### BEFORE 

### THE DEPARTMENT OF 

### TRANSPORTATION OFFICE OF 

### THE SECRETARY 

### WASHINGTON, D.C. ) 2010 U.S.-Haneda 

## Combination ) Services 

### Allocation 

## Proceeding 

# ) Docket DOT-OST-2O10-0018 ) 

### CONSOLIDATED REPLY OF 

### HA\ryAIIAN AIRLINES. INC.
Communications 

### with respect 

### to this document should be addressed to: 

### Mark B.

# Dunkerley Jonathan B. 

### Hill President 

### & Chief Executive 

# Offìcer J. Parker Erkmann 

### Brent Olson 

### HoylH.

# Zia Dow Lohnes 

### PLLC Senior

### Vice President, General

## Counsel 1200 

### New Hampshire 

### Ave., 

### NW 

### & Corporate 

# Secretary Suite 800 

# Hoyt.Zia@hawaiianair.com Washington, 

### DC 20036 (202) 716-2000 

### Mark K.

# Arimoto (202) 776-4725 

### (fax) Associate General

# Counsel jhill@dowlohnes.com 

## Mark.Arimoto@hawaiianair.com perkmann@dowlohnes.com bolson@dowlohnes.com 

### Hawaiian 

### Airlines, Inc. P.O. 

### Box

# 30008 Counsel 

### for Hawaiian 

### Airlines, Inc. 

### Honolulu, 

### HI 96820-0008

September 

### 73,2012)

2010 U.S.-Haneda 

## Combination ) Services 

### Allocation 

## Proceeding ) 

### BEFORE THE 

### DEPARTMENT OF

### TRANSPORTATION OFFICE OF 

### THE SECRETARY 

### WASHINGTON, D.C. 

### DOT-OST-2010-0018

2012 

### Reply of Hawaiian 

### Airlines, Inc. Page 

## I of 12

Docket DOT-OST-2O1 0-001 8 September 

### 13,2012



### CONSOLIDATED REPLY OF 

### HA\ryAIIAN AIRLINES, INC. It is clear 

### from the

### four applications and subsequent answers that the Department faces a choice between 

### just two 

### options. It can grant 

### Hawaiian's Kona 

### application 

### with 

### fuIl confidence that, based upon the past 

### two years' experience, the last 

### remaining frequency 

### to Haneda 

### will be put 

### to its highest and best 

### use. This choice 

### would confirm 

### DOT's commitment 

### to strengthening 

### small carriers, increasing 

### competition 

### in a 

### highly concentrated market, 

### avoiding duplicative service proposals, creating new nonstop service, 

### promoting economic 

### growth, and, most 

### importantly, awarding slots where the proposed service

### will be sustainable. Or, the Department can grant the 

### application 

### of any 

### of the three alliance carriers 

## - which each seek

### to serve markets already 

### swollen

### with
excess 

### capacity. Then, 

### with the certainty that the past 

### two years' experience brings, the Department can 

### look forward to a delayed start 

### of the awarded service, 

### followed by 

### low load factors and repeated cancellations that 

### ultimately 

### will lead to either suspension 

## of the awarded service or yet another request 

### to change the gateway to Haneda.DOT-OST-2O10-0018 

### 20i2 Reply of Hawaiian 

### Airlines, Inc. Page2 

### of 12 These alliance carriers, 

### which operate 

### in an 

### oligopolistic market where 

### their alliances 

### control 97 percent 

### of the 

### United States-Tokyo frequencies, nevertheless clamor 

### for more Haneda service even though the record establishes their proposals 

### will result 

### in mediocre, 

### if not unsustainable, load 

### factors. Undaunted by the facts, every 

### oligopoly
carner continues 

### to assert that the connecting service

### to its proposed gateway 

### will make 

### its application a success 

### while the others' proposed connecting service and gateways are doomed 

### to

### failure. In doing so, they ignore what the last 

### two years' operating experience at Haneda has taught

## - connecting service 

### is of negligible importance to Haneda customers. 

### Accordingly, the alliance 

### carriers' proposals do not 

### offer measurable 

### public interest benefits, 

### while the selection 

### of Hawaiian's Kona service 

### will help ameliorate the 

### significant market 

### power wielded 

### by the three alliances 

### in the 

### U.S.