND HANEDA FREQUENCY Exhibit HA-2013A-200 Docket OST-2010-0018 Page 1 of 1

• Hawaiian Has Outperformed All Other U.S. Flag Haneda Carriers (Exhibit 201) • Hawaiian Has the Highest HND Load Factor of All U.S. Flag Carriers (Exhibit 202) • HNL-HND Had the Greatest Positive Impact on Tokyo Traffic (Exhibit 203) • Hawaiian Has Provided Consistent Competit ive HND Service to Japanese Flag Carriers (Exhibit 204) • Only Hawaiian Stood Up to Strong Japanese Competition (Exhibit 205) • Hawaiian Started Its Haneda Service Before Any Other U.S. Flag Carrier (Exhibit 206) • Hawaiian is the Only U.S. Flag Carrier Th at Has Provided Uninterrupted Service to HND (Exhibit 207) • Hawaiian Operated All of Its Awarded Frequencies While U.S. Flag Mainland Carriers Squandered 45% of Their Awarded U.S. – Haneda Frequencies (Exhibit 208)

### HAWAIIAN HAS OUTPERFORMED ALL OTHER U.S. FLAG HANEDA CARRIERS
410,699
257,264 153,617 87,864 0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000 450,000



### HNL LAX JFK DTW Cumulative Onboard HND Passengers- November 2010 – April 2013

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

### Carrier: HA DL AA DL Exhibit HA-2013A-201 Docket OST-2010-0018 Page 1 of 1

### HAWAIIAN HAS THE HIGHEST HANEDA LOAD FACTOR OF ALL U.S. FLAG HANEDA CARRIERS
84.7% 69.3% 77.1% 72.0%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90%



### HNL JFK LAX DTW Load Factor – 12 Months Ended April 2013

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

### Carrier: HA AA DL DL Exhibit HA-2013A-202 Docket OST-2010-0018 Page 1 of 1

### HNL-HND HAD THE GREATEST POSITIVE IMPACT ON TOKYO TRAFFIC
365,087 321,552

109,546 6,061 -77,620 -100,000

-50,000 0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000

HNL LAX JFK SFO DTW Change in Tokyo* Onboard Passengers 2009 /1 -YE April 2013

1/ CY 2009 was the base year from the first HND case. * Tokyo includes NRT and HND. Source: U.S. DOT, T-100 Data. Exhibit HA-2013A-203 Docket OST-2010-0018 Page 1 of 1

### HAWAIIAN HAS PROVIDED CONSISTENT COMPETITIVE HND SERVICE TO JAPANESE FLAG CARRIERS

Source: Innovata Schedule data. Period with Service Exhibit HA-2013A-204 Docket OST-2010-0018 Page 1 of 1

HA
NH (HNL)
JL (HNL) Nov ’10 May ‘11 Nov ‘11 May ‘12 Nov ‘12 May ’13 Nov ’13 May ‘14

### ONLY HAWAIIAN STOOD UP TO STRONG JAPANESE COMPETITION

1,785 1,821 1,762 1,791 1,789 1,429
892 512
0 200 400 600 800 1,000 1,200 1,400 1,600 1,800 2,000

HA-HNL JL-SFO JL-HNL NH-LAX NH-HNL DL-LAX AA-JFK DL-DTW U.S.-HND Flights – Cumul ative November 2010-April 2013

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

### U.S. Flag Japan Flag Exhibit HA-2013A-205 Docket OST-2010-0018 Page 1 of 1

### HAWAIIAN STARTED ITS HANEDA SERVICE BEFORE ANY OTHER U.S. FLAG CARRIER Carrier - Gateway Hawaiian- HNL Delta- DTW Delta-LAX American-JFK Delta-SEA November 2010 February 2011 February 2011 February 2011 June 2013

Source: Innovata Schedule data. 

### Start Month Exhibit HA-2013A-206 Docket OST-2010-0018 Page 1 of 1

### HAWAIIAN IS THE ONLY U.S. FLAG CARRIER THAT HAS PROVIDED UNINTERRUPTED SERVICE TO HND

Source: Innovata Schedule data. Period of Service Exhibit HA-2013A-207 Docket OST-2010-0018 Page 1 of 1

HA DL (LAX) DL (DTW) DL (SEA) AA (JFK) Nov ’10 May ‘11 Nov ‘11 May ‘12 Nov ‘12 May ’13 Nov ’13 May ‘14Hawaiian

Source: U. S. DOT T-100 data, January 2011-April 2013. Exhibit HA-2013A-208 Docket OST-2010-0018 Page 1 of 1

Available Frequencies Used 55% Available Frequencies

Not Used 45% U.S. Flag Mainland Carriers

Available Frequencies Used 100% 

### HAWAIIAN OPERATED ALL OF ITS AWARDED FREQUENCIES WHILE U.S. FLAG MAINLAND CARRIERS SQUANDERED 45% OF THEIR AWARDED U.S. – HANEDA FREQUENCIES

### 300 SERIES: HAWAII IS THE MOST IMPORTANT U.S. – JAPAN MARKET

### 300 Series Exhibits HAWAII IS THE MOST IMPORTANT U.S. – JAPAN MARKET Exhibit HA-2013A-300 Docket OST-2010-0018 Page 1 of 1

• Hawaii is the Largest U.S. - Japan Passenger Market (Exhibit 301) • Hawaii – Japan Passengers Increased a Whopping 19% in 2012 (Exhibit 302) • The Hawaii-Tokyo O&D Market is 90% Larger Than California (Exhibit 303) • Hawaii is Even Larger Relative to Califor nia than it Was in the Last Haneda Case (Exhibit 304) • The Hawaii-Tokyo O&D Market is Nearly Twi ce the Size of California With the Same Number of Haneda Designations (Exhibit 305) • The Hawaii-Tokyo O&D Market is Much Larg er than the Second Largest U.S. State (Exhibit 306) • The Hawaii – Tokyo Market is Growing Fa ster Than the Mainland-Tokyo Market (Exhibit 307) • Hawaii is the Largest U.S. - Haneda Gateway (Exhibit 308) • Hawaii With Three Designations Has Almost as Many Haneda Gateway Passengers as the Five Mainland Gateways Combined (Exhibit 309) • The Hawaii-Haneda O&D Market is 13% Larg er Than All Other States Combined (Exhibit 310) • The Hawaii-Haneda O&D Market is Over Twi ce the Size of California With the Same Number of Haneda Designations (Exhibit 311) • Honolulu Generated 31% More Haneda O&D Passengers With Three Gateways Than the Other Five U.S. - Haneda G ateways Combined (Exhibit 312)

### HAWAII IS THE LARGEST U.S.-JAPAN PASSENGER MARKET
2,991,157 2,443,142

776,336 629,329 511,143 483,060 236,417 288,593 472,460 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 2,200,000 2,400,000 2,600,000 2,800,000 3,000,000

HI CA NY Il MI TX WA VA GA Exhibit HA-2013A-301 Docket OST-2010-0018 Page 1 of 1



### Passengers Gateway Passengers

Source: U.S. DOT, T-100 Data, YE April 2013.

### HAWAII-JAPAN PASSENGERS INCREASED A WHOPPING 19% IN 2012

2,465,668 2,934,343

0 500,000 1,000,000 1,500,000 2,000,000 2,500,000 3,000,000 3,500,000

2011 2012 Exhibit HA-2013A-302 Docket OST-2010-0018 Page 1 of 1



### Onboard Passengers

+19%

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

### THE HAWAII-TOKYO O&D MARKET IS 90% LARGER THAN CALIFORNIA

779,736 1,481,928

0 200,000 400,000 600,000 800,000 1,000,000 1,200,000 1,400,000 1,600,000 YE September 2013 Tokyo* MIDT Passengers



### Hawaii California +90% Exhibit HA-2013A-303 Docket OST-2010-0018 Page 1 of 1

* Includes HND and NRT. Note: MIDT sample has not been expa nded to acc ount for direct bookings and does not reflect total market size. Source: MIDT, via Travelport.

### HAWAII IS EVEN LARGER RELATIVE TO CALIFORNIA THAN IT WAS IN THE LAST HANEDA CASE

90%
63%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Last Time This Time % Hawaii O&D Larger Than California Exhibit HA-2013A-304 Docket OST-2010-0018 Page 1 of 1

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

### THE HAWAII-TOKYO O&D MARKET IS NEARLY TWICE THE SIZE OF CALIFORNIA WITH THE SAME NUMBER OF HANEDA DESIGNATIONS

779,736 1,481,928

0 200,000 400,000 600,000 800,000 1,000,000 1,200,000 1,400,000 1,600,000

Hawaii California YE September 2013 Tokyo* MIDT Passengers

HND Designations: 

### 3 3 Ave. Passengers per Designation: 493,976 259,912 Exhibit HA-2013A-305 Docket OST-2010-0018 Page 1 of 1

* Includes HND and NRT. Note: MIDT sample has not been expanded to account for direct bookings and reflects relative but not total market size. Source: MIDT, via Travelport.

