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

____________________________________ ) Motions and Applications of ) ) HAWAIIAN AIRLINES, INC. ) ) Docket DOT

- OST

- 2010

- 0018 AMERICAN AIRLINES, INC. ) ) in the matter of 2010 U.S.

- Haneda ) Combination S ervices ) Allocation Proceeding )

____________________________________ )
CONSOLIDATED ANSWER OF HAWAIIAN AIRLINES, INC. Communications with respect to this document should be addressed to: Mark B. Dunkerley President & Chief Executive Officer Peter Ingram Executive Vice President and Chief Commercial Officer Hoyt H. Zia Senior Vice President, General C ounsel & Corporate Secretary Hoyt.Zia@hawaiianair.com Hawaiian Airlines, Inc. P.O. Box 30008 Honolulu, HI 96820

- 0008 J. Parker Erkmann Jonathan B. Hill Geoff Rapoport Cooley LLP 1299 Pennsylvania Ave., NW Suite 700 Washington, DC 20004 (202) 842

- 7800 (202) 842

- 7899 (fax) jhill@cooley.com perkmann@cooley.com grapoport@cooley.com Counsel for Hawaiian Airlines, Inc.

January 12, 2015

### Table of Contents Page

- i

I. HAWAIIAN’S PROPOSED SERVICE TO KONA WILL SUCCEED COMMERCIALLY AND THE REFORE MAXIMIZE THE PUBLIC BENEFITS OF THE AVAILABLE HAN EDA SLOT PAIR.
................................ .............................. 8 A. Because the Traffic between Hawaii and Tokyo is Immense, It Can Easily Support Additional Nonstop Service.
................................ ................................ .... 9 B. Hawaiian’s Kona Service Will Exceed the Performance of All Mainland Gateways Proposed in this Entire Proceeding.
................................ .................... 18 C. Hawaiian Proposes to Fly the Largest Aircraft in this Procee ding.
..................... 24 D. Hawaiian Proposes a Geographically Diverse Gateway.
................................ ..... 26 E. Because Hawaiian Has Been the Most Reliable U.S. Carrier Operating at Haneda, It Has Earned Another Haneda Opportunity.
................................ ........ 26 II. THE INITIATION OF HA NEDA

- KONA SERVICE WILL BE ST SERVE THE O BAMA ADMINISTRATION’ S EXPRESS GOAL OF IN CREASING FOREIGN TOURISM, EXP ANDING THE ECONOMY A ND INCREASING U.S. JOBS.
................................ ................................ ................................ ....................... 29 A. Hawaiian’s Proposed Service Will Bring the Most Foreign Tourists and Therefore the Most Economic Benefits to the United States.
.............................. 31 B. Ha waiian’s Honolulu Service Has Brought the Greatest Economic Benefit to the U.S.
................................ ................................ ................................ ............ 33 C. Delta and American Offer No Specific Economic Stimulus Benefits.
................ 33 III. DELTA’S HANEDA

- SEATTLE SERVICE RECO RD DEMONSTRATES THAT THE SEATTLE

- HANEDA MARKET IS NOT LARGE ENOUGH TO SUPPORT DIRECT HANED A SERVICE SO THE DEP ARTMENT SHOULD REVOKE DELTA’S FREQU ENCY ALLOCATION.
................................ ................... 34 A. The Seattle Market Is Not Large Enough to Support Delta’s Proposed Service.
................................ ................................ ................................ ................. 35 B. Delta’s Promise of More Connections Will Not Save its Haneda

- Seatt le Service.
................................ ................................ ................................ ................. 36 C. Delta’s Service Proposal Offers the Least Capacity in this Proceeding.
............. 38 D. Because of Delta’s Woeful Haneda Service Record, the Department Should Revoke Delta’s Seattle Frequency.
................................ .......................... 39 IV. THE DEPARTMENT SHOUL D REJECT AMERICAN’S INFLATED CLAIMS AND AWARD THE AVAILA BLE FREQUENCY TO HAW AIIAN.
.......................... 41

### Table of Contents (continued) Page

- ii

A. The Los Angeles

- Tokyo Route Has So Much Capacity that Implementation of American’s Proposal Will Require Service Cutbacks.
.......... 44 1. American Has Already Indicated it will Cut its NRT

- LAX Service.
...... 45 2. Implementation of American’s LAX

- HND Proposal Will Reduce Load Factors so Low that the Service Will Fail.
................................ ..... 47 B. The Benefits of Connecting Service Promised by American Are Overblown.
................................ ................................ ................................ ........... 48 C. Kona is More Deserving of a Haneda Award than Los Angeles.
........................ 52 D. American Has a Poor Haneda Service Record.
................................ ................... 54 V. THE GRANT OF HAWAIIA N’S APPLICATION WILL STRENGTHEN A SMALL COMPETITOR.
................................ ................................ ................................ 54 VI. AWARDING THE AVAILAB LE FREQUENCY TO HAWA IIAN WILL BOTH PROMOTE INDEPENDENT COMPETITION AND PRES ERVE THE COMPETITIVE BALANCE AMO NG THE MAJOR ALLIANC E’S AT HANEDA.
................................ ................................ ................................ ........................ 57 A. The Grant of Hawaiian’s Application to Serve Kona Will Reduce Concentration in Markets Dominated by the Three Global Alliances.
................ 57 B. Because Hawaiian Is Independent, the Grant of Hawaiian’s Application Will Benefit Competition Rather than the Major Alliances.
............................... 59 VII. HAWAIIAN HAS A UNIQU E INCENTIVE TO MAKE ITS KONA SERVICE A SUCCESS.
................................ ................................ ................................ ................... 62 VIII. HAWAIIAN OFFERS SUPE RIOR CUSTOMER SERVIC E.
................................ ....... 63 CONCLUSION
................................ ................................ ................................ ............................ 63

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 1 of 65
BEFORE THE DEPARTMENT OF TRANSPORTATION OFFICE OF THE SECRETARY WASHINGTON, D.C.

____________________________________ ) Motions and Applications of ) ) HAWAIIAN AIRLINES, INC. ) ) Docket DOT

- OST

- 2010

- 0018 AMERICAN AIRLINES, INC. ) ) in the matter of 2010 U.S.

- Haneda ) Combination Services ) Allocation Proceeding ) ____________________________________)
CONSOLIDATED ANSWER OF HAWAII AN AIRLINES, INC. Because Delta is not willing to provide the transportation authorized by the Department of Transportation (“Department” or “DOT”) granting authority for service between Seattle and Tokyo’s Haneda International Airport (“Haneda” or “HND”) , 1 

### the Department initiated this “fresh examination” of the record to determine the “best use” for this precious air service right. 2 

### Specifically, the Department has directed that the winning proposal will be the one that “maximize[s] public benefits”
. 3 

### Hawaiian submits that the “fresh examination” should include an evaluation of the policy goals that the Department seeks to achieve. In these proceedings, the

1 

### DOT Order 2013

- 2

- 4 (Feb. 4, 2013), hereinafter “Seattle Allocation Order”. Under the Federal Aviation Act, a carrier may be granted a certificate if it is “fit, willing and able” to provide the authorized transportation. 49 U.S.C. § 41102. Delta has d emonstrated that it is not willing, and it may be unable to serve the Haneda

- Seattle route. 2 

### DOT Order 2014

- 12

- 9 (Dec. 15, 2014), the “Initiating Order”. 3 

### Initiating Order, at 6.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 2 of 64

2 Department has cited achieving geographic diversity and to enhance connecting opportunities as
a justifications for selecting Los Angeles (or, “LAX”) and Seattle. 4 

### As will be discussed in this Answer, market experience demonstrates that those goals are not attainable in this proceeding given the applications for Haneda

- mainland service before the De partment. The Department has also sought input on the “effects on the market structure and on competition in the U.S.

- Japan market.” 5 

### This latter inquiry is of critical importance. The Department should promote the public’s interest in enhancing compet ition against the global alliances that currently dominate the U.S.

- Japan market . In the initial Haneda allocation proceeding, the Department found that: “Hawaiian’s entry into the Japanese market should be a positive development, in terms of offering gre ater choice to travelers as well as increased competition in the U.S.

- Japan market.” 6 

### Since the initial proceeding, the Department has only awarded U.S.

- Haneda authority to the major alliances, which today hold seven of the eight available Haneda frequenc ies. Given the alliances’ abysmal track record of using Haneda authority, this proceeding presents an opportunity to reaffirm the public interest goal of increasing competition expressed in the initial order and therefore maximize the public benefits
. Ha waiian made the most of its Haneda opportunity, flying the awarded Honolulu

- Haneda route continuously and expanding its network between the U.S. and Japan to further increase
4 

### DOT Order 2012

- 11

- 12 (Nov. 12, 2012), hereinafter , “ Order Show Cause 2 ” , at 6 (granting Delta’s motion to transfer service to Seattle because it promote “the geographic diversity of the U.S.

- Haneda gateways” and that “connecting services . . . further support the viability of Delta’s proposed new gateway service”); DOT Order 2010

- 5

- 7 (May. 7, 2010), her einafter “Order Show Cause 1”, at 9 (awarding Haneda frequency to Delta for Los Angeles service because it opens a West Coast Haneda gateway and “accommodate[es] the very large local Los Angeles

- Tokyo traffic base while also pr oviding a number of connecting opportunities to Tokyo traffic”). 5 

### See Initiating Order, at 6. 6 

### Order Show Cause 1, at 8.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 3 of 64

3 competition. Despite the success, Hawaiian’s market share even on the routes bet ween Tokyo and Hawaii trails the major alliances by a large margin. 7 

### In consideration of the market conditions and the weakness of the proposals submitted by the alliance carriers, rigorous analysis of four years of operational data compel s the result in this proceeding. On the merits, t he operational data demonstrates

– no proves
– that Hawaiian has the strongest application and should be awarded the frequency
. Two prior times in this proceeding, the Department has been confronted with a service failure. The Department should ensure it doesn’t happen for a third time! Hawaiian Airlines, Inc. (“Hawaiian”) respectfully submits that the Department should examine the lessons of now four years of U.S.

- Haneda service. What have we learned in that time?

• We have a bilateral agreement that opens a new and important airport for international transportation between the United States and Japan. That good news is tempered by the reality that the time restriction for operations under the b ilateral, make operati ng a successful flight from the continental United States difficult, if not impossible. 8



### • Japanese travelers will use the service for leisure travel between Japan and Hawaii. 9 

### In fact, Honolulu has generated more passengers than all other U
. S
. gateways combined. See HA

- 2015A

- 307.

• T he economic benefit of foreign originating passengers on U.S. carriers far exceeds the economic benefit to the United States of services that perform poorly and rely on a mix of U.S. and Japanese originating traffic
. See HA

- 2015A

- 610.

• After the Department granted the applications for antitrust immunity of the oneworld alliance (JAL and American) and the Star Alliance (United and ANA), 10 

### these alliances

7 

### See HA

- 2015A

- 707 (showing Hawaiian with an 8% market share compared to 25% for Star, 33% for Sky Team and 34% for oneworld). 8 

### See HA

- 2015A

- 104 (cataloguing mainland Haneda gateway service failures and difficulties). 9 

### See HA

- 2015A

- 213 (demonstrating HND load factors are higher than load factors at Narita International Airport (“NRT”) for Honolulu (“HNL”) service but that HND l oad factors are lower than for comparable NRT services at mainland gateways).

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 4 of 64

4 have implemented their respective joint venture agreements to act as single economic entities. The resulting consolidation has left the Japan

- U.S. market “highly concentrated” and a difficult competitive environment for smaller non

- aligned carriers. See HA

- 2015A

708 .

• Although we have repeatedly heard in each proceeding about the benefit of connecting traffic ( New York, Detroit and Seattle ), th ose benefits have proven to be a mirage
. 11 

### HND connecting flights on U.S. flag carriers have all averaged less th an 3% share of connecting markets. See HA

- 2015A

- 91 6
. Nothing has changed that would lead us to expect a different result this time.

• L os Angeles (“LAX”) has ample Haneda capacity, 12 

### but American propose s to inject more. Delta and ANA already serve the route and the additional capacity will swamp the market to the point where another service will fail. See HA

- 2015A

- 9 27 , 9 30
. A dding capacity in to LAX will repeat American’s experience in New York, Delta’s experience in Detroit and Delta’s current debacle in Seattle , requiring another carrier selection proceeding. But the Department has an alternative. Honolulu is the one gateway that works under the bilateral with Japan as it stands today. I ts combined p assenger count exceeds all other Haneda gateways combined. See HA

- 2015A

- 908
. By proposing service to Kona International Airport (“Kona” or “KOA”), Hawaiian is offering to serve a new, large, attractive market currently unserved from either Haneda or Nari ta with much of the same appeal as the massive Tokyo

Honolulu market
. See HA

- 2015A

- 109, 50 5
. Because Kona lacks nonstop service, Hawaiian expects robust acceptance of its service and significant market stimulation
. See HA

- 2015A

- 508

- 09. Indeed, Hawaiian’s proposal of the largest aircraft in this proceeding reflects its confidence

10 

### DOT Order 2010

- 11

- 10 (Nov. 10, 2010), hereinafter “U.S.

- Japan Alliance Case”, at 1. 11 

### See HA

- 2015A

- 916

- 19 (showing that Delta and American both have carried less than 3% of Tokyo traffic in the proposed connecting routes in their previous applications for Haneda service). 12 

### See HA

- 2015A

- 904 (depicting 56 weekly LAX

- Tokyo round trips).

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 5 of 64

5 in the service. See HA

- 2015A

- 113
. We can hope for a different result with another mainland proposal this time around , but the Department and competing carriers should face reality

-- the highest and best use of this scarce frequency, given the terms of the bilateral and the current market , is to grant Hawaiian’s request for Kona

- Haneda service. A grant to Hawaiian has the significant additional benefit of checki ng the power of the dominant global alliances operating in the U.S.

- Japan market. While Hawaiian is nominally competing against individual U.S. carriers, Delta and American, in this proceeding, they are only the U.S. representatives of their much larger g lobal alliances. Having received antitrust immunity, these U.S.

- Japan joint ventures coordinate their competitive conduct , function as single economic entities and wield significant economic power. By granting Hawaiian’s application, the Department will promote network competition with the major alliances that dominate the U.S.

- Japan market. 13 

### In addition to promoting competition, the Department can meet its statutory obligation to promote “the continued strengthening of small air carriers to ensure a more effective and competitive airline industry.” 14 

### This proceeding is an exceedingly rare op portunity to achieve th at public interest mandate. Here, the Department can promote the growth of the only carrier , Hawaiian Airlines, willing to take on these behemoths on their own ground. Make no mistake, this is no charity case. After analyzing the data, the Department must conclude Hawaiian has the strongest service proposal for a number of reasons.

13 

### See HA

- 2015A

- 704 (depicting alliances’ collective U.S.

- Tokyo market share of 98%). 14 

### See 49 U.S.C. Section 40101(a)(13)

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 6 of 64

6 First, because of unmet demand for nonstop Haneda

- Kona service, 15 

### Hawaiian’s proposed service will be a commercial success. Kona is the second

- largest route between the United States and Tokyo currently without nonstop service. See HA

- 2015A

- 502. Although Kona already is a popular connecting destination for Japanese tourists, 16 

### Hawaiian projects that the introduction of its new service will push demand even higher, resulting in a robust, sustainable service. See HA

- 2015A

- 508

- 09
. To meet demand, Hawaiian has proposed the largest aircraft in this proceeding. See HA

- 2015A

- 113
. Second , Hawaiian’s Kona

- Haneda service will generate the most economic benefits for the United States. The introduction of nonstop Haneda

- Kona service will stimulate far more Japanese tourists to visit the United States than the competing applications. See HA

- 2015A

- 613. T heir spending will result in far more U.S. exports, economic growth and ultimately more U.S. jobs. See HA

- 2015A

- 614

- 17. 17 

### Hawaiian’s proposal to use the largest aircraft in this proceeding magnifies the comparative benefit of Hawa iian’s application. See HA

- 2015A

- 114. More seats lead to more passengers which lead to more tourist spending which leads to more economic growth for the United States. No other application in this proceeding comes close to providing the economic benefits that Hawaiian’s service will generate. Third , Delta’s inability or unwillingness to use the Seattle

- Haneda authority justifies the Department’s reallocation of the frequency. Delta’s Seattle

- Haneda market is, as Hawaiian

15 

### See HA

- 2015A

- 301. 16 

### See HA

- 2015A

- 506

- 07. 17 

### For example Hawaiian’s proposed KOA service will add $117 million per year to U.S. GDP output compared to $34 million for American’s proposed LAX service and less than $8 million for Delta’s current SEA service. See HA

- 2015A

- 616.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 7 of 64

7 predicted during the 2012 proceeding, 18 

### too small to support year

- round s ervice, which has been demonstrated by Delta’s startling, unilateral winter season cutbacks. Fourth , American’s proposal to add more capacity to a glut of existing Haneda

- Los Angeles (“LAX”) capacity will simply lead to more service cu tbacks by either Am erican or Delta, which already serves the route. Four years of experience demonstrates that Haneda connecting service is insufficient to rescue this failing proposition. See HA

- 2015A

- 91 6

- 19
. Fifth , an award to Hawaiian will fulfill the Congressional mand ate to the Department to strengthen smaller carriers. The Federal Aviation Act directs that the Department shall consider, in its evaluation of the policies that serve the public interest, “ the continued strengthening of small air carriers to ensure a mor e effective and competitive airline industry.” 19 

### Hawaiian has made the most of its single Honolulu

- Haneda frequency, carrying more passengers than any other U.S. carrier. See HA

- 2015A

- 202. Despite the robust growth of Hawaiian’s international network, Hawaiian remains a fraction of the size of Delta and the U.S.

- Japan joint ventures that it competes against , s ee HA

- 2015A

- 11 5 , even on routes between Tokyo and Hawaii
. See HA

2015A

- 707. In the face of a consolidating industry, Haw aiian respectfully submits that the Department’s opportunities to promote the growth and development of smaller carriers are few. In the new world order of fewer, more massive network carriers and their immunized joint ventures, the Department should take every opportunity to balance the playing field and strengthen a smaller competitor.

18 

### See Consolidated Ans wer of Hawaiian Airlines, Inc. , DOT

- OST

- 2010

- 0018 (Sep. 6, 2012), hereinafter “Hawaiian 2012 Answer”, at 29 (“Seattle is still too small to support more service and, like Detroit, will not be rescued by connecting service from Delta, Alaska or anyone else. ”). 19 

### See 49 U.S.C. Section 40101(a)(13)

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 8 of 64

8 Sixth , an award to Hawaiian preserves the competitive balance in the U.S.

- Haneda market. In its prior decisions, t he Department always has allowed U.S. carriers that are not part of a U.S.

- Japan joint venture to retain three of the four U.S.

- Haneda frequencies
. 20 

### Because Delta has proven that it is not willing to provide the transportation that DOT has authorized at two different gateways , the dominance of the U.S
. - Japan alliances (Star and oneworld) on U.S.

- Haneda routes can only be avoided by awarding the remaining frequency to Hawaiian. Seventh , Hawaiian is uniquely committed to Haneda because it has no vested interest in the competing Tokyo airport, Narita (“NR T”) , as the other applicants clearly do. Hawaiian does not have to worry about diverting traffic from Narita flights and has every incentive to make Haneda

- Kona a success. Finally, Hawaiian offers customer service superior to that of its competitors in th is proceeding. I. Hawaiian ’s Propos ed Service to Kona Will Succeed Commercially and Therefore Maximize the Public Benefits of the Available Haneda Slot Pair. Hawaiian’s proposed Kona service will provide the most public interest benefits primarily because it will be a commercial success. Tokyo

- Kona is a significant market within the much larger market between Tokyo and t he State of Hawai i. This market is huge, much larger than the market between Tokyo and any other U.S. state, including California. See HA

2015A

- 301

- 04. While t he market between Kona and Tokyo already is significant , Hawaiian expects that the introduction of nonstop service will stimulate significant additional traffic. See HA

- 2015A

- 620 . The market follows in the footsteps of other succ essful Haneda gateways that

20 

### Since the initial proceeding, Delta has held two Haneda frequencies and Hawaiian has held one.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 9 of 64

9 rely mostly on traffic from Japanese leisure travelers
. See HA

- 2015A

- 109. C onnecting service will be limited, 21 

### but market experience demonstrates that the amount of connecting service available has not been particularly import ant in the success of a particular Haneda gateway. See HA

- 2015A

- 91 6

- 19 . Instead, success has been highly correlated with local market demand , s ee HA

- 2015A

- 102 , which will be the backbone of the proposed Kona service
. Accordingly, an award of the Kona ro ute to Hawaiian will replicate the unparalleled success that Hawaiian has had at Honolulu where it has taken full advantage of the opportunity that the Department gave it in 2010 , meeting all route proceeding commitments. To repeat that success, the Department should grant Hawaiian another Haneda opportunity. A. Because the Traffic between Hawaii and Tokyo is Immense, It Can Easily Support Additional Nonstop Service. In evaluating the competing applications in this proceeding , the Department should make its decision based on historical market performance data. The data demonstrates unequivocally that the size of the market between Tokyo and Hawaii is so large that it can support additional Haneda service. The other applicant s in this proceeding would have the Department dismiss Hawaiian’s application out

- of

- hand, touting the benefits of their connections. While Hawaii is a small state geographically, it is by far the largest travel market between Japan and the United States. See HA

- 2015A

- 301. Hawaii is an overwhelmingly popular destination for Japanese tourists. For many years, Hawaii has been the preferred destination for Japanese visitors. See HA

- 2015A

- 602.

21 

### Unlike American, Hawaiian does not think a 10

- hour connection is convenient. See HA

2015A

- 921 .