-Tokyo market. 

### In contrast 

### to Hawaiian's application, the 

### oligopoly carriers include no evidence whatsoever that 

### their proposed routes 

### will create any economic benefit to the 

### United States. 

### Significantly, they make no attempt to rebut the

### viability or substantial economic benefits 

### of Hawaiian's proposal, 

### which 

### will result 

### in real, certain and measurable benefits to 

### Hawaii and the 

### United States as a

### whole. Rather, they attempt 

### to deride 

### Hawaiian's proposal because 

### it offers few connections, yet ignore the fact that the Haneda-Kona market has strong, 

### proven demand. The 

### irrefutable fact is that, 

### of all the gateways proposed 

### in this proceeding, the greatest demand 

### is

### for service to 

### Hawaii, and the
answers 

### in this proceeding do not contest the fact that 

### this demand 

### will drive significant economic benefits, 

### including more 

### jobs and increased spending 

### in Hawaii and the 

### United States.DOT-OST-2010-0018 2012 

### Reply of Hawaiian 

### Airlines, Inc. Page3 

### of 12 Given the record 

### in this proceeding, 

### DOT should choose the 

### only viable 

### option and select 

### Hawaiian's route, the largest market 

### in this proceeding 

### not served by nonstop service between the 

### United States and Japan. 

# I. Full Airplanes and U.S. 

### Economic 

### Growth 

### Are in the 

### Public Interest. Hawaiian's proposed service

### to Kona 

### will serve the 

### public interest best because 

## it offers what none 

### of the other proposed services can

## - a sustainable volume 

### of passengers, day 

### in and day

### out. Flying 

### full airplanes is at the heart 

### of the Department's 

### public interest 

### analysis. Absent a

### viable, sustainable demand 

### for service, other 

### public interest goals are 

### only 

### illusory and cannot be 

### achieved. 

### With the Kona-Haneda market, there can be no question that strong demand 

### exists. Accordingly, the Department can

### fulfill
numerous other 

### public interest goals through an award 

### to Hawaiian, 

### including: new nonstop service; reduced concentration 

### in the U.S.-Japan market and increased 

### competition; strengthening the smallest competitor 

### (by far) in this proceeding; 

### avoiding handing the 

### benefit of the sole slots at issue to the Japanese carriers 

### who are aligned 

### with two of the other 

### U.S. applicants; and creating enonnous economic 

### growth during a

### time when every 

### job counts. See, e.g., Consolidated 

### Answer of Hawaiian 

### Airlines, Inc., OST

### 2010-0018, at7-18 (Sept. 

### 6,2012) ("Answer of 

### Hawaiian"). These are all 

### significant public interest 

### benefits, and are achievable 

### only because there 

### is ample passenger demand 

### for service between Haneda and Kona. None 

### of the other applicants disputes the

### viability of Hawaiian's Kona service. 

### To the contrary, 

### Delta even acknowledges that 

### "Haneda-Hawaii service is an attractive commercial 

### proposition 

### for carriers." Consolidated 

### Answer of Delta

### Air Lines, Inc., OST-2010-0018, 

### at 11 

### (Sept.6,2012) 

### ("Answerof Delta"). NorcantheydisputetheDOT-OST-2010-0018 2012 Reply 

### of Hawaiian 

### Airlines, Inc. Page 4

### of 72 substantial 

### financial benefits that 

### Hawaiianls Kona service is projected 

### to generate: $73.8 

### million in new exports 

### annually; an 

### additional $135 

### million in U.S. GDP growth; 1,400 U.S. 

### jobs, and a $39 

### million increase 

### in aggregate U.S. household earnings. 