### THE HAWAII-TOKYO O&D MARKET IS MUCH LARGER THAN THE SECOND LARGEST U.S. STATE

779,736 357,440 103,124 102,277 90,640 1,481,928

89,186 84,561 0 200,000 400,000 600,000 800,000 1,000,000 1,200,000 1,400,000 1,600,000

Ha wa

ii C alifor n ia Ne w Yo rk

Wash in

gton Ne v ada Illinois T exas Fl or

ida YE September 2013 Tokyo* MIDT Passengers Exhibit HA-2013A-306 Docket OST-2010-0018 Page 1 of 1

Hawaii Has Almost Twice the Tokyo Passengers as California with the Same Number of HND Designations

Current HND Designations: 3 3 1 1 * Includes HND and NRT. Note: MIDT sample has not been expanded to account for direct bookings and reflects relative but not total market size. Source: MIDT, via Travelport.

### THE HAWAII – TOKYO MARKET IS GROWING FASTER THAN THE MAINLAND-TOKYO MARKET

17.8%

8.6%

0% 2% 4% 6% 8% 10% 12% 14% 16% 18% 20%

Hawaii - Tokyo* Mainland - Tokyo* % Onboard Passenger Change CY 2009- YE April 2013

* Includes HND and NRT. Note: Hawaii includes service from all Hawaiian Islands. Source: U.S. DOT, T-100 Data. Exhibit HA-2013A-307 Docket OST-2010-0018 Page 1 of 1

### HAWAII IS THE LARGEST U.S. - HANEDA GATEWAY
501,544

265,198 128,559 111,087 51,087 0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000 450,000 500,000 550,000

HNL LAX SFO JFK DTW HND Onboard Passengers – 12 Months Ended April 2013

Source: U.S. DOT, T-100 Data. Exhibit HA-2013A-308 Docket OST-2010-0018 Page 1 of 1

### HAWAII WITH THREE DESIGNATIONS HAS ALMOST AS MANY HANEDA GATEWAY PASSENGERS AS THE FIVE MAINLAND GATEWAYS COMBINED

501,544

0 100,000 200,000 300,000 400,000 500,000 600,000

HNL ALL Mainland Gateways 

### DTW JFK

LAX 555,951



### SFO HND Onboard Passengers – 12 Months Ended April 2013

Source: U.S. DOT, T-100 Data. Exhibit HA-2013A-309 Docket OST-2010-0018 Page 1 of 1



### Designations: 3 5

### THE HAWAII-HANEDA O&D MARKET IS 13% LARGER THAN ALL OTHER_STATES COMBINED

193,159 74,415 25,257 12,504 40,959 392,527

0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000 450,000

Hawaii YE September 2013 HND MIDT Passengers Exhibit HA-2013A-310 Docket OST-2010-0018 Page 1 of 1

Note: MIDT sample has not been ex panded to acc ount for direct bookings. Numbers reflect relative but not total market size. Source: MIDT, via Travelport. Current HND Designations: 3 5 California New York Nevada Washington Other 346,294193,159 392,527

0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000 450,000

Hawaii California YE September 2013 HND MIDT Passengers

Current HND Designations: 

### 3 3 THE HAWAII-HANEDA O&D MARKET IS OVER TWICE THE SIZE OF CALIFORNIA WITH THE SAME NUMBER OF HANEDA DESIGNATIONS Exhibit HA-2013A-311 Docket OST-2010-0018 Page 1 of 1

Note: MIDT sample has not been ex panded to acc ount for direct bookings. Numbers reflect relative but not total market size. Source: MIDT, via Travelport.

### HONOLULU GENERATED 31% MORE HANEDA O&D PASSENGERS WITH THREE GATEWAYS THAN THE OTHER FIVE U.S. - HANEDA GATEWAYS COMBINED
361,373

0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000

HNL ALL Other Gateways 

### DTW JFK
LAX 275,273


### SFO MIDT Local Passengers – 12 Months Ended September 2013 Exhibit HA-2013A-312 Docket OST-2010-0018 Page 1 of 1

Note: MIDT sample has not been ex panded to acc ount for direct bookings. Numbers reflect relative but not total market size. Source: MIDT, via Travelport. 

### SEA +31%

### 400 SERIES: HAWAII NEEDS MORE HANEDA CAPACITY – SFO DOES NOT

### 400 Series Exhibits HAWAII NEEDS MORE HANEDA CAPACITY – SFO DOES NOT Exhibit HA-2013A-400 Docket OST-2010-0018 Page 1 of 1

• The Hawaii – Haneda Market Has a Far Greater Need for Additional Service Than the California – Haneda Market (Exhibit 401) • HNL-HND Service Generated 353,422 New Tokyo O&D Passengers (Exhibit 402) • HNL-HND Service Has Generated More Ne w Tokyo O&D Passengers Than All the Other U.S. - HND Gateways Combined (Exhibit 403) • Hawaii Had the Highest Tokyo Point of Orig in Percentage of All Haneda Gateways (Exhibit 404) • The Hawaii – Haneda Market Utilized Its Capa city More Efficiently Than Mainland – Haneda Markets (Exhibit 405) • The Three Highest Haneda Carrier Load Fa ctor Segments Were All From Hawaii (Exhibit 406) • Many Hawaiian HNL-HND Flights Op erated at Capacity (Exhibit 407) • JAL Experiences Its Lowest U.S.-Tok yo Load Factor at SFO (Exhibit 408) • SFO-HND Operated With Nearly 50,000 Empty Seats (Exhibit 409) • In September 2013 JAL Began Using Its Smalle st Transpacific Aircraft For the Small HND-SFO Market (Exhibit 410) • JAL, the Incumbent SFO-HND Carrier, Had to Cancel SFO-NRT in Order to Support Its SFO-HND Flight (Exhibit 411) • Only the Failed DTW and JFK Routes Had Lower Haneda Load Factors Than SFO (Exhibit 412) • All Three U.S.-HND Mainland Gateway Carriers Experienced Significant Diversion Fr om Their NRT Flights (Exhibit 413)193,159 151,956 392,527

0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000 450,000

Hawaii California U.S. Mainland YE September 2013 Haneda MIDT Passengers

HND Designations: 

### 3 3 2 Ave. Passengers per Designation: 130,842 64,386 75,978 Exhibit HA-2013A-401 Docket OST-2010-0018 Page 1 of 1


### THE HAWAII – HANEDA MARKET HAS A FAR GREATER NEED FOR ADDITIONAL SERVICE THAN THE CALIFORNIA– HANEDA MARKET

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

### HNL-HND SERVICE GENERATED 353,422 NEW TOKYO O&D PASSENGERS
353,422

61,860 21,477 15,032 3,562 -8,682 -50,000 0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000

HNL JFK LAX SEA DTW SFO Change in Tokyo MIDT Passengers CY 2009 /1 -YE September 2013 Exhibit HA-2013A-402 Docket OST-2010-0018 Page 1 of 1

Note: MIDT sample has not been expa nded to acc ount for direct bookings and does not reflect total market size. 1/ CY 2009 was the base year from the first HND case. Source: MIDT, via Travelport.353,422

0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000

HNL ALL Other Gateways 93,249 Exhibit HA-2013A-403 Docket OST-2010-0018 Page 1 of 1


### HNL-HND SERVICE HAS GENERATED MORE NEW TOKYO O&D PASSENGERS THAN ALL THE OTHER U.S. - HND GATEWAYS COMBINED Change in Tokyo MIDT Passengers CY 2009 /1 -YE September 2013

Note: MIDT sample has not been expa nded to acc ount for direct bookings and does not reflect total market size. 1/ CY 2009 was the base year from the first HND case. Source: MIDT, via Travelport.

### HAWAII HAD THE HIGHEST TOKYO POINT OF ORIGIN PERCENTAGE OF ALL HANEDA GATEWAYS

96% 74% 71% 66% 63% 54%

0% 20% 40% 60% 80% 100% 120%

HNL JFK LAX SFO SEA DTW % Point of Origin Tokyo* Passengers – YE September 2013

* Includes HND and NRT. Source: MIDT via Travelport. Exhibit HA-2013A-404 Docket OST-2010-0018 Page 1 of 1

### THE HAWAII – HANEDA MARKET UTILIZED ITS CAPACITY MORE EFFICIENTLY THAN MAINLAND – HANEDA MARKETS
85% 75% 72%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90%

HNL Mainland SFO HND Load Factor– 12 Months Ended April 2013

Source: U.S. DOT, T-100 Data. Exhibit HA-2013A-405 Docket OST-2010-0018 Page 1 of 1

### THE THREE HIGHEST HANEDA CARRIER LOAD FACTOR SEGMENTS WERE ALL FROM HAWAII

87.0% 84.7% 83.4% 81.7% 77.1% 72.1% 69.3% 72.0%

50% 55% 60% 65% 70% 75% 80% 85% 90%

HNL-NH HNL-HA HNL-JL LAX-NH LAX-DL SFO-JL DTW-DL JFK-AA Load Factor – 12 Months Ended April 2013

Source: U.S. DOT, T-100 Data. Exhibit HA-2013A-406 Docket OST-2010-0018 Page 1 of 1

0%69 100 125 169 198

39 0 50 100 150 200 250 Flights: November 1, 2012 – October 31, 2013

Load Factor: 

