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 Services )

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

Benjamin 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

bberlin@dowlohnes.com 

Counsel for Hawaiian Airlines, Inc.

December 9, 2013
TABLE 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 Aircraft 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 Greatest 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 Kona 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 Highest 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....................................................................... 45
V. Hawaiian Has a Unique Incentive to Make Its Haneda Service a Success. ................... 47

VI. Hawaiian Offers Superior Customer Service. .................................................................. 48

Conclusion ................................................................................................................................... 48
DOT-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 Services )

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 States 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 by 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 analysis 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-OST2010-0018, 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 successful 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. carrier 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 October 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 slots 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 mainland 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 

cancelled 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 proceeding, 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 introduction 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 traffic 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 to a significant extent on U.S.-originating passengers from SFO. A 

rigorous analysis of the available data leads to the inevitable conclusion that Hawaiian’s KonaHaneda 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-2013A-500, 501, 502.

• The Tokyo-Kona market is sufficiently large that 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, see HA-2013A-613, and consequently generate the most domestic

economic growth, see HA-2013A-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 track 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 

success.

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 abundance 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 have 

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 frequencies (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 the 
DOT-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 HA2013A-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 HanedaHonolulu Route Has Been By Far the Most Successful Route, Warranting an 

Award of Additional Service 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. It 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 Reliable U.S. Carrier Operating at Haneda.

Hawaiian initiated its Haneda service before any other U.S. carrier, beginning in 

November 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 Start-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 throughout the tragic events of the Japanese earthquake, tsunami and associated nuclear 

disaster—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 their
DOT-OST-2010-0018

2013 Answer of Hawaiian Airlines, Inc.

Page 8 of 49

Haneda routes. See HA-2013A-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-2013A-204, 205.

By contrast, other airlines have repeatedly halted service and requested waivers 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. Gateways.

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 popular, 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 commitment to Haneda service in its 

decision making, that factor tips heavily in favor of Hawaiian.

C. Hawaiian Up-gauged the Aircraft It 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 proposed 

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 an 
DOT-OST-2010-0018

2013 Answer of Hawaiian Airlines, Inc.

Page 11 of 49

aircraft that seats only 268, which is approximately 10% smaller 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 already 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 Than United

HA-2013A-112.
DOT-OST-2010-0018

2013 Answer of Hawaiian Airlines, Inc.

Page 12 of 49

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

Service to Japan. 

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

simply operate the single successful route awarded to it between Haneda and Honolulu. Instead, 

it has seized the opportunity facilitated by the Department’s award of Haneda slots. For years, 

Hawaiian’s presence in Japan had been limited to charter service and the marketing of its InterIsland services to tourists who traveled to Hawaii on other carriers. The introduction of 

Hawaiian’s Haneda service established it as a legitimate competitive provider of travel between 

Japan and the Hawaiian Islands. The 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 SapporoChitose and free sale codeshare service with ANA to Hiroshima, Kagoshima, 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 therefore economic growth to the U.S. Again, Hawaiian delivered 

on its promises. Hawaiian carried more U.S.-bound passengers than any other U.S. carrier. See

HA-2013A-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 over 
DOT-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-611; 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 

many years, Hawaii has been the preferred destination for Japanese visitors. See HA-2013A602. 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 increasing 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 largest U.S.-Japan market, see 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, California. 
DOT-OST-2010-0018

2013 Answer of Hawaiian Airlines, Inc.

Page 16 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 relative 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 TokyoHawaii and Tokyo-California markets is attributable to the fact that Hawaii-Tokyo traffic is 
DOT-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 combined. See HA-2013A-309. And the HawaiiHaneda 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, California – 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.-Haneda gateways combined. See HA2013A-312.

The size of the Hawaii-Japan market is evident in other metrics as well. The HawaiiHaneda market experiences a much higher load factor than does the comparable mainland 
DOT-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 passengers 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 traffic 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-2013A402. 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. Remarkably, 

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 carriers’ operations at Narita. See HA2013A-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 satisfy 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 effects of the applicants’ service proposals on the overall competitive 
DOT-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, where 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 commercially viable. 

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

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

been highly correlated with local market demand. See HA-2013A-103. As Exhibit HA-2013A102 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 lowest point of sale in Tokyo, other than American’s abandoned JFK service. See HA2013A-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, Haneda.

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 HA2013A-105. 
DOT-OST-2010-0018

2013 Answer of Hawaiian Airlines, Inc.

Page 24 of 49

Hawaiian’s proposed service to Kona will satisfy 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 Proceeding.