### Exhibits 

### HA-2012A-402,403,404,405. None 

### of the other applicants 

### claim that any comparable economic benefits 

### will result from their proposed service.l 

### In fact, the

### few 

### trivial, non-substantive 

### criticisms of Hawaiian's proposed service that the other applicants muster up 

### simply 

### highlight the 

### overwhelming strength

### of Hawaiian's proposal. For example, 

### American and 

### United attempt 

### to dismiss 

### Hawaiian's Kona service because 

### it

### will feature 

### only 

### two connections. Answer 

### of American Airlines, Inc., OST-2010-0018, at 7 (Sept. 

### 6,2012) ("Answer of American"); Consolidated 

### Answer of United

### Air Lines, 

### Inc., OST-2010-0018, at 8 (Sept. 

### 6,2012) ("Answer 

### of United"). But as the record establishes 

### irrefutably, the success 

### of Haneda service does 

### not depend on connecting 

### service. The experience 

### of both Delta at 

### Detroit and Los Angeles and

### American at 

### New 

### York amply demonstrates the 

### point. None 

### of these

1The 

### Hawaii Tourism 

### Authority has undertaken a separate estimate 

### of the economic impact 

### of Hawaiian's proposed service

### to Kona, and 

### its conclusions 

### affirm Hawaiian's analysis: Number 

### of statewide 

### jobs supported 

### (direct, indirect and 

### induced): 1,571 

### jobs (may not be 

### all new 

### jobs) state govemment tax revenue generated (direct, 

### indirect and 

### induced): $14.88 

### million Total direct 

### visitor expenditures: $136.61 

### million. Notes: Economic 

### impact is 

### inclusive of 

### visitor spending, 

### jobs and tax revenues at a statewide 

### level. HTA's economic impact 

### model only tracks state 

### level tevenue at this 

### time. Estimates were 

### provided 

### in an 

### email from 

### Momi Akimseu, Hawaii Tourism 

### Authority to 

### Ann 

### Botticelli, Hawaiian 

### Airlines, Inc. (Sept. 

### 5,2012).DOT-OST-2O10-0018 2012 Reply 

### of Hawaiian 

### Airlines, Inc. Page 5

### of 12 markets have performed as

### well as 

### Hawaiian's Honolulu-Haneda 

### flight, a market 

### with limited connecting 

### service. Hawaiian's Kona flights, like its Honolulu flights, 

### will be 

### filled with the substantial Haneda-Kona 

### O&D traffic and

### without the supposed benefits 

### of connecting traffi 

### c. Exhibits 

### HA-20I2 A-203, 204, 205. 

### All three applicants also discount 

### Hawaiian's Kona proposal due to the 

### high level of Japan 

### point of sale passengers 

### in the 

### Tokyo-Kona 

### market. See, e.g., 

### Answer of Delta, at

### 4. However, because success 

### in the Haneda market has proven 

### highly correlated 

### with Japan 

### point of sale passengers, this supposed weakness is actually one 

### of Kona's greatest 

### strengths. ,Se¿

## ExhibitH{-2}I2[-101. The experience 

### of the last 

### two years makes this fact 

### unassailable. Further, the Department recognizes that economic development generated 

### by foreign tourists 

### traveling to the U.S. 

### is an 

### affirmative public interest factor, and not the strike against 

### Hawaiian's application that the other applicants seek to charactenze 

### it as. See Order 2010-5-7 at 9 

### (May I 

### ,2070) ("The Department has 

### previously found benefit 

### to the 

### Hawaiian economy 

### to be an 

### affìrmative public interest factor 

### worthy of decisional 

### weight 

### in our regulatory proceedings"); Expanded 

### Air Services at 

### Høwaii International 

### Airports, Order 99-12-70, at 4 

### (Dec. 10, 1999) 

### ("We find that 

### our actions are consistent 

### with the 

### public interest, asthey

### will provide important benefits 

### to the State 

### of Hawaii, its economy, and the 

### traveling and shipping 

### public."). Only Hawaiian has presented the Department 

### with evidence 

### of the economic benefits 

### of its application. The alliance 

### carriers' definition of public benefit appears to be premised on the 

### notion that the award must derive 

### from the carnage 

### of U.S.-originating passengers. Such
a 