### 100%  99%  98%  97%  96%  95% Exhibit HA-2013A-407 Docket OST-2010-0018 Page 1 of 1


### MANY HAWAIIAN HNL-HND FLIGHTS OPERATED AT CAPACITY

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

### JAL EXPERIENCES ITS LOWEST U.S .-TOKYO LOAD FACTOR AT SFO 

### 85% 83% 83% 82% 82% 81% 74% 72% 80% 81%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90%

HNLNRT HNLHND LAXNRT GUMNRT HNLNGO HNLKIX ORDNRT JFKNRT BOSNRT SFOHND JL Load Factor – 12 Months Ended April 2013

Source: U.S. DOT, T-100 Data. Exhibit HA-2013A-408 Docket OST-2010-0018 Page 1 of 1

### SFO-HND OPERATED WITH NEARLY 50,000 EMPTY SEATS

128,559

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 April

Source: U.S. DOT, T-100 Data. 178,373 

### 49,814 Empty Seats

SFO-HND Averaged 68 Empty Seats per Flight Exhibit HA-2013A-409 Docket OST-2010-0018 Page 1 of 1245 245 245 245 245 186 245 245 186 245 186 186

0 50 100 150 200 250 300

Ja nu

ary

February M a rch April M a

y Jun e J ul

y

A

ugust

S

ep

te

mb e

r

Oc t ober

N

o

ve

mb er December JAL Average Seats per Aircraft SFO-HND Exhibit HA-2013A-410 Docket OST-2010-0018 Page 1 of 1


### IN SEPTEMBER 2013 JAL BEGAN USING ITS SMALLEST TRANSPACIFIC AIRCRAFT FOR THE SMALL HND-SFO MARKET B777 B787

Source: U.S. DOT, T-100 Data and Innovata Schedule data. 2013

### JAL, THE INCUMBENT SFO-HND CARRIER, HAD TO CANCEL SFO-NRT IN ORDER TO SUPPORT ITS SFO-HND FLIGHT
175,610

0 0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000 180,000 200,000

YE October 2010 Latest 12 Months Exhibit HA-2013A-411 Docket OST-2010-0018 Page 1 of 1

Source: U.S. DOT, T-100 Data. JL SFO-NRT Onboard Passengers

### ONLY THE FAILED DTW AND JFK ROUTES HAD LOWER HANEDA LOAD FACTORS THAN SFO Load Factor – 12 Months Ended April 2013

Source: U.S. DOT, T-100 Data. Exhibit HA-2013A-412 Docket OST-2010-0018 Page 1 of 1

87% 85% 83% 82% 77% 72% 69% 72%

50% 55% 60% 65% 70% 75% 80% 85% 90%

HNLN H HNLH A HNL-JL LAXN H LAX-DL SFO-JL DTWD L JFKA A-130,819 -121,241 -53,972

-140,000 -120,000 -100,000

-80,000 -60,000 -40,000 -20,000 0 DL-DTW AA-JFK DL-LAX Change in NRT Onboard Passengers – 12 Months Ended April 2013/1 Compared to 12 Months Before HND Service Began

1/ For DTW the end period is year ended September 2012 (the last period with DTW-HND nonstop). Source: U.S. DOT, T-100 Data. Exhibit HA-2013A-413 Docket OST-2010-0018 Page 1 of 1


### ALL THREE U.S.-HND MAINLAND GATEWAY CARRIERS EXPERIENCED SIGNIFICANT DIVERSION FROM THEIR NRT FLIGHTS

### 500 SERIES: KONA IS THE BEST USE OF THE U.S.’s 4 TH 

### HANEDA FREQUENCY

### 500 Series Exhibits KONA IS THE BEST USE OF THE U.S.’s 4 TH 

### HANEDA FREQUENCY Exhibit HA-2013A-500 Docket OST-2010-0018 Page 1 of 1

• Kona is the Only New Tokyo Gateway Pr oposed in This Proceeding (Exhibit 501) • Kona is the Second Largest U.S. Market Wi thout Nonstop Service to Tokyo (Exhibit 502) • Kona is the Second Largest Po int of Sale Japan Market Without Nonstop Service to Tokyo (Exhibit 503) • Despite Not Having Nonstop Service to To kyo, Kona Has More Point of Sale Japan Passengers Than Thirteen Markets With Tokyo Nonstop Service (Exhibit 504) • Kona, Like the Very Successful Honolulu Serv ice, Has a Very High Percentage of Point of Sale Japan Passengers (Exhibit 505) • The Big Island is the 2 nd Most Visited Island in Hawaii for Japanese (Exhibit 506) • The Big Island is Hawaii’s Fastest Growing Island for Japanese Visitors (Exhibit 507) • 14% of Japanese Visitors to Hawaii Visi ted Kona and the Big Island (Exhibit 508) • The Big Island Without Nonstop Service, Already Has More Japanese Visitors Than the Bay Area With 6 Daily Nonstops (Exhibit 509) • Kona Will Generate Over 160,000 Onboard Passengers (Exhibit 510) • Kona Can be Expected to Produce Sim ilar Onboard Passenger Numbers to HA’s Successful HNL-HND Service (Exhibit 511) • Kona Will Outperform Current/Previous Si ngle-Slot Mainland Gateways to Haneda (Exhibit 512) • Kona Will Outperform All Current/Previous Mainland Gateways to Haneda (Exhibit 513)

### KONA IS THE ONLY NEW TOKYO GATEWAY PROPOSED IN THIS PROCEEDING

SFO Bay Area
KOA TYO Exhibit HA-2013A-501 Docket OST-2010-0018 Page 1 of 1

40

0 0 5 10 15 20 25 30 35 40 45

SFO Bay Area KOA Current Roundtrips per Week

Source: Innovata schedule for the week of November 4, 2013.

### KONA IS THE SECOND LARGEST U.S. MARKET WITHOUT NONSTOP SERVICE TO TOKYO

100,647
58,847 47,567 18,621 15,519 0 20,000 40,000 60,000 80,000 100,000 120,000

LAS KOA MCO MIA OGG YE September 2013 Tokyo* MIDT

* Includes HND and NRT. Note: MIDT sample has not been expa nded to acc ount for direct bookings and does not reflect total market size. Source: MIDT, via Travelport. Exhibit HA-2013A-502 Docket OST-2010-0018 Page 1 of 1

### KONA IS THE SECOND LARGEST POINT OF SALE JAPAN MARKET WITHOUT NONSTOP SERVICE TO TOKYO

95,312
57,415 42,357 14,472 14,167 0 20,000 40,000 60,000 80,000 100,000 120,000

LAS KOA MCO MIA OGG YE September 2013 Tokyo* MIDT Point of Sale Japan

* Includes HND and NRT. Note: MIDT sample has not been expa nded to acc ount for direct bookings and does not reflect total market size. Source: MIDT, via Travelport. Exhibit HA-2013A-503 Docket OST-2010-0018 Page 1 of 1

### DESPITE NOT HAVING NONSTOP SERVICE TO TOKYO, KONA HAS MORE POINT OF SALE JAPAN PASSENGERS THAN THIRTEEN MARKETS WITH TOKYO NONSTOP SERVICE54,05748,46735,37127,40710,0928,89957,41526,40511,02820,54519,99121,08816,49822,530

0 10,000 20,000 30,000 40,000 50,000 60,000 70,000

KOA ORD BOS IAD SAN PDX IAH ATL EWRDTWDFW DEN MSP SJC YE September 2013 Tokyo* MIDT Point of Sale Japan

* Includes HND and NRT. Note: MIDT sample has not been expa nded to acc ount for direct bookings and does not reflect total market size. Source: MIDT, via Travelport. Exhibit HA-2013A-504 Docket OST-2010-0018 Page 1 of 1

### KONA, LIKE THE VERY SUCCESSFUL HONOLULU SERVICE, HAS A VERY HIGH PERCENTAGE OF POINT OF SALE JAPAN PASSENGERS % Point of Sale Japan of Tokyo* MIDT Passengers – YE September 2013

* Includes HND and NRT. Source: MIDT via Travelport. 