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 10 of 64

10 Demand is so high that more Japanese visit Hawaii than visit the rest of the U.S. combined.

HA

- 2015A

- 603. Moreover, Japanese continue to visit Hawaii in increasing numbers

– 3 percent more Japanese tourists visited Hawaii in 2013 than in 2012. See HA

- 2015A

- 606. The same **OVER 20% MORE JAPANESE TOURISTS VISIT HAWAII THAN VISIT THE ENTIRE U.S. MAINLAND** 

1,578

1,223



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

Hawaii U.S. Mainland* 2013 Japanese Visitors to U.S. Destinations (000 )



### +29

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 11 of 64

11 cannot be said of visitors to the rest of the U.S., as Hawaii attracted nearly fifty pe rcent more new Japanese visitors in 2013 as the rest of the United States combined:

HA

- 2015A

- 604. This trend has been confirmed over a five

- year period. See HA

- 2015A

- 305 (comparing 17.7% growth in Hawaii

- Tokyo market since 2009 to 10.5% growth in Tokyo

mainland markets)
. No other state comes close to the popularity of Hawaii, as Hawaii attracted more than three times a s many visitors as the second most popular state, California. See HA

HAWAII ATTRACTED 47 PERCENT MORE NEW JAPANESE VISITORS THAN THE U.S. MAINLAND

47,000

32,000

0 5,000 10,000 15,000 20,000 25,000 30,000 35,000 40,000 45,000 50,000

Japanese Visitors to Hawaii Japanese Visitors to Mainland U.S. Increased Japanese Visitors (2013 Total

– 2012 Total)

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 12 of 64

12 2015A

- 607. Even considering the passenger market overall, Hawaii is the largest U.S.

- Japan market. S ee HA

- 2015A

- 301. Indeed, t he Tokyo

- Hawaii O& D market is much larger than the next

- largest state, California.

HA

- 2015A

- 304. Even though California has been allocated one more Haneda frequency than the State of Hawaii, the Hawaii

- Tokyo O&D market is nearly twice the size. See HA

- 2015A

303

- 04. T he Hawaii

- Tokyo market is even larger relative to California than it was during the THE HAWAII - TOKYO O&D MARKET IS MUCH LARGER THAN THE SECOND LARGEST U.S. STATE

773,048

331,809 104,247 101,320 98,835 1,496,911

97,023 96,231 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 Nevada Illinois Washington Texas Florida YE September 2014 Tokyo* MIDT Passengers

Current HND Designations: 3 4 1

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 13 of 64

13 last Haneda proceeding. See HA

- 2015A

- 304 (94 percent larger this time compared to 90 percent larger last time). The widening chasm between the size of the Tokyo

- Hawaii an d Tokyo

California markets is attributable to the fact that Hawaii

- Tokyo traffic is growing while traffic to the California markets is actually shrinking. See HA

- 2015A

- 40 6
. The size of the Hawaii

- Japan market is again reflected in the performance of the U.S.

- Haneda gateways. Honolulu is, by far, the largest Haneda gateway. See HA

- 2015A

- 306. Although Honolulu has three Haneda frequencies, it has more Haneda gateway passenge rs than the five mainland gateways combined. See HA

- 2015A

- 307. And the Hawaii

- Haneda O&D market with three frequencies is 60 percent larger than all other states combined with five frequencies:

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 14 of 64

14 HA

- 2015A

- 308. Indeed, the Hawaii

- Haneda O&D market is o ver twice the second

- largest U.S. state, California

– even though California has an additional Haneda frequency. See HA

- 2015A

309.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 15 of 64

15 HA

- 2015A

- 309. Honolulu, with three Haneda frequencies, generated significantly more (31 percent) Haneda O&D passengers than the other five U.S.

- Haneda gateways combined. See HA

2015A

- 310. The siz e of the Honolulu

- Tokyo market is evident in other metrics as well. The Honolulu

- Haneda market experiences a much higher load factor than does the comparable mainland gateways. See HA

- 2015A

- 40 9

- 11 . Moreover, the higher load factors are on larger aircraf t than the mainland markets . Every Honolulu segment carried more passengers than any 172,260 435,153

0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000 450,000 500,000

Hawaii California YE September 2014 HND MIDT Passengers

Current HND Designations: 3 4 THE HAWAII - HANEDA O&D MARKET IS OVER TWICE THE SIZE OF CALIFORNIA WITH ONE FEWER HANEDA DESIGNATION

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 16 of 64

16 mainland route. See HA

- 2015A

- 412
. The inevitable conclusion is that the State of Hawaii needs another Haneda gateway, while California does not. Indeed, the average nu mber of passengers per designation at Honolulu is much higher than the average for the U.S. mainland, meaning Hawaii is drastically underserved from Haneda compared to California.

HA

- 2015A

- 401. 172,260

22,440 435,153

0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000 450,000 500,000

Hawaii California Washington YE September 2014 Haneda MIDT Passengers



### HND Designations: 3 4 1 Ave. Passengers per Designation: 145,051 43,065 THE HAWAII

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

– HANEDA MARKET

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 17 of 64

17 In contrast to the mainland Haneda gateways, the introduction of Haneda

- Honolulu servi ce stimulated growth in traffic. The results are astounding; 370,927 more passengers flew to Honolulu in the year ended September 2014 than flew in calendar year 2009. See HA

- 2015A

408 . This performance blew away the other U.S. gateways, w hich saw little, if any, additional traffic growth.

HA

- 2015A

- 404
. The traffic growth in Honolulu was higher than the rest of the U.S.

- Haneda gateways combined by approximately a factor of nearly twenty - six. See HA

- 2015A

- 408 . The HNL - HND SERVICE GENERATED 370,927 NEW TOKYO O&D PASSENGERS

370,927

33,546
-8,231 10,602 6,624
-28,247 -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 2014

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 18 of 64

18 stimulation that will result from additional service to Hawaii, rather than just the dive rsion of existing Narita traffic, is a primary reason for granting Hawaiian’s application. B. Hawaiian’s Kona Service Will Exceed the Performance of All Mainland Gateways Proposed in this Entire Proceeding. Hawaiian’s Kona proposal follows the blueprint for a successful Haneda gateway. S uccess has been highly correlated with local market demand
. See HA

- 2015A

- 102. As Exhibit HA

- 2015A

- 103 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 82% and the highest share of Tokyo

- originating passengers, while both Seattle and Los Angeles have lower load factors and lower point of sale in Tokyo. See id . This result makes perfect sense. Tokyo resid ents are most likely to understand the convenience of their downtown airport, Haneda, and make purchasing decisions accordingly. Kona is a similarl y situated local market with 96% of the traffic with a Tokyo point of origin. See HA

- 2015A

- 105. Not only does Kona follow the blueprint for success at Haneda, it is a large market in its own right more than capable of sustaining a new gateway. Even without nonstop service, the Kona

- Tokyo is a significant Tokyo market. See HA

- 2015A

- 502. Indeed, despite not having nonstop service to Tokyo, Kona has more point of sale Japan passengers than thirteen markets with Tokyo nonstop service.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 19 of 64

19 DESPITE NOT HAVING NONSTOP SERVICE TO TOKYO, KONA HAS MORE POINT OF SALE JAPAN PASSENGERS THAN 13 MARKETS WITH TOKYO NONSTOP S ERVICE 22



### As a result , Hawaiian expects that the introduction of nonstop service will stimulate substantial additional traffic, resulting in a service that will be more than financially viable. See HA

- 2015A

508

- 09. Hawaiian predicts that its Kona service, as measured by the number of onboard

22 

### See HA

- 2015A

- 504.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 20 of 64

20 passengers, will outperform all of the other single frequency Haneda gateways. See HA

- 2015A

510. Better than that, it will outperform all current or previous mainland Hane da gateways.

See HA

- 2015A

- 510. Moreover, Kona is the most underserved gateway proposed in this proceeding. The State of Hawaii represents the most popular travel destination for the Japanese visitors to the U.S. See HA

- 2013A

- 603. And Hawaii’s status as the premier Jap anese U.S. tourist destination promise s not to abate

– as the rate of growth for Japanese tourists visiting Hawaii exceeds the rate of

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 21 of 64

21 mainland visitors. See HA

- 2013A

- 604

- 06. Despite the huge numbers of Japanese visiting Hawaii, Kona, t he second

- most popular destination after Honolulu, 23 

### lacks nonstop service from Tokyo. Hawaiian sees Kona as an overlooked opportunity to put this underutilized Haneda slot pair to its highest and best use rather than have it allocated to serve a LAX, whic h is awash in nonstop service to Tokyo

– with a stunning 56 roundtrips per week including 14 roundtrips from Haneda. See HA

- 2015A

- 501. Even before the stimulation Hawaiian expects in the Kona market, the market will be underserved relative to LAX, as calc ulated by the number of MIDT passengers per flight. 24 

### Kona already is a strong market with significant existing traffic from Tokyo. See HA

2015A

- 504. More than 13 percent of Japanese tourists visiting Hawaii visit the Big Island. See HA

- 2015A

- 507. And with nonstop service, Hawaiian would expect this traffic to grow significantly as markets gaining nonstop service typically do. See HA

- 2015A

- 620 . Hawaiian projects that the Kona service will bring in more than 3 50 % percent more new vis itors than LAX and more than ten times the visitors than Seattle. See HA

- 2015A

- 613.

23 

### See HA

- 2015A

- 506

- 07. 24 

### See HA

- 2015A

- 909.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 22 of 64

22 HAWAIIA N’S KONA FLIGHT WILL BRING IN OVER 350 % MORE NEW U.S. VISITORS THAN A THIRD LAX GATEWAY 25



### But even before accounting for growth, Hawaiian estimates that the resul ting traffic on the HND

KOA route would amount to over 160,000 onboard passengers per year. See HA

- 2015A

- 508. This projected traffic would be comparable to Hawaiian’s successful Honolulu service, as depicted in the chart below:

25 

### See HA

- 2015A

- 613 .

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 23 of 64

23 HA

- 2015A

- 509. 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

- 2015A

- 510

- 11. Consider ing the track record of other Haneda gateways and LAX and SEA in particular, the Department must conclude that the award of an available slot pair to Hawaiian will result in the most public benefits.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 24 of 64

24 C. Hawaiian Proposes to Fly the Largest Aircraft in this Pr oceeding. Hawaiian’s service will maximize the public benefits because it proposes to use the largest aircraft in this proceeding. See HA

- 2015A

- 113
. For its Kona service, Hawaiian proposes to use an A330 with 294 seats . In contrast, American has propos ed to initiate service on its LAX

- HND route with a B777

- 200 that seats only 247 ; 26 

### Hawaiian’s aircraft is 19% larger. See HA

- 2015A

- 113 . Although American promises to introduce a configuration of the B772 with 260 seats, 27 

### Hawaiian’s A330 will still be 34 seats and 13% larger. On the occasions when it does fly the Seattle

- Haneda route, Delta proposes to use the smallest aircraft in this proceeding, a B

- 767 with only 210 seats. 28 

### Hawaiian’s aircraft is 84 seats and 40% larg er. The true difference in the competing proposals is in the capacity that Hawaiian will actually fly. Because Delta has failed to operate daily service for many months of the year , 29 

### Hawaiian proposes to fly 80% more capacity.

26 

### Application of American Airlines, Inc. , DOT

- OST

- 2010

- 0018 (Jan. 5, 2015), hereinafter “American Application”, at 2. 27 

### Id., at 5. 28 

### Response of Delta Air Lines, Inc. To Evi dence Request , DOT

- OST

- 2010

- 0018 (Jan. 5, 2015), hereinafter “Delta Application”, at 3. 29 

### For this calculation, Hawaiian used historical T

- 100 data. Hawaiian’s seat advantage would be even higher if Hawaiian included Delta’s recent winter cancellation.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 25 of 64

25 HA

- 2015A

- 114
. Unlike its competitors in this proceeding, see HA

- 2015

- 911 , Hawaiian has a record of meeting its aircraft size commitment. As it promised in the initial proceeding, Hawaiian increased the size of the aircraft it uses to serve Haneda. After initiating service with 264

- seat B767, Hawaiian began to fly 294

- seat A3 30 as these larger airplanes were acquired and introduced into its fleet , just as it had promised in its initial application
. The relative capacity is an important factor to consider, as it was decisional for the Department when it initially awarded Delta its Detroit frequency on the strength of its proposal to use a 403

- seat B747. See Order 180,310

118,930 214,620

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 Pr oposals and Actual for Delta HAWAIIAN WILL PROVIDE SIGNIFICANTLY MORE HANEDA CAPACITY THAN AMERICAN OR DELTA

Hawaiian

(A330) American (B777) +19%

Delta* (B767) +80%

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 26 of 64

26 Show Cause 1 , at 10 (“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 accom modate traffic from both the Detroit

- Tokyo local market and its catchment area.”). D. Hawaiian Proposes a Geographically Diverse Gateway. The Department can achieve its public interest goal of promoting “the geographic diversity of the U.S.

- Haneda gateways” 30 

### by selecting a market currently without nonstop service. To achieve this goal, Hawaiian’s Kona service is the only choice. While Delta purports to offer the only Haneda

- Seattle service, its performance demonstrates that the service is not viable. Ameri can’s proposal offers no geographic diversity because it proposes to serve a gateway with two existing Haneda frequencies from ANA and Delta. Hawaiian expects that the alliance carriers will criticize its application because it is “another” Hawaii gatewa y. This position is misguided. Kona and Honolulu are almost as far away from one another as New York is from Boston, but Kona and Honolulu lack the convenient rail link. No one considers New York and Boston to be part of the same air travel market and n o one should consider Honolulu and Kona to be one in the same . The fact is that Kona and Honolulu are geographically quite distinct and an award to Kona will satisfy the Department’s goal of promoting geographic diversity. E. Because Hawaiian Has Been the Most Reliable U.S. Carrier Operating at Haneda , It Has Earned Another Haneda Opportunity. In November 2010, Hawaii an initiated its Haneda service, which proved to be three months prior to when the other U.S. carriers started their respective Haneda service s. See HA

2015A

- 207. The remaining U.S. carriers requested extensions of the time to start their respective 30 

### Order Show Cause 2, at 6

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 27 of 64

27 services. 31 

### Since initiating its service, Hawaiian has operated it continuously, even throughout the tragic events of the Japanese earthquake, tsu nami and associated nuclear disaster

— in stark contrast to other U.S. carriers. See HA

- 2015A

- 208. Indeed, Hawaiian has conducted more operations on its Haneda

- Honolulu route than any other U.S. carrier on their Haneda routes. See HA

- 2015A

- 206. Only Hawa iian has stood up to the competition provided by the Japanese carriers by operating consistently and flying a competitive number of segments. See HA

- 2015A

205, 208. By contrast, other airlines have repeatedly halted service and requested waivers of the 90

- day dormancy condition. 32 

### And now Delta has decided not to ask for permission, unilaterally converting Seattle

- Haneda to a seasonal market. 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

2015A

- 104 . United’s San Francisco service has only survived by utilizing the smallest available aircraft an d cutting capacity from Narita. H awaiian’s service from Honolulu to Haneda far out

- performed other U.S. gateways. Hawaiian’s load factor of 82.7 percent for its Haneda service is the best of all U.S. flag carriers.

31 

### See Motion of Delta Air Lines, Inc. for a 30 Day Startup Extension , DOT

- OST

- 2010

- 0018 (Sept. 7, 2010); Motion of American Airlines, Inc. for 28

- Day Start

- up Extension (New York JFK

– Tokyo Haneda) , DOT

- OST

- 2010

- 0018 (Dec. 20, 2010). 32 

### See, e.g., Motion of Delta Air Lines, Inc. , DOT

- OST

- 2010

- 0018 (June 3, 2011); Motion of American Airlines, Inc. for Dormancy Waiver , DOT

- OST

- 2010

- 0018 (June 30, 2011).

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 28 of 64

28 HA

- 2015A

- 203. The Honolulu

- Haneda service has proven very popular, resulting in increased traffic from Tokyo and more traffic growth than any other gateway. See HA

- 2013A

- 204. In deed, the U.S. flag mainland carriers have squandered their awarded frequencies, squandering them 41 % of the time

– compared to Hawaiian’s 100% utilization: HAWAIIAN HAS THE HIGHEST HANEDA LOAD FACTOR OF ALL U.S. FLAG HANEDA CARRIERS

82.7% 78.7% 76.3%

56.6% 71.2%

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

HNL LAX JFK SEA Mainland Average Load Factor OF ALL U.S. FLAG HANEDA CAR

Carrier: HA DL AA DL

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 29 of 64

29 HA

- 2015A

- 209. To the extent the Department considers commitment to Haneda service in its decision making, that factor tip s heavily in favor of Hawaiian. II. The Initiation of Haneda - Kona Service Will Best Serve the Obama Administration’s Express Goal of Increasing Foreign Tourism, Expanding the Economy and Increasing U.S. Jobs. Stimulation of international tourism is a Presidential

- level economic policy priority. In fact, President Obama created the Task Force on Travel Competitiveness with the singular goal of “increas[ ing] American jobs by attracting and welcoming 100 million international visitors, who we estimate will spend $250 billion, annually by the end of 2021.” 33 , 34 

### The motivation

33 

### “National Travel & Tourism Strategy,” Task Force on Travel Competitiveness, International Trade Administration of the Department of Commerce, at 1. 34 

### Executive Order 13597, Jan. 19, 2012. Hawaiian

Available Frequencies Used 59% Available Frequencies

Not Used

41% 

### U.S. Flag Mainland Carriers

Available Frequencies Used 100% HAWAIIAN OPERATED ALL OF ITS AWARDED FREQUENCIES WHILE U.S. FLAG MAINLAND CARRIERS SQUANDERED 41% OF THEIR AWARDED U.S. CARRIERS SQUANDERED

One - Way Frequencies Wasted Through June 2014: 0 3,230

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 30 of 64

30 behind the administration’s efforts to increase international tourism to the Unite d States is clear. Every dollar spent by international tourists is an economic export that adds to the gross domestic product. Speaking at the Baseball Hall of Fame just last year, the President said, “[T]ourism translates into jobs and it translates into economic growth. When visitors come here, they . . . rent cars; they stay in hotels; they eat in restaurants. . . . I want to turn the 70 million tourists that came last year into 100 million each year by the beginning of the next decade.” 35 

### Delta apparently agrees , as its CEO, Richard Anderson stated : “Delta applauds President Obama's efforts to increase travel and tourism to the United States. Expanding this important sector of the economy means more job growth and economic opportunities across o ur nation.” 36 

### American’s support for this proposition is even stronger. In the letters American submitted with its Los Angeles Application, American’s supporters , including the sixteen members of the House and Senate supporting its application, repeatedly argued that: “These nonstop flights to Haneda are scarce assets that should be distributed among U.S. carriers to obtain the maximum consumer and economic benefits. ” HA

- 2015A

- 61 8 . Under American’s standard, this route proceeding is a laydown case for H awaiian.

35 

### President Barack Obama, Barack. Remarks by the President on Creating Jobs Through Tourism , The White House, Office of the Press Secretary (201 4), http://www.whitehouse.gov/the

- press - office/2014/05/22/remarks

- president

- creating

- jobs

through

- tourism
. 36 

### Jeff Zients and Valerie Jarr ett What CEOs are Saying: The Business Community’s Take on President Obama's National Travel and Tourism Strategy , The White House Blog (2014), http://www.whitehouse.gov/blog/2014/05/23/what

- ceos - are - saying

- business

- community

- s - take

president

- obamas

- national

- travel

- and

- .

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 31 of 64

31 A. Hawaiian’s Proposed Service Will Bring the Most Foreign Tourists and Therefore the Most Economic Benefits to the United States. 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 Hawai i. Unlike the competing proposals , Hawaiian’s Kona service focuses on bringing in visitors and spending to Hawaii and the United States. Money spent i n 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

- 201 5 A

- 610
. To the extent American and Delta will operate their proposed services, they will have a c omparatively balanced distribution of Japanese and U.S. resident originating traffic
. See HA

- 2015A

- 109
. 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 propose d 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, 008 , or nearly four times American ’s proposed gateway and more than ten times Delta’s proposed gateway
. See HA

- 20 15A

- 613, 619. Japanese visitors spend a significant amount of money during their trips, so Hawaiian’ s Kona service will have an even greater
eco nomic impact. See HA

- 201 5 A

- 106
. Hawaiian projects that the proposed Kona service would result in $ 64.8 million additional dollars injected into the economy of Hawaii and the United States annually, nearly four times higher than the impact of LAX and 17 times as high as Seattle
. See HA

- 201 5 A

- 615.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 32 of 64

32 HAWAIIAN’S KONA FLIG HT WILL INCREASE U.S . EXPORTS BY $64.8 M ILLION 37



### Accounting for typical economic multipliers, this incremental spending will result in an additional $1 16.7 million in U.S. GDP growth, more t han three times American ’s proposed service and more than fifteen times Delta’s service
. See HA

- 2013A

- 616. This GDP growth will support an additional 1, 151 U.S. jobs, more than four times American ’s proposal and more than fifteen times Delta’s proposal
. See HA

- 2013A

- 614. Moreover, aggregate U.S. household

37 

### See HA

- 2015A

- 615.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 33 of 64

33 earnings will increase by over $ 35.4 mi llion annually, again nearly four times American’s proposal and more than fifteen times Delta’s 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 Show Cause 1, at 9 (“The Department has previously found benefit to the Hawaiian economy to be an affirmative public interest factor wor thy of decisional weight in our regulatory proceedings.”). B. Hawaiian’s Honolulu Service Has Brought the Greatest Economic Benefit to the U.S. Hawaiian’s projections for the economic benefits of its Kona service are backed up by documented experience on Hawa iian’s Honolulu route. In all prior proceedings in this docket, Hawaiian has predicted that its proposed service would bring Japanese visitors and spending and therefore economic growth to the U.S. Again, Hawaiian has delivered on its promises. Hawaiian carried more U.S.