### naffow interpretation 

### of the statute is inconsistent 

### with past decisions 

### of theDOT-OST-2010-0018 2012 Reply 

### of Hawaiian 

### Airlines, Inc. Page 6

### of 72 Department, such as the Department's 2010 award 

### of a single Haneda frequency to 

### Hawaiian in this docket, 

### but also disregards the fact that 

### foreign originating passengers spend money 

### in the 

### United States and 

### drive economic growth. 

### In addition, 

### American and Delta assert 

### it would be 

### "unfair" for 

### half of the eight U.S.-Haneda frequencies 

### to be used 

### for service

### to 

### Hawaii. This argument smacks 

### of hlpocrisy 

## - American and 

### United are both seeking

### to add a

### fourth frequency to 

### California, even though the 

### Hawaii market 

### is 63 percent larger than 

### Califomia's and yet possesses 

### only three 

### frequencies. Se¿ 

### Exhibits 

### HA-2012R-107,108. In any event, 

### their argument is belied by the record, 

### which establishes that 

### Hawaii 

### fully deserves at least 

### four frequencies (U.S. and Japanese) due 

### to strong demand 

### for 

### Hawaii-HND flights and weak demand 

### for mainland-HND 

### flights. Hawaii generated 514,465 

### HND O&D passengers

### with three frequencies 

### in the year ended June

### 2072. By contrast, the mainland mustered only 420,366 

### HND O&D passengers 

### with five frequencies 

## - less than 

### half the passengers per frequency 

### of the 

### Hawaii designations. See 

### Exhibit 

### HA-2012R-101. In addition, the Hawaii-Haneda market 

### utilized its capacity more 

### efficiently than U.S. mainland-Haneda as evidenced 

### by a Hawaii-Haneda load factor 

### of 78 percent compared 

### to a load factor 

### of 67 percent 

### for the U.S. mainland-Haneda 

### routes. ,See 

### Exhibit HA20t2R-102. Faced 

### with this stagnant demand 

### for mainland-Haneda 

### flights, the U.S. 

### oligopoly carriers cancelled more than 57 percent 

### of their 

### flights and downgauged

### their aircraft. 

### SeeExhibitH1'-20124-107, 807. Even 

### with these drastic steps, nearly 200,000 out 

### of 594,000 total 

### mainland seatswere empty, and the mainland load factors 

### were only 67DOT-OST-2O10-0018 2012 

### Reply of Hawaiian 

### Airlines, Inc. PageT 

### of 12 percent, 1 1 percent 

### lower than the 

### Hawaii load 

### factors. See 

### Exhibits HA-2012R-102,

10s. These load factors 

### for the other applicants are 

### not sustainable and, even

### with an award to 

### Hawaiian for service 

### to Kona, are 

### likely to get worse, not 

### better. Specifically,
were the other carriers 

### to live up to their 

### prior stated commitments 

### in 2013 

### by 

### flying the 

### four remaining mainland frequencies 

### daily and 

### with the size 

### of aircraft promised, they 

### would add more than 400,000 additional 

### mainland-HND seats, 

### for atotal 

### of 961,980. See 

### Exhibits HA-2012R-103, 104, 

### 105. But the entire 

### mainland-HND market has proven to be 

### only 400,000 annual passengers, the same as

### the capacity lost to cancellations and 

### downgauging. See

## id. Accordingly, to achieve sustainable load factors the mainland

### HND would have 

### to grow at an 

### astonishingT0 to 96 

### percent. See 

### Exhibit HA-2012R

### 106. Again, these 

### dire forecasts assume that 

### Hawaiian's application 

### is granted; the numbers 

### would be even more catastrophic should 

### DOT grant one 

### of the mainland applications 

### with the 

### resulting five mainland-HND frequencies. The market has spoken 

### clearly here

## - there are too many 

### mainland-HND flights being offered by the alliance carriers.

### Finally, Delta and 

### United make the 

### ridiculous suggestion that 

### Hawaiian could and should 

### offer its service 

### from Narita instead 

### of Haneda because the Open Skies Agreement 

### allows unrestricted access to 

### Narita.2 Delta and 

### United's 

### "invitation" to

### join them at 

### Narita is a self-serving gesture, 

### devoid of a 

### realistic consideration 

### of such an option. 

### First and foremost, the

### oligopoly carriers' interconnected web 

### of service dominates the

2