### 98% 96% 74% 71% 66% 63% 54%

0% 20% 40% 60% 80% 100% 120%

KOA HNL JFK LAX SFO SEA DTW Exhibit HA-2013A-505 Docket OST-2010-0018 Page 1 of 1

### THE BIG ISLAND IS THE 2 nd 

### MOST VISITED ISLAND IN HAWAII FOR JAPANESE

203,009

69,719 27,907 1,409,721

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 Ha waii Island where Kona is located. Source: State of Hawaii Department of Business, Economic Development, and Tourism, 2012 A nnual Visitor Research Report. 203,009 visitors is equivalent to 406,018 O&D passengers or 556 passengers per day each way. /1 Year Over Year Growth: 18% 23% 10% 18% Exhibit HA-2013A-506 Docket OST-2010-0018 Page 1 of 1

### THE BIG ISLAND IS HAWAII’S FASTEST GROWING ISLAND FOR JAPANESE VISITORS

23% 18% 18%
10%

0% 5% 10% 15% 20% 25%

Big Island O'ahu Kaua'i Maui County % Change in Japanese Visitors 2011-2012

1/ The Big Island refers to Ha waii Island where Kona is located. Source: State of Hawaii Department of Business, Economic Development, and Tourism, 2012 A nnual Visitor Research Report. Exhibit HA-2013A-507 Docket OST-2010-0018 Page 1 of 1

/1Big Island 13.9%

Other Hawaii 86.1% 

### 14% OF JAPANESE VISITORS TO HAWAII VISITED KONA AND THE BIG ISLAND

Distribution of Japanese Visitors to Hawaii



### Total 2011 Japanese Visitors: 1,465,654 Total 2011 Hawaii-Japan Onboard Passengers: 2,934,343 Source: State of Hawaii Department of Business, Economic Development, and Tourism, 2012 A nnual Visitor Research Report. Exhibit HA-2013A-508 Docket OST-2010-0018 Page 1 of 1203,009 144,222

0 50,000 100,000 150,000 200,000 250,000

Big Island Bay Area Japanese Visitors Exhibit HA-2013A-509 Docket OST-2010-0018 Page 1 of 1 

### THE BIG ISLAND WITHOUT NONSTOP SERVICE, ALREADY HAS MORE JAPANESE VISITORS THAN THE B AY AREA WITH 6 DAILY NONSTOPS

Daily Nonstop: 0 6 Source: State of Hawaii Department of Business, Economic Development, and Tourism, 2012 A nnual Visitor Research Report. U.S. Department of Commerce Office of Travel and Tourism Industries, 2012 Market Profile: Japan.

### KONA WILL GENERATE OVER 160,000 ONBOARD PASSENGERS

YE Apr. 2013 HNL-TYO* Onboard Passengers Ratio of KOA-TYO* to HNL-TYO* When KOA Had Nonstop Service /1 HA HND-KOA Onboard Passengers Before Growth

* Includes HND and NRT. 1/ KOA share calculated using CY 2009 data (the last full calendar year with daily nonstop service) from NRT-KOA when JAL oper ated nonstop service. 2/ 160,664 is equivalent to 40% share of Japan- Big Island Visitors. Source: U.S. DOT, T-100 Data and MIDT. 2,008,298 8% 160,664 Exhibit HA-2013A-510 Docket OST-2010-0018 Page 1 of 1

/2Source: U.S. DOT, T-100 Data, YE November 2011and Ex hibit HA -2012A-204. 160,664 156,733

0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000 180,000

KOA HNL Tokyo* Haneda to Hawaii 1 st Year Onboard Passengers 103% Exhibit HA-2013A-511 Docket OST-2010-0018 Page 1 of 1


### KONA CAN BE EXPECTED TO PRODUCE SIMILAR ONBOARD PASSENGER NUMBERS TO HA’S SUCCESSFUL HNL-HND SERVICE

(Exhibit 512) HA Actual for 1 st Year of Service160,664 128,559 111,087
51,087

0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000 180,000

KOA Proposed SFO - Actual JFK - Actual DTW - Actual HND Onboard Passengers – 12 Months Ended April 2013 and Proposed for KOA

Source: U.S. DOT, T-100 Da ta and Exhibi t HA-2012A-204. Exhibit HA-2013A-512 Docket OST-2010-0018 Page 1 of 1


### KONA WILL OUTPERFORM CURRENT/PREVIOUS SINGLE-SLOT MAINLAND GATEWAYS TO HANEDA

(Exhibit 512)160,664 134,878 130,320 128,559 111,087
51,087
0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000 180,000

HA-KOA Proposed NH-LAX Actual DL-LAX Actual JL-SFO Actual AA-JFK Actual DL-DTW Actual HND Onboard Passengers – 12 Months Ended April 2013 and Proposed for KOA

Source: U.S. DOT, T-100 Da ta and Exhibi t HA-2012A-204. Exhibit HA-2013A-513 Docket OST-2010-0018 Page 1 of 1 

### KONA WILL OUTPERFORM ALL CURRENT/PREVIOUS MAINLAND GATEWAYS TO HANEDA

(Exhibit 512)

### 600 SERIES: ECONOMIC IMPACT

### 600 Series Exhibits ECONOMIC IMPACT • Japanese Visitors to Hawaii Spend 62% More Than the U.S. Average (Exhibit 601) • Hawaii Has Been the Preferred Destination For Japanese Visitors Since 2001 (Exhibit 602) • Over 20% More Japanese Tourists Visit Hawaii Than Visit the Entire U.S. Mainland (Exhibit 603) • Japanese Tourists Visiting Hawaii Grew 20% From 2011 to 2012 (Exhibit 604) • Hawaii Attracted Over Three Times as Many New Japanese Visitors As the U.S. Market (Exhibit 605) • Japanese Visitors Are Showing an Increasing Preference for Hawaii Over the Mainland U.S. (Exhibit 606) • Hawaii Has Nearly Three Times the Japanes e Visitors to California (Exhibit 607) • Hawaiian’s Honolulu Flight Brought in Over 117% More U.S. Visitors Than the Second Highest U.S. Carrier HND Gateway (Exhibit 608) • Hawaiian’s Honolulu Flight Accounted for Nearly 3,000 U.S. Jobs, Over Double the Second Highest HND Gateway (Exhibit 609) • Hawaiian’s Honolulu Flight Brought in $365.1 Million in New U.S. Exports Over Two Times the Second Highest HND Gateway (Exhibit 610) • Hawaiian’s Honolulu Flight Accounted fo r Over $657million in U.S. GDP - Over 110% More Than the Second Highest HND Gateway (Exhibit 611) • Hawaiian’s Honolulu Flight Accounted For $191 Million in U.S. Household Earnings - More Than Double the Second Hig hest HND Gateway (Exhibit 612) • Hawaiian’s Kona Flight Will Bring in Over 267% More U.S. Visitors Than a Second SFO Gateway (Exhibit 613) • Hawaiian’s Kona Flight Will Create Nearly 1,400 U.S. Jobs, Over Four Times United’s SFO Proposal (Exhibit 614) • Hawaiian’s Kona Flight Will Bring In $75.4 Million in New U.S. Exports Over 4 1⁄2 Times the United Proposal (Exhibit 615) • Hawaiian’s Kona Flight Will Increase U.S. GDP by Over $135 Million, or Over Four Times the United Proposal (Exhibit 616) • Hawaiian’s Kona Flight Would Increase U.S. Household Earnings by $40 Million, Over 4 1⁄2 Times the United Proposal (Exhibit 617) • Japanese Visitors to Hawaii Spend 62% More Than the U.S. Average (Exhibit 618) • Explanation of Economic Impact Method (Exhibit 619) • Calculation of Kona St imulation (Exhibit 620) • Calculation of SFO St imulation (Exhibit 621) • Calculation of Incremental Japanese Visitors (Exhibit 622) • Calculation Cumulative Visitors on U.S. Flag Carrier – HND Flights to Date (Exhibit 623) Exhibit HA-2013A-600 Docket OST-2010-0018 Page 1 of 1

### JAPANESE VISITORS TO HAWAII SPEND 62% MORE THAN THE U.S. AVERAGE

$1,171 $1,895

$0 $200 $400 $600 $800 $1,000 $1,200 $1,400 $1,600 $1,800 $2,000 $2,200 $2,400

Hawaii U.S. Average Note: Includes spending by Japanese Visito rs at destination with all values updat ed to 2013 using GDP price deflator. Sources: U.S. Department of Commerce Office of Trav el and Tourism Industries, 2012 Market Profile: Japan; Overseas And Mexican Visi tors To California (2011), Visit California, August 2012; 2012 Annual Visitor Research Report, State of Hawaii, D epartment of Business, Economic Development & Tourism Japanese Spending in U.S. per Visitor (2013 Estimate) Exhibit HA-2013A-601 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% 41%

0% 5% 10% 15% 20% 25% 30% 35% 40% 45% 50%

2001 2002 2003 2004 2005 2006 2007 2009 2011 2012 Share of Japanese Travelers to the U.S. Visiting Hawaii (Multiple Answers Allowed)

Source: U.S. Department of Commerce Office of Trav el and Tourism Industries, 2012 Market Profile: Japan Exhibit HA-2013A-602 Docket OST-2010-0018 Page 1 of 1

### OVER 20% MORE JAPANESE TOURISTS VISIT HAWAII THAN VISIT THE ENTIRE U.S. MAINLAND

Source: U.S. Department of Commerce Office of Trav el and Tourism Industries, 2012 Market Profile: Japan. 1,531 1,268

0 200 400 600 800 1,000 1,200 1,400 1,600 1,800

Hawaii U.S. Mainland 2012 Japanese Visitors to U. S. Destinations (000’s) Exhibit HA-2013A-603 Docket OST-2010-0018 Page 1 of 1



### +21%

### JAPANESE TOURISTS VISITING HA WAII GREW 20% FROM 2011 TO 2012

Source: U.S. Department of Commerce Office of Trav el and Tourism Industries, 2012 Market Profile: Japan. 1,271 1,531

0 200 400 600 800 1,000 1,200 1,400 1,600 1,800

2011 2002 Japanese Visitors to Hawaii Destinations (000’s) Exhibit HA-2013A-604 Docket OST-2010-0018 Page 1 of 1