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

the largest travel market for the Japanese visitors to the U.S. 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 underutilized 
DOT-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-2013A501. 

Kona in particular is a strong market – the island of Hawaii is easily 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. Nearly 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 Island, 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-509. And with nonstop service, Hawaiian would expect this traffic to grow 

significantly as markets gaining nonstop service typically 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 HNDKOA route would amount to over 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 existing 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, Hawaiian 

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 particular, the Department must 
DOT-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 State of Hawaii. Unlike United’s SFO proposal, Hawaiian’s Kona service 

focuses on bringing in spending to Hawaii and the United States and not exporting that spending 

to Japan or other destination countries. Money spent in the United States, and more specifically 

on the island of Hawaii, by Japanese passengers is the functional equivalent of increased 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-2013A105.

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 gateway. 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 service 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 economic 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 United’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 and 

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. SouthwestNortheast Service Case, 22 C.A.B. 973 (1955); New York-Florida Case, 24 C.A.B. 94 (1956). 

Recent proceedings confirm that the Department continues to weigh this factor heavily in its 

public interest analysis because strengthening smaller carriers remains the best way for the 

Department to enhance competition and reduce market concentration. 1998 U.S.-Brazil 

Combination Service Case, Order 98-12-33, at 8 (Dec. 29, 1998) (finding its selection of 
DOT-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 market 

that has not seen the entry of any new U.S. competitor since the year 2000.”)

This principle strongly favors an award of the frequency to Hawaiian. By comparison, 

United is 15 times the size of Hawaiian. See HA-2013A-113. 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 operated the awarded route 

successfully, but it used this operating base to build a successful scheduled service franchise in 

Japan. Hawaiian’s success surpassed the Department’s aspirations in its 2010 Order: 

“Hawaiian’s entry into the Japanese market should be a positive development, in terms of 

offering greater choice to travelers as well as increased competition in the U.S.-Japan market.” 

Order 2010-5-7 at 8. Hawaiian respectfully submits that Department should recognize the 

wisdom in its prior decision and build upon that success by awarding a second Haneda 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 

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

were conditioned on the United States and Japan entering into the Open Skies Agreement that 

made 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 oneworld alliances (of which, respectively, 

Delta, United and American are members) control 98 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 Haneda, 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 Northwest 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. DOJ & 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 this 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 slot pair to any of the 

other applicants would simply strengthen the alliances’ hold on the Japanese market, the grant of

Hawaiian’s application would double its service to Tokyo. Although even Hawaii-Tokyo service 

would still be dominated by the alliances, see Exhibit HA-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 experience 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 procompetitive, yet not immunized, codeshare 

 6

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

Antitrust Division typically assesses the competitive effects of concentration on a 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 resulted 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 

United, can bring the benefits of increased competition to U.S.-Japanese markets. 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-111. The public benefit of reducing 

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

expand upon its successful platform through the award of an additional slot at Haneda. 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 Is Independent of the Major Alliances, the Grant of 

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

Japanese Flag Carriers.

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

control of the routes to the Japanese flag alliance partners of American and United. American 

and JAL are part of the oneworld alliance, which received antitrust immunity in 2010. U.S.-

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

8 Because JAL took down its NRT-SFO service when it established HND-SFO, JAL was left 

with a single poor-performing daily service to the Bay Area. United’s proposed introduction of 

HND-SFO service threatens 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 oneworld and Star applications 

for antitrust immunity, the Department found the “intended commercial effects of the[se] . . . 

joint venture agreements are similar to those resulting from a merger.” Id. at 3 (emphasis 

added). As a result, the award of the slot pair to United 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 compromise in 

the MOU by which four Haneda slot pairs were to be allocated to Japanese carriers and four 

were to be allocated to U.S. carriers. The Star and oneworld alliances already hold five of the 

eight available slot pairs. The Department should take the opportunity 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 alliance 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 protecting 

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 Is 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 has 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-305, 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, especially because Hawaii’s three Haneda designations have generated almost as 

many Haneda passengers as all five of the other Haneda designations combined. See HA2013A-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 below, 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 

Highest Tokyo-U.S. Market Share.

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

proceeding. Like other markets 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 yearround 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 recently 

introduced 7 more weekly roundtrips to San Jose, which is well within the SFO catchment area. 

See HA-2013A-905. The market-based decisions of carriers currently serving the Bay Area from 

Tokyo demonstrate that the market cannot support additional capacity. See HA-2013A-114. 