### This suggestion ignores the considerable 

### difficulty in obtaining operational slots at 

### Narita, which by itself is a 

### significant barrier 

### to entry 

### into this airport.DOT-OST-2O1 0-00 I 8 2012 Reply 

### of Hawaiian 

### Airlines, Inc. Page 8

### of 12 U.S.-Japan market 

### from 

### Narita. They have defacto 

### control of the 

### airport and 

### its gates. 

### Oneworld (American) offers 444 

### weekly roundtrip Narita 

### flights; Skyteam (Delta) offers 382 

### weekly Narita roundtrip 

### flights; and Star

### Alliance (United) offers 687 

### weekly Narita roundtrip 

### flights. ,Se¿ 

### HA-Exhibit HA-20124-106. Their dominance 

### is so pervasive that 

### they control 99 percent 

### of the capacity between 

### Narita and the 

### United States and

### fly over 1,500 frequencies 

### overall per week 

### from the 

### airport. ^lee 

### ExhibitHL-20124-501, 106. The alliance carriers also dominate the huge 

### Tokyo-Honolulu market, 

### flying 

### all64 of the 

### weekly round 

### trip flights between 

### Narita and 

### Hawaii. ^Se¿ 

### ExhibitH{-2012R-109. Even accounting 

### for Hawaiian's existing Haneda-Honolulu service, the alliances dominate the 

### Tokyo-Hawaii market, 

### controlling 92 percent 

### of the capacity. ,lee 

### Exhibit HA-2012A-505. Operating a single 

### flight a day 

### from the hub 

### of entrenched incumbents 

### in a market so concentrated makes no business 

### or economic sense. 

### Offering Narita service

### would not 

### only require 

### Hawaiian to incur duplicative startup expensesto those 

### incurred at Haneda, but 

### it would put Hawaiian in the same 

### conflicting position, which all three 

### of the other applicants face, 

### of having to compete against 

### its own 

### Narita flights 

### for Tokyo passengers. 

### By contrast, Haneda 

### offers a 

### relatively level 

### playing 

### field where 

### all U.S. carriers are on 

### similar footing and none has an advantage 

### of having established 

### their presence at the 

### airport as 

### long ago as

### the 1950s. Hawaiian's Haneda service has 

### flourished, and its lack 

### of Narita service frees 

### it to focus 

### exclusively on Haneda and avoid the 

### conflicted positions that the alliance carriers have, where expanding service atDOT-OST-2O 10-001 8 2012 

### Reply of Hawaiian 

### Airlines, Inc. Page 9

### of 12 Haneda 

### only serves to reduce 

### their service at 

### Narita. Hawaiian 

### will accordingly decline the spiders' 

### invitation to enter 

### their web.3 

# il. Not 

### in the 

### Public Interest 

## - Empty Seats 

### and Cancelled 

### Flights. Hawaiian's answer exhaustively detailed the flaws 

### in the 

### oligopoly carriers' proposals, and so 

### Hawaiian

### will not recite those flaws here

### too. Simply put, none

### of other proposed gateways 

### will stimulate enough passengers 

### to create sustainable load 

### factors. Even 

### with stimulation the 

### LAX-Tokyo estimated load factor is 

### only 73 percenta 

### with American's service,

### while SFO-Tokyo 

### with United and 

### SEA-Tokyo 

### with Delta have estimated load factors 

### of 66 percent and 59 percent, 

### respectively. See 

### Exhibits 

### HA20I2A-711 

### (AA), 816 

### (DL), 