### +20%

### HAWAII ATTRACTED OVER THREE TIMES AS MANY NEW JAPANESE VISITORS AS THE U.S. MARKET

Source: U.S. Department of Commerce Office of Trav el and Tourism Industries, 2012 Market Profile: Japan. 260,000

85,000

0 50,000 100,000 150,000 200,000 250,000 300,000

Japanese Visitors to Hawaii Japanese Visitors to U.S. Japanese Visitors to Hawaii Destinations Exhibit HA-2013A-605 Docket OST-2010-0018 Page 1 of 1

### JAPANESE VISITORS ARE SHOWING AN INCREASING PREFERENCE FOR HAWAII OVER THE MAINLAND U.S.

Source: U.S. Department of Commerce Office of Trav el and Tourism Industries, 2012 Market Profile: Japan. 20%

7%

0% 5% 10% 15% 20% 25%

Hawaii U.S. % Change in Japanese Visitors (2011-2012) Exhibit HA-2013A-606 Docket OST-2010-0018 Page 1 of 1

### HAWAII HAS NEARLY THREE TIMES THE JAPANESE VISITORS TO CALIFORNIA

1,531

514

0 200 400 600 800 1,000 1,200 1,400 1,600 1,800

Hawaii California 2012 Visitors to U.S. Destinations (000’s)

Hawaii Relative Size: 2.98x Note: Includes multiple destinations. Source: U.S. Department of Commerce Office of Trav el and Tourism Industries, 2012 Market Profile: Japan. Exhibit HA-2013A-607 Docket OST-2010-0018 Page 1 of 1

Hawaii Has Almost Three Times the Japanese Visitors as California with the Same Number of Designations

### CUMULATIVE ECONOMIC IMPACT TO DATE OF U.S. FLAG CARRIER HANEDA SERVICES

### HAWAIIAN’S HONOLULU FLIGHT BROUGHT IN OVER 117% MORE U.S. VISITORS THAN THE SECOND HIGHEST U.S. CARRIER HND GATEWAY 194,753

89,836 55,440 26,351 0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000 180,000 200,000

HA-HNL DL-LAX AA-JFK DL-DTW

Source: Exhibi t HA-2013A-622. Cumulative Japanese Visitors from HND Services (November 2010-April 2013) Exhibit HA-2013A-608 Docket OST-2010-0018 Page 1 of 1

### HAWAIIAN’S HONOLULU FLIGHT ACCOUNTED FOR NEARLY 3,000 U.S. JOBS, OVER DOUBLE THE SECOND HIGHEST HND GATEWAY Total Employment Impact of Japanese Visitors to the U.S. (Annual) Exhibit HA-2013A-609 Docket OST-2010-0018 Page 1 of 1

Note: Induced estimates calculated using standard multip liers from the U.S. Bureau of Economic Analysis. Source: U.S. Bureau of Economic Analysis RIMS II Multip liers; Exhibits HA-2013A-618 and Exhibits HA-2013A-622. 

### 398 921 1,380 2,988

0 500 1,000 1,500 2,000 2,500 3,000 3,500

HA-HNL DL-LAX AA-JFK DL-DTW Direct Jobs Induced Jobs

### HAWAIIAN’S HONOLULU FLIGHT BROUGHT IN $365.1 MILLION IN NEW U.S. EXPORTS OVER TWO TIMES THE SECOND HIGHEST HND GATEWAY

$365.1

$153.1 $64.9 $30.9 $0.0 $50.0 $100.0 $150.0 $200.0 $250.0 $300.0 $350.0 $400.0

HA-HNL DL-LAX AA-JFK DL-DTW Cumulative Spending (Exports) of Jap anese Visitors to the U.S. (Millions)

Note: Expenditures calculated using aver age expenditures per visitor x estimated Total Japanese visitors. Exhibit HA-2013A-610 Docket OST-2010-0018 Page 1 of 1

Source: U.S. Bureau of Economic Analysis RIMS II Mult ipliers; Exhibits HA-2013A- 618 and Exhibits HA-2013A-622

### HAWAIIAN’S HONOLULU FLIGHT ACCOUNTED FOR OVER $657 MILLION IN U.S. GDP - OVER 110% MORE THAN THE SECOND HIGHEST HND GATEWAY

$59.0 $125.7 $312.5 $657.3

$0.0 $100.0 $200.0 $300.0 $400.0 $500.0 $600.0 $700.0

HA-HNL DL-LAX AA-JFK DL-DTW Direct Spending Induced Impacts Cumulative GDP Impact of Japanese Visitors to the U.S. (Millions) Exhibit HA-2013A-611 Docket OST-2010-0018 Page 1 of 1

Note: Induced estimates calculated using standard multip liers from the U.S. Bureau of Economic Analysis. Source: U.S. Bureau of Economic Analysis RIMS II Mult ipliers; Exhibits HA-2013A- 618 and Exhibits HA-2013A-622

### HAWAIIAN’S HONOLULU FLIGHT ACCOUNTED FOR $191 MILLION IN U.S. HOUSEHOLD EARNINGS - MORE THAN DOUBLE THE SECOND HIGHEST HND GATEWAY

$17.4 $36.7 $87.3 $195.2

$0.0 $50.0 $100.0 $150.0 $200.0 $250.0

HA-HNL DL-LAX AA-JFK DL-DTW Direct Spending Induced Impacts Cumulative Earnings Impact of Japan ese Visitors to the U.S. (millions) Exhibit HA-2013A-612 Docket OST-2010-0018 Page 1 of 1

Note: Induced estimates calculated using standard multip liers from the U.S. Bureau of Economic Analysis. Source: U.S. Bureau of Economic Analysis RIMS II Multip liers; Exhibits HA-2013A-618 and Exhibits HA-2013A-622.

### PREDICTED INCREMENTAL ECONOMIC IMPACT OF PROPOSED SERVICE

### HAWAIIAN’S KONA FLIGHT WILL BRING IN OVER 267% MORE U.S. VISITORS THAN A SECOND SFO GATEWAY Incremental Japanese Visitors from Proposed HND Services Exhibit HA-2013A-613 Docket OST-2010-0018 Page 1 of 1

Note: Induced estimates calculated using standard multip liers from the U.S. Bureau of Economic Analysis. Source: U.S. Bureau of Economic Analysis RIMS II Multipliers; Exhibits HA-2013A-619-621. 39,798

10,835
0 5,000 10,000 15,000 20,000 25,000 30,000 35,000 40,000 45,000

HA-KOA UA-SFO

### HAWAIIAN’S KONA FLIGHT WILL CREATE NEARLY 1,400 U.S. JOBS, OVER FOUR TIMES UNITED’S SFO PROPOSAL Total Employment Impact of Japanese Visitors to the U.S. (Annual) Exhibit HA-2013A-614 Docket OST-2010-0018 Page 1 of 1

Note: Induced estimates calculated using standard multip liers from the U.S. Bureau of Economic Analysis. Source: U.S. Bureau of Economic Analysis RIMS II Multipliers; Exhibits HA-2013A-618-621. 

### 297 1,393

0 200 400 600 800 1,000 1,200 1,400 1,600

HA-KOA UA-SFO Direct Jobs Induced Jobs

### HAWAIIAN’S KONA FLIGHT WILL BRING IN $75.4 MILLION IN NEW U.S. EXPORTS OR OVER 4 1⁄2 TIMES THE UNITED PROPOSAL Incremental Spending (Exports) of Jap anese Visitors to the U.S. (Millions)

Note: Expenditures calculated using average expenditures per visitor x estimated in cremental Japanese visitors. Exhibit HA-2013A-615 Docket OST-2010-0018 Page 1 of 1

Source: U.S. Bureau of Economic Analysis RIMS II Multipliers; Exhibits HA-2013A-618-621. $75.4

$16.5 $0.0 $10.0 $20.0 $30.0 $40.0 $50.0 $60.0 $70.0 $80.0

HA-KOA UA-SFO

### HAWAIIAN’S KONA FLIGHT WILL INCREASE U.S. GDP BY OVER $135 MILLION, OR OVER FOUR TIMES THE UNITED PROPOSAL incremental GDP Impact of Japanese Visitors to the U.S. (Millions) Exhibit HA-2013A-616 Docket OST-2010-0018 Page 1 of 1

Note: Induced estimates calculated using standard multip liers from the U.S. Bureau of Economic Analysis. Source: U.S. Bureau of Economic Analysis RIMS II Multipliers; Exhibits HA-2013A-618-621. $31.7 $135.6

$0.0 $20.0 $40.0 $60.0 $80.0 $100.0 $120.0 $140.0 $160.0

HA-KOA UA-SFO Direct Spending Induced Impacts

### HAWAIIAN’S KONA FLIGHT WOULD INCREASE U.S. HOUSEHOLD EARNINGS BY $40 MILLION, OVER 4 1⁄2 TIMES THE UNITED PROPOSAL Incremental Earnings Impact of Jap anese Visitors to the U.S. (millions) Exhibit HA-2013A-617 Docket OST-2010-0018 Page 1 of 1

Note: Induced estimates calculated using standard multip liers from the U.S. Bureau of Economic Analysis. Source: U.S. Bureau of Economic Analysis RIMS II Multipliers; Exhibits HA-2013A-618-621. $8.8 $40.3

