BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

______________________________ 

 ) 

In the matter of ) 

 ) Docket DOT-OST-2010-0018 

2010 U.S.-Haneda Combination ) 

Services Allocation Proceeding ) 

______________________________ ) 

ANSWER OF HAWAIIAN AIRLINES, INC.

Communications with respect to this document should be addressed to: 

Jonathan B. Hill 

J. Parker Erkmann 

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 

Counsel for Hawaiian Airlines, Inc. 

June 14, 2011 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

______________________________ 

 ) 

In the matter of ) 

 ) Docket DOT-OST-2010-0018 

2010 U.S.-Haneda Combination ) 

Services Allocation Proceeding ) 

______________________________ ) 

ANSWER OF HAWAIIAN AIRLINES, INC.

 Hawaiian Airlines, Inc. (“Hawaiian”) submits this Answer in response to the 

Motion of Delta Air Lines, Inc. (“Delta”) filed June 3, 2011 in the above-captioned 

docket. For the third time, Delta has requested relief from the dormancy condition 

applicable to its service from Detroit to Tokyo’s Haneda Airport. Specifically, Delta has 

asked the Department to grant it authority to stop and start the service at its discretion, 

calling for what appears to be unlimited “flexibility” in providing its proposed service 

between Detroit and Haneda. Conversely, Hawaiian has upheld the commitments it made 

in the route proceeding by initiating its Haneda service without delay and maintaining 

that service since its inception. In addition, consistent with its application for initial 

approval of the Haneda routing, Hawaiian remains willing to add an additional frequency 

between Haneda and Honolulu starting in December 2011. Hawaiian therefore opposes 

Delta’s third Motion for delay and requests that it be denied, while also requesting that 

the Department award the Haneda-Detroit frequency to Hawaiian for the additional 

Haneda-Honolulu service.1

                                                           

1

 Given the distribution channels within Japan, commencement of a second route to 

Hawaii from Haneda by December of 2011 is a significant and complex undertaking that 

usually would require several more months of preparation. Should DOT give it the 
2

Hawaiian Has Sought Two Daily Haneda Slot Pairs. 

 Since its initial application in this proceeding, Hawaiian has sought the award of 

two daily slot pairs for service between Haneda and Honolulu. See Application of 

Hawaiian Airlines, DOT-OST-2010-0018, (Feb. 16, 2010), at ¶ 5. Although the final 

order in this proceeding awarded Hawaiian only one daily slot pair, see Order 2010-7-2 

(the, “Final Order”), Hawaiian was the first U.S. carrier to start service to Haneda on 

November 17, 2010. Hawaiian also will be the first carrier to take advantage of the open 

skies opportunities to other Japanese destinations, commencing service from Honolulu to 

Osaka on July 12, 2011. 

 Of the carriers awarded a daily slot pair in the Final Order, Hawaiian is the only 

carrier that has not delayed and/or down-gauged its service in contravention of the 

commitments made in the route proceedings. Delta and American Airlines, Inc., the 

other two U.S. carriers awarded Haneda authority, delayed starting their service to 

Haneda. On September 7, 2010, Delta requested a 30-day extension of the start-up 

condition that the Final Order placed on its service between Haneda and both Detroit and 

Los Angeles. See Motion of Delta Air Lines for a 30-Day Startup Extension, DOT-OST2010-0018 (Sep. 7, 2010). On December 20, 2010, American requested a 28-day 

extension of the start-up condition on its service between Haneda and New York’s JFK 

airport in a “me-too” filing after the Department granted Delta an extension requiring 

them to start service no later than March 1, 2011. See Motion of American Airlines, Inc. 

for 28-Day Start-up Extension (JFK-Haneda), DOT-OST-2010-0018 (Dec. 20, 2010). 

                                                                                                                                                                                

opportunity, however, Hawaiian is prepared to start its additional service by December of 

this year. 
3

Each time, Hawaiian filed an answer informing the Department that it was ready to 

initiate a second Haneda to Honolulu daily flight should Delta or American fail to abide 

by the start-up conditions in the Final Order. See Answer of Hawaiian Airlines, Inc. to 

Motion of Delta for Startup Extension, DOT-OST-2010-0018, (Sep. 15, 2010); Answer 

of Hawaiian Airlines, Inc. to Motion to American for Startup Extension, DOT-OST2010-0018, (Dec. 21, 2010).2

 

 The Department granted the request of Delta and American for the initial delays. 

Hawaiian’s Commitment to its Haneda Service is Unique.