913 

### (UA). These 

### low load factors are 

### simply unsustainable, especially since Japan-mainland 

### traffic is decreasing. See 

### Exhibit 

### HA-20I2A-305. The 

### oligopoly carriers' answers each 

### point to one or more 

### ancillary public interest factors that they 

### claim to 

### meet. Yet the 

### public interest factors they cite 

### provide far greater support 

### to Hawaiian's application than 

### their 

### own. For instance, 

### in opposing 

### American's 

### LAX application, 

### United correctly asserts that 

### "the Department looks 

### unfavorably on 

### duplicative service proposals 

### in limited-entry route proceedings."

3

### Th" ans*ers of the alliance carriers attempt to make a something out 

### of a non-issue, the 

### availability of CBP 

### facilities at 

### Kona. The 

### airport has been and continues to be used to accommodate 

### intemational air carrier operations 

### from Japan as recently as

### August. 

### JAL has used 

### Kona for numerous charters, and 

### Hawaiian 

### will be using the 

### airport for charter service

### this coming

### fall. Moreover, the state 

### of Hawaii has committed to invest $500 

### million in upgrading the

### facilities at 

### Kona International

### Airport. See 

### Hawaii's 8500M 

### planfor Kona 

### aìrport includes medical 

## ffice space, 

### Pacific Business News 

### (Aug. 30, 2012) 

### (available at: 

### http://www.bizjournals.com/pacific/bloe/morning call/2012l08/hawaiis-50Om-plan-for

### kona-aimort.html). a

### American's 

### HND-LAX load factor 

### would be 56 percent based on 

### Deita's experience at 

## LAX. S¿¿ 

### ExhibitH{-2012^-706.DOT-OST-2O10-0018 2012 

### Reply of Hawaiian 

### Airlines, Inc. Page 10

### of 12 

### Answer of United, at

### 9. This is somewhat 

### hypocritical. Though 

### American is seeking to add a

### third 

### HND-LAX frequency 

### (in addition to 53 

### NRT-LAX weekly round trips), 

### United's choice, San Francisco, also already has a Haneda frequency and 33 

### NRT weekly round

## tips. See 

### Exhibit HA-2012A-201 (depicting total weekly frequencies 

### from Tokyo, 

### including 14 

### weekly 

### HND round 

### trips to 

### LAX and 7

### weekly 

### HND roundtrips 

### to SFO). Even Seattle already has

## 2l NRT weekly round 

### trips. See

### id. Of the 

### four gateways at issue 

### in this proceeding, 

### only one has no 

### duplicative service 

## - Kona. 

### Delta 

### similarly asserts that 

### "the Department has 

### long emphasized the importance 

### of 'provid[ing] consumers 

### with the special convenience 

### of nonstop service 

### in a market that does not receive 

## it."' Answer of Delta, at 9 

### (quoting Order 98-12-33 at

### 7). But Seattle already has 21

### weekly nonstop 

### flights to 

### Narita 

### Tokyo. See 

### ExhibitH$-2}L2\- 201. By contrast, 

### only one gateway at issue is 

### truly lacking the "special convenience

## of nonstop service" 

## - Kona. The 

### introduction of nonstop service on a route 

### typically generates a 

### significant increase 

### in

### traffic. Accordingly, the impact 

### of nonstop service on
a

### tourist-centric destination 

### like Kona 

### will be 

### immense. Even assuming a conservative 

### level 

### of stimulation, Kona service 

### will result 

### in more money, more 

### jobs, and more 

### growth than any other proposed 

### gateway. See 

### Exhibits 

### HA-2012A-402,403,404,405.DOT-OST-2O10-0018 

### 20i2 Reply of Hawaiian 

### Airlines, Inc.



## Pagellof12

Conclusion For the foregoing reasons, Hawaiian 

### respectfully requests that the Department deny the other three applications and award 

### Hawaiian the 

### daily slot 

### pair to operate 

### daily combination service between Haneda and Kona, 

### Hawaii. 

### lly submitted,

nathan B. 