$0.0 $5.0 $10.0 $15.0 $20.0 $25.0 $30.0 $35.0 $40.0 $45.0

HA-KOA UA-SFO Direct Spending Induced Impacts

### EXPLANATION OF ECONOMIC IMPACT METHOD

• Direct Japanese Visitor Expendi tures were broken down into expense type from Three Sources:

– HNL/KOA: State of Hawaii, Department of Business, Economic Development & Tourism, 2012 Annual Visitor Research Report;

– LAX/SFO: Visit California, Overseas And Mexican Visitors To California (2011), October 2011;

– NYC/DTW/Connecting Passengers: U.S. Department of Commerce Office of Travel and Tourism Industries, 2012 Market Profile: Japan

– All values updated to 2013 using GDP price deflator
• Multiplied Japanese Visitor Expenditures broken down by expense type by the estimated incremental Japanese Visitors for each market.
• 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 metr opolitan area. For connecting visitors, we used multipliers based on the U.S mainland. Exhibit HA-2013A-618 Docket OST-2010-0018 Page 1 of 1

### CALCULATION OF KONA STIMULATION Exhibit HA-2013A-619 Docket OST-2010-0018 Page 1 of 1



### KONA 1 YE Apr. 2013 HNL-TYO* O nboard Passengers 2,008,298 2 KOA Share of NRT-KOA When Both HNL and KOA Had Nonstop Service 8% 3 Estimated KOA Passengers With Service 160,664 4 Current Unadjusted MIDT KOA-TYO* 58,847 Adjustment Factor to Account for Direct Bookings /1 0.35 5 Adjusted KOA-TYO* Passengers 79,443 6 Stimulated passengers 81,221 ( Row 3 - Row 5)

Note: The HNL-TYO market increased 211,993 in the first year after HND service and 365,087 through April 2013. * Includes HND and NRT. 1/ For purposes of comparability HA has used a 35% MIDT adjustment factor th roughout the Haneda cases.

### CALCULATION OF SFO STIMULATION

(A) Year Ended Apr. 2013 scheduled passenger serv ice only from U.S. DOT, T-100 Data. (B) Current Seats from (A) adjusted to account for new UA se rvice, discontinued DL SFO-NRT se rvice, new NH SJC-NRT service and downgauged JL SFO-HND service. (C) (B)/(A) -1 (D) Uses standard DOT QSI formula: Stimulation = ((Future Seats/Cu rrent Seats)/(0. 3741 + 0.5561(Futu re Seats/Current Seats)))/1. 075. (E) Year Ended Apr. 2013 scheduled passenger serv ice only from U.S. DOT, T-100 Data. (F) (E) x (D) * Includes HND and NRT. 1/ Assumes full additional flight and does not re flect UA’s suggested r eduction of NRT service. Exhibit HA-2013A-620 Docket OST-2010-0018 Page 1 of 1

Current Annual Seats (A) Proposed Annual Seats (B) % Change (C) QSI Stimulation (D) Current Onboard Passengers (E) Stimulated Onboard Passengers (F) 874,419 978,216 11.9%

4.5% 723,912

32,576 Between TYO* and SFO Bay Area – After DL Suspension and Proposed UA HND /1

### CALCULATION OF INCREMENTAL JAPANESE VISITORS

1/ For connecting passengers, used the U.S. mainland average Point-of-Orgin Japan %. (A) From Exhibi t HA-2012A-408. (B) From YE Sept. 2013 MIDT via TravelPort. For UA, uses NRT service excluding beyond NRT to calculate. (C) From YE Sept. 2013 MIDT via TravelPort. For UA , uses NRT service excludi ng beyond NRT to calculate. (D) From YE Sept. 2013 MIDT via TravelPort. (E) From YE Sept. 2013 MIDT via TravelPort. (F) (A) x (B) x (D) / 2. (G) (A) x (C) x (E) / 2. (H) (F) + (G) Exhibit HA-2013A-621 Docket OST-2010-0018 Page 1 of 1

(A) (B) (C) (D) (E) (F) (G) (H) % Local Connecting Total Stimulated % Local Connecting Point-of-Sale Japan % Roundtrips Roundtrips Japanese Passengers Passengers Passengers Local Connecting/1 (Visitors) (Visitors) Visitors Kona 81,221 100% 0% 98% 0.0% 39,798 0 39,798 SFO Bay Area 32,576 48% 52% 66% 67.0% 5,150 5,675 10,835

### CALCULATION OF CUMULATIVE VISITORS ON U.S. FLAG CARRIER – HND FLIGHTS TO DATE

1/ Local vs. connecting share of onboard passengers calc ulated from From YE Sept. 2013 MIDT via TravelPort. 2/ Onboard passengers x point of sale japan passengers / 2. Exhibit HA-2013A-622 Docket OST-2010-0018 Page 1 of 1

Cumulative HND Onboard Passengers Through April 2013 /1 Point of Sale Japan Local Connecting Total Local Connecting HA Honolulu 394,271 16,428 410,699 96% 67% DL Detroit 47,447 40,417 87,864 54% 67% AA New York 113,677 39,940 153,617 74% 67% DL Los Angeles 182,657 74,607 257,264 71% 67%
Cumulative HND Visitors /2 Local Connecting Total HA Honolulu 189,250 5,503 194,753 DL Detroit 12,811 13,540 26,351 AA New York 42,060 13,380 55,440 DL Los Angeles 64,843 24,993 89,836
Note: Induced estimates calculated using standard multip liers from the U.S. Bureau of Economic Analysis. Source: U.S. DOT, T-100 Data and Travleport MIDT data.

### 700 SERIES: ALLIANCE CARRIERS DOMINATE THE TOKYO MARKET

### 700 Series Exhibits ALLIANCE CARRIERS DOMINATE THE TOKYO MARKET Exhibit HA-2013A-700 Docket OST-2010-0018 Page 1 of 1

• The Star/Oneworld/Skyteam Oligopoly Domina tes Current U.S. – Tokyo Frequencies (Current Schedules) (Exhibit 701) • The Star/Oneworld/Skyteam Oligopoly Controls 98% Of Current U.S. – Tokyo Frequencies (Current Schedules) (Exhibit 702) • The Star/Oneworld/Skyteam Oligopoly Domina tes the U.S. – Tokyo Passenger Market (YE April 2013) (Exhibit 703) • The Star/Oneworld/Skyteam Oligopoly Controls 98% of All U.S. – Tokyo Gateway-toGateway Passengers (YE April 2013) (Exhibit 704) • American’s ATI Partner, JAL, and United’s ATI Partner, ANA, Control 77% of All Departures at Haneda (Cur rent Schedules) (Exhibit 705) • American’s ATI Partner, JAL, and United’s ATI Partner, ANA, Control 81% of Haneda Capacity (Current Schedules) (Exhibit 706) • The Star/Oneworld/Skyteam Oligopoly Controls 92% of Current Hawaii – Tokyo Frequencies (Current Schedules) (Exhibit 707) • ATI and Mergers Have Increased U.S. – Tokyo Market Concentration to an Alarming Level (Exhibit 708) • U.S.-Tokyo Market Concentration Has In creased Sharply Since the Last Haneda Proceeding (Exhibit 709)

### THE STAR/ONEWORLD/SKYTEAM OLIGOPOLY DOMINATES CURRENT U.S. – TOKYO FREQUENCIES (CURRENT SCHEDULES)

114 120 182

0 20 40 60 80 100 120 140 160 180 200

Star SkyTeam oneworld Nonaligned Weekly Roundtrip Flights Betw een the U.S. and Tokyo*

* Includes HND and NRT. Source: Innovata schedule for the week of November 4,2013. Exhibit HA-2013A-701 Docket OST-2010-0018 Page 1 of 1

(UA) (DL) (AA) (HA) 7

### THE STAR/ONEWORLD/SKYTEAM OLIGOPOLY CONTROLS 98% OF CURRENT U.S. – TOKYO FREQUENCIES (CURRENT SCHEDULES)

Star 43%

SkyTeam 28% oneworld 27% Unaligned (Hawaiian) 2% Distribution of Current U.S. – Tokyo* Flights by Alliance

* Includes HND and NRT. Source: Innovata schedule for the week of November 4, 2013. Exhibit HA-2013A-702 Docket OST-2010-0018 Page 1 of 13,618 3,104 2,245

181 0 500 1,000 1,500 2,000 2,500 3,000 3,500 4,000

Star SkyTeam oneworld Hawaiian 

### THE STAR/ONEWORLD/SKYTEAM OLIGOPOLY DOMINATES THE U.S. – TOKYO* PASSENGER MARKET (YE APRIL 2013) Annual Onboard Passengers (000’s)

* Includes HND and NRT. Source: U. S. DOT T-100 data, YE April 2013. Subsid iary carriers are included with the parent carrier. Exhibit HA-2013A-703 Docket OST-2010-0018 Page 1 of 1

(UA) (DL) (AA) (HA)

### THE STAR/ONEWORLD/SKYTEAM OLIGOPOLY CONTROLS 98% OF ALL U.S. – TOKYO GATEWAY-TO-GATEWAY PASSENGERS (YE APRIL 2013)

Star 39%

SkyTeam 34% oneworld 25% Unaligned (Hawaiian) 2% Distribution of Annual U.S. – Tokyo * Onboard Passengers by Alliance