ANA has added service to SJC, rather than SFO. Id. Delta has announced that it will drop SFONRT 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 and 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 market 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-2013A111. The Star Alliance also has the largest Tokyo-U.S. market share. See id. Awarding the slot 

pair to United serves to put capacity where it is not needed and grant additional authority to the 
DOT-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] competition in the U.S.-Tokyo market while failing to 

achieve the goal of “address[ing] the need for U.S.-Haneda service in the largest mainland U.S.-

Tokyo O&D markets,” given the existing surplus of HND-SFO service. Order 2010-5-7 at 8.

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

successful. JAL’s service has been plagued by unused capacity and a surplus of seats. See HA2013A-409. JAL’s SFO service has the lowest load factor of any Haneda gateway besides 

Delta’s failed Detroit service and American’s abandoned JFK service, see 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-2013A-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-2013A111. 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 United’s candor in admitting that the 
DOT-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 factors, 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.

United’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 data 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 nonexistent. 

See id. In the last year, only 7,313 passengers flew to all of those connecting cities. See HA2013A-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 long-term basis. See HA2013A-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 years 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 addition, the Kona 
DOT-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 Its Haneda Service a Success.

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

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

commitments to that airport. United and ANA operate 45 segments from Narita, including 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 Narita 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 suspensions 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 promote, sell 

and operate its service at the airport. As a result, its service is additive to the capacity of the 

Tokyo-U.S. market, which has led to an expanding Tokyo-Honolulu market and a superior 

operating record at Haneda. 
DOT-OST-2010-0018

2013 Answer of Hawaiian Airlines, Inc.

Page 48 of 49

VI. Hawaiian Offers Superior Customer Service.

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

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

United on a plethora of important customer service metrics. In the 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 market 

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

bberlin@dowlohnes.com

Counsel for Hawaiian Airlines, Inc.
CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Answer of Hawaiian Airlines, Inc. was 

served this 9th day of December 2013 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.sinick@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 4th 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 Poor Predictor of Haneda Success (Exhibit 101)

• High Tokyo Point-of-Sale is a Strong Predictor 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 Hawaiian Than it is to United/Star (Exhibit 109)

• The Star Alliance Already Has Both the Largest SFO – Tokyo Share and the Largest U.S. to 

Tokyo Share (Exhibit 110)

• Hawaiian Will Operate the Largest 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 operating 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-April 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 Operated 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 THAN 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 Travel 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 smaller 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 awarded frequencies. (Exhibit A-207)

• Hawaiian transported 156,733 passengers 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 1
80%

0%

20%

0%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

Star

SkyTeam/1

oneworld

Hawaiian

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%

Star

SkyTeam

oneworld

Hawaiian

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 Hawaiian and were unable to 

sustain HND service at their awarded gateways
REAL WORLD ROUTE DECISIONS 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 too 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 Competitive 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 That 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 – Cumulative 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 ‘14
Hawaiian

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 California than it Was in the Last Haneda Case 

(Exhibit 304)

• The Hawaii-Tokyo O&D Market is Nearly Twice the Size of California With the Same 

Number of Haneda Designations (Exhibit 305)

• The Hawaii-Tokyo O&D Market is Much Larger than the Second Largest U.S. State 

(Exhibit 306)

• The Hawaii – Tokyo Market is Growing Faster 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% Larger Than All Other States Combined 

(Exhibit 310)

• The Hawaii-Haneda O&D Market is Over Twice 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 Gateways Combined (Exhibit 312)
HAWAII IS THE LARGEST U.S.-JAPAN PASSENGER MARKET

2,991,157

2,443,142

776,336

629,329

511,143483,060

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 expanded to account 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

Hawaii

California

New York

Washington

Nevada

Illinois

Texas

Florida

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 expanded to account 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

346,294
193,159

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 expanded to account 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 expanded to account 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 New Tokyo O&D Passengers Than All the 

Other U.S. - HND Gateways Combined (Exhibit 403)

• Hawaii Had the Highest Tokyo Point of Origin Percentage of All Haneda Gateways 

(Exhibit 404)

• The Hawaii – Haneda Market Utilized Its Capacity More Efficiently Than Mainland –

Haneda Markets (Exhibit 405)

• The Three Highest Haneda Carrier Load Factor Segments Were All From Hawaii 

(Exhibit 406)

• Many Hawaiian HNL-HND Flights Operated at Capacity (Exhibit 407)