### Hill J. Parker Erkmann Brent Olson 

### Dow Lohnes 

### PLLC 1200 

### New Hampshire 

### Ave., 

### NW Suite 800 Washington, 

### DC 20036 (202) 776-2000 (202) 716-4725 

### (fax) jhill@dowlohnes.com perkmann@dowlohnes. com bolson@dowlohnes.com Counsel 

### for Hawaiian 

### Airlines, lnc.

### DOT-OST-2010-0018 2012Reply of Hawaiian 

### Airlines, Inc. Page 12 

### of 12



### CERTIFICATE OF SERVICE I hereby 

### certify that a copy 

### of the 

### foregoing Consolidated 

### Reply of Hawaiian 

### Airlines, Inc. was served 

### this 13tn day 

### of September 2012 via email transmission or U.S. 

### mail on the

### following: Carl.nelson@aa.com 

### Robert.wirick@aa.com Francis.heil@aa.com James.kaleieh@aa.com Marshall. sinick@squiresanders. com Edward. sauer@squiresanders. com Sascha.vanderbellen@delta. com Jeff.morqan @delta. com Sametta. c.barnett@delta. com Tim. OMalle)¡@alpa.org Dan.weiss@united.com Steve.morri sse)¡@united. com Jonathan. linde@united. com 

### rbkeiner@crowell.com lhalloway@cromwell. com 

### gmurphy@crowell.com esta.rosenberg@dot. gov 

### brett.kruger@dot.sov urskr@state.qov iohn.allen@faa.gov 

### William. stallin gs@usdoj. eov 

### info@airlineinfo.com Ambassador 

### Ichiro Fujisaki Embassy 

### of Japan 2520 Massachusetts 

### Ave., 

### NW Washington, 

### DC 20008

### INDEX OF EXHIBITS Exhibit Number Description No. of Pages Exhibit HA

-2012R

-101 The Hawaii

–HanedaMarketHas A Far Greater Need ForAdditional Service Than The Mainland

– HanedaMarket 1

Exhibit HA

-2012R

-102 TheHawaii

–Haneda Market Utilized Its Capacity MoreEfficientlyThan Mainland

–Haneda Markets 1

Exhibit HA

-2012R

-103 Even Without Detroit,Mainland

–HanedaWill Have 255,590 More Cy 2013 Seats Than In Ye Feb. 2012 1

Exhibit HA

-2012R

-104 If Delta Operated Its Promised 747 From Lax, Mainland

–HanedaWould Have 373,850 More Seats Than In Ye Feb. 2012 Even Without Detroit 1

Exhibit HA

-2012R

-105 The Mainland

–Haneda Market Does Not Need And Cannot Support Another Service 1
Exhibit HA

-2012R

-106 TheMainland

–HanedaWould Have To Grow 70%

-96% OverYe February 2012 Levels To Fill 80% Of Scheduled Seats 1

Exhibit HA

-2012R

-107 TheHawaii

–Tokyo O&D MarketIs Nearly Twice The Size Of CaliforniaWith The Same Number Of Haneda Designations 1

Exhibit HA

-2012R

-108 TheHawaii

–HanedaO&D MarketIs Nearly Twice The Size Of CaliforniaWith The Same Number Of Haneda Designations 1

Exhibit HA

-2012R

-109 The Three Alliances Operate EveryFlight In The Narita

–HawaiiMarket 1

### 420,366 514,465

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

Hawaii U.S. Mainland 

### YE June 2012 Haneda MIDT Passengers

Note: Includes an adjustment to MIDT to reflect direct bookings. For purposes of comparability HA has used DL’s 35% MIDT adjustment factor. Source: MIDT, via Travelport. 

### HND Designations: 

## 3 5 Ave. Passengers per Designation: 171,488 84,073 Exhibit HA-2012R-101 Docket OST-2010-0018 Page 1 of 1



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

## THE HAWAII – HANEDA MARKET UTILIZED ITS CAPACITY MORE EFFICIENTLY THAN MAINLAND – HANEDA MARKETS

78% 67%

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

Hawaii Mainland 

### HND Load Factor– 12 Months Ended February 2012

Source: U.S. DOT, T-100 Data. Exhibit HA-2012R-102 Docket OST-2010-0018 Page 1 of 1

## EVEN WITHOUT DETROIT, MAINLAND - HANEDA WILL HAVE 255,590 MORE CY 2013 SEATS THAN IN YE FEB. 2012

849,720

594,130

0 100,000 200,000 300,000 400,000 500,000 600,000 700,000 800,000 900,000 1,000,000