* Includes HND and NRT. Source: U. S. DOT T-100 data, YE April 2013. Subsid iary carriers are included with the parent carrier. Exhibit HA-2013A-704 Docket OST-2010-0018 Page 1 of 1ANA 44%

JAL 33% 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 November 4, 2013. Exhibit HA-2013A-705 Docket OST-2010-0018 Page 1 of 1ANA 49%
JAL 32% Others 19% 

### AMERICAN’S ATI PARTNER, JAL, AND UNITED’S ATI PARTNER, ANA, CONTROL 81% OF HANEDA CAPACITY (CURRENT SCHEDULES) Distribution of Current HND Seats

Source: Innovata schedule for the week of November 3, 2013. Exhibit HA-2013A-706 Docket OST-2010-0018 Page 1 of 128 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*

* Includes HND and NRT. Source: Innovata schedule for the week of November 4, 2013. Exhibit HA-2013A-707 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

* Includes HND and NRT. Source: Innovata schedule for the week of August 13, 2012. Exhibit HA-2013A-707 Docket OST-2010-0018 Page 2 of 21,516 1,683 2,858 3,321

0 500 1,000 1,500 2,000 2,500 3,000 3,500

2009 2010 YE Feb 2012 YE Apr 2013 

### ATI AND MERGERS HAVE INCREASED U.S. – TOKYO MARKET CONCENTRATION TO AN ALARMING LEVEL U.S. – Tokyo* HHI Based on Onboard Passengers Exhibit HA-2013A-708 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. Market s with HHIs between 1500 and 2500 are considered “Moderately Concentrated”. Markets with HHIs above 25 00 are considered “Highly Concentrated”. The U.S.- Tokyo market has been transformed from Mode rately Concentrated to Highly Concentrated. * Includes HND and NRT. Source: U. S. DOT T-100 data; U.S. Department of Justice & F ederal Trade Commission, Horizont al Merger Guidelines, Aug 2010.2,858 3,321

0 500 1,000 1,500 2,000 2,500 3,000 3,500

YE February 2012 YE April 2013 

### U.S.-TOKYO MARKET CONCENTRATION HAS INCREASED SHARPLY SINCE THE LAST HANEDA PROCEEDING

* Includes HND and NRT. 1/ Exhibit HA-2012A-506. Source: U. S. DOT T-100 data; U.S. Department of Justice & F ederal Trade Commission, Horizont al Merger Guidelines, Aug 2010. Exhibit HA-2013A-709 Docket OST-2010-0018 Page 1 of 1

/1 U.S. – Tokyo* HHI Based on Onboard Passengers

Note: HHI, or Herfindahl-Hirschman Index is a measure of market concentration (based on market shares) used commonly by the Department of Justice. Market s with HHIs between 1500 and 2500 are considered “Moderately Concentrated”. Markets with HHIs above 25 00 are considered “Highly Concentrated”. The U.S.- Tokyo market has been transformed from Mode rately Concentrated to Highly Concentrated.

### 800 SERIES: HAWAIIAN’S RECORD OF OUTSTANDING PERFORMANCE

### 800 Series Exhibits HAWAIIAN’S RECORD OF OUTSTANDING PERFORMANCE

• Hawaiian Has a Better On-Time Performan ce Than the Large Legacy U.S. Airlines (Exhibit 801) • Hawaiian’s Mishandled Bags Rate is Far Lower Than United (Exhibit 802) • Hawaiian’s Denied Boardings Rate is Far Lower Than United (Exhibit 803) • Hawaiian’s Complaint Rate is Far Lower Than United (Exhibit 804) • Hawaiian Has Consistently Achieved the Be st On-Time Performance in the Industry (Exhibit 805) • Hawaiian Has Consistently Outperformed th e Other Applicant Carriers in Terms of Mishandled Bags (Exhibit 806) • Hawaiian Has Consistently Outperformed th e Other Applicant Carriers in Terms of Customer Complaints (Exhibit 807) Exhibit HA-2013A-800 Docket OST-2010-0018 Page 1 of 1

### HAWAIIAN HAS A BETTER ON-TIME PERFORMANCE THAN THE LARGE LEGACY U.S. AIRLINES

Source: U.S. DOT, Air Travel C onsumer Report, page 5, October 2013. YE August 2013 Percentage of On-Time Arrivals



### Rank: 1 3 9 12 Exhibit HA-2013A-801 Docket OST-2010-0018 Page 1 of 1

93.5 85.0 78.8 74.6

0 10 20 30 40 50 60 70 80 90 100

Hawaiian Delta United American

### HAWAIIAN’S MISHANDLED BAGS RATE IS FAR LOWER THAN UNITED

Source: U.S. DOT, Air Travel Cons umer Report. YTD includes January – August 2013. 2.3 3.5

0.0 0.5 1.0 1.5 2.0 2.5 3.0 3.5 4.0

Hawaiian United YTD 2013 Number of Mishandled Bags per 1,000 Passengers



### Rank: 4 9 Exhibit HA-2013A-802 Docket OST-2010-0018 Page 1 of 1

### HAWAIIAN’S DENIED BOARDINGS RATE IS FAR LOWER THAN UNITED

Source: U.S. DOT, Air Travel Cons umer Report. YTD includes January – June 2013. 1.82 8.22

0.00 1.00 2.00 3.00 4.00 5.00 6.00 7.00 8.00 9.00

Hawaiian United YTD 2013 Number of Denied Boardings per 10,000 Passengers



### Rank: 2 9 Exhibit HA-2013A-803 Docket OST-2010-0018 Page 1 of 1

### HAWAIIAN’S COMPLAINT RATE IS FAR LOWER THAN UNITED

1.25 2.36

0.00 0.50 1.00 1.50 2.00 2.50

Hawaiian United YTD 2013 Number of Complaints per 100,000 Enplanements



### Rank: 9 14 Exhibit HA-2013A-804 Docket OST-2010-0018 Page 1 of 1

Source: U.S. DOT, Air Travel Cons umer Report. YTD includes January – August 2013.

### 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-August 2013. Exhibit HA-2013A-805 Docket OST-2010-0018 Page 1 of 1

Ranking 2004 2005 2006 2007 2008 2009 2010 2011 2012 YE 8/2013 1 HA HA HA HA HA HA HA HA HA HA 2 3 UA DL 4 DL 5 DL DL 6 UA DL 7 UA 8 UA AA UA 9 AA UA 10 AA UA DL 11 DL AA 12 DL AA 13 AA UA UA 14 AA 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-2013A-806 Docket OST-2010-0018 Page 1 of 1

Note: The lower the ranking the fewest number of mishandled bags per passenger. Source: U.S. DOT, Air Travel Consumer Reports 2004-June 2013. Ranking 2004 2005 2006 2007 2008 2009 2010 2011 2012 YTD 2013 1 HA HA HA 2 HA HA HA HA 3 4 HA DL HA 5 DL DL 6 7 UA HA 8 UA UA UA UA AA 9 AA UA 10 UA DL AA 11 AA AA AA AA UA AA UA UA 12 DL AA DL DL DL AA 13 14 DL DL 15 16 17 18 19

### HAWAIIAN HAS CONSISTENTLY OUTPERFORMED THE OTHER APPLICANT CARRIERS IN TER MS OF CUSTOMER COMPLAINTS

Note: The lower the ranking the fewest number of complaints per passenger. Source: U.S. DOT, Air Travel Consumer Reports 2004-August 2013. Customer Complaints Rank Exhibit HA-2013A-807 Docket OST-2010-0018 Page 1 of 1

Ranking 2004 2005 2006 2007 2008 2009 2010 2011 2012 YTD 2013 1 2 HA HA HA 3 HA HA HA 4 AA HA DL 5 UA UA AA DL 6 UA UA 7 AA AA AA DL 8 HA 9 AA UA HA 10 UA HA 11 DL 12 DL 13 AA AA 14 DL DL DL AA AA UA 15 UA 16 DL UA 17 UA 18 DL 19

### 900 SERIES: ANSWER TO UA

### 900 Series Exhibits ANSWER TO UNITED Exhibit HA-2013A-900 Docket OST-2010-0018 Page 1 of 1

• UA/NH Has a Huge Commitment to Narita (Exhibit 901) • Haneda Will Not be Very Important to United in the Overall Context of Its U.S.-Japan Network (Exhibit 902) • United Has Less Than a Huge Co mmitment to SFO-TYO (Exhibit 903) • United’s Application Suggests It Might Reduce SFO-TYO to Only One Daily YearRound Even if Awarded HND (Exhibit 904) • United’s ATI Relationship With ANA Pr ovides an Incentive to Reduce SFO-NRT Frequency (Exhibit 905) • United’s 2010 Assessment of SFO and DTW Shows That SFO Would be a Failure on the Scale of the DTW Fiasco (Exhibit 906) • United’s Proposed SFO-HND Schedules Wo uld Merely Duplicate JAL’s (Exhibit 907) • Delta Already Offers Haneda Connections to Interior U.S. Points (Exhibit 908) • United Proposes Miniscule Interi or U.S. Benefits (Exhibit 909) • Kona Has Over Twice as Many HND Passeng ers as All of United’s Unduplicated Roundtrip Points Behind SFO (Exhibit 910) • United Proposes to Add 20%-24% More Capacity Next Summer In the Struggling Bay Area- T okyo Market (Exhibit 911) • The Most Recent T-100 Data Show the Bay Area-Tokyo Market With Over 150,000 Empty Seats (Exhibit 912)

