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., OST2010-0018, 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"). Norcantheydisputethe
DOT-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

1 The 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, as they 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 the
DOT-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 seats were empty, and the mainland load factors were only 67
DOT-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,

1 0s.

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 a total 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 mainlandHND would have to grow at an astonishingT0 to 96 percent. See Exhibit HA-2012R106. 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 de facto 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 expenses to 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 at
DOT-OST-2O 1 0-001 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-forkona-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

S ascha.vanderbellen@delta. com

Jeff.morqan @delta. com

S ametta. c.barnett@delta. com

Tim. OMalle)¡@alpa.org

Dan.weiss@united.com

S teve.morri s se)¡@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 – Haneda Market Has A Far Greater 

Need For Additional Service Than The Mainland –

Haneda Market

1

Exhibit HA-2012R-102 The Hawaii – Haneda Market Utilized Its Capacity 

More Efficiently Than Mainland – Haneda

Markets

1

Exhibit HA-2012R-103 Even Without Detroit, Mainland – Haneda Will

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 – Haneda Would 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 The Mainland – Haneda Would Have To Grow 

70%-96% Over Ye February 2012 Levels To Fill 

80% Of Scheduled Seats

1

Exhibit HA-2012R-107 The Hawaii – Tokyo O&D Market Is Nearly 

Twice The Size Of California With The Same 

Number Of Haneda Designations

1

Exhibit HA-2012R-108 The Hawaii – Haneda O&D Market Is Nearly 

Twice The Size Of California With The Same 

Number Of Haneda Designations

1

Exhibit HA-2012R-109 The Three Alliances Operate Every Flight In The 

Narita – Hawaii Market

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 WOULD HAVE 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 to use 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