 Despite the effects of the March 11, 2011 earthquake and tsunami, Hawaiian has 

maintained its Haneda-Honolulu service at the levels and with the aircraft it committed to 

undertake in its original application to the Department. The other carriers awarded 

Haneda rights in the Final Order cannot make that statement. Even before the 

earthquake, Delta planned to reduce capacity on its Detroit-Haneda route by downgauging its aircraft from Boeing 747s to Boeing 777s,3

 reducing capacity by 

approximately 120 seats per flight. On or about March 17, 2011, Delta announced that it 

                                                           

2

 Hawaiian was not the only carrier concerned by the repeated requests for delay. On 

March 24, 2011, United filed a motion to be awarded backup authority given Delta’s 

repeated failure to start and continue service in a timely manner. Hawaiian also filed an 

application asking that it be awarded backup authority. See, Application and 

Consolidated Answer of Hawaiian Airlines, Inc. DOT-OST-2010-0018 (Apr. 7, 2011). 

3 See Things in the Sky – Delta Seeks Flexibility on Haneda Slots, USA TODAY (Jun. 6, 

2011), http://travel.usatoday.com/alliance/flights/boardingarea/post/2011/06/Things-inthe-Sky---Delta-Seeks-Flexibility-on-Haneda-Slots/173222/1). The pledge to use Boeing 

747 aircraft on the Detroit-Haneda route was a factor in the Department’s awarding the 

route: “Delta’s proposed use of B747 aircraft for its Detroit service would also maximize 

use of its hub gateway in serving Haneda, enabling it to accommodate traffic from both 

the Detroit-Tokyo local market and its catchment area.” Order 2010-5-7. 
4

was suspending its Haneda service as of March 24, 2011. American subsequently 

announced that it was also suspending its Haneda service. 

The Haneda-Detroit Service Is Not Viable. 

 Hawaiian has presented to the Department clear and convincing evidence that 

Delta’s Detroit-Haneda service, even prior to the earthquake, was not developing into a 

sustainable operation. As stated in paragraphs 5 and 6 of Hawaiian’s April 7, 2011 filing 

in this docket: 

Delta had over 10,000 advance bookings [from] Narita to Detroit, but only 

approximately 4,200 advance bookings to Haneda. See MIDT Advance 

Bookings Data for DTW-NRT and DTW-HND on Delta for March 2011 

(as of Feb. 28, 2011). Although Delta was offering service with the same 

aircraft capacity on both routes, its bookings to Haneda from Detroit were 

only 41.8% of its bookings to Narita from that same U.S. gateway. 

Moreover, given Delta’s load factors on its Detroit-Narita route in March 

2010, and assuming the same ratio of Haneda to Narita bookings for its 

flights from Detroit, Delta was facing the prospect of a dìsastrous 38% 

load factor for its Detroit-Haneda flights in March 2011. The outlook for 

those flights beyond March was similarly grim, as Delta’s total advance 

bookings for its Detroit Haneda flights for all periods after March were 

only 15.7% of its Detroit-Narita flights. In fact, Delta’s combined DetroitNarita and Detroit-Haneda bookings for March 2011 were only 5.5% 

higher than Delta’s March 2010 bookings for Detroit-Narita alone, even 

though Delta was offering twice as many seats in March 2011. This 

confirms Hawaiian’s earlier economic analysis in this proceeding that 

Delta’s Haneda service would simply shift passengers from its Narita 

flights and that operating to both Tokyo airports from Detroit would not be 

sustainable. Delta’s advance bookings for its Los Angeles-Narita and Los 

Angeles-Haneda flights paints a similarly grim picture of the lack of 

demand and unsustainability of Delta’s Los-Angeles-Haneda service. See

MIDT Advance Bookings Data for LAX-NRT and LAX-HND on Delta 

for March 2011 (as of Feb. 28,2011). 

Application and Consolidated Answer of Hawaiian Airlines, Inc. DOT-OST-2010-0018 

(Apr. 7, 2011), at ¶¶ 5-6 (footnote omitted). Delta has failed to present evidence that its 

Haneda-Detroit route will ever lead to a sustainable service. 
5

The Award of a Second Honolulu-Haneda 

Frequency is a Better Use of Valuable Haneda Slots. 

 Due to the lack of demand for Haneda-Detroit service (even prior to the 

earthquake and tsunami), the Department should reallocate that frequency. Even now, 

Delta cannot commit to operating that frequency in accordance with the Final Order’s 

grant of these rights. The Department accordingly should award that frequency to 

Hawaiian so it can initiate its proposed second service to Honolulu. Because of the 

strength of the Tokyo-Honolulu market and Hawaiian’s Haneda service in particular, that 

reallocation would be a better use of the scarce operating rights between Tokyo and the 

United States for several reasons. 