### UA/NH HAS A HUGE COMMITMENT TO NARITA

UA/NH’s 45 Narita Segments - 501 Weekly Departures Bangkok (BKK) Beijing (PEK) Chengdu (CTU) Chicago-O'Hare (ORD) Dalian (DLC) Delhi (DEL) 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) Yangon (RGN) Source: Innovata schedule for the week of November 4, 2013. Exhibit HA-2013A-901 Docket OST-2010-0018 Page 1 of 1

IAD IAD IAD IAD

EWR EWR EWR EWR TPE TPE TPE TPE XMN XMN XMN XMN HKG HKG HKG HKG CTU CTU CTU CTU HGH HGH HGH HGH OKA OKA OKA OKA CAN CAN CAN CAN LHR LHR LHR LHR JFK JFK JFK JFK SJC SJC SJC SJC SFO SFO SFO SFO KMQ KMQ KMQ KMQ HIJ HIJ HIJ HIJ FUK FUK FUK FUK NGO NGO NGO NGO KIJ KIJ KIJ KIJ

SDJ SDJ SDJ SDJ NRT NRT NRT SHE SHE SHE SHE CTS CTS CTS CTS

BKK BKK BKK BKK BOM BOM BOM BOM C DG C C C DG C DG CDG C

CGK CGK CGK CGK DEL DEL DEL DEL DEN DEN DEN DEN DLC DLC DLC DLC FRA FRA FRA FRA

GUM GUM GUM GUM HNL HNL HNL HNL IAH IAH IAH IAH ICN ICN ICN ICN ITM ITM ITM ITM LAX LAX LAX LAX MNL MNL MNL MNL MUC MUC MUC MUC ORD ORD ORD ORD PEK PEK PEK PEK

PVG PVG PVG PVG RGN RGN RGN RGN SEA SEA SEA SEA

SGN SGN SGN SGN SIN SIN SIN SIN TAO TAO TAO TAO

### HANEDA WILL NOT BE VERY IMPORTANT TO UNITED IN THE OVERALL CONTEXT OF ITS U.S.-JAPAN NETWORK Exhibit HA-2013A-902 Docket OST-2010-0018 Page 1 of 1

### UNITED HAS LESS THAN A HUGE COMMITMENT TO SFO-TYO Exhibit HA-2013A-903 Docket OST-2010-0018 Page 1 of 1



### • Proposed SFO-HND will be down ga uged to smaller B787 with almost 100 fewer daily seats • No commitment to continue 2 nd 

### SFO-NRT daily flight • No mention of replacing SFO- NRT capacity loss by March 2014 cancellation of Delta’s 767 SFO-NRT daily nonstop service

### UNITED’S APPLICATION SUGGESTS IT MIGHT REDUCE SFO-TYO SERVICE TO ONLY ONE DAILY YEAR-ROUND EVEN IF AWARDED HND

“ Historically, United has operat ed up to two daily flights during certain time periods between San Francisco and Tokyo Narita. 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 5 (emphasis added). Exhibit HA-2013A-904 Docket OST-2010-0018 Page 1 of 1

### UNITED’S ATI RELATIONSHIP WITH ANA PROVIDES AN INCENTIVE TO REDUCE SFO-NRT FREQUENCY

United ANA

* Includes HND and NRT. Source: Innovata Schedule Data, Week November 3, 2013 14 7 21
Note: ANA recently added San Jose service. This service will recapture passengers currently driving from the San Jose Service Area. SFO-TYO* Current Weekly Roundtrip Flights Exhibit HA-2013A-905 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-2013A-906 Docket OST-2010-0018 Page 1 of 1

### UNITED’S PROPOSED SFO-HND SCHEDULES WOULD MERELY DUPLICATE JAL’S Exhibit HA-2013A-907 Docket OST-2010-0018 Page 1 of 1



### 6:10 PM

10:25 PM 4:25 PM

12:05 AM 7:10 PM

11:40 PM 5:45 PM

1:35 AM 

## SFO
HND JAL Actual 

## United Proposed 

## JAL Actual 

## United Proposed

Note: All times local.BUR BUR BUR BUR SNA SNA SNA SNA SAN SAN SAN SAN 

### LAX LAX SBA SBA SBA SBA PDX PDX PDX PDX

SMF SMF SMF SMF OAK OAK OAK OAK SFO SFO SFO SFO 

### SEA SEA BLI BLI BLI BLI

SUN SUN SUN SUN PSC PSC PSC PSC YKM YKM YKM YKM

DFW ALW

DEN DEN DEN DEN BOI BOI BOI BOI SLC SLC SLC SLC LWS LWS LWS LWS EAT EAT EAT EAT PUW BZN BZN BZN BZN GEG GEG GEG GEG MSO MSO MSO MSO

MCO MCO MCO MCO HLN HLN HLN HLN BIL BIL BIL BIL RDM RDM RDM RDM

ATL ATL ATL ATL OMA OMA OMA OMA GTF GTF GTF GTF

PHX PHX PHX PHX FCA FCA FCA FCA

TUS TUS TUS TUS LAS LAS LAS LAS ORD ORD ORD ORD MSP MSP MSP MSP

PSP PSP PSP PSP ONT ONT ONT ONT FAT FAT FAT FAT DTW
SJC SJC SJC SJC JFK JFK JFK JFK BOS BOS BOS BOS

RDU RDU RDU RDU CVG CVG CVG CVG MCI MCI MCI MCI

MIA MIA MIA MIA TPA TPA TPA TPA MSY MSY MSY MSY 

### DELTA ALREADY OFFERS HANEDA CONNECTIONS TO INTERIOR U.S. POINTS Exhibit HA-2013A-908 Docket OST-2010-0018 Page 1 of 1

DL Haneda Route Connects Both Directions Eastbound Connection Westbound Connection To HND

Source: Innovata schedules, June 2014.

### UNITED PROPOSES MINISCUL E INTERIOR U.S. BENEFITS Exhibit HA-2013A-909 Docket OST-2010-0018 Page 1 of 1

Salt Lake City Chicago Houston Washington Dulles Dallas/Ft. Worth New York/Newark Cleveland Reno Santa Barbara Monterey Eugene Medford Redding Eureka/Arcata Modesto Total SLC ORD IAH IAD DFW EWR CLE RNO SBA MRY EUG MFR RDD ACV MOD HND MIDT Passengers U.S. Rank Market Code 1,594 1,520 1,387 935 905 297 246 125 124 69 59 36 12 3 1 7,313 17 18 20 23 24 44 45 57 58 78 86 107 162 233 270 Total of All UA Proposed “New” Roundtrip Points Behind SFO /1

1/ UA roundtrip connections that do not already have r oundtrip connections. (tie) (tie) (tie) (tie) (tie)

### KONA HAS NEARLY THREE TIMES AS MANY HND PASSENGERS AS ALL OF UNITED’S UNDUPLICATED RO UNDTRIP POINTS BEHIND SFO YE September 2013 HND MIDT Passengers 20,879

7,313
0 5,000 10,000 15,000 20,000 25,000

KOA Exhibit HA-2013A-910 Docket OST-2010-0018 Page 1 of 1

Total of All UA Proposed “New” Roundtrip Points Behind SFO
NOTE: MIDT SAMPLE HAS NOT BEEN EXPANDED TO ACCOUNT FOR DIRECT BOOKINGS AND DOES NOT REFLECT TOTAL MARKET SIZE. Source: MIDT, via Travelport.

### UNITED PROPOSES TO ADD 20%-24% MORE CAPACITY NEXT SUMMER IN THE STRUGGLING BAY AREA-TOKYO MARKET SFO – 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

Projected 2014 Seats 818,346 +20%

* Includes HND and NRT. 1/ YE April 2013 T-100 seats less DL SFO-NRT, less JL SFO-HND down gauge, and plus NH SJC-NRT which began June 2013. Source: U. S. DOT T-100 data, YE Apr. 2013 and Innovata schedule data. B777 Exhibit HA-2013A-911 Docket OST-2010-0018 Page 1 of 1

159,870

NH SJC-NRT 115,340 JL SFO-HND 135,780 NH SFO-NRT 186,166 UA SFO-NRT 381,060

/1 +24% Proposed UA SFO-HND B787 195,640

### THE MOST RECENT T-100 DATA SHOW THE BAY AREA-TOKYO MARKET WITH OVER 150,000 EMPTY SEATS SFO – 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

YE Apr. 2013 T-100 Seats 58,510 Exhibit HA-2013A-912 Docket OST-2010-0018 Page 1 of 1

DL SFO-NRT JL SFO-HND NH SFO-NRT UA SFO-NRT Empty Seats

24,020 49,814 18,163 Total Empty Seats = 150,507 874,419

* Includes HND and NRT. Source: U. S. DOT T-100 data, YE Apr. 2013 and Innovata schedule data.