• JAL Experiences Its Lowest U.S.-Tokyo Load Factor at SFO (Exhibit 408)

• SFO-HND Operated With Nearly 50,000 Empty Seats (Exhibit 409)

• In September 2013 JAL Began Using Its Smallest 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 From 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 expanded to account 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 expanded to account 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%

HNLNRTHNLHNDLAXNRTGUMNRTHNLNGOHNLKIXORDNRTJFKNRTBOSNRTSFOHND

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 1
245 245 245 245 245

186

245 245

186

245

186 186

0

50

100

150

200

250

300

January

February

March

April

May

June

July

August

September

October

November

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 HHNLH AHNL-JL LAXN HLAX-DL SFO-JL DTWD LJFKA 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 4TH HANEDA FREQUENCY
500 Series Exhibits

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

Exhibit HA-2013A-500

Docket OST-2010-0018

Page 1 of 1

• Kona is the Only New Tokyo Gateway Proposed in This Proceeding (Exhibit 501)

• Kona is the Second Largest U.S. Market Without Nonstop Service to Tokyo (Exhibit 

502)

• Kona is the Second Largest Point of Sale Japan Market Without Nonstop Service to 

Tokyo (Exhibit 503)

• Despite Not Having Nonstop Service to Tokyo, Kona Has More Point of Sale Japan 

Passengers Than Thirteen Markets With Tokyo Nonstop Service (Exhibit 504)

• Kona, Like the Very Successful Honolulu Service, Has a Very High Percentage of Point 

of Sale Japan Passengers (Exhibit 505)

• The Big Island is the 2nd 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 Visited 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 Similar Onboard Passenger Numbers to HA’s 

Successful HNL-HND Service (Exhibit 511)

• Kona Will Outperform Current/Previous Single-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 expanded to account 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 expanded to account 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 SERVICE 54,057 48,467 35,371 27,407 10,092 8,899 57,415 26,405 11,028 20,545 19,991 21,088 16,49822,530

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 expanded to account 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 2nd 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 Hawaii Island where Kona is located.

Source: State of Hawaii Department of Business, Economic Development, and Tourism, 2012 Annual 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 Hawaii Island where Kona is located.

Source: State of Hawaii Department of Business, Economic Development, and Tourism, 2012 Annual Visitor Research Report.

Exhibit HA-2013A-507

Docket OST-2010-0018

Page 1 of 1

/1
Big 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 Annual Visitor Research Report.

Exhibit HA-2013A-508

Docket OST-2010-0018

Page 1 of 1
203,009

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 BAY AREA WITH 6 DAILY NONSTOPS

Daily Nonstop: 0 6

Source: State of Hawaii Department of Business, Economic Development, and Tourism, 2012 Annual 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 operated 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

/2
Source: U.S. DOT, T-100 Data, YE November 2011and Exhibit 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 1st 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 1st Year of Service
160,664

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 Data and Exhibit 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 Data and Exhibit 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 Japanese 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 for 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 Highest 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 Stimulation (Exhibit 620)

• Calculation of SFO Stimulation (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 Visitors at destination with all values updated to 2013 using GDP price deflator. 

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

Overseas And Mexican Visitors To California (2011), Visit California, August 2012;

2012 Annual Visitor Research Report, State of Hawaii, Department 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 Travel 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 Travel 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 HAWAII GREW 20% FROM 2011 TO 2012

Source: U.S. Department of Commerce Office of Travel 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 Travel 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 Travel 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 Travel 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: Exhibit 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 multipliers from the U.S. Bureau of Economic Analysis.

Source: U.S. Bureau of Economic Analysis RIMS II Multipliers; 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 Japanese Visitors to the U.S. (Millions)

Note: Expenditures calculated using average 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 Multipliers; 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 multipliers from the U.S. Bureau of Economic Analysis.

Source: U.S. Bureau of Economic Analysis RIMS II Multipliers; 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 Japanese Visitors to the U.S. (millions)

Exhibit HA-2013A-612

Docket OST-2010-0018

Page 1 of 1

Note: Induced estimates calculated using standard multipliers from the U.S. Bureau of Economic Analysis.

Source: U.S. Bureau of Economic Analysis RIMS II Multipliers; Exhibits HA-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 multipliers 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 multipliers 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 Japanese Visitors to the U.S. (Millions)

Note: Expenditures calculated using average expenditures per visitor x estimated incremental 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 multipliers 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 Japanese Visitors to the U.S. (millions)

Exhibit HA-2013A-617

Docket OST-2010-0018

Page 1 of 1

Note: Induced estimates calculated using standard multipliers from the U.S. Bureau of Economic Analysis.