YE February 2012 CY 2013 Scheduled 

### Mainland U.S. Seats to/from Haneda Exhibit HA-2012R-103 Docket OST-2010-0018 Page 1 of 1



### Including DTW Capacity Excluding DTW Capacity 

## +255,590

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

## IF DELTA OPERATED ITS PROMISED 747 FROM LAX, MAINLAND-HANEDA WOULDHAVE 373,850 MORE SEATS THAN IN YE FEB. 2012 EVEN WITHOUT DETROIT

594,130

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

YE February 2012 CY 2013 Scheduled and DL Upguages to Proposed 747 

### Mainland U.S. Seats to/from Haneda Exhibit HA-2012R-104 Docket OST-2010-0018 Page 1 of 1



### Including DTW Capacity Excluding DTW Capacity 

## +373,850

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

### 967,980 Additional Capacity if DL Uses 747 @ LAX

## THE MAINLAND – HANEDA MARKET DOES NOT NEED AND CANNOT SUPPORT ANOTHER SERVICE

594,130 399,570 967,980 849,720

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

1/ Calculated by subtracting seats from actual passengers. 2/ This is the mainland capacity if Delta were touse the 403 seat 747 that it proposed for LAX-HND. Source: Exhbits HA-2012R-103-104; U.S. DOT,T-100 Data and Innovata Schedule Data. YE Feb.

2012 CY 2013 Scheduled (Excluding DTW) CY 2013 With DL 747/2

(Excluding DTW) YE Feb. 2012 Passengers (All Mainland Gateways Including Detroit) 

### Mainland-HND Seats Empty Seats /1 

### 568,410 450,150

194,460 Exhibit HA-2012R-105 Docket OST-2010-0018 Page 1 of 1

## THE MAINLAND-HANEDA WOULD HAVE TO GROW 70%-96% OVER YE FEBRUARY 2012 LEVELS TO FILL 80% OF SCHEDULED SEATS

781,584 679,776

399,570

0 100,000 200,000 300,000 400,000 500,000 600,000 700,000 800,000 900,000

YE February 2012 Passengers Needed to Fill 80% of CY 2013 Seats Passengers Needed to Fill 80% of CY 2013 Seats with DL 747 @ LAX 

### Mainland U.S. Onboard Passengers to/from Haneda Exhibit HA-2012R-106 Docket OST-2010-0018 Page 1 of 1



### Note: The U.S. Mainland – NRT average load factor for YE Feb. 2012 was 80%. 

## +70%

Source: Exhibit HA-2012R-105; U.S. DOT, T-100 Data and Innovata Schedule Data. 

## +96%

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

1,071,594 1,749,373

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

Hawaii California 

### YE June 2012 Tokyo MIDT Passengers

Current HND Designations: 

## 3 3 Exhibit HA-2012R-107 Docket OST-2010-0018 Page 1 of 1

Note: Includes an adjustment to MIDT to reflect direct bookings. For purposes of comparability HA has used DL’s 35% MIDT adjustment factor. Source: MIDT, via Travelport.

### 275,608 514,465

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

Hawaii California 

### YE June 2012 HND MIDT Passengers

Current HND Designations: 

## 3 3 THE HAWAII-HANEDA O&D MARKET IS NEARLY TWICE THE SIZE OF CALIFORNIA WITH THE SAME NUMBER OF HANEDA DESIGNATIONS Exhibit HA-2012R-108 Docket OST-2010-0018 Page 1 of 1

Note: Includes an adjustment to MIDT to reflect direct bookings. For purposes of comparability HA has used DL’s 35% MIDT adjustment factor. Source: MIDT, via Travelport.

### 29

21

14

0 0 5 10 15 20 25 30 35

SkyTeam oneworld Star Hawaiian 

### Weekly Roundtrip Flights to/from NRT - Hawaii

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

## THE THREE ALLIANCES OPERATE EVERY FLIGHT IN THE NARITA – HAWAII MARKET

(DL)(AA) (UA) (HA) Exhibit HA-2012R-109 Docket OST-2010-0018 Page 1 of 1