- bound passengers than any other U.S. carrier. See HA

- 201 5 A

- 608. T hese 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 $455. 3 mill ion in U.S. exports,
see HA

- 2015A

- 610, accounted for over $826 million in U.S. gross domestic product, see HA

2015A

- 611, generated more than $250 million in U.S. household earnings, see HA

- 2013A

- 612, and created more than 2,300 U.S. jobs, which is, in each case, approximately double the second highest Haneda gateway. See HA

- 2015A

- 609. C. Delta and American Offer No Specific Economic Stimulus Benefits. Neither Delta nor American cites specif ic economic stimulus benefits of their proposals because they are minimal. The omission on American’s part is surprising given the decisional standard of “maxim[izing] consumer and economic benefits” advocated by its supporters. See

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 34 of 64

34 HA

- 2015A

- 618
. When f lying U
. S
. citizens overseas, the only significant U
. S
. economic benefit is the sale of airfares, which is more than offset by foreign spending while abroad

— and of no benefit to the U
. S
. economy. See HA

- 2015A

- 110
. A proposal that blends U.S. travelers wi th Japanese travelers breaks even at best. Conversely, when Japanese travel to the U.S. on a U.S. carrier, every dollar spent on the trip is a U.S. export and a benefit to the US economy. Los Angeles World Airports ( “ LAWA ” ) asserts that Hawaiian’s propo sed service would “serve Japan’s interest while sacrificing the broader U
. S
. interest.” 38 

### This isn’t just wrong, i t’s laughably wrong. It’s wrong like the assertion that “selling American

- made cars in Japan serves only Japan’s interest” is wrong. If that’s not the case, then someone should tell the Detroit automakers (and the President). Until then, the Department should h eed the President’s directive to make stimulation of international travel to the United States a top priority and award the
ava ilable frequency to Hawaiian’s proposed Kona service
. III. Delta’s Haneda - Seattle Service Record Demonstrates that the Seattle - Haneda Market is Not Large Enough to Support Direct Haneda Service So the Department Should Revoke Delta’s Frequency Allocation. Delta’s unilateral decision to convert its Seattle

- Haneda service to seasonal should be the last straw. The Department should exercise its discretion to revoke the frequency and reallocate it to Hawaiian. Delta’s decision does not stand in isolation. It has a long history of failed commitments in this proceeding, repeatedly overpromising and under delivering:

• In the initial Haneda allocation proceeding, Delta promised to fly a B747 to Detroit. It k ept that commitment for just 37 days
. Hawaiian’s Answer to Petition

38 

### Supplemental Comments of Los Angeles World Airports, Operator of Los An geles International Airport, In Support of American Airlines LAX

– Tokyo Haneda Proposal , DOT

OST

- 2010

- 0018 (Jan. 5, 2015), at 6.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 35 of 64

35 for Reconsideration , DOT

- OST

- 2010

- 0018 (Jan. 2, 2015), hereinafter “Hawaiian 2015 Answer” , at HA

- 1.

• After a little more than a year of starting up the Detroit service, and after receiving a waiver of the dormancy condition, Delta abandoned th e Detroit service having provided only 26% of the proposed seats. See id.

• In Seattle, afte r initially promising to fly a 298

- seat A330 in the 2010 route allocation proceeding, Delta now proposes to fly a 208

- seat B767. See id.

• When Delta hasn’t cancell ed its Seattle service, it has flown largely empty aircraft with a load factor of only 57% , less than the load factor of other failed Haneda gateways. See HA

- 2015A

- 1004. With its track record, the Department should stop giving Delta the benefit of the do ubt. Delta’s record demonstrates that this scarce resource can be put to better use. A. The Seattle Market Is Not Large Enough to Support Delta’s Proposed Service. The evidence submitted in prior proceedings in this docket demonstrates that the Seattle marke t is not large enough to support Haneda service. I n 2015, nothing has changed. Indeed, in the 2010 proceeding, the Department concluded that the Seattle market was too small to support an award of a Haneda slot. See Order Show Cause 1, at 10 (awarding slots to serve LAX because it is “significantly larger than both the San Francisco

- Tokyo and Seattle

- Tokyo markets”). Since then , the Seattle market has not grown and is still too small to support the service and, like Detroit, has and wil l continue to fail. See HA

- 2015A

- 407
. With the lack of connecting traffic flows over Haneda gateways, 39 

### successful Haneda gateways have relied on strong Tokyo point

- of

- sale local traffic. See HA

- 2015A

- 102. Seattle does not have enough local traffic to su pport Delta’s service. By comparison, the Hawaii

- Tokyo market is 14 times as large as the market between Tokyo and the state of Washington. See HA

- 39 

### See HA

- 2015A

- 916

- 19.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 36 of 64

36 2015A

- 302. As a result, Delta’s current load factor at Seattle is lower than the load factors for the two Haneda gateways that have failed, JFK and Detroit
. See HA

- 2015A

- 1004 (showing Seattle’s 57% load factor compared to JFK’s 72% and Detroit ’s 65%). By comparison, Hawaiian’s service carried 263% more passengers to and from Honolulu than Delta’s service to Seattle. See HA

- 2015A

- 211 . If DOT allows Delta to continue its operation at Seattle, the outcome i s clear

-- continuation of the present failed service and perpetuation of Delta’s
un willingness to put the frequency to its highest and best use. B. Delta’s P romise of More Connections Will Not Save its Haneda - Seattle Service. Carriers in this proceeding have long promised benefits of connecting services, but those benefits have failed to materialize. The 2010 award of a Haneda slot pair to Delta’s proposed De troit service was predicated upon its superior connecting traffic flows that never showed up at the gate
. See HA

- 2015A

- 917 . In the 2012 proceeding, Delta again promised that connecting service from Seattle would save the day, asserting that it would succeed in Seattle with only half the connecting opportunities of Delta’s failed Detroit service. See Hawaiian 2012 Answer , at HA

- 2012A

- 805

- 6 . This claim was dubious given Delta’s Haneda operating history and the overlapping nature of the proposed connections with Delta’s existing Los Angeles service. As a result, Hawaiian predicted that Delta’s load factors would be insufficient to sustain the service. See Hawaiian 2012 Answer at HA

- 2012A

- 815, 816 (predicting a 59% load factor). Hawaiian’s prediction proved optimistic as Delta’s load factor for 12 month ending June 2014 was the lowest of all gateways coming in at 56.6%, as comp ared to Honolulu at 82.7%. See HA

- 2015A

203. Nevertheless, in awarding Delta the Seattle

- Haneda authority in 2012, the Department relied upon Delta’s representations about connecting service: “We tentatively find that Delta’s

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 37 of 64

37 proposed service would furt her serve the public interest by providing a number of western cities with a first one

- stop connecting opportunity to Haneda.” See Order Show Cause 2 at 5. The benefits of that connecting service promised by Delta have proven illusory at best. In fact t aking a look at what Delta promised in 2012, actual performance reveals a truly astounding statistic: Delta actually carried less than 2% of Tokyo passengers in the connecting markets they proposed in their 2012 application. See HA

- 2015A

- 917. A closer l ook at Delta’s proposed expansion at Seattle reveals that there is little reason to believe the situation will improve. Although Delta has added domestic routes and frequency at Seattle , the improvement in HND connections is quite modest . Comparing the t ime when Delta suspended Haneda service, November 2014, to March 2015 when the service purportedly will restart, the only citie s that gain a new connection to and from Haneda via Seattle during Sep tember to December 201 5 are : Anchorage (“ ANC ”), which still will not con nect both directions in November and December; Boise (“BOI”); Denver (“DEN”) and Sacramento (“SMF”), which already has a comparable Delta connection from LAX. See HA

- 2015A

- 1011. In the summer, Minneapolis

- St. Paul (which already h as a nonstop from Narita) and some towns in Southeast Alaska gain connections, but Denver loses its eastbound connection in July and August. 40 

### Some of the existing connections are a little faster, but overall Delta’s Seattle expansion will not make a signi ficant difference. Considering the minimal impact that Delta’s Haneda connecting service has had in any market, see HA

- 2015A

- 916

- 17, Delta’s claim that an improved Seattle network will enhance the prospects of its SEA

- HND service is dubious.

40 

### Delta Published Schedule Data, via Innovata, as of Jan. 6, 2015.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 38 of 64

38 Delta also promises that this time things will be different because “Delta’s own metal services have proved significantly more effective in supporting Delta’s international operation than Alaska

- operated codeshare flights.” Delta Application at 2. Well, that’s not what Delta said last time. The Department relied on Delta’s representation that “Alaska provides effective feed traffic for Delta’s other Seattle services to Asia.” Order Show Cause 2 at 6. Delta’s statement lead the Department to conclude: “we tentati vely find that the proposed connections, offered through Delta’s marketing relationship with Alaska, further support the viability of Delta’s proposed new gateway service and grant of Delta’s motion.” Id. Again, Delta’s representations have been proven s pectacularly wrong

– as Delta ’s share of connecting markets has hovered below 2% in its proposed connecting markets
. See HA

- 2015A

- 9 1 7. The Department must give no weight to Delta’s proposed connecting benefits. C. Delta’s Service Proposal Offers the Least Capacity in this Proceeding. Reflecting the small market and lack of connecting service, Delta continues a longstanding trend and proposes the smallest aircraft in this proceeding. Having proposed to serve the market with a 298

- seat A330 in 2010, Delta in 2012 offered a 225

- seat B767

- 300 ER, which wa s not only the smallest aircraft in Delta’s international fleet but the smallest aircraft proposed in th at proceeding. See Hawaiian 2012 Answer at HA

- 2012A

- 109. Th is time around, Delta again is flying the smallest aircraft in its fleet able to complete the flight, a 208

- seat B767. 41 

### See HA

- 2015A

- 1005. Because Delta is unwilling to use its Seattle frequency on a daily basis, the difference in the capacity that Delta proposes for the Haneda market is even greater, as Hawaiian has proposed over 200% more seats than Delta has scheduled. See HA

- 2015A

- 1006.
41 

### According to T

- 100 and Innovata s chedule data the B767 Delta has been using has 208 seats. Delta is now proposing a 210

- seat version of the B767.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 39 of 64

39 D. Because of Delta’s Woeful Haneda Service Record, t he Department Should Revoke Delta’s Seattle Frequency. Delta’ s performance in the Seattle

- Haneda market does not warrant continuing the service. Delta’s failings in the Seattle market are well documented. Rather than utilizing the valuable frequency from Seattle to its highest and best use, Delta wasted 248 flight s that it could have flown from September 2013 through March of 2015. HA

- 2015A

- 1002. When Delta has flown, its load factors have been an abysmal 57%. See HA

- 2015A

- 1003. Some months they have been less than 35%. See HA

- 2015A

- 1003. As has been noted, t his load factor is lower than other failed Haneda gateways. See HA

- 201 5A

- 1004. The Department should not rely on Delta’s promises that its Seattle service is on the upswing. 42 

### In the prior proceedings in this docket , Delta’s actual performance has fallen far short of the projectio ns submitted to the Department. The chart below d emonstrates the stark difference between the service levels that Delta has proposed and what it has actually delivered. In every Haneda proceeding, Delta has failed to come close to fulfilling its commitments.

42 

### See Delta Application, at 2 (“Dedicated Delta (and Delta Connection) operated capacity has fueled the growth of the Seattle hub, and will s upport and enhance the success of the Seattle

Haneda flight.”).

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 40 of 64

40 See HA

- 2015A

- 1007. In contrast Hawaiian has kept its promises and delivered stellar performance. Hawaiian, with one designation , has carried more Haneda passeng ers than any other airline, including Delta with the two designations it has enjoyed during that entire time. See HA

- 2015A

- 1008. From November 2010

- June 2014, Hawaiian carried 616,834 passengers to Delta’s total of 553,086 from Seattle, Detroit and Los A ngeles combined. See HA

- 2015A

- 1008. The records are not comparable and justify the revocation of Delta’s Haneda

- Seattle frequency and its reallocation to Hawaiian for its proposed Kona service.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 41 of 64

41 IV. The Department Should Reject American’s Inflated Claims an d Award the Available Frequency to Hawaiian. American’s application to serve LAX is an exercise in self

- delusion. As a foundational matter, American appears to prefer to pretend that the State of Hawai i does not exist. While several of American’s exhibit s honestly point out that LAX is the largest Tokyo O&D market “in the continental United States , ” 43 

### other references in the application omit that crucial qualifier and claim LAX is “ the largest U.S.

- Tokyo market.” 44 

### This is flatly wrong. The largest Tokyo

- U.S. O&D market is Tokyo

Honolulu/ Hawaii, and it isn’t even close. 45

43 

### See, e.g., American Application, at Exhibits AA

- 201, 203, 401 (emphasis added)
. 44 

### American Application, at 2, 11 45 

### See HA

- 2015A

- 9 08
.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 42 of 64

42 T he size of the Los Angeles market is not the only delusion in American’s A pplication. The self

- proclaimed “ largest U.S. airline ” has portra yed itself as an upstart seeking a tender foothold in Japan:

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 43 of 64

43 American’s efforts [to secure a more comprehensive network to Japan] have been either practically or legally impeded by the incumbent carriers’ opposition and strong market position, which is t he product of their many decades head start in Asia on American, which in turn, is the product of their privileged ‘incumbent’ position. American Application , at 3. Oh , p lease
. This statement must be read twice to be believed. American is in an immunized joint venture with a Japanese flag incumbent carrier , JAL. In its pleadings arguing for the grant of antitrust immunity, American and JAL pledged to act as a single firm. 46 

### See Joint Application for Antitrust Immunity , DOT

- OST 2010

- 0034 (Feb. 12, 2010), at 2 (“This proposed alliance will create metal neutrality between two of oneworld’s core transpacific members

– American and JAL.”). JAL and American function as a single economic entity and have every advantage of incumbency, including two Haneda

- U.S. frequencies; see HA

- 2015A

- 902 ; 33 percent of the Haneda departures overall; see HA

- 2015A

- 705; 111 weekly flights between Tokyo and the U.S.; see HA

- 2015A

- 903 ; and 14 weekly roundtrips between Tokyo and LAX. See HA

- 2015A

- 905 . If the Department is going to credit the role of underdog in this proceeding, it should favor a nonaligned carrier that is less than a tenth of American’s size. See HA

- 2015A

- 11 5
. Even dismissing the puffery in American’s a pplication , Hawaiian’s Kona application is superior for a number of independent reasons. First , American’s

46 

### Hawaiian has a proposal for American. If American will stop playing the “poor upstart” card in DOT proceedings, Hawaiian will stop arguing that the Department should fulfill its mandate to strengthen smaller carriers, see Part V, infra , long before Hawa iian’s network reaches 260 destinations served by 627 aircraft, which is the current size of American. See American Airlines, Fleet Statistics (2015), http://www.aa.com/i1 8n/amrcorp/corporateInformation/facts/fleet.jsp ; American Airlines, Profile: AMR Corporation At A Glance (2015), http://www.aa.com/i18n/aboutUs/corporateResponsibility/profile/amr

- corporation

- at
- a glance.jsp.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 44 of 64

44 introduction of more LAX

- Tokyo capacity into a saturated market will require service cutbacks . Even if American’s service does survive, it is likel y that, under those circumstances, Delta’s will not. Second , American has promised benefits of its connecting service, which are either redundant or grossly overstated. Third , given the ample capacity and likelihood of a service failure, Kona is more des erving of Haneda authority than Los Angeles . Finally, American’s Haneda service record does not engender confidence that it will maximize the public benefits of this scarce resource. A. The Los Angeles - Tokyo Route Has So Much Capacity that Implementation of American’s Proposal Will Require Service Cutbacks . In proposing to serve Los Angeles, American offers nothing new. Indeed, it reiterates a proposal that the Department rejected when approving Delta’s transfer of its Detroit service to Seattle. Back then, the Department denied American’s application concluding that Los Angeles already had ample Haneda service: we note that Los Angeles already has two daily nonstop flights to Haneda. . . . Given the very limited opportunities for U.S. carrier service to Haneda, we tentatively do not find American’s arguments persuasive for adding more Haneda service at Los Angeles while other significant U.S.

- Tokyo gateways have no access to Haneda. Order Show Cause 2 at 6. In 2013, American must have seen the wisdom in the Department’s decision and did not even attempt to transfer its JFK authority to Los Angeles or apply for the route once DOT noticed a proceeding . In contrast, Hawaiian has expressed confidence in its proposed Kona route and sought that additional aut hority at every opportunity. Nevertheless, American has proposed to serve a market, Tokyo

- LAX , that already has capacity in abundance. The Tokyo

- LAX market already is served by 56 weekly roundtrips,

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 45 of 64

45 including Haneda service offered by both Sky Team’s Delta and Star’s ANA. See HA

- 201 5 A

904
. A significant number of the total Tokyo

- LAX services are offered by oneworld , which provid es 14 of the weekly roundtrips. See HA

- 201 5 A

- 903, 905
. More problematically, the market is shrinking. See HA

- 2015A

- 406
. With JAL’s daily service to San Diego, oneworld has even more capacity nearby in Southern California
. See HA

- 201 5 A

- 903
. Now American proposes to add capacity to a market that needs none
. See HA

- 2015A

- 108
. Moreover, due to the restrictions in the bilateral, American proposes to fly almost the exact same sch edule as Delta’s HND

- LAX service and will depart Haneda about the same time as ANA’s service
. See HA

2015A

- 910
. Indeed, Delta’s service has survived only because it has repeatedly downgauged it s aircraft from a B747 with 403 seats down to the smallest aircraft in Delta’s seat capable of flying the route a 208

- seat B767 with barely more than half the capacity. See HA

- 201 5 A

- 91 2

- 14
. Indeed, Delta’s LAX

- HND results demonstrate that the market cann ot even sustain a modest upgauge to a B777, which would drop load factors to an uneconomic 56%. See HA

- 2015A

- 913
. Adding more capacity into the face of these statistics does not make sense. Accordingly, American’s service will work only if there are ser vice cutbacks. 1. American Has Already Indicated it will Cut its NRT - LAX Service. One strategy for reducing capacity to make way for a new LAX

- Haneda service would be to eliminate redundant Narita service. American has already foreshadowed its strategy to do just that. In its 2014 application for LAX service, American used its same flight numbers for the proposed LAX

- HND service as it uses for its current NRT

- LAX service. 47

47 

### Motion and Application of American Airlines , DOT

- OST

- 2010

- 0018 (Oct. 2, 2014), at Exhibit AA

- 2; Consolidated Answer of Delta Air Lines, Inc. , DOT

- OST

- 2010

- 0018 (Oct. 17, 2014), hereinafter “Delta 2014 Answer”, at DL

- 3.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 46 of 64

46 American should be commended for the honesty displayed in this initial application , but implementation of its scheme is not in the public interest. When implemented, American’s service cutback will eliminate much of the purported benefit of its proposed service and provide no competitive benefits
. This scheme should be all that the Department needs to know about American’s confidence in the need for more HND

- LAX service. Nor should American’s initial application be dismissed as a typographical error. American followed the same service cutback strategy in the 2010 H aneda allocation proceeding . Upon receiving HND

- JFK authority,

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 47 of 64

47 American eliminated NRT

- JFK service. An award to American may allow the oneworld alliance to fine tune its U.S.

- Japan service schedule, but it will not maximize the public benefits. 2. Implementation of American’s LAX - H ND Proposal Will Reduce Load Factors so Low that the Service Will Fail. Because LAX

- H ND has abundant capacity, introduction of American’s service will make all three of the services uneconomic. Hawaiian projects that the addition of American’s capacity will have little, if any, stimulating effect on passengers. 48 

### See HA

- 2015A

- 621 (estimatin g stimulation of only 4.15%). This will result in an abysmal load factor on American’s flight of 50.5%. See HA

- 2015A

- 930. Four years of operating experience at Haneda have amply demonstrated that this load factor is not sustainable. Indeed, Hawaiian pr ojects that American’s load factor, and the average load factor for the entire HND

- LAX market, will be below that of Seattle with a third carrier
. The market is simply not large enough for a third carrier.

48 

### Hawaiian’s analysis assumes that American will continue to operate NRT

- LAX.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 48 of 64

48 WITH THREE CARRIERS, THE LAX - HND MARKET WILL FAIL JUST LIKE JFK, DTW AND SEA (LAX - HND LOAD FACTOR

– YE JUNE 2014) 49



### Hawaiian respectfully submits that an award to American will result in yet another Haneda reallocation proceeding in short order. B. The Benefits of Connecting Service Promised by American Ar e Overblown. American’s attempts to prop up its tired application by touting the benefits of connecting service rely on exaggerated claims and reflect a misunderstanding of the Haneda market. 50 

### As a

49 

### HA

- 2015A

- 930.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 49 of 64

49 threshold matter, the operating experience at Haneda has demonstrated that the connecting service has minimal impact on any connecting market. See HA

- 2015A

- 917

- 20. Moreover, American’s claims of increasing the number of connections rely on very generous assumptions about what is a realistic connection. When reasonable assumptions are made, the additional connections are minimal. The benefits of American’s connections are also minimized by the fact that American’s service is redundant with other connecting services or nonstop service from Tokyo. T he number of Haneda passengers making connections at U.S. gateways is in significant. In the connecting markets originally proposed by U.S. flag carriers in previous HND proceedings , the share of Tokyo passengers using HND has averaged less than 3 %
. See HA

2015A

- 91 6 . This has held true for Delta’s LAX service, see HA

- 2015A

- 918; Delta’s Seattle service, see HA

- 2015A

- 91 8 ; and American’s JFK service. See HA

- 2015A

- 919 . Accordingly, the competitive benefits touted by American have been demonstrated to be negligible at best. American’s claims of connecting benefits now have no credibility. American’s claim that it will be able to offer up to “32 connections in both directions . . .

– more than any other Los Angeles

- Haneda carrier” 51 

### relies on a completely un realistic assumption about what is a practical connection. In performing this contorted analysis, American has included connections of up to 10 hours in its count. See HA

- 2015A

- 921
. If a more practical four hour connection is used, the number of connect ing markets plummets to 12. See HA

- 2015A

- 922
.

50 

### See American Application, at 4, 6, 12. 51 

### Id., at 2.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 50 of 64

50 AMERICAN’S ROUNDTRIP CONNECTIONS DROP FRO M 32 TO 12 WHEN CONNECTING TIME S ARE LIMITED TO REA SONABLE LEVELS 52



### The connecting services offered by American are likely to provide minimal benefits for another reason: they are redundant with other connections . Delta already offers a similar connecting network from LAX, see HA

- 2015A

- 915 , and most large interior points already have

52 

### See HA

- 2015A

- 922. FAT FAT FAT FAT SJC SFO MRY MRY MRY MRY

TPA

GRU SAN RNO SMF SMF SMF SMF YVR

EUG

LAX LAX ATL ATL ATL ATL

AUS AUS AUS AUS BNA BOS BOS BOS BOS

CLT CLT CLT CLT DEN

DFW ELP ELP ELP ELP IAD

IAH JFK

LAS LAS LAS LAS

MCO
MIA ORD

PBI PBI PBI PBI PHL PHL PHL PHL

PHX PHX PHX PHX

SAT SAT SAT SAT SLC

TUS TUS TUS TUS To HND

12 Normal Connections

- Limited to 4

- Hour Connections

AUS AUS AUS AUS YVR

SAN

LAX LAX SJC DEN

ELP ELP ELP ELP IAH LAS LAS LAS LAS
PHX PHX PHX PHX

SAT SAT SAT SAT SLC

TUS TUS TUS TUS To HND 32 Points from Exhibit AA

- 107

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 51 of 64

51 connecting Haneda service. See HA

- 2015A

- 924. In fact, American is only offering three roundtrip connecting markets that do not already have convenient Haneda roundtrips today. See HA

- 2015A

- 92 4
.