Source: U.S. Bureau of Economic Analysis RIMS II Multipliers; Exhibits HA-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 Expenditures 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 metropolitan 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* Onboard 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 throughout the Haneda cases. 
CALCULATION OF SFO STIMULATION

(A) Year Ended Apr. 2013 scheduled passenger service only from U.S. DOT, T-100 Data. 

(B) Current Seats from (A) adjusted to account for new UA service, discontinued DL SFO-NRT service, new NH SJC-NRT service and 

downgauged JL SFO-HND service. 

(C) (B)/(A) -1

(D) Uses standard DOT QSI formula: Stimulation = ((Future Seats/Current Seats)/(0.3741 + 0.5561(Future Seats/Current Seats)))/1.075. 

(E) Year Ended Apr. 2013 scheduled passenger service only from U.S. DOT, T-100 Data.

(F) (E) x (D)

* Includes HND and NRT.

1/ Assumes full additional flight and does not reflect UA’s suggested reduction 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 Exhibit 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 excluding 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 calculated 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 multipliers 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 Dominates 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 Dominates 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 (Current 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 Increased 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 Between 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 1
3,618

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. Subsidiary 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. Subsidiary carriers are included with the parent carrier.

Exhibit HA-2013A-704

Docket OST-2010-0018

Page 1 of 1
ANA

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 1
ANA

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 1
28 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 2
1,516

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. Markets with HHIs between 1500 and 2500 are considered 

“Moderately Concentrated”. Markets with HHIs above 2500 are considered “Highly Concentrated”. The U.S.-

Tokyo market has been transformed from Moderately Concentrated to Highly Concentrated.

* Includes HND and NRT.

Source: U. S. DOT T-100 data; U.S. Department of Justice & Federal Trade Commission, Horizontal 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 & Federal Trade Commission, Horizontal 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. Markets with HHIs between 1500 and 2500 are considered 

“Moderately Concentrated”. Markets with HHIs above 2500 are considered “Highly Concentrated”. The U.S.-

Tokyo market has been transformed from Moderately Concentrated to Highly Concentrated.
800 SERIES:

HAWAIIAN’S RECORD OF OUTSTANDING PERFORMANCE
800 Series Exhibits

HAWAIIAN’S RECORD OF OUTSTANDING PERFORMANCE

• Hawaiian Has a Better On-Time Performance 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 Best On-Time Performance in the Industry

(Exhibit 805)

• Hawaiian Has Consistently Outperformed the Other Applicant Carriers in Terms of 

Mishandled Bags (Exhibit 806)

• Hawaiian Has Consistently Outperformed the 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 Consumer 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 Consumer 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 Consumer 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 Consumer 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 TERMS OF CUSTOMER COMPLAINTS

Note: The lower the ranking the fewest number of complaints per passenger.

Source: U.S. DOT, Air Travel Consumer Reports 2004-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 Commitment 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 Provides 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 Would Merely Duplicate JAL’s (Exhibit 907)

• Delta Already Offers Haneda Connections to Interior U.S. Points (Exhibit 908)

• United Proposes Miniscule Interior U.S. Benefits (Exhibit 909)

• Kona Has Over Twice as Many HND Passengers 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- Tokyo 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 IADEWR 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 KIJSDJ SDJ SDJ SDJ

NRT NRT NRT

SHE SHE SHE SHE CTS CTS CTS CTS

BKK BKK BKK BKK

BOM BOM BOM BOM

CCCCCCCDG DGDGDG

CGK CGK CGK CGK

DEL DEL DEL DEL

DLC DLC DEN DEN DEN DEN DLC DLC

FRA FRA FRA FRA

GUM GUM GUM GUM

HNL HNL HNL HNL

IAH IAH IAH IAH

ICN ICN ICN ICN ITMITMITMITM 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 gauged to smaller B787 with 

almost 100 fewer daily seats

• No commitment to continue 2nd 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 operated 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

MCI MCI MCI MCI CVG CVG CVG CVG

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 MINISCULE 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

Market Code Passengers U.S. Rank

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 roundtrip connections.

(tie)

(tie)

(tie)

(tie)

(tie)
KONA HAS NEARLY THREE TIMES AS MANY HND PASSENGERS AS 

ALL OF UNITED’S UNDUPLICATED ROUNDTRIP 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 downgauge, 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.