 First, as Hawaiian pointed out in the original proceeding, Honolulu is by far the 

largest gateway between Tokyo and the United States. See Consolidated Answer of 

Hawaiian Airlines, Inc., DOT-OST-2010-0018 (Mar. 1, 2010), at Exhibit HA-A-210 

(attached hereto as Exhibit HA-1) (stating that 25% of all Tokyo O&D passengers use 

Honolulu as their gateway). Honolulu is also the largest U.S. O&D passenger market to 

and from Tokyo. Id. at HA-A-211 (attached hereto as Exhibit HA-2). By comparison, 

Honolulu is more than 3000% larger than Detroit. See id. Given the overwhelming 

popularity of the Honolulu-Tokyo market, the award of a second daily slot pair to 

Hawaiian for an additional Honolulu frequency would be justified. 

 Second, even after the earthquake and tsunami, the Tokyo-Honolulu market 

remains very strong. As demonstrated in Exhibit HA-3, Honolulu bookings are down 

less in the Honolulu-Tokyo market than in the overall U.S.-Tokyo market. After an 

initial impact period, Hawaiian’s bookings for its Haneda-Honolulu service have not only 

rebounded but now exceed pre-earthquake levels. See Exhibit HA-4. Hawaiian is 


Docket OST-DOT-2010-0018 

HAWAIIAN AIRLINES, INC. 

EXHIBIT HA-1 
25% OF ALL U.S. – TOKYO O&D PASSENGERS 

USED HNL AS THEIR GATEWAY

HNL

25%

GUM

21%

LAX

13%

SFO

8%

JFK

6%

SPN

5%

IAD

2%

DTW

2%

SEA

2%

Others

10%

ORD

5%

Source: MIDT, via TravelPort, CY 2009.

Exhibit HA-A-210

Docket OST-2010-0018

Page 1 of 1

Page 63
Docket OST-DOT-2010-0018 

HAWAIIAN AIRLINES, INC. 

EXHIBIT HA-2 
HNL IS THE LARGEST U.S. O&D PASSENGER MARKET TO/FROM TOKYO

1.04

0.90

0.45

0.36

0.25 0.24

0.05 0.05 0.04 0.04 0.04 0.03

0.10 0.07

0.09 0.09 0.07

0.00

0.20

0.40

0.60

0.80

1.00

1.20

HNL*GUM* L.A.

Area*

NYC* Bay

Area*

SPN CHI LAS SEA* KOA IAD BOS MCO SAN ATL PDXDTW*

CY 2009 MIDT (Millions)

*Service to gateway requested by applicant carrier. L.A. Area includes LAX,BUR,ONT, and SNA. Bay Area = SFO, OAK, SJC.

CHI = ORD and MDW, NYC=EWR,JFK,LGA.

Source: MIDT, via TravelPort, CY 2009.

Exhibit HA-A-211

Docket OST-2010-0018

Page 1 of 1

Page 64
Docket OST-DOT-2010-0018 

HAWAIIAN AIRLINES, INC. 

EXHIBIT HA-3 
PASSENGER BOOKINGS BETWEEN HONOLULU AND TOKYO ARE DOWN 

LESS THAN THE U.S. AVERAGE CITED BY DELTA

Exhibit HA-3

Docket OST-2010-0018

-15%

-25%

-30.0%

-25.0%

-20.0%

-15.0%

-10.0%

-5.0%

0.0%

HNL-Tokyo Bookings /1 U.S. - Tokyo Bookings /2

% Year Over Year Change (June 2011 Compared to June 2010)

1/ MIDT, as of May 31, 2011. Includes passengers onboard NRT and HND flights.

2/ Docket OST-2010-0018, Motion of Delta Air Lines, June 3, 2011, Exhibit DL-1.
Docket OST-DOT-2010-0018 

HAWAIIAN AIRLINES, INC. 

EXHIBIT HA-4 
HAWAIIAN’S HANEDA SERVICE HAS FULLY RECOVERED

Exhibit HA-4

Docket OST-2010-0018

413

304

343

393

456

0

50

100

150

200

250

300

350

400

450

500

Prior Impact

Period

Rebound 1 Rebound 2 Rebound 3

Average Passengers Per Day

Source: Hawaiian Airlines.

(11/17-3/10) (3/11-5/19) (5/20 -6/2) (6/3-6/16) (6/17-6/30)