See HA

- 2015A

- 924 . If these are all the connecting benefits that American can muster, the data demonstrates that Kona is a far superior market. Kona has over three times as many Tokyo passengers and over thirty times as many HND passengers as all of American’s unduplicated roundtrip points behind LAX. SAT SAT SAT SAT HND HND LAX LAX AUS AUS AUS ELP ELP ELP ELP AMERICAN IS ONLY OFFERING THREE ROUNDTRIP CONNECTING MARKETS THAT DO NOT ALREADY HAVE CONVENIENT HND ROUNDTRIPS TODAY

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 52 of 64

52 HA

- 2015A

- 925. Given American’s track record of inflated claims of connecting benefits, the Department should discount any purported benefit from American’s proposed connections. C. Kona is More Deserving of a Haneda Award t han Los Angeles. American would have the Department believe that Kona is a small market that does not deserve a scarce Haneda slot. This view is not supported by the facts. Given the number of seats

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 53 of 64

53 proposed in this proceeding, Kona is underserved relative to Los Angeles

– even before accounting for stimulation in the respective markets. See HA

- 2015A

- 911 (calculating the ratio of passengers before stimulation to the number of proposed seats in the ma rket). A comparison between the number of MIDT passengers per flight in both Kona and Los Angeles yields the same result. EVEN BEFORE STIMULAT ION KONA IS UNDERSER VED RELATIVE TO L AX 53 

### (YE SEPTEMBER 2014 T OKYO MIDT PASSENGERS PER FLIGHT)

The Department sh ould remedy this imbalance by granting Hawaiian’s application. Indeed, an award to American would further imbalance an already imbalanced situation in which Hawaii has far more MIDT passenger per Haneda frequency than California. See HA

- 2015A

- 402, 403.

53 

### See HA

- 2015A

- 909.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 54 of 64

54 D. American Has a Poor Haneda Service Record . The Department should be skeptical of American’s claim of public benefits for another reason. When awarded a frequency in the 2010 proceeding, American performed poorly. American started its service 93 days late
. See HA

- 2015A

- 104 . When it started Haneda

- JFK service, it suspended service from Narita, and it failed to operate the service reliably, experiencing 353 no

- op days before turning in the frequency. See HA

- 2015A

- 104 . In contrast, Hawaiian has flown the most Haneda frequencies of any U.S. carrier, started before any other U.S. carrier, operated continuously compared to intermittent service from U.S. carrier rivals, operates the largest aircraft from Haneda and flown the most onboard passengers. See HA

20 15A

- 206

- 11. The comparative Haneda service record strongly favors an award to Hawaiian. V. The Grant of Hawaiian’s Application Will Strengthen a Small Competitor. The grant of Hawaiian’s application to serve Kona will satisfy the longstanding public interest goal of strengthening small air carriers. The Federal Aviation Act 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. See e.g., St. Louis

- Southeast Service Case , 27 C.A.B. 342, 347 (1958) (“[T]he need of a smaller carrier for route strengthening has been, and should be, an important factor to be considered by us in selecting a carrier to provide needed service.”); c.f. Southwest

- Northeast Service Case , 22 C.A.B. 973 (1955); New York

Florida Case , 2 4 C.A.B. 94 (1956).

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 55 of 64

55 Recent proceedings confirm that the Department continues to weigh this factor in its public interest analysis because strengthening smaller carriers remains the best way for the Department to enhance competition and reduce market concentration. See 1998 U .S.

- Brazil Combination Service Case , DOT

- OST

- 1998

- 3863, Order 98

- 12

- 33, at 8 (Dec. 29, 1998) (finding its selection of 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 , DOT

- OST

- 2007

- 0006, 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 h as not seen the entry of any new U.S. competitor since the year 2000.” )
. This public interest factor also influenced the Department’s decision in the initial Haneda Allocation Proceeding when it awarded the first available slot pair to Hawaiian , which wo uld achieve the important objective of enhancing competition in the U.S.

- Tokyo market as a new entrant. . . . 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. 54 

### This principle strongly favors an award of the frequency to Hawaiian. By any measure , Delta and American are ten times the size of Hawaiian
. See HA

- 201 5 A

- 11 5 . Also , unlike Delta and American , Hawaiian is not affiliated with any major alliance. American and its immunized oneworld partner JAL overwhelm Hawaiian’s 7 weekly flights from Tokyo to the United States, flying 111 weekly round trips or 15 times more service from Tokyo than Hawaiian of fers. See

54 

### Order Show Cause 1, at 8.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 56 of 64

56 HA

- 201 5 A

- 701. Delta and its Skyteam partners offer 119 weekly round trips or 17 times as much service from Tokyo as Hawaiian. See HA

- 2013A

- 701. It has never been more important for the Department to fulfill its statutory obligation to promote the strengthening of small carriers. The last decade has ushered in a wave of consolidation in the airline industry coupled with the growth of global alliances, many of which have received antitrust immunity to facilitate coordination between the i r members . The phenomenon can certainly be observed by in the U.S.

- Japan market that Delta and the U.S.

- Japan joint ventures dominate. See HA

- 2015A

- 703

- 04, 707. The only antidote to this trend toward consolidation is Hawaiian. Among all U.S. carriers, it is uniquely positioned with both the capability (given its widebody fleet) and willingness to challeng e the global behemoths. If the D epartment values the promotion of new competition, it must grant Hawaiian ’s application. The Department, however, does not need to sacrifice other public interest benefits by awarding the frequency to Hawaiian. Despite its small size, Hawaiian’s track record in this proceeding demonstrates it is in the best position to maximize the benefit from the available frequency
. 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. Indeed, 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 Show Cause 1, at 8. The 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. If the Department

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 57 of 64

57 indeed wants to promote competition from non

- align ed carriers, it should award authority to smaller carriers when they have demonstrated the ability to succeed. In these circumstances where both American and Delta have had the opportunity to serve Haneda and either returned or failed to use the slot, the Department should award the next opportunity to Hawaiian. VI. Awarding the Available Frequency to Hawaiian Will Both Promote Independent Competition and Preserve the Competitive Balance Among the Major Alliance’s at Haneda. A. The Grant of Hawaiian’s Applicatio n to Serve Kona Will Reduce Concentration in Markets Dominated by the Three Global Alliances. Delta has repeatedly argued in this proceeding that it should be entitled to two of the four available frequencies so that it can counteract the “inherent advanta ges” that the two immunized U.S.

- Japanese alliances have over Delta and its Sky Team partners
. 55 

### The premise of this argument is that the Department should ensure a competitive equilibrium among the dominant alliances . Achieving that goal would have the a dverse impact of replicating what the three alliances have achieved across the Atlantic, where the oneworld, Sky T eam and Star allianc es have sufficient market power to stifle the entry and expansion of non

- aligned airlines . In this proceeding, the Depart ment should aim for achieving a higher public interest goal and promote independent competition, and Hawaiian i s the on ly applicant providing an alternative to the dominance of the aligned carriers with their historical advantages of incumbency. See HA

20 15A

- 702. Granting Hawaiian’s application will incrementally reduce the power of the alliances. 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 55 

### See, e.g., Delta 2014 Answer, at 10.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 58 of 64

58 of Haneda slots possible. U.S.

- Japan Alliance Case , at 1. While Hawaiian 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 market s highly concentrated. The Sky T eam, oneworld and Star alliances control 98 percent of the U.S.

- Tokyo frequencies, 98 percent of passengers and 92 percent of Tokyo

- Ho nolulu frequencies. See HA

- 201 5 A

- 70 2 , 70 4 , 70 7
. American’s oneworld alliance already has a significant market share at Haneda, where it control s 3 1 percent of the seats . See HA

- 2015 A

- 706
. 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 wou ld still be dominated by the alliances, see HA

- 201 5 A

- 707 (depicting Hawaiian’s eight percent share of Hawaii

- Tokyo frequencies compared to the alliances’ 92 percent), it will give Hawaiian a stronger base from which to grow. Four years of operating exper ience 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 Consol idated Reply of Hawaiian Airlines, Inc. , DOT

- OST

- 2010

- 0018 (Mar. 8, 2010) , at 6

- 7. Not content to simply operate the single successful route between Haneda and Honolulu, Hawaiian seized the opportunity granted by the Department and the Open Skies Agreemen t with Japan. For years, Hawaiian’s presence in Japan had been limited to charter service and the marketing of its Inter

Island services to tourists who traveled to Hawaii on other carriers. The introduction of

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 59 of 64

59 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 servic es to additional cities in Japan, including Osaka, Sendai and Sapporo

- Chitose and free sale codeshare service with ANA to Hiroshima, Kagoshima, Oita, Okinawa, Osaka

- Itami and Sapporo

- Chitose. Not to be overlooked , Hawaiian’s willingness to compete with th e 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

- 40 3 . In fact, Honolulu generated approxim ately twenty - five times the passengers than all other gateways combined. See HA

- 201 5 A

- 40 4 . The public benefit of reducing this highly concentrated market is significant and Hawaiian should be given the opportunity to expand upon its successful platform t hrough the award of an additional slot pair at Haneda. B. Because Hawaiian Is Independent, the Grant of Hawaiian’s Application Will Benefit Competition Rather than the Major Alliances . Awarding the available Haneda frequency to Hawaiian is necessary to maximize the benefit of this valuable air service right. Delta has argued repeatedly in this proceeding that the Department’s consideration of the “overall competitive environment” and “market structure” require that the Department allow it to retain two frequencies to balance the “inherent advantages” the U.S.

- Japanese alliances have. 56 

### The Department has again pledged to consider

56 

### See, e.g., Consolidated Answer of Delta Air Lines, Inc. , DOT

- OST

- 2010

- 0018 (Sep. 6. 2012), hereinafter “Delta 2012 Answer”, at 5 (quoting Order 2012

- 8

- 20).

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 60 of 64

60 those factors in this proceeding. 57 

### Because Delta has been unable or unwilling to use it s Seattle frequency effectively , consideration of this public interest in balancing the competitive market structure now favors Hawaiian. An award to Hawaiian is necessary to prevent the U.S.

- Japanese alliances from dominating the U.S.

- Haneda market. As a result of the compromise in the MOU by which four Haneda slot pairs were to be allocated to Japanese carriers and four were t o be allocated to U.S. carriers , the Star and oneworld alliances already hold five of the eight available slot pairs. ANA and Uni ted are now part of an immunized alliance as are American and JAL. See U.S.

- Japan Alliance Case , Order 2010

- 11

- 10. In touting the benefits of antitrust immunity, the applicants stated that the alliance would be structured to be “metal neutral,” meaning t hat 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. Despite American’s claim that its service would “inject a new U.S. competitor to Haneda , ” 58 

### the award of the slot pair to American is the equivalen t of awarding it to oneworld , meaning that six of the eight Haneda

- U.S. frequencies would be controlled by the U.S.

- Japan joint ventures
.

57 

### Initiating Order, at 6 (“The Department will also consider the effects of each service proposal on the overall competitive environment, including effects on the market structure and on competition in the U.S.

- Japan market.”) 58 

### American Application, at 1 0.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 61 of 64

61 Allowing Delta to retain the Haneda slot pair will not preserve the competitive benefit of the slot pair. Delta has demonstrated that it is not willing to fly the slot with regularity, 59 

### and the flight has proven to be unpopular on the rare occasions when it has been flown, demonstrating abysmal load factors. 60 

### Indeed, Delta’s Seattle load factors have been lowe r than tw o failed Haneda routes. DELTA’S SEATTLE - HANEDA LOAD FACTOR I S BELOW THE AVERAGE LOAD FACTOR OF TWO HANEDA ROUTES THAT HAVE FAILED 61

59 

### See HA

- 2015A

- 208, 1002 (depicting 248 unused SEA

- HND roundtrips). 60 

### See HA

- 2015A

- 1003 (averaging a 57% load factor). 61 

### See HA

- 2015A

- 1004.

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 62 of 64

62 Accordingly, this valuable air service right is being wasted. Under Delta’s stewardship, the benefits of five of seven Ha neda frequencies are being enjoyed by the U.S.

- Japan alliances. The Department should maximize the public benefit of the frequency by awarding it to the only
non aligned carrier with an impeccable record of maximizing the available Haneda authority

– Hawaiian Airlines, improving the “overall competitive environment” and “market structure
. ” The alternative is to hand th is valuable frequency right to the JAL

- American joint venture
. VII. Hawaiian has a Unique Incentive to Make its Kona Service a Success. Onl y Hawaiian’s proposed service to Kona will introduce nonstop service from Tokyo to a market that does not currently have it. Unlike the other carriers in this proceeding, Hawaiian has no investment in operations and facilities at Narita. Narita is domina ted by the alliance carriers, which have huge commitments to that airport. The JAL

- American joint venture operate s 36 segments from Narita, including 14 weekly frequencies to LAX
. See HA

- 201 5 A

901, 90 3
. Delta operate s 17 segments from Narita, including 135 weekly departures
. See HA

2015A

- 100 1
. 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

- 201 5 A

- 109. Both the American

- JAL joint venture and Delta have significant investments in their operations at Narita. See HA

- 201 5 A

- 901, 1001. In fact, the fear of diversion from existing Narita services has likely been a major contributor to the periodic suspensio ns of all the mainline route s from the alliance carriers. With the substantial investment of oneworld at Narita, American 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

### DOT

- OST

- 2010

- 0018 2015 Answer of Hawaiian Airlines, Inc. Page 63 of 64

63 Tokyo

- U.S. market, which has led to an expanding Tokyo

- Honolulu market and a superior operating record at Haneda. VIII. 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 Delta and American on important customer service metrics. In the year endin g October 2014 , Hawaiian again led its legacy airline co mpetitors in on

- time arrivals, s ee HA

- 201 5A

- 801, extending its winning streak to a full decade. See HA

- 201 5 A

- 805. Hawaiian also bests Delta and American in the rate of mishandled bags, see HA

- 201 5 A

- 802. By a substantial margin, Hawaiian has a much lower rate of passengers denied boarding. See HA

- 201 5 A

- 803 (depicting Delta ’s rate more than eight times Hawaiian’s rate and American’s rate more than nine times Hawaiian’s rate ). Hawaiian’s superior service manifests itself in a primary indicator of customer satisfaction

– fewer customer complaints. By that measure , Hawaiian’s customer complaint rate
was on par with Delta and nearly a third of American’s customer complaint rat e . See HA

201 5 A

- 804. Conclusion As set forth in this Answer, the public interest will be best served by the award of Delta’s functionally abandoned Haneda slot pair to Hawaiian Airlines. Kona is the only market presented to the Department without nons top 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.

### 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 But SEA and LAX do Not 500 Kona is t he Best Use of the U.S.’s 4 th 

### Haneda Frequency 600 Economic Impact 700 Alliance Carriers Dominate the Tokyo Market 800 Hawaiian’s Record of Outstanding Performance 900 Rebuttal to American 1000 Rebuttal to Delta

### 100 SERIES: SUMMARY EXHIBITS

### 100 Series Exhibits Exhibit HA

- 2015A

- 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)

• Mainland - Haneda Service Has Been A Recipe For Failure For U.S. Legacy Carriers ( Exhibit 104)

• American Is Proposing Service Eerily Similar To Services That Have Failed At Other Mainland Gateways (Exhibit 105)

• Delta’s SEA Proposal Is A Proven Loser (Exhibit 106)

• HND Passenger Flow Behind Mainland Gateway Is A Myth (Exhibit 107)

• American Adds Nothing to a Market that Needs Nothing (Exhibit 108)

• Kona Has A Tokyo Point Of Origin That Is Consistent With Success ( Exhibit 109)

• Japanese Originating Passengers Are Far More Valuable To The U.S. Economy Than U.S. Originating Passengers (Exhibit 110)

• Hawaiian Kept Its Haneda Route Case Commitments (Exhibit 111)

• Haneda Service Is Far More Important To Hawaiian Than It Is To The Large Alliance Carriers (Exhibit 112)

• Hawaiian Will Operate The Largest Aircraft (Exhibit 113)

• Hawaiian Will Provide More Haneda Capacity Than American Or Delta (Exhibit 114)

• The Three Alliances Are Each Over 5 0 Times The Size Of Hawaiian (Exhibit 115)

### 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 616,834 DL - LAX YES YES YES YES YES NO 391,167 AA - JFK YES YES YES YES YES NO 229,709 DL - DTW YES YES YES YES YES NO 87,864 DL - SEA YES YES YES YES YES NO /2 74,055 Exhibit HA

- 2015A

- 101 Docket OST

- 2010

- 0018 Page 1 of 1

Note: Excludes UA - SFO since it has just started. 1/ U.S. DOT, T - 100 data , November 2010 - June 2014.

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

82% 77%

57% 72% 69% 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 d ata, November 2010 - June 2014and MIDT data via Travelport, YE September 2014. 

### SFO JFK HNL

% Point of Origin Tokyo* 

### Correlation Between Point of Origin /1 

### Tokyo * 

### and Load Factor = 0.81 Exhibit HA

- 2015A

- 102 Docket OST

- 2010

- 0018 Page 1 of 1



### LAX

DTW
SEA

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

100% 94%

46% 65% 65%

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 when each service began to April 2015. Does not penalize carriers for starting late. Source: Innovata schedule data and MIDT data via Travelport, YE September 2014. 

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

% Point of Origin Tokyo* 

### Correlation Between Point of Origin /1 

### Tokyo * 

### and Authorized Flights Operated = 0.79 Exhibit HA

- 2015A

- 103 Docket OST

- 2010

- 0018 Page 1 of 1



### DL - LAX

DL - SEA

### MAINLAND - HANEDA SERVICE HAS BEEN A RECIPE FOR FAILURE FOR U.S. LEGACY CARRIERS Mainland Gateways Awarded Exhibit HA

- 2015A

- 104 Docket OST

- 2010

- 0018 Page 1 of 1



### Proposal Real World Results
DTW

LAX

JFK

SEA

SFO Daily B747

Daily B747

Daily B777

Daily B767

Daily B777 • Service started 94 days late • Aircraft downgraded to smaller B777 in July 2011 • 319 noop days from service start date to suspension date • A ll service suspended in Sept. 2012

• Service started 94 days late • Aircraft downgraded to smaller B777 in June 2011 • Aircraft downgraded to smaller A330 in Oct. 2011 • Aircraft downgraded to smaller B767 in Mar. 2013 • 90 noop days from service start date to April 2015

• Service started 93 days late • Suspended JFK - NRT service concurrently with HND start • 353 noop days from service start to April 2015 • A ll service suspended in Nov. 2013

• Proposed A330 aircraft in first Haneda case • Instituted service with smaller B767 • Service downgraded to less than daily in most months from September 2013 through September 2014 • Service suspended most days from October 2014 - March 2015 • 248 noop days from start date to April 2015

• UA reduced NRT capacity with the addition of HND • UA’s LAX - TYO total seats are down after adding HND

### AMERICAN 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 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 YES UA - SFO YES YES YES YES YES NO ?

AA - LAX YES YES YES YES YES NO Exhibit HA

- 2015A

- 105 Docket OST

- 2010

- 0018 Page 1 of 1

### DELTA’S SEA PROPOSAL IS A PROVEN LOSER Exhibit HA

- 2015A

- 106 Docket OST

- 2010

- 0018 Page 1 of 1



## • 57% average load factor (Exhibit A - 1003)

• Virtually no service during winter 2014 - 2015

• 248 roundtrips not operated (Exhibit A - 1002)

• Only 43% of proposed seats were operated (Exhibit A - 1007)

• Long list of failed commitments

### HND - PASSENGER FLOW VIA MAINLAND GATEWAYS IS A MYTH Exhibit HA

- 2015A

- 107 Docket OST

- 2010

- 0018 Page 1 of 1



## • Delta’s Detroit Proposal (2010)

̶ Fantasy/Regulatory World: 106 flow points touted as support

̶ Real World: Flow points achieved less than 3% TYO share



## • Delta’s LAX Proposal (2010)

̶ Fantasy/Regulatory World: 18 points touted as support

̶ Real World: Flow points achieved less than 2.5% TYO share (Exhibit A - 918)



## • American’s JFK Proposal (2010)

̶ Fantasy/Regulatory World: 17 points touted as support

̶ Real World: Flow points achieved less than 3% TYO share (Exhibit A - 919)



## • Delta’s SEA Proposal (2012)

̶ Fantasy/Regulatory World: 42 flow points touted as support

̶ Real World: Flow points achieved less than 2% TYO share (Exhibit A - 917)



## • American’s LAX Proposal (2014)

̶ Fantasy/Regulatory World: 25 - 32 flow points touted as support

̶ Real World : Should be less than 3% based on historical experience and current passengers using LAX (Exhibit A - 920)

### AMERICAN ADDS NOTHING TO A MARKET THAT NEEDS NOTHING Exhibit HA

- 2015A

- 108 Docket OST

- 2010

- 0018 Page 1 of 1



## • LAX - Tokyo O&D passenger level is still below 2009 level (Exhibit A - 406)

• Number of AA exhibits presenting evidence of a need for more LAX - HND capacity: 0

• American apparently intends to discontinue LAX - NRT service with the start of HND - LAX (Exhibit A - 931)

• Service proposal duplicates current incumbent times (Exhibit A - 910)

• Failure at JFK blamed on the same restrictive HND times that apply to LAX today

• Behind gateway proposal touts service with up to 10 hours “connecting” time (Exhibit A - 921)

• Flow traffic will be insignificant (Exhibits A - 922 - 925)

̶ Only 3 unduplicated connecting markets with a Tokyo O&D of only 18,000

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

- 2015A

- 109 Docket OST

- 2010

- 0018 Page 1 of 1

Source: MIDT via Travelport. 

### 95% 96%

66% 63% 57% 70%


## 53%

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

HNL KOA LAX SFO SEA JFK DTW

% Point of Sale Japan of Tokyo MIDT Passengers – YE September 2014

Discontinued HND Routes Current HND Routes

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

$1,660

$1,066

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

Japan Originating Passengers to Hawaii Japan Originating Passengers to All U.S U.S. Originating Passengers Exhibit HA

- 2015A

- 110 Docket OST

- 2010

- 0018 Page 1 of 1



### Average Spending in U.S.

Note: Includes spending by Japanese Visitors at destination with all values updated to 2014 using GDP price deflator. Sources: U.S. Department of Commerce Office of Travel and Tourism Industries, 2013Market Profile: Japan; 2013 Annual Visitor Research Report, State of Hawaii, Department of Business, Economic Development & Tourism

### HAWAIIAN KEPT ITS HANEDA ROUTE CASE COMMITMENTS Exhibit HA

- 2015A

- 111 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 - 208)

• Hawaiian proposed A330 aircraft and Hawaiian operates A330 aircraft.

• Hawaiian operated all of its awarded frequencies. (Exhibit A - 209)

• Hawaiian transported 156,733 passengers in its first full year of service (Exhibit A - 509) and 177,261 passengers in the latest reported T - 100 data.135

91

26 0 0 20 40 60 80 100 120 140 160

Delta United American Hawaiian 616

430 319

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 January 5, 2015. 

### By Carrier By Alliance 

### HANEDA SERVICE IS FAR MORE IMPORTANT TO HAWAIIAN THAN IT IS TO THE LARGE ALLIANCE CARRIERS Exhibit HA

- 2015A

- 112 Docket OST

- 2010

- 0018 Page 1 of 1

### HAWAIIAN WILL OPERATE THE LARGEST AIRCRAFT

247
210 294

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

### Proposed Aircraft Size



### Hawaiian (KOA) ( A330 ) Exhibit HA

- 2015A

- 113 Docket OST

- 2010

- 0018 Page 1 of 1

Source : Applications. 

### American (LAX) (B777) Delta (SEA) (B767)180,310

118,930 214,620

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 and Actual for Delta 

### HAWAIIAN WILL PROVIDE SIGNIFICANTLY MORE HANEDA CAPACITY THAN AMERICAN OR DELTA Exhibit HA

- 2015A

- 114 Docket OST

- 2010

- 0018 Page 1 of 1

*Actual YE June 2014 seats operated from T - 100 for Delta . Source : Applications for Hawaiian and American. 

### Hawaiian

( A330 ) American (B777) +19%



### Delta* (B767) +80%17,288 17,190

338 21,523

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

### System Available Seat Miles per Week (Millions)

Source Innovata schedule data , week January 5, 2015. 

### Star oneworld SkyTeam Hawaiian THE THREE ALLIANCES ARE EACH OVER 50 TIMES THE SIZE OF HAWAIIAN Exhibit HA

- 2015A

- 115 Docket OST

- 2010

- 0018 Page 1 of 3



### Times as

Large as HA: 64x 51x 51x3,324 2,963

51 4,561

0 500 1,000 1,500 2,000 2,500 3,000 3,500 4,000 4,500 5,000 

### Active Fleet

Source: Diio Mi and alliance websites. 

### Star oneworld SkyTeam Hawaiian Exhibit HA

- 2015A

- 115 Docket OST

- 2010

- 0018 Page 2 of 3



### Times as

Large as HA: 89x 65x 58x 

### THE THREE ALLIANCES ARE EACH OVER 50 TIMES THE SIZE OF HAWAIIAN507 588

10 654

0 100 200 300 400 500 600 700 

### Onboard Passengers (Millions)

Source: U.S. DOT, T - 100 data and Alliance websites. Exhibit HA

- 2015A

- 115 Docket OST

- 2010

- 0018 Page 3 of 3



### Times as

Large as HA: 65x 51x 59x 

### THE THREE ALLIANCES ARE EACH OVER 50 TIMES THE SIZE OF HAWAIIAN

Star oneworld SkyTeam Hawaiian

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

### 200 Series Exhibits HAWAIIAN HAS EARNED A SECOND HANEDA FREQUENCY Exhibit HA

- 2015A

- 200 Docket OST

- 2010

- 0018 Page 1 of 1



### • Hawaiian Has Outperformed All Other U.S. Flag Haneda Carriers (Exhibit 201)
• With One Designation Hawaiian Has Carried More Haneda Passengers Than Any Other U.S. Flag Carrier Including Delta Which Has Two (Exhibit 202)
• Hawaiian Has the Highest Haneda Load Factor of All U.S. Flag Haneda Carriers (Exhibit 203)
• HNL - HND Had The Greatest Positive Impact On Tokyo Traffic (Exhibit 204)
• Hawaiian Has Provided Consistent Competitive HND Service To Japanese Flag Carriers (Exhibit 205
• Only Hawaiian Stood Up To Strong Japanese Competition (Exhibit 206)
• Hawaiian Started Its Haneda Service Before Any Other U.S. Flag Carrier (Exhibit 207)
• Hawaiian Is The Only U.S. Flag Carrier That Has Provided Uninterrupted Service to HND (Exhibit 208)
• Hawaiian Operated All Of Its Awarded Frequencies While U.S. Flag Mainland Carriers Squandered 41% Of Their Awarded U.S.

– Haneda Frequencies (Exhibit 209)
• Hawaiian Operates The Largest Aircraft To HND Of All U.S. Flag Carriers (Exhibit 210)
• In The Latest Year Available, Hawaiian’s HNL - HND Service Carried 58% More Onboard Passengers Than The Second Highest U.S. Flag Carrier Haneda Route and 263% More Than SEA (Exhibit 211)
• Of All U. S. Tokyo Gateways Only HNL Has A Higher HND Load Factor Than NRT (Exhibit 212)
• NRT Is Preferred To The Mainland, HND Is Preferred To Hawaii (Exhibit 213)

### HAWAIIAN HAS OUTPERFORMED ALL OTHER U.S. FLAG HANEDA CARRIERS Exhibit HA

- 2015A

- 201 Docket OST

- 2010

- 0018 Page 1 of 1

616,834

391,167

229,709

87,864 74,055
0 100,000 200,000 300,000 400,000 500,000 600,000 700,000



### HNL LAX JFK DTW SEA Cumulative Onboard HND Passengers - November 2010 – June 2014

Note: Since UA began nonstop service in November 2014, data is not yet available. Source : U.S. DOT, T - 100 data
. 

### Carrier: HA DL AA DL DL Discontinued Discontinued

### WITH ONE DESIGNATION, HAWAIIAN HAS CARRIED MORE HANEDA PASSENGERS THAN ANY OTHER U.S. FLAG CARRIER INCLUDING DELTA WHICH HAS TWO

229,709 616,834

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



### HA DL AA UA Cumulative Onboard HND Passengers - November 2010 – June 2014

* = Failed Route Note: Since UA began nonstop service in November 2014, data is not yet available. Source : U.S. DOT, T - 100 data
. 

### HNL LAX DTW* SEA

JFK* 553,086



### Number of Designations 1 2 1 1 Exhibit HA

- 2015A

- 202 Docket OST

- 2010

- 0018 Page 1 of 1



### Data Not Available

### HAWAIIAN HAS THE HIGHEST HANEDA LOAD FACTOR OF ALL U.S. FLAG HANEDA CARRIERS Exhibit HA

- 2015A

- 203 Docket OST

- 2010

- 0018 Page 1 of 1

82.7% 78.7% 76.3%

56.6% 71.2%

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



### HNL LAX JFK SEA Mainland Average Load Factor – 12 Months Ended June 2014

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

### Carrier: HA DL AA DL

### HNL - HND HAD THE GREATEST POSITIVE IMPACT ON TOKYO TRAFFIC Exhibit HA

- 2015A

- 204 Docket OST

- 2010

- 0018 Page 1 of 1

370,927

33,546
-8,231 10,602 6,624
-28,247 -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 2014

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.

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

Source: Innovata schedule data. Exhibit HA

- 2015A

- 205 Docket OST

- 2010

- 0018 Page 1 of 1



### Period with Service

HA

NH (HNL)

JL (HNL) Nov ’10 May ‘11 Nov ‘11 May ‘ 12 Nov ‘12 May ’13 Nov ’13 May ’14 Nov ‘14 May ‘15

### ONLY HAWAIIAN STOOD UP TO STRONG JAPANESE COMPETITION

2,636 2,668 2,614 2,643 2,640 2,238

1,300

628 512

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

HAHNL JLSFO JLHNL NHLAX NHHNL DLLAX AAJFK DLSEA DLDTW 

### U.S. - HND Flights – Cumulative November 2010 - June 2014

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

### U.S. Flag Japan Flag Exhibit HA

- 2015A

- 206 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 United - SFO November 2010 February 2011 February 2011 February 2011 June 2013 November 2014

Source: Innovata schedule data. 

### Start Month Exhibit HA

- 2015A

- 207 Docket OST

- 2010

- 0018 Page 1 of 1

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

- 2015A

- 208 Docket OST

- 2010

- 0018 Page 1 of 1



### Period of Service

HA
DL (LAX)
DL (DTW)
DL (SEA)
AA (JFK)
UA (SFO) Nov ’10 May ‘11 Nov ‘11 May ‘ 12 Nov ‘12 May ’13 Nov ’13 May ’14 Nov ‘14 May ‘15

Source : Innovata schedule.Exhibit HA

- 2015A

- 209 Docket OST

- 2010

- 0018 Page 1 of 1



### Hawaiian

Note: Does not include the impact of Delta’s recent discontinuation of service for the Winter. Source : U. S. DOT T - 100 data , November 2010 - June 2014. Available Frequencies Used 59% Available Frequencies

Not Used 41% 

### U.S. Flag Mainland Carriers

Available Frequencies Used 100% 

### HAWAIIAN OPERATED ALL OF ITS AWARDED FREQUENCIES WHILE U.S. FLAG MAINLAND CARRIERS SQUANDERED 41% OF THEIR AWARDED U.S.

– HANEDA FREQUENCIES

One - Way Frequencies Wasted Through June 2014: 0 3,230

### HAWAIIAN OPERATES THE LARGEST AIRCRAFT TO HND OF ALL U.S. FLAG CARRIERS

294

210 210 269

0 50 100 150 200 250 300 350



### HNL SEA LAX SFO Average Current Aircraft Size

Source: Innovata schedules through June 2015. 

### Carrier: HA DL DL UA Aircraft Type: A330 B767 B767 B777 Exhibit HA

- 2015A

- 210 Docket OST

- 2010

- 0018 Page 1 of 1

### IN THE LATEST YEAR AVAILABLE, HAWAIIAN’S HNL - HND SERVICE CARRIED 58% MORE ONBOARD PASSENGERS THAN THE SECOND HIGHEST U.S. FLAG CARRIER HANEDA ROUTE AND 263% MORE THAN SEA

177,261

112,471

67,274 53,468

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



### HNL LAX SEA JFK Onboard HND Passengers 12 Months Ended June 2014



### +58%

Note: Since UA began nonstop service in November 2014, data is not yet available. Source : U.S. DOT, T - 100 data. 

### Carrier: HA DL DL AA Discontinued 

### +263% Exhibit HA

- 2015A

- 211 Docket OST

- 2010

- 0018 Page 1 of 1

### OF ALL U.S. TOKYO GATEWAYS, ONLY HNL HAS A HIGHER HND LOAD FACTOR THAN NRT

85% 82%

75%

57% 76% 81% 85%
79% 79% 77%

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

HNL LAX SFO SEA JFK 

### Tokyo Load Factor – YE June 2014

Note: Includes all carriers. Source : U.S. DOT, T - 100 data. Exhibit HA

- 2015A

- 212 Docket OST

- 2010

- 0018 Page 1 of 1



### NRT HND 0%

### NRT IS PREFERRED TO THE MAINLAND, HND IS PREFERRED TO HAWAII

85%

75% 81% 81%

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

HNL Mainland Gateways (LAX,SEA,SFO,JFK) 

### Tokyo Load Factor – YE June 2014

Note: Includes all carriers. Source : U.S. DOT, T - 100 data. Exhibit HA

- 2015A

- 213 Docket OST

- 2010

- 0018 Page 1 of 1



### NRT HND - 6 pts +4 pts

### 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

- 2015A

- 300 Docket OST

- 2010

- 0018 Page 1 of 1



### • Hawaii Is The Largest U.S. - Japan Passenger Market (Exhibit 301)
• The Hawaii - Tokyo O&D Market Is 94% Larger Than California And Over 14 Times Larger Than Washington (Exhibit 302)
• The Hawaii - Tokyo O&D Market Is Nearly Twice The Size Of California With Fewer Haneda Designations (Exhibit 303)
• The Hawaii - Tokyo O&D Market Is Much Larger Than The Second Largest U.S. State (Exhibit 304)
• The Hawaii - Tokyo Market Is Growing Faster Than The Mainland - Tokyo Market (Exhibit 305)
• Hawaii Is The Largest U.S. - Haneda Gateway (Exhibit 306)
• Hawaii With Three Designations Has More Haneda Gateway Passengers Than The Five Mainland Gateways Combined (Exhibit 307)
• The Hawaii - Haneda O&D Market Is 60% Larger Than All Other States Combined (Exhibit 308)
• The Hawaii - Haneda O&D Market Is Over Twice The Size of California With One Fewer Haneda Designation (Exhibit 309)
• Honolulu Generated 94% More Haneda O&D Passengers With Three Gateways Than The Other Five U.S. - Haneda Gateways Combined (Exhibit 310)

### HAWAII IS THE LARGEST U.S. - JAPAN PASSENGER MARKET

3,100,109

2,437,103

779,426 653,978 503,367 458,011 425,272

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 3,200,000

HI CA NY Il TX WA MI Exhibit HA

- 2015A

- 301 Docket OST

- 2010

- 0018 Page 1 of 1



### Passengers Gateway Passengers

Source: U.S. DOT, T - 100 data, YE June 2014. 

### State

### THE HAWAII - TOKYO O&D MARKET IS 94% LARGER THAN CALIFORNIA AND OVER 14 TIMES LARGER THAN WASHINGTON

773,048

98,835 1,496,911

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

### YE September 2014 Tokyo* MIDT Passengers



### Hawaii California +94% Exhibit HA

- 2015A

- 302 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. 

### Washington +1,415%

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

773,048

98,835 1,496,911

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

Hawaii California Washington 

### YE September 2014 Tokyo* MIDT Passengers

HND Designations: 

### 3 4 1 Ave. Passengers per Designation: 498,970 193,262 98,835 Exhibit HA

- 2015A

- 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 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 Exhibit HA

- 2015A

- 304 Docket OST

- 2010

- 0018 Page 1 of 1

773,048

331,809 104,247 101,320 98,835 1,496,911

97,023 96,231 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 Nevada Illinois Washington Texas Florida 

### YE September 2014 Tokyo* MIDT Passengers

Hawaii Has Almost Twice the Tokyo Passengers as California with One Fewer HND Designation

Current HND Designations : 3 4 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

17.7%

10.5%

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

Hawaii - Tokyo* Mainland - Tokyo* 

### % Onboard Passenger Change CY 2009 - YE June 2014

* Includes HND and NRT. Note: Hawaii includes service from all Hawaiian Islands. Source : U.S. DOT, T - 100 data. Exhibit HA

- 2015A

- 305 Docket OST

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- 0018 Page 1 of 1

### HAWAII IS THE LARGEST U.S. - HANEDA GATEWAY

508,660

249,732

105,892 67,274 53,468
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 SEA JFK 

### HND Onboard Passengers – 12 Months Ended June 2014

Source: U.S. DOT, T - 100 data. Exhibit HA

- 2015A

- 306 Docket OST

- 2010

- 0018 Page 1 of 1



### Designations: 3 2 2 1 1

### HAWAII WITH THREE DESIGNATIONS HAS MORE HANEDA GATEWAY PASSENGERS THAN THE FIVE MAINLAND GATEWAYS COMBINED

508,660

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

HNL ALL Mainland Gateways 

### JFK SEA

LAX 476,366



### SFO HND Onboard Passengers – 12 Months Ended June 2014

Note: Mainland includes data from 5 segments (JFK - AA, SEA - DL, SFO - JL, LAX - NH, LAX - DL). Source : U.S. DOT, T - 100 data. Exhibit HA

- 2015A

- 307 Docket OST

- 2010

- 0018 Page 1 of 1



### Designations: 3 5

### THE HAWAII - HANEDA O&D MARKET IS 60% LARGER THAN ALL OTHER_STATES COMBINED

172,260 25,880 22,440 17,910 33,966 435,153

0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000 450,000 500,000

Hawaii 

### YE September 2014 HND MIDT Passengers Exhibit HA

- 2015A

- 308 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 272,456172,260 435,153

0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000 450,000 500,000

Hawaii California 

### YE September 2014 HND MIDT Passengers

Current HND Designations: 

### 3 4 THE HAWAII - HANEDA O&D MARKET IS OVER TWICE THE SIZE OF CALIFORNIA WITH ONE FEWER HANEDA DESIGNATION Exhibit HA

- 2015A

- 309 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 94% MORE HANEDA O&D PASSENGERS WITH THREE GATEWAYS THAN THE OTHER FIVE U.S. - HANEDA GATEWAYS COMBINED

400,230

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

HNL ALL Other Gateways 

### JFK

LAX 206,048



### SFO MIDT Local Passengers – 12 Months Ended September 2014 Exhibit HA

- 2015A

- 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. 

### SEA +94%

### 400 SERIES:
HAWAII NEEDS MORE HANEDA CAPACITY BUT SEA AND LAX DO NOT

### 400 Series Exhibits HAWAII NEEDS MORE HANEDA CAPACITY

– SEA AND LAX DO NOT Exhibit HA

- 2015A

- 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)
• An Award To American Would Further Imbalance An Already Imbalanced Situation (Exhibit 402)
• An Award To Hawaiian Would Be A Step Towards Rectifying The California/Hawaii Imbalance (Exhibit 403)
• HNL - HND Service Generated More Passengers than all Other HND Gateways (Exhibit 404)
• The HNL - HND Service Has Generated 370,927 New Tokyo O&D Passengers (Exhibit 405)
• The LAX - Tokyo O&D Market Has Declined Since The Original HND Proceeding (Exhibit 406)
• The SEA - Tokyo O&D Market Has Increased Slightly Since The Original HND Proceeding (Exhibit 407)
• HNL - HND Service Has Generated More New Tokyo O&D Passengers Than All The Other U.S. - HND Gateways Combined (Exhibit 408)
• Hawaii Had The Highest Tokyo Point Of Origin Percentage Of All Haneda Gateways (Exhibit 409)
• The Hawaii - Haneda Market Utilized Its Capacity More Efficiently Than Mainland Haneda Markets (Exhibit 410)
• Three Of The Highest Haneda Carrier Load Factor Segments Were From Hawaii (Exhibit 411)
• Each Hawaii Carrier Segment Carried More Onboard Passengers Than Any Mainland Route (Exhibit 412)172,260

22,440 435,153

0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000 450,000 500,000

Hawaii California Washington 

### YE September 2014 Haneda MIDT Passengers

HND Designations : 

### 3 4 1 Ave. Passengers per Designation: 145,051 43,065 22,440 Exhibit HA

- 2015A

- 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.Exhibit HA

- 2015A

- 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. Source : MIDT, via Travelport. 34,452 145,051

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

Hawaii California 

### YE September 2014 Haneda MIDT Passengers per Designation

HND MIDT 435,153 172,260 HND Designations with AA Award: 3 5 Ave. Passengers per Designation: 145,051 34,452 

### AN AWARD TO AMERICAN WOULD FURTHER IMBALANCE AN ALREADY IMBALANCED SITUATIONExhibit HA

- 2015A

- 403 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. Source : MIDT, via Travelport. 43,065 108,788

0 20,000 40,000 60,000 80,000 100,000 120,000

Hawaii California 

### YE September 2014 Haneda MIDT Passengers per Designation

HND MIDT 435,153 172,260 HND Designations With HA KOA Award: 4 4 Ave. Passengers per Designation: 108,788 43,065 

### AN AWARD TO HAWAIIAN WOULD BE A STEP TOWARDS RECTIFYING THE CALIFORNIA/HAWAII IMBALANCE

### HNL - HND SERVICE GENERATED MORE PASSENGERS THAN ALL OTHER HND GATEWAYS

370,927

33,546
-8,231 10,602 6,624
-28,247 -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 2014 Exhibit HA

- 2015A

- 404 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.Exhibit HA

- 2015A

- 405 Docket OST

- 2010

- 0018 Page 1 of 1

* Tokyo includes NRT and HND. Note : MIDT sample has not been expanded to account for direct bookings and does not reflect total market size. Source : MIDT, via Travelport. 1,410,886

1,039,959

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

2009 YE September 2014 

### HNL - Tokyo* MIDT Passengers 

### THE HNL - HND SERVICE HAS GENERATED

370,927 NEW TOKYO O&D PASSENGERS

+370,927Exhibit HA

- 2015A

- 406 Docket OST

- 2010

- 0018 Page 1 of 1

* Tokyo includes NRT and HND. Note : MIDT sample has not been expanded to account for direct bookings and does not reflect total market size. Source : MIDT, via Travelport. 443,032 451,263

0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000 450,000 500,000

2009 YE September 2014 

### LAX - Tokyo* MIDT Passengers 

### THE LAX - TOKYO O&D MARKET HAS DECLINED SINCE THE ORIGINAL HND PROCEEDING

- 8,231Exhibit HA

- 2015A

- 407 Docket OST

- 2010

- 0018 Page 1 of 1

* Tokyo includes NRT and HND. Note : MIDT sample has not been expanded to account for direct bookings and does not reflect total market size. Source : MIDT, via Travelport. 96,034 85,432

0 20,000 40,000 60,000 80,000 100,000 120,000

2009 YE September 2014 

### SEA - Tokyo* MIDT Passengers 

### THE SEA - TOKYO O&D MARKET HAS INCREASED SLIGHTLY SINCE THE ORIGINAL HND PROCEEDING

+10,602370,927

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

HNL ALL Other Gateways 14,294 Exhibit HA

- 2015A

- 408 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 2014

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

95%

70% 66% 63% 57% 53%

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

HNL JFK LAX SFO SEA DTW 

### % Point of Origin Tokyo* Passengers – YE September 2014

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

- 2015A

- 409 Docket OST

- 2010

- 0018 Page 1 of 1

### THE HAWAII

– HANEDA MARKET UTILIZED ITS CAPACITY MORE EFFICIENTLY THAN MAINLAND

– HANEDA MARKETS

85% 82%

57% 75%

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

HNL LAX SEA Mainland 

### HND Load Factor – 12 Months Ended June 2014

Source: U.S. DOT, T - 100 data. Exhibit HA

- 2015A

- 410 Docket OST

- 2010

- 0018 Page 1 of 1

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

87% 85% 84% 83% 79% 76%

57% 75%

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

HNLNH HNL-JL LAXNH HNLHA LAX-DL JFKAA SFO-JL SEADL 

### Load Factor – 12 Months Ended June 2014

Source: U.S. DOT, T - 100 data. Exhibit HA

- 2015A

- 411 Docket OST

- 2010

- 0018 Page 1 of 1

0% 

### Seats per Day Each Way : 219 309 223 294 196 96 195 163

### EACH HAWAII CARRIER SEGMENT CARRIED MORE ONBOARD PASSENGERS THAN ANY MAINLAND ROUTE

191,721 177,261
139,678 137,261 112,471 105,892

53,468 67,274

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

HNLJL HNLHA HNLNH LAXNH LAXDL SFOJL SEADL JFKAA 

### Load Factor – 12 Months Ended June 2014

Source: U.S. DOT, T - 100 data. Exhibit HA

- 2015A

- 412 Docket OST

- 2010

- 0018 Page 1 of 1

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

### HANEDA FREQUENCY

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

### HANEDA FREQUENCY Exhibit HA

- 2015A

- 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 2 nd 

### Most Visited Island In Hawaii For Japanese (Exhibit 506)
• 13% Of Japanese Visitors To Hawaii Visited Kona and The Big Island (Exhibit 507)
• Kona Will Generate Over 160,000 Onboard Passengers (Exhibit 508)
• Kona Can Be Expected To Produce Similar Onboard Passenger Numbers To HA’s Successful HNL - HND Service (Exhibit 509)
• Kona Will Outperform Current/Previous Single - Slot Mainland Gateways To Haneda (Exhibit 510)
• Kona Will Outperform All Current/Previous Mainland Gateways To Haneda (Exhibit 511 )

### LAX LAX

KOA KOA TYO TYO SEA SEA 

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

- 2015A

- 501 Docket OST

- 2010

- 0018 Page 1 of 1

56

14 0 0 10 20 30 40 50 60

LAX SEA** KOA 

### Current Tokyo Roundtrips per Week

** Note: excludes DL - HND from SEA because it was discontinued during the period analyzed. Source : Innovata schedule for the week of January 5, 2015.

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

- 2015A

- 502 Docket OST

- 2010

- 0018 Page 1 of 1

102,490

58,767 55,689

21,994 19,862

0 20,000 40,000 60,000 80,000 100,000 120,000

LAS KOA MCO CMH MIA 

### YE September 2014 Tokyo MIDT

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

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

- 2015A

- 503 Docket OST

- 2010

- 0018 Page 1 of 1

94,809

56,385 50,016

14,918 14,363

0 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000 90,000 100,000

LAS KOA MCO OGG MIA 

### YE September 2014 Tokyo MIDT Point of Sale Japan

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

### Japan Point of Sale Passengers are vital because they bring additional spending into the U.S. which grows the U.S. Economy and supports new U.S. jobs!

### DESPITE NOT HAVING NONSTOP SERVICE TO TOKYO, KONA HAS MORE POINT OF SALE JAPAN PASSENGERS THAN THIRTEEN MARKETS WITH TOKYO NONSTOP SERVICE Exhibit HA

- 2015A

- 504 Docket OST

- 2010

- 0018 Page 1 of 155,09444,23538,40836,99213,1319,00456,38525,97118,15923,72024,97821,20121,17926,319

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

KOA SEA BOS IAD SAN EWR SJC DTW ATL PDX IAH DFW DEN MSP 

### YE September 2014 Tokyo MIDT Point of Sale Japan

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

### KONA, LIKE THE VERY SUCCESSFUL HONOLULU SERVICE, HAS A VERY HIGH PERCENTAGE OF POINT OF SALE JAPAN PASSENGERS Exhibit HA

- 2015A

- 505 Docket OST

- 2010

- 0018 Page 1 of 1



### 95% 96%

66% 63% 57% 70% 

## 53%

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

HNL KOA LAX SFO SEA JFK DTW

% Point of Sale Japan of Tokyo MIDT Passengers – YE September 2014

Failed HND Routes Current HND Routes

Source: MIDT via Travelport.

### THE BIG ISLAND IS THE 2 nd 

### MOST VISITED ISLAND IN HAWAII FOR JAPANESE

199,117

80,805
29,430 1,458,205

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, 2013 Annual Visitor Research Report. 199 , 117 visitors is equivalent to 398 , 235 O&D passengers or 546 passengers per day each way . /1 Exhibit HA

- 2015A

- 506 Docket OST

- 2010

- 0018 Page 1 of 1

### Big Island 13.1%

Other Hawaii 86.9% 

### 13% OF JAPANESE VISITORS TO HAWAII VISITED KONA AND THE BIG ISLAND

Distribution of Japanese Visitors to Hawaii



### Total 2013 Japanese Visitors: 1,518,517 Total 2013 Hawaii - Japan Onboard Passengers : 3,046,398

Source: State of Hawaii Department of Business, Economic Development, and Tourism, 2013 Annual Visitor Research Report. Exhibit HA

- 2015A

- 507 Docket OST

- 2010

- 0018 Page 1 of 1

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

YE June 2014 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 operat ed nonstop service
. 2/ 160,602 is equivalent to 40% share of Japan - Big Island Visitors
. Source: U.S. DOT, T - 100 data and MIDT. 

### 2,007,523

8% 160,602 Exhibit HA

- 2015A

- 508 Docket OST

- 2010

- 0018 Page 1 of 1

/2Source : U.S. DOT, T - 100 data, YE November 2011and Exhibit HA - 2015A - 508. 160,602 156,733

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

KOA HNL 

### Tokyo* Haneda to Hawaii 1 st 

### Year Onboard Passengers

+2% Exhibit HA

- 2015A

- 509 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 A - 508) HA Actual for 1 st Year of Service160,602

105,892 122,078

67,274 52,018

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 SEA - Actual DTW - Actual 

### HND Onboard Passengers – 12 Months Ended June 2014 and Proposed for KOA

Note: Uses YE June 2014 for SFO and SEA and uses last year of service for JFK and DTW. Source : U.S. DOT, T - 100 data and Exhibit HA - 2015A - 508. Exhibit HA

- 2015A

- 510 Docket OST

- 2010

- 0018 Page 1 of 1



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

(A - 508)160,602 137,261 112,471 105,892 122,078

67,274 52,018

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-SEA Actual DL-DTW Actual 

### HND Onboard Passengers – 12 Months Ended June 2014 and Proposed for KOA Exhibit HA

- 2015A

- 511 Docket OST

- 2010

- 0018 Page 1 of 1



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

(A - 508)

Note: Uses last year of service for JFK and DTW. Source : U.S. DOT, T - 100 data and Exhibit HA - 2015A - 508

### 600 SERIES: ECONOMIC IMPACT

### 600 Series Exhibits ECONOMIC IMPACT Exhibit HA

- 2015A

- 600 Docket OST

- 2010

- 0018 Page 1 of 2



### • Japanese Visitors To Hawaii Spend 56% 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)
• Hawaii Attracted 47 Percent More New Japanese Visitors Than The U.S. Mainland (Exhibit 604)
• 59% Of New Japanese Visitors To The U.S. Chose Hawaii Over The Mainland (Exhibit 605)
• Japanese Visitors To Hawaii Are Still Growing Faster Than Visitors To The Mainland U.S. (Exhibit 606)
• Hawaii Has Over Three Times The Number Of Japanese Visitors As California (Exhibit 607)
• Hawaiian’s Honolulu Flight Brought In Over 131% More U.S. Visitors Than The Second Highest U.S. Carrier HND Gateway (Exhibit 608)
• Hawaiian’s Honolulu Flight Accounted For Over 2,300 U.S. Jobs, Over Double The Second Highest HND Gateway (Exhibit 609)
• Hawaiian’s Honolulu Flight Brought In $455.4 Million In New U.S. Exports or Over Two Times The Second Highest HND Gateway (Exhibit 610)
• Hawaiian’s Honolulu Flight Accounted For $827 Million In U.S. GDP

– Nearly Double The Second Highest HND Gateway (Exhibit 611)
• Hawaiian’s Honolulu Flight Accounted For $250 Million In U.S. Household Earnings

– More Than Double The Second Highest HND Gateway (Exhibit 612)
• Hawaiian’s Kona Flight Will Bring Over 350% More New Japanese Visitors Than A Third LAX Gateway (Exhibit 613)
• Hawaiian’s Kona Flight Will Create Over 1,100 U.S. Jobs, Nearly Four Times American’s LAX Proposal (Exhibit 614)
• Hawaiian’s Kona Flight Will Bring In $64.8 Million In New U.S. Exports Or Nearly Four Times The American Proposal (Exhibit 615)
• Hawaiian’s Kona Flight Will Increase U.S. GDP By $117 Million, Or Over Three Times The American Proposal (Exhibit 616)

### 600 Series Exhibits ECONOMIC IMPACT Exhibit HA

- 2015A

- 600 Docket OST

- 2010

- 0018 Page 2 of 2



### • Hawaiian’s Kona Flight Will Increase U.S. Household Earnings By $35 Million, Nearly Four Times The American Proposal (Exhibit 617)
• A Reading Of AA’s Form Support Letter Shows That Hawaiian Should Be Selected For Haneda (Exhibit 618)
• Explanation Of Economic Impact Method (Exhibit 619)
• Calculation Of Kona Passenger And Visitor Stimulation and Economic Impacts (Exhibit 620)
• Calculation Of Stimulation And Japanese Visitors For Proposed AA HND - LAX (Exhibit 621)
• Calculation Of Loss Passengers And Of Japanese Visitors If No DL SEA - HND Nonstop (Exhibit 622)
• Calculation Of Cumulative Visitors On U.S. Flag Carrier - HND Flights To Date (Exhibit 623)

### JAPANESE VISITORS TO HAWAII SPEND 56% MORE THAN THE U.S. AVERAGE

$1,066 $1,660

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

Hawaii U.S. Average

Note: Includes spending by Japanese Visitors at destination with all values updated to 2014 using GDP price deflator. Sources : U.S. Department of Commerce Office of Travel and Tourism Industries, 2013Market Profile: Japan; 2013 Annual Visitor Research Report, State of Hawaii, Department of Business, Economic Development & Tourism 

### Japanese Spending in U.S. per Visitor ( 2014 Estimate) Exhibit HA

- 2015A

- 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% 42%

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

2001 2002 2003 2004 2005 2006 2007 2009 2011 2012 2013 

### Share of Japanese Travelers to the U.S. that Visit Hawaii (Multiple Answers Allowed)

Source: U.S. Department of Commerce Office of Travel and Tourism Industries, 2013 Market Profile: Japan Exhibit HA

- 2015A

- 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, 2013 Market Profile: Japan. 1,578

1,223

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

Hawaii U.S. Mainland* 

### 2013 Japanese Visitors to U.S. (000’s) Exhibit HA

- 2015A

- 603 Docket OST

- 2010

- 0018 Page 1 of 1



### +29%

* Estimated based on year - to - year growth for all regions except Mountain (for which volumes were suppressed).

### HAWAII ATTRACTED 47 PERCENT MORE NEW JAPANESE VISITORS THAN THE U.S. MAINLAND

Source: U.S. Department of Commerce Office of Travel and Tourism Industries, 2013 Market Profile: Japan. 47,000

32,000

0 5,000 10,000 15,000 20,000 25,000 30,000 35,000 40,000 45,000 50,000



### Japanese Visitors to Hawaii Japanese Visitors to Mainland U.S. 

### Increased Japanese Visitors (2013 Total – 2012 Total) Exhibit HA

- 2015A

- 604 Docket OST

- 2010

- 0018 Page 1 of 1Hawaii 59% Mainland U.S. 41% 

### 59% OF NEW JAPANESE VISITORS TO THE U.S. CHOSE HAWAII OVER THE MAINLAND Year Over Year Change In Visitors from Japan Exhibit HA

- 2015A

- 605 Docket OST

- 2010

- 0018 Page 1 of 1

Source: U.S. Department of Commerce Office of Travel and Tourism Industries, 2013 Market Profile: Japan. 

### 79,000 New Japanese Visitors

### JAPANESE VISITORS TO HAWAII ARE STILL GROWING FASTER THAN VISITORS TO THE MAINLAND U.S.

Source: U.S. Department of Commerce Office of Travel and Tourism Industries, 2013 Market Profile: Japan. 3%

1%

0.0% 0.5% 1.0% 1.5% 2.0% 2.5% 3.0% 3.5%



### Hawaii U.S. 

### % Change in Japanese Visitors (2012 - 2013) Exhibit HA

- 2015A

- 606 Docket OST

- 2010

- 0018 Page 1 of 1

### HAWAII HAS OVER THREE TIMES THE NUMBER OF JAPANESE VISITORS AS CALIFORNIA

1,578

477

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

Hawaii California 

### 2013 Visitors to U.S. Destinations (000’s )

Hawaii Relative Size: 3.31x

Note: Includes multiple destinations. Source: U.S. Department of Commerce Office of Travel and Tourism Industries, 2013 Market Profile: Japan. Exhibit HA

- 2015A

- 607 Docket OST

- 2010

- 0018 Page 1 of 1



### Hawaii Has Over Three Times the Japanese Visitors as California with one fewer HND designation

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

### HAWAIIAN’S HONOLULU FLIGHT BROUGHT IN OVER 131% MORE U.S. VISITORS THAN THE SECOND HIGHEST U.S. CARRIER HND GATEWAY

291,935

126,580 78,059 26,350 22,428 0 50,000 100,000 150,000 200,000 250,000 300,000 350,000

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

Source: Exhibit HA - 2015A - 623. 

### Cumulative Japanese Visitors from HND Services (November 2010 - June 2014) Exhibit HA

- 2015A

- 608 Docket OST

- 2010

- 0018 Page 1 of 1

### HAWAIIAN’S HONOLULU FLIGHT ACCOUNTED FOR OVER 2,300 U.S. JOBS, OVER DOUBLE THE SECOND HIGHEST HND GATEWAY Total Employment Impact of Japanese Visitors to the U.S. ( Annual*) Exhibit HA

- 2015A

- 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; Exhibit HA - 2015A - 619 and Exhibit HA - 2015A - 623. 

### 128 163 400 1,091 2,349

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



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

* Estimated based on total job - years over the service’s operating period divided by the years of operation.

### HAWAIIAN’S HONOLULU FLIGHT BROUGHT IN $455.3 MILLION IN NEW U.S. EXPORTS OR OVER TWO TIMES THE SECOND HIGHEST HND GATEWAY

$455.3

$203.5

$83.2 $28.1 $23.9 $0.0 $50.0 $100.0 $150.0 $200.0 $250.0 $300.0 $350.0 $400.0 $450.0 $500.0

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

### 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

- 2015A

- 610 Docket OST

- 2010

- 0018 Page 1 of 1

Source: U.S. Bureau of Economic Analysis RIMS II Multipliers; Exhibits HA - 2015A - 619 and Exhibits HA - 2015A - 623

### HAWAIIAN’S HONOLULU FLIGHT ACCOUNTED FOR $827 MILLION IN U.S. GDP - NEARLY DOUBLE THE SECOND HIGHEST HND GATEWAY

$46.1 $53.9 $161.1 $414.9 $826.5

$0.0 $100.0 $200.0 $300.0 $400.0 $500.0 $600.0 $700.0 $800.0 $900.0

HA-HNL DL-LAX AA-JFK DL-DTW DL-SEA Direct Spending Induced Impacts 

### Cumulative GDP Impact of Japanese Visitors to the U.S. (Millions) Exhibit HA

- 2015A

- 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 - 2015A - 619 and Exhibits HA - 2015A - 623

### HAWAIIAN’S HONOLULU FLIGHT ACCOUNTED FOR $250 MILLION IN U.S. HOUSEHOLD EARNINGS - MORE THAN DOUBLE THE SECOND HIGHEST HND GATEWAY

$250.4

$116.3

$47.7 $16.1 $13.9 $0.0 $50.0 $100.0 $150.0 $200.0 $250.0 $300.0

HA-HNL DL-LAX AA-JFK DL-DTW DL-SEA Direct Spending Induced Impacts 

### Cumulative Earnings Impact of Japanese Visitors to the U.S. (millions) Exhibit HA

- 2015A

- 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 - 2015A - 619 and Exhibits HA - 2015A - 623.

### PREDICTED INCREMENTAL ECONOMIC IMPACT OF PROPOSED SERVICE

### HAWAIIAN’S KONA FLIGHT WILL BRING OVER 350% MORE NEW JAPANESE VISITORS THAN A THIRD LAX GATEWAY

Incremental Japanese Visitors from Proposed HND Services Exhibit HA

- 2015A

- 613 Docket OST

- 2010

- 0018 Page 1 of 1

Source : Exhibits HA - 2015A - 619 - 622. 

### 39,008

8,187 3,599 0 5,000 10,000 15,000 20,000 25,000 30,000 35,000 40,000 45,000

HA-KOA AA-LAX DL-SEA

### HAWAIIAN’S KONA FLIGHT WILL CREATE OVER 1,100 U.S. JOBS, NEARLY FOUR TIMES AMERICAN’S LAX PROPOSAL Total Employment Impact of Japanese Visitors to the U.S. ( Annual) Exhibit HA

- 2015A

- 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 - 2015A - 619 - 622. 

### 75 259 1,151

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



### HA-KOA AA-LAX DL-SEA Direct Jobs Induced Jobs

### HAWAIIAN’S KONA FLIGHT WILL BRING IN $64.8 MILLION IN NEW U.S. EXPORTS OR NEARLY FOUR TIMES THE AMERICAN 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

- 2015A

- 615 Docket OST

- 2010

- 0018 Page 1 of 1

Source : U.S. Bureau of Economic Analysis RIMS II Multipliers; Exhibits HA - 2015A - 619 - 622. 

### $64.8

$16.3
$3.8 $0.0 $10.0 $20.0 $30.0 $40.0 $50.0 $60.0 $70.0

HA-KOA AA-LAX DL-SEA

### HAWAIIAN’S KONA FLIGHT WILL INCREASE U.S. GDP BY $117 MILLION, OR OVER THREE TIMES THE AMERICAN PROPOSAL

Incremental GDP Impact of Japanese Visitors to the U.S. (Millions) Exhibit HA

- 2015A

- 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 - 2015A - 619 - 622. 

### $7.5 $34.0 $116.7

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

HA-KOA AA-LAX DL-SEA Direct Spending Induced Impacts

### HAWAIIAN’S KONA FLIGHT WILL INCREASE U.S. HOUSEHOLD EARNINGS BY $35 MILLION, NEARLY FOUR TIMES THE AMERICAN PROPOSAL

Incremental Earnings Impact of Japanese Visitors to the U.S. (millions) Exhibit HA

- 2015A

- 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 - 2015A - 619 - 622. 

### $2.3 $9.3 $35.4

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

HA-KOA AA-LAX DL-SEA Direct Spending Induced Impacts

### A READING OF AA’S FORM SUPPORT LETTER SHOWS THAT HAWAIIAN SHOULD BE SELECTED FOR HANEDA Exhibit HA

- 2015A

- 618 Docket OST

- 2010

- 0018 Page 1 of 2

“These nonstop flights to Haneda are scarce assets that should be distributed among U.S. carriers to obtain the maximum consumer and economic benefits .” Emphasis added. .........Congressional Delegation “The nonstop flights to Haneda Airport are scarce national resources that should be distributed amongst U.S. carriers to obtain the maximum consumer and economic benefits .” Emphasis added
.

..... U.S.

– Japan Council “...the nonstop flights to Haneda are scarce national resources that should be distributed amongst U.S. carriers to obtain the maximum consumer and economic benefits .” Emphasis added

..... Henry Y. Ota “The nonstop flights to Haneda are scarce national resources that should be distributed amongst U.S. carriers to obtain the maximum consumer and economic benefits .” Emphasis added
.

..... TTA, Inc “The nonstop flights to Haneda are scarce national resources that should be distributed amongst U.S. carriers to obtain the maximum consumer and economic benefits .” Emphasis added
.

..... C&H International “The nonstop flights to Haneda are scarce national resources that should be distributed amongst U.S. carriers to obtain the maximum consumer and economic benefits .” Emphasis added.

..... Kintetsu International Express “The nonstop flights to Haneda are scarce national resources that should be distributed amongst U.S. carriers to obtain the maximum consumer and economic benefits .” Emphasis added
.

..... NTA America, Inc. 

### • Hawaiian’s Kona Flight will create over 1,100 U.S. Jobs, Nearly Four Times American’s LAX Proposal (Exhibit A - 614)

• Hawaiian’s Kona Flight Will Bring in $64.8 Million in New U.S. Exports or Nearly Four Times the American Proposal (Exhibit A - 615)

• Hawaiian’s Kona Flight Will Increase U.S. GDP By $117 Million or Over Three Times the American Proposal (Exhibit A - 616)

• Hawaiian’s Kona Flight Will Increase U.S. Household Earnings by $35 Million Nearly Four Times the American Proposal (Exhibit A - 617)

### A READING OF AA’S FORM SUPPORT LETTER SHOWS THAT HAWAIIAN SHOULD BE SELECTED FOR HANEDA Exhibit HA

- 2015A

- 618 Docket OST

- 2010

- 0018 Page 2 of 2

“The nonstop flights to Haneda are scarce national resources that should be distributed amongst U.S. carriers to obtain the maximum consumer and economic benefits .” Emphasis added. .....Pacific Commerce Bank “The nonstop flights to Haneda are scarce national resources that should be distributed amongst U.S. carriers to obtain the maximum consumer and economic benefits .” Emphasis added. .....Los Angeles Sports & Entertainment Commission “The nonstop flights to Haneda are scarce national resources that should be distributed amongst U.S. carriers to obtain the maximum consumer and economic benefits .” Emphasis added. .....Able Freight

“ The nonstop flights to Haneda are scarce national resources that should be distributed amongst U.S. carriers to obtain the maximum consumer and economic benefits .” Emphasis added
.

..... Limruger “The nonstop flights to Haneda are scarce national resources that should be distributed amongst U.S. carriers to obtain the maximum consumer and economic benefits .” Emphasis added.

..... Fellowship Travel International “The nonstop flights to Haneda are scarce national resources that should be distributed amongst U.S. carriers to obtain the maximum consumer and economic benefits .” Emphasis added.

..... Union Bank “The nonstop flights to Haneda are scarce national resources that should be distributed amongst U.S. carriers to obtain the maximum consumer and economic benefits .” Emphasis added.

..... Commodity Forwarders Inc.

### 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, 2013 Annual Visitor Research Report;

– LAX: Visit California, Overseas And Mexican Visitors To California ( 2013), October 2014;

– NYC/DTW/SEA/Connecting Passengers: U.S. Department of Commerce Office of Travel and Tourism Industries, 2013 Market Profile: Japan

– All values updated to 2014 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 the Detroit multipliers. Exhibit HA

- 2015A

- 619 Docket OST

- 2010

- 0018 Page 1 of 1Exhibit HA

- 2015A

- 620 Docket OST

- 2010

- 0018 Page 1 of 1



### CALCULATION OF KONA PASSENGER AND VISITOR STIMULATION AND ECONOMIC IMPACTS

KONA 1 YE Jun. 2014 HNL - TYO* Onboard Passengers 2,007,523 2 KOA Share of NRT - KOA When Both HNL and KOA Had Nonstop Service 8% 3 Estimated KOA Passengers With Service 160,602

4 Current Unadjusted MIDT KOA - TYO* 58,767 5 Adjustment Factor to Account for Direct Bookings /1 1 .35 6 Adjusted KOA - TYO * Passengers Before Stimulation 79,335

7 Stimulated passengers 81,266 ( Row 3 - Row 6) 8 Percent Local Passengers 100% 9 Percent Point - of - Sale Japan 96%
10 Total New Japanese Visitors (Roundtrip) 39,008 (Row 7 x Row 8 x Row 9 / 2)

* Includes HND and NRT . YE September 2014. 1 / For purposes of comparability HA has used a 35 % MIDT adjustment factor throughout the Haneda cases.

### CALCULATION OF STIMULATION AND JAPANESE VISITORS FOR PROPOSED AA HND - LAX Exhibit HA

- 2015A

- 621 Docket OST

- 2010

- 0018 Page 1 of 1

(A) Year Ended June 2014 scheduled passenger service only from U.S. DOT, T - 100 data. (B) Current Seats from (A) adjusted to account for American’s proposed annual seats of 180,410 (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) MIDT via Travelport, YE September 2014 (F) Adjustment for direct bookings. Same as used in past HND cases. (G) (E) x (F) (H) (D) x (G) (I) MIDT via Travelport, YE September 2014 (J) (H) x (I) / 2 * Includes HND and NRT . Numbers may not add to totals due to rounding. 

### Current Annual Seats (A) Proposed Annual Seats (B) % Change (C) QSI Stimulation (D) Unadjusted Current Local Passengers (E) Adjustment Factor for Direct Bookings (F) Total Current Local Passengers (G) Stimulated Passengers (H) Point of Sale Japan (I) Estimated New Visitors from Japan (J) 1,641,849 1,822,159 11.0% 4.15% 443,032 1.35 598,093

24,810 66% 8,187 Between TYO* and LAXExhibit HA

- 2015A

- 622 Docket OST

- 2010

- 0018 Page 1 of 1



### CALCULATION OF LOSS PASSENGERS AND OF JAPANESE VISITORS IF NO DL SEA - HND NONSTOP

* Includes HND and NRT . Numbers may not add to totals due to rounding. 

### Current Annual Seats (A) Proposed Annual Seats (B) % Change (C) QSI Loss (D) Unadjusted Current Local Passengers (E) Adjustment Factor for Direct Bookings (F) Total Current Local Passengers (G) Lost Passengers without DL HND (H) Point of Sale Japan (I) Estimated Lost Visitors from Japan (J) 561,993 443,063

21.2% 9.7404% 96,034 1.35 129,646

12,628 57% 3,599 Between TYO* and SEA

(A) Year Ended June 2014 scheduled passenger service only from U.S. DOT, T - 100 data. (B) Current Seats from (A) adjusted to take out year ended June 2014 seats for DL. (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) MIDT via Travelport, YE September 2014 (F) Adjustment for direct bookings. Same as used in past HND cases. (G) (E) x (F) (H) (D) x (G) (I) MIDT via Travelport, YE September 2014 (J) (H) x (I) / 2

### CALCULATION OF CUMULATIVE VISITORS ON U.S. FLAG CARRIER

– HND FLIGHTS TO DATE

1/ Local vs. connecting share of onboard passengers calculated from YE Sept. 2014 MIDT via TravelPort. 2/ Onboard passengers x point of sale japan passengers / 2. Exhibit HA

- 2015A

- 623 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. DOT, T - 100 data and Travleport MIDT data. Cumulative HND Onboard Passengers Through June 2014 /1 Point of Sale Japan Local Connecting Total Local Connecting
HA Honolulu 510,739 106,095 616,834 95% 93% DL Detroit 47,447 40,417 87,864 54% 67% AA New York 162,864 66,845 229,709 70% 63% DL Los Angeles 224,139 167,028 391,167 66% 63% DL Seattle 29,992 44,063 74,055 57% 63%

Cumulative HND Visitors /2 Local Connecting Total

HA Honolulu 242,601 49,334 291,935

DL Detroit 12,811 13,540 26,350 AA New York 57,002 21,056 78,059 DL Los Angeles 73,966 52,614 126,580 DL Seattle 8,548 13,880 22,428

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

### 700 Series Exhibits ALLIANCE CARRIERS DOMINATE THE TOKYO MARKET Exhibit HA

- 2015A

- 700 Docket OST

- 2010

- 0018 Page 1 of 1



### • The Star/ Oneworld / Skyteam Oligopoly Dominates Current U.S. - Tokyo Frequencies (Exhibit 701)
• The Star/ Oneworld / Skyteam Oligopoly Controls 98% Of Current U.S. - Tokyo Frequencies (Exhibit 702)
• The Star/ Oneworld / Skyteam Oligopoly Dominates The U.S. - Tokyo Passenger Market (Exhibit 703)
• The Star/ Oneworld / Skyteam Oligopoly Controls 98% Of All U.S. - Tokyo Gateway - To Gateway Passengers (Exhibit 704)
• American’s ATI Partner, JAL, And United’s ATI Partner, ANA, Control 77% Of All Departures At Haneda (Exhibit 705)
• American’s ATI Partner, JAL, and United’s ATI Partner, ANA, Control 80% Of Haneda Capacity (Exhibit 706)
• The Star/ Oneworld / Skyteam Oligopoly Controls 92% Of Current Hawaii - Tokyo Frequencies (Exhibit 707)
• ATI And Mergers Have Increase U.S. - Tokyo Market Concentration To An Alarming Level (Exhibit 708)

### THE STAR/ONEWORLD/SKYTEAM OLIGOPOLY DOMINATES CURRENT U.S.

– TOKYO FREQUENCIES (Current Schedules)

111 119 175

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 January 5, 2015. Exhibit HA

- 2015A

- 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 42%

SkyTeam 29% 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 January 5, 2015. Exhibit HA

- 2015A

- 702 Docket OST

- 2010

- 0018 Page 1 of 1

### 3,856

2,808 2,257

177 0 500 1,000 1,500 2,000 2,500 3,000 3,500 4,000 4,500

Star SkyTeam oneworld Hawaiian 

### THE STAR/ONEWORLD/SKYTEAM OLIGOPOLY DOMINATES THE U.S.

– TOKYO* PASSENGER MARKET (YE June 2014)

Annual Onboard Passengers (000’s)

* Includes HND and NRT. Source : U. S. DOT T - 100 data, YE June 2014. Subsidiary carriers are included with the parent carrier. Exhibit HA

- 2015A

- 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 June 2014)

Star 42%

SkyTeam 31% 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 June 2014. Subsidiary carriers are included with the parent carrier. Exhibit HA

- 2015A

- 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 January 5, 2015. Exhibit HA

- 2015A

- 705 Docket OST

- 2010

- 0018 Page 1 of 1ANA 49%

JAL 31%

Others

20% 

### AMERICAN’S ATI PARTNER, JAL, AND UNITED’S ATI PARTNER, ANA, CONTROL 80% OF HANEDA CAPACITY (Current Schedules)

Distribution of Current HND Seats

Source: Innovata schedule for the week of January 5, 2015. Exhibit HA

- 2015A

- 706 Docket OST

- 2010

- 0018 Page 1 of 1

### 29 28

21

7

0 5 10 15 20 25 30 35

oneworld SkyTeam 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 January 5, 2015. Exhibit HA

- 2015A

- 707 Docket OST

- 2010

- 0018 Page 1 of 2



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

### oneworld 34%

SkyTeam 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 January 5, 2015. Exhibit HA

- 2015A

- 707 Docket OST

- 2010

- 0018 Page 2 of 2

### 1,516 1,683 2,872

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

2009 2010 YE June 2014 

### ATI AND MERGERS HAVE INCREASED U.S.

– TOKYO MARKET CONCENTRATION TO AN ALARMING LEVEL
U.S. – Tokyo* HHI Based on Onboard Passengers Exhibit HA

- 2015A

- 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.

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

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

- 2015A

- 800 Docket OST

- 2010

- 0018 Page 1 of 1



### • 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 The Alliance Carriers (Exhibit 802)
• Hawaiian’s Denied Boardings Rate Is Far Lower Than The Alliance Carriers (Exhibit 803)
• Hawaiian’s Complaint Rate Is Far Lower Than American’s (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)

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

Note: Effective January 2014, the American Airlines and US Airways data are combined for ranking purposes and appear as Ameri can Airlines. Source : U.S. DOT, Air Travel Consumer Report, page 5, December 2014. 

### YE October 2014 Percentage of On - Time Arrivals



### Rank: 1 4 6 7 Exhibit HA

- 2015A

- 801 Docket OST

- 2010

- 0018 Page 1 of 1



### 92.6 83.1 76.7 76.4

0 10 20 30 40 50 60 70 80 90 100

Hawaiian Delta American United

### HAWAIIAN’S MISHANDLED BAGS RATE IS FAR LOWER THAN THE ALLIANCE CARRIERS

Source: U.S. DOT, Air Travel Consumer Report. YTD includes January
– August 2014. 

### 2.2 2.5 3.7 3.8

0.0 0.5 1.0 1.5 2.0 2.5 3.0 3.5 4.0 4.5

Hawaiian Delta United American 

### YTD 2014 Number of Mishandled Bags per 1,000 Passengers



### Rank: 4 5 7 8 Exhibit HA

- 2015A

- 802 Docket OST

- 2010

- 0018 Page 1 of 1

### HAWAIIAN’S DENIED BOARDINGS RATE IS FAR LOWER THAN THE ALLIANCE CARRIERS

Source: U.S. DOT, Air Travel Consumer Report. YTD includes January
– June 2014. 

### 0.07 0.59 0.69 1.73

0.00 0.20 0.40 0.60 0.80 1.00 1.20 1.40 1.60 1.80 2.00

Hawaiian Delta American United 

### YTD 2014 Number of Denied Boardings per 10,000 Passengers



### Rank: 2 5 6 9 Exhibit HA

- 2015A

- 803 Docket OST

- 2010

- 0018 Page 1 of 1

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

0.77 0.78 2.26 3.00

0.00 0.50 1.00 1.50 2.00 2.50 3.00 3.50

Delta Hawaiian American United 

### YTD 2014 Number of Complaints per 100,000 Enplanements



### Rank: 3 4 10 11 Exhibit HA

- 2015A

- 804 Docket OST

- 2010

- 0018 Page 1 of 1

Source: U.S. DOT, Air Travel Consumer Report. YTD includes January
– August 2014.

### 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 2014. Exhibit HA

- 2015A

- 805 Docket OST

- 2010

- 0018 Page 1 of 1

Ranking 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 YTD 8/2014
1 

### HA HA HA HA HA HA HA HA HA HA HA 2 3 UA DL DL DL 4 5 DL DL 6 UA DL UA 7 UA AA 8 UA AA UA 9 AA UA 10 AA UA DL AA 11 DL AA 12 DL 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

- 2015A

- 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 - August 2014. Ranking 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 YTD 2014
1 

### HA HA HA 2 

### HA HA HA HA 3 4 

### HA DL DL 

### HA 5 DL HA DL 6 7 UA 

### HA UA 8 UA UA UA UA AA AA 9 AA A A 10 UA DL U A 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 2014. 

### Customer Complaints Rank Exhibit HA

- 2015A

- 807 Docket OST

- 2010

- 0018 Page 1 of 1

Ranking 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 YTD 2014
1 2 

### HA HA HA 3 

### HA HA HA DL DL 4 AA 

### HA HA 5 UA UA AA DL 6 UA UA 7 AA AA AA DL 8 

### HA 9 AA UA 10 UA HA 

### HA AA 11 DL UA 12 DL 13 AA 14 DL DL DL AA AA 15 UA AA 16 DL UA UA 17 UA 18 DL 19

### 900 SERIES: ANSWER TO AMERICAN

• AA/ JL Has A Huge Commitment To Narita (Exhibit 901)
• American Has Access To Haneda (Exhibit 902)
• American Has Extensive And Widespread Access To Tokyo (Exhibit 903)
• LAX - Tokyo Already Has Eight Daily Roundtrips From Five Carriers (Exhibit 904)
• American and JAL Already Operate 14 Weekly Roundtrips Between LAX and Tokyo (Exhibit 905)
• American’s First HND Failure At JFK Had The Second Lowest Load Factor Behind Only Delta’s At SEA (Exhibit 906)
• AA’s Proposed HND Startup Dates Are Inconsistent With Its Actual HND Record (Exhibit 907)
• LAX Is Not The Largest U.S. - Tokyo Market (Exhibit 908)
• Even Before Stimulation, KOA Is Underserved Relative to LAX (Exhibit 909)
• American’s Proposed LAX - HND Schedules Would Merely Duplicate Current HND Schedules (Exhibit 910)
• In March 2013 Delta Began Using Its Smallest Transpacific Aircraft For The HND - LAX Market (Exhibit 911)
• Delta Has Only Survived In The HND - LAX Route By Downgauging To Its Smallest Possible Aircraft

– American’s Additional Capacity Would Not Be Sustainable (Exhibit 912)
• Delta’s LAX - HND Results Show The Market Could Not Even Support A Modest Upgauge To A B777 (Exhibit 913)
• LAX - HND Operated With Over 50,000 Empty Seats (Exhibit 914)
• AA’s LAX Domestic Operation Is Not Significantly Different From Delta’s LAX Domestic Operation (Exhibit 915)
• The Proposed Connections On Past HND Awards Have Averaged Less Than 3% Share Of Tokyo Markets (Exhibit 916)
• Delta’s HND - SEA Service Has Carried Less Than 2% Of Passengers In The Connecting Markets It Proposed In Its 2012 Application (exhibit 917)
• Delta’s HND - LAX Service Has Carried Less Than 2.5% Of Passengers In The Connecting Markets It Proposed In Its 2010 Application (Exhibit 918) Exhibit HA

- 2015A

- 900 Docket OST

- 2010

- 0018 Page 1 of 2

### 900 SERIES: ANSWER TO AMERICAN

• American’s HND - JFK Service Carried Less Than 3% Of Passengers In The Connecting Markets It Proposed In Its 2010 Application (Exhibit 919)
• The Two Current LAX - HND Nonstops Carry Less Than 3% Of LAX - Tokyo Passengers Today In American’s Proposed Domestic Connecting Markets (Exhibit 920)
• American Includes Connections Of Over 10 Hours In Its Analysis (Exhibit 921)
• American’s Roundtrip Connections Drop From 32 To 12 When Connecting Times Are Limited To Four Hours (Exhibit 922)
• Of American’s Twelve Reasonable Connections, Eight Already Have Convenient Service To HND (Exhibit 923)
• American Is Only Offering Three Domestic Roundtrip Connecting Markets That Do Not Already Have Convenient HND Roundtrips Today (Exhibit 924)
• Kona Has Over Three Times As Many Tokyo Passengers And Over 30 Times As Many HND Passengers As All Of American’s Unduplicated Roundtrip Points Behind LAX (Exhibit 925)
• Hawaiian Will Provide 19% More Annual Seats Than American (Exhibit 926)
• An American LAX - HND Service Would Experience Disastrous Load Factors (Exhibit 927)
• Almost 85% of American’s Proposed LAX - HND Capacity Could Be Offset By Delta Fulfilling Its 2010 LAX - HND Commitment (Exhibit 928)
• The LAX - HND Market Cannot Support Three Nonstop Carriers (Exhibit 929)
• With Three Carriers The LAX - HND Market Will Join JFK, DTW and SEA As The Next Failed HND Designation (Exhibit 930)
• American Used Its Current NRT - LAX Flight Numbers In Its October 2014 HND - LAX Application (Exhibit 931) Exhibit HA

- 2015A

- 900 Docket OST

- 2010

- 0018 Page 2 of 2

### AA/JL HAS A HUGE COMMITMENT TO NARITA

AA/JL’s 36 Narita Segments - 347 Weekly Departures Exhibit HA

- 2015A

- 901 Docket OST

- 2010

- 0018 Page 1 of 1

Source: Innovata schedule for the week of January 5 - 11, 2015. Bangkok (BKK) Beijing (PEK) Boston (BOS) Chicago O'Hare (ORD) Dalian (DLC) Dallas/Ft. Worth (DFW) Delhi (DEL) Frankfurt (FRA) Fukuoka (FUK) Guam, (GUM) Guangzhou (CAN) Hanoi (HAN ) Helsinki (HEL) Ho Chi Minh City (SGN) Hong Kong (HKG) Honolulu (HNL) Jakarta (CGK) Kaohsiung (KHH) Koror, Palau Isl (ROR) Kuala Lumpur (KUL) Los Angeles (LAX) Manila (MNL) Moscow (DME) Nagoya (NGO) New York Kennedy (JFK) Osaka (ITM) Paris (CDG) Pu Dong (PVG) Pusan (PUS) San Diego (SAN) Sapporo (CTS) Seoul (ICN) Singapore (SIN) Sydney (SYD) Taipei (TPE) Vancouver (YVR ) KHH KHH KHH TPE TPE TPE TPE ITM ITM ITM ITM FUK FUK FUK FUK PUS PUS PUS PUS NGO NGO NGO ICN ICN ICN ICN DLC DLC DLC DLC CDG CDG CDG FRA FRA FRA FRA

HKG HKG HKG JFK JFK JFK JFK

ROR ROR ROR NRT NRT NRT SAN SAN SAN SAN CTS CTS CTS CTS PEK PEK PEK PEK

PVG PVG PVG PVG

CGK CGK CGK SIN SIN SIN SIN KUL KUL KUL KUL

SGN SGN SGN

CAN CAN CAN HAN HAN HAN HAN BKK BKK BKK DEL DEL DEL DEL DME DME DME HEL HEL HEL HEL

BOS BOS BOS DFW

GUM GUM GUM HNL HNL HNL HNL LAX LAX LAX LAX

MNL MNL MNL ORD ORD ORD

SYD SYD SYD SYD YVR YVR YVR YVR

### AMERICAN HAS ACCESS TO HANEDA Exhibit HA

- 2015A

- 902 Docket OST

- 2010

- 0018 Page 1 of 1

Source : Innovata schedule. 

### HND HND SFO SFO SFO SFO

HNL HNL HNL HNL JFK JFK JFK JFK

AA 2010 designation AA/JL ATI code - share

### AMERICAN HAS EXTENSIVE AND WIDESPREAD ACCESS TO TOKYO Exhibit HA

- 2015A

- 903 Docket OST

- 2010

- 0018 Page 1 of 1

Source: Innovata schedule for the week of January 5, 2015. SAN SAN SAN SAN 

### TYO TYO BOS BOS BOS

DFW

GUM GUM GUM HNL HNL HNL HNL JFK JFK JFK JFK
LAX LAX LAX LAX ORD ORD ORD SFO SFO SFO SFO

BOS DFW GUM HNL JFK LAX Total LAX ORD Total ORD SAN SFO Total Weekly Flights JL AA JL JL JL AA JL
AA JL
JL JL 7 14

7 29 14

7 7 14

5 7 12

7 7 111 Carrier Weekly Flights Yes Yes Yes Yes Yes Yes Yes
Yes Yes
Yes Yes AA Code 1,302 3,458 1,610 8,280 3,283 1,729 1,981 3,710 1,235 1,981 3,216 1,302 1,981 28,142 Weekly

Seats

### LAX LAX TYO TYO 

### LAX - TOKYO ALREADY HAS EIGHT DAILY ROUNDTRIPS FROM FIVE CARRIERS Exhibit HA

- 2015A

- 904 Docket OST

- 2010

- 0018 Page 1 of 1

Source: Innovata schedule for the week of January 5, 2015. AA DL JL NH SQ UA 7 14

7 14

7 7 56 Weekly Tokyo Flights 1,729 3,493 1,981 3,402 2,863 1,533 15,001 Weekly Tokyo Seats

### AMERICAN AND JAL ALREADY OPERATE 14 WEEKLY ROUNDTRIPS BETWEEN LAX AND TOKYO

American
JAL

Source: Innovata schedule d ata , Week of January 5, 2015. 

### 7
7
14 LAX - TYO Current Weekly Roundtrip Flights Exhibit HA

- 2015A

- 905 Docket OST

- 2010

- 0018 Page 1 of 1



### When AA was awarded JFK - HND authority in 2010, it reduced all JFK - NRT service

### AMERICAN’S FIRST HND FAILURE AT JFK HAD THE SECOND LOWEST LOAD FACTOR BEHIND ONLY DELTA’S SECOND AT SEA
Historical 12 Months Moving HND Load Factors

Note: Includes all carriers. If 12 months of continuous service, the first period was the first 12 months of continuous serv ice . Only DTW did not have a full 12 months of continuous service. Source : U.S. DOT, T - 100 data. Exhibit HA

- 2015A

- 906 Docket OST

- 2010

- 0018 Page 1 of 1

0% 10% 20% 30% 40% 50% 60% 70% 80% 90%Oct-11Dec-11Feb-12Apr-12Jun-12Aug-12Oct-12Dec-12Feb-13Apr-13Jun-13Aug-13Oct-13Dec-13Feb-14Apr-14Jun-14 

### HNL LAX SFO JFK
SEA DTW

### AA PROPOSED HND STARTUP DATES ARE INCONSISTENT WITH ITS ACTUAL HND RECORD



## • 2014 Proposed Startup Days: 60

• 2010 Actual Startup Days: 118 Exhibit HA

- 2015A

- 907 Docket OST

- 2010

- 0018 Page 1 of 1

### LAX IS NOT THE LARGEST U.S.

– TOKYO MARKET Exhibit HA

- 2015A

- 908 Docket OST

- 2010

- 0018 Page 1 of 1



### YE September 2014 Tokyo* MIDT Passengers

Note : MIDT sample has not been expanded to account for direct bookings and reflects relative but not total market size . Includes all U.S. states. Source : MIDT, via Travelport. 443,032 310,428 218,184 102,490 99,459 96,034 1,410,886

HNL LAX JFK SFO LAS ORD SEA 

### 3.2x • “... the largest US - Tokyo market, Los Angeles

– Haneda .” (AA Application, p. 2) • “...Los Angeles is the largest US - Haneda O&D market.” (AA Application, p. 11) • “...LAX is the largest Haneda O&D market in the U.S. (AA Application, T - 2 p.4) • “...the Largest Haneda O&D market from the U.S. (AA Application, T - 2 p.4) 

### AA Misstatements

TYO HND 103,317 63,417 25,766 24,463 22,165 17,149 400,230

HNL LAX SFO LAS KOA SEA JFK 

### 3.9x

### EVEN BEFORE STIMULATION KOA IS UNDERSERVED RELATIVE TO LAX

66 81

0 10 20 30 40 50 60 70 80 90

KOA LAX 

### YE September 2014 Tokyo* MIDT Passengers per Flight

YE Q3 2014 Passengers Before Stimulation: 58,757 443,032 YE Q3 2014 Flights Scheduled Flights Including Proposed : 730 6,757 Passengers per Flight: 81 66 Exhibit HA

- 2015A

- 909 Docket OST

- 2010

- 0018 Page 1 of 2

* 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
.

### EVEN BEFORE STIMULATION KOA IS UNDERSERVED RELATIVE TO LAX

0.24 0.27

0.23 0.23 0.24 0.24 0.25 0.25 0.26 0.26 0.27 0.27 0.28

KOA LAX 

### YE September 2014 Tokyo* MIDT Passengers per Seat

YE Q3 2014 Passengers Before Stimulation: 58,757 443,032 YE Q3 2014 Seats Scheduled Seats Including Proposed : 214,260 1,845,269 Passengers per Seat: 0.27 0.24 Exhibit HA

- 2015A

- 909 Docket OST

- 2010

- 0018 Page 2 of 2

* 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
.

### AMERICAN’S PROPOSED LAX - HND SCHEDULES WOULD MERELY DUPLICATE CURRENT HND SCHEDULES 

## Eastbound Exhibit HA

- 2015A

- 910 Docket OST

- 2010

- 0018 Page 1 of 2



### 1715

0005 1700

0000 

# LAX

HND Delta Actual 

# American Proposed

Note: All times local. Innovata schedule data and AA Application , Exhibit AA - 102. Winter Schedules used for all. 

### 1700

0005 

# ANA ActualExhibit HA

- 2015A

- 910 Docket OST

- 2010

- 0018 Page 2 of 2



### 1706

2220 1705

2300 

# LAX

HND Delta Actual 

# American Proposed

Note: All times local. Innovata schedule data and AA Application , Exhibit AA - 102. Winter Schedules used for all. 

### 0005

0505 

# ANA Actual 

### AMERICAN’S PROPOSED LAX - HND SCHEDULES WOULD MERELY DUPLICATE CURRENT HND SCHEDULES 

## Westbound0 50 100 150 200 250 300 350 400 450

January March May July September November January March May July September November January March May July September November January March May July September November January March 

### DL Average Seats per Aircraft LAX - HND Exhibit HA

- 2015A

- 911 Docket OST

- 2010

- 0018 Page 1 of 1



### IN MARCH 2013 DELTA BEGAN USING ITS SMALLEST TRANSPACIFIC AIRCRAFT FOR THE HND - LAX MARKET

B747 (403 Seats)

B767 (208 Seats)

Source: Innovata schedule data. 

### 2011 B777 (269 Seats) A330 (241 Seats)

2012 2013 2014 2015

### DELTA HAS ONLY SURVIVED IN THE HND - LAX ROUTE BY DOWNGAUGING TO ITS SMALLEST POSSIBLE AIRCRAFT

– AMERICAN’S ADDITIONAL CAPACITY WOULD NOT BE SUSTAINABLE



### 46% 70% 75% 79% 86% 83% 81%

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

B747 Period B777 Period A330 Period B767 Period DLTokyoU.S. Load Factor CurrentTokyoU.S. Load Factor HAHNLHND Load Factor 

### Delta LAX - HND Load Factor – YE June 2014

Source: U.S. DOT, T - 100 data. Exhibit HA

- 2015A

- 912 Docket OST

- 2010

- 0018 Page 1 of 1

Period : Feb - Mar ‘11



### 403 Seats 241 Seats 208 Seats 269 Seats

Jun Oct ‘11 Oct ’11 - Mar – ’13 Since Mar ‘1383% 84% 81%

63% 72% 81% 84% 88% 89%

67% 73% 82%

58% 52% 48% 64% 63% 60% 58% 52% 45% 58% 60% 59%



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

Jul13 Aug13 Sep13 Oct13 Nov13 Dec13 Jan14 Feb14 Mar14 Apr14 May14 Jun14 

### Current DL LAX-NRT DL With A B777 on LAX-HND DL LAX - HND Load Factor Exhibit HA

- 2015A

- 913 Docket OST

- 2010

- 0018 Page 1 of 1



### DELTA’S LAX - HND RESULTS SHOW THE MARKET COULD NOT EVEN SUPPORT A MODEST UPGAUGE TO A B777

Note: Assumes a 291 seat B777. Source : U.S. DOT, T - 100. 

### YE June 2014 Current = 79% YE June 2014 With B777 = 56%

### LAX - HND OPERATED WITH OVER 50,000 EMPTY SEATS

249,732

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

Onboard Passengers Seats Offered by DL and NH 

### LAX - HND Passengers and Seats – 12 Months Ended June 2014

Source: U.S. DOT, T - 100 data. 305,600 

### 55,868 Empty Seats

LAX - HND Averaged 153 Empty Seats per Day Exhibit HA

- 2015A

- 914 Docket OST

- 2010

- 0018 Page 1 of 1

### CONNECTING PASSENGERS HAVE NEVER BEEN SIGNIFICANT ON HND ROUTESTPA TPA TPA TPA

MCO MCO MCO MCO

HNL HNL HNL HNL

OGG OGG OGG OGG LIH LIH LIH LIH LIH LIH LIH LIH LIH CVG CVG CVG CVG 

### LAX LAX

KOA KOA KOA KOA BOI BOI BOI BOI GEG GEG GEG GEG SEA SEA SEA SEA PDX PDX PDX PDX

OAK OAK OAK OAK SJC SJC SJC SJC SMF SMF SMF SMF SFO SFO SFO SFO

ATL ATL ATL ATL

AUS AUS AUS AUS BNA BNA BNA BNA BOS BOS BOS BOS BZN BZN BZN BZN

CMH CMH CMH CMH

DFW DTW
IND IND IND IND JAC JAC JAC JAC
JFK JFK JFK JFK

LAS LAS LAS LAS MCI MCI MCI MCI

MEM MEM MEM MEM

MIA MIA MIA MIA MSP MSP MSP MSP

MSY MSY MSY MSY PHX PHX PHX PHX RDU RDU RDU RDU
SAN SAN SAN SAN SLC SLC SLC SLC TPA TPA TPA TPA

MCO MCO MCO MCO

HNL HNL HNL HNL

OGG OGG OGG OGG LIH LIH LIH LIH LIH LIH LIH LIH LIH FAT FAT FAT FAT ASE ASE ASE ASE EGE EGE EGE EGE

AUS AUS AUS AUS SAT SAT SAT SAT EUG EUG EUG EUG RDM RDM RDM RDM

SJC SJC SJC SJC SMF SMF SMF SMF SFO SFO SFO SFO MRY MRY MRY MRY

KOA KOA KOA KOA LAS LAS LAS LAS IAD IAD IAD IAD


### LAX LAX ABQ ABQ ABQ ABQ BNA BNA BNA BNA BOS BOS BOS BOS CMH CMH CMH CMH DCA DCA DCA DCA DEN DEN DEN DEN

DFW ELP ELP ELP ELP IAH IAH IAH IAH IND IND IND IND JFK JFK JFK JFK

MIA MIA MIA MIA OKC OKC OKC OKC ORD ORD ORD ORD

PBI PBI PBI PBI PHX PHX PHX PHX RNO RNO RNO RNO

SAF SAF SAF SAF
SAN SAN SAN SAN SLC SLC SLC SLC STL STL STL STL

TUS TUS TUS TUS XNA XNA XNA XNA 

### AA’s LAX DOMESTIC OPERATION IS NOT SIGNIFICANTLY

DIFFERENT FROM DELTA’S LAX DOMESTIC OPERATION Exhibit HA

- 2015A

- 915 Docket OST

- 2010

- 0018 Page 1 of 1

Source: Innovata schedules for the week of January 5, 2015. Total Nonstop Destinations Daily Flight Departures Daily Seat Departures 42 146 17,050

Total Nonstop Destinations Daily Flight Departures Daily Seat Departures 36 125 16,113 

# American

Delta

### THE PROPOSED CONNECTIONS ON PAST HND AWARDS HAVE AVERAGED LESS THAN 3% SHARE OF TOKYO MARKETS

2.4% 1.6% 2.9% 0.0% 10.0% 20.0% 30.0% 40.0% 50.0% 60.0% 70.0% 80.0% 90.0% 100.0%

Via DL LAX-HND Via DL SEA-HND Via AA JFK-HND 

### % Of Tokyo Passengers in Originally Proposed Connecting Markets Using HND Flights

Source: Exhibit HA - 2015A - 17 - 19. Exhibit HA

- 2015A

- 916 Docket OST

- 2010

- 0018 Page 1 of 1Source : Applications and MIDT via Travelport. Summer 2014 (June
– September). ALW PSC

STS SFO

ONT SNA BUR LAX ATL BLI

BOI BOS BZN

ORD

DEN DTW EUG

FAT

FLL GTF HLN FCA

LAS LWS

MFR MSP MSO

OAK

MCO PSP PHX PDX PUW

RDM

RNO SMF SLC

SAN SJC GEG

TUS Exhibit HA

- 2015A

- 917 Docket OST

- 2010

- 0018 Page 1 of 1



### DELTA’S HND - SEA SERVICE HAS CARRIED LESS THAN 2% OF PASSENGERS IN THE CONNECTING MARKETS IT PROPOSED IN ITS 2012 APPLICATION

Los Angeles San Francisco Chicago O'Hare Las Vegas Boston San Diego Orlando Portland San Jose Detroit Atlanta Denver Minneapolis/St. Paul Salt Lake City Phoenix Anchorage Boise Sacramento Ft. Lauderdale Tucson Fairbanks Bozeman Reno Spokane 94 1,040 40 3,714 30 182 114 612 177

94 146 158

49 269 147 423

37 28

5 11 128

22

8 41 155,367 80,586 40,266 32,871 27,304 20,703 17,327 17,095 16,067 15,541 15,306

9,291 7,763 6,815 6,041 2,509 1,865 1,179 1,089 1,080 1,028

800 701 638 0.1% 1.3% 0.1% 11.3%

0.1% 0.9% 0.7% 3.6% 1.1% 0.6% 1.0% 1.7% 0.6% 3.9% 2.4% 16.9%

2.0% 2.4% 0.5% 1.0% 12.5%

2.8% 1.1% 6.4 % Claimed DL Connecting Market ( 2012 Application) Actual via DL SEA - HND Total Tokyo DL Share Eugene Fresno Medford Missoula Orange County Pasco Oakland Bend/Redmond Palm Springs Ontario Kalispell Juneau Great Falls Helena Bellingham Pullman Ketchikan Lewiston Sitka Burbank Santa Rosa Walla Walla Total 11 6 16 15

7 21

5 5 0 3 17 30 17 14

2 3 3 3 13

2 0 3 7,765 573 431 397 339 302 275 185 156 144 140 126 108

55 51 51 30 25 25 20 21 15

7 482,708 1.9% 1.4% 4.0% 4.4% 2.3% 7.6% 2.7% 3.2% 0.0% 2.1% 13.5% 27.8% 30.9% 27.5%

3.9% 10.0% 12.0% 12.0% 65.0%

9.5% 0.0% 42.9%

1.6% Claimed DL Connecting Market ( 2012 Application) Total Tokyo DL Share 

### DL’s Proposed Connecting Points

Actual via DL SEA - HNDSource : Applications and MIDT via Travelport. Summer 2014 (June
– September). Exhibit HA

- 2015A

- 918 Docket OST

- 2010

- 0018 Page 1 of 1

New York Kennedy Las Vegas San Diego Orlando Detroit Atlanta Minneapolis/St. Paul Salt Lake City Indianapolis Washington National Cincinnati Tampa Memphis Ft. Lauderdale Reno Redding Mammoth Lakes Prescott Total 361 3,126

606 688 188 354 100 245

46 16 108

50 43

9 1 0 0 0 5,941 116,925 32,871 20,703 17,327 15,541 15,306

7,763 6,815 5,112 4,478 2,848 2,220 1,635 1,089

701 109 4 2 251,449 0.3% 9.5% 2.9% 4.0% 1.2% 2.3% 1.3% 3.6% 0.9% 0.4% 3.8% 2.3% 2.6% 0.8% 0.1% 0.0% 0.0% 0.0% 2.4% Claimed DL Connecting Market (2010 Application) Actual via DL LAX - HND Total Tokyo DL Share ATL CVG DTW

FLL IND

LAS MMH

MEM MSP

JFK

MCO PRC RDD RNO SLC

SAN

TPA DCA 

### DELTA’S HND - LAX SERVICE HAS CARRIED LESS THAN 2.5% OF

PASSENGERS IN THE CONNECTING MARKETS IT PROPOSED IN ITS 2010 APPLICATION

DL’s Proposed Connecting PointsTPA DCA BWI BOS ORD CLE CMH

DFW

MIA MCO PIT

RDU STL Exhibit HA

- 2015A

- 919 Docket OST

- 2010

- 0018 Page 1 of 1

Chicago O'Hare Boston Orlando Dallas/Ft. Worth Columbus Miami Washington National Raleigh/Durham Pittsburgh Baltimore St. Louis Cleveland Tampa Total 44 969 1,187 10 51 549 340 197

23 69 27 53 58 3,577 34,260 28,498 15,239 11,117

7,596 5,024 4,141 3,636 2,718 2,575 2,577 2,476 2,144 122,001 0.1% 3.4% 7.8% 0.1% 0.7% 10.9%

8.2% 5.4% 0.8% 2.7% 1.0% 2.1% 2.7% 2.9% Claimed AA Connecting Market ( 2010 Application) Actual via AA JFK - HND Total Tokyo AA Share SJU STT

Source : Applications and MIDT via Travelport. Summer 2013 (June
– September). 

### AMERICAN’S HND - JFK SERVICE CARRIED LESS THAN 3% OF PASSENGERS IN THE CONNECTING MARKETS IT PROPOSED IN ITS 2010 APPLICATION
AA’s Proposed Connecting PointsFAT FAT FAT FAT SJC SJC SJC SJC SFO SFO SFO SFO MRY MRY MRY MRY

TPA TPA TPA TPA

GRU GRU GRU GRU SAN SAN SAN SAN RNO RNO RNO RNO SMF SMF SMF SMF YVR YVR YVR YVR

EUG EUG EUG EUG



### LAX LAX ATL ATL ATL ATL

AUS AUS AUS AUS BNA BNA BNA BNA BOS BOS BOS BOS

CLT CLT CLT CLT DEN DEN DEN DEN

DFW ELP ELP ELP ELP IAD IAD IAD IAD

IAH IAH IAH IAH JFK JFK JFK JFK

LAS LAS LAS LAS

MCO MCO MCO MCO

MIA MIA MIA MIA ORD ORD ORD ORD

PBI PBI PBI PBI PHL PHL PHL PHL

PHX PHX PHX PHX

SAT SAT SAT SAT SLC SLC SLC SLC

TUS TUS TUS TUS 

### THE TWO CURRENT LAX - HND NONSTOPS CARRY LESS THAN 3% OF LAX TOKYO PASSENGERS TODAY IN AMERICAN’S PROPOSED DOMESTIC CONNECTING MARKETS Exhibit HA

- 2015A

- 920 Docket OST

- 2010

- 0018 Page 1 of 1

Source : Exhibit AA - 107 and March 2015 schedule; MIDT via Travelport
. Winter 2013 - 14 (November - February).

New York Kennedy San Francisco Las Vegas Chicago O'Hare Boston Orlando San Diego Washington Dulles San Jose Atlanta Dallas/Ft. Worth Houston Intercont Miami Denver Phoenix Nashville 385 1,430 3,986 56 95 530 730

84 338 312 123 265 203 124 411

70 91,626 65,752 35,690 26,309 20,286 19,817 19,128 16,900 11,986 11,751 11,707 10,829

8,171 6,823 5,551 4,881 0.4% 2.2% 11.2%

0.2% 0.5% 2.7% 3.8% 0.5% 2.8% 2.7% 1.1% 2.4% 2.5% 1.8% 7.4% 1.4 % Claimed AA Domestic

Connecting Market ( 2015 Application) via DL/NH LAX - HND Total Tokyo DL/NH Share Salt Lake City Philadelphia Austin San Antonio Tampa Charlotte Tucson Sacramento El Paso Reno West Palm Beach Fresno Eugene Monterey Total 149 31 54 63 26 26 39 59 13 21

0 0 0 7 9,630 3,143 3,083 2,751 2,074 2,020 1,908 1,044

886 662 558 443 315 309 103 386,506 4.7% 1.0% 2.0% 3.0% 1.3% 1.4% 3.7% 6.7% 2.0% 3.8% 0.0% 0.0% 0.0% 6.8% 2.5% Claimed AA Domestic

Connecting Market ( 2015 Application) Via DL/NH LAX - HND Total Tokyo DL/NH Share 

### AA’s Proposed LAX Connecting Points

### AMERICAN INCLUDES CONNECTIONS OF OVER 10 HOURS IN ITS ANALYSIS Exhibit HA

- 2015A

- 921 Docket OST

- 2010

- 0018 Page 1 of 1

Source : Exhibit AA - 502. 

### Over 10 Hour Connection!FAT FAT FAT FAT SJC SJC SJC SJC SFO SFO SFO SFO MRY MRY MRY MRY

TPA TPA TPA TPA

GRU GRU GRU GRU SAN SAN SAN SAN RNO RNO RNO RNO SMF SMF SMF SMF YVR YVR YVR YVR

EUG EUG EUG EUG



### LAX LAX ATL ATL ATL ATL

AUS AUS AUS AUS BNA BNA BNA BNA BOS BOS BOS BOS

CLT CLT CLT CLT DEN DEN DEN DEN

DFW ELP ELP ELP ELP IAD IAD IAD IAD

IAH IAH IAH IAH JFK JFK JFK JFK

LAS LAS LAS LAS

MCO MCO MCO MCO

MIA MIA MIA MIA ORD ORD ORD ORD

PBI PBI PBI PBI PHL PHL PHL PHL

PHX PHX PHX PHX

SAT SAT SAT SAT SLC SLC SLC SLC

TUS TUS TUS TUS 

### AMERICAN’S ROUNDTRIP CONNECTIONS DROP FROM 32 TO 12 WHEN CONNECTING TIMES ARE LIMITED TO FOUR HOURS Exhibit HA

- 2015A

- 922 Docket OST

- 2010

- 0018 Page 1 of 1

To HND

Source : Exhibit AA - 107 and March 2015 schedule. 

### 12 Normal Connections - Limited to 4 - Hour Connections

AUS AUS AUS AUS YVR YVR YVR YVR

SAN SAN SAN SAN 

### LAX LAX SJC SJC SJC SJC DEN DEN DEN DEN

ELP ELP ELP ELP IAH IAH IAH IAH LAS LAS LAS LAS
PHX PHX PHX PHX

SAT SAT SAT SAT SLC SLC SLC SLC

TUS TUS TUS TUS To HND 

### 32 Points from Exhibit AA - 107SJC SJC SJC SJC



### LAX LAX SFO SFO DEN DEN DEN DEN

IAH IAH IAH IAH LAS LAS LAS LAS

PHX PHX PHX PHX SAN SAN SAN SAN SLC SLC SLC SLC

TUS TUS TUS TUS 

### OF AMERICAN’S TWELVE REASONABLE CONNECTIONS, EIGHT ALREADY HAVE CONVENIENT SERVICE TO HND Exhibit HA

- 2015A

- 923 Docket OST

- 2010

- 0018 Page 1 of 1

Haneda Route DL to LAX UA via LAX UA via SFO To HND

Note: Includes only roundtrip options with a four hour maximum and a one hour minimum connect time. Source : Innovata schedule data, March 2015
. DEN IAH LAS PHX SAN SJC SLC TUS UA via SFO , UA via LAX UA via SFO , UA via LAX UA via SFO , DL via LAX DL via LAX UALAX , DL via LAX DL via LAX DL via LAX UASFO via SFO HND Market Current Connecting OptionsSAT SAT SAT SAT 

### HND HND LAX LAX AUS AUS AUS ELP ELP ELP ELP 

### AMERICAN IS ONLY OFFERING THREE DOMESTIC ROUNDTRIP CONNECTING MARKETS THAT DO NOT ALREADY HAVE CONVENIENT HND ROUNDTRIPS TODAY Exhibit HA

- 2015A

- 924 Docket OST

- 2010

- 0018 Page 1 of 1

Note: Uses a minimum connect time of one hour and a maximum connect time of four hours. Source: Proposed and actual schedules for March 2015. Tokyo MIDT Passengers YE September 2014 Airport HND NRT Total Austin (AUS) 381 9,365 9,746 San Antonio (SAT) 304 5,768 6,072 El Paso (ELP) 61 2,240 2,301 Total 746 17,373 18,119

### KONA HAS OVER THREE TIMES AS MANY TOKYO PASSENGERS AND OVER 30 TIMES AS MANY HND PASSENGERS AS ALL OF AMERICAN’S UNDUPLICATED ROUNDTRIP POINTS BEHIND LAX YE September 2014 Tokyo MIDT Passengers 56,767

18,119

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



### KOA Exhibit HA

- 2015A

- 925 Docket OST

- 2010

- 0018 Page 1 of 1

Total of All AA Proposed “New” Roundtrip Points Behind LAX

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

### YE September 2014 HND MIDT Passengers

24,463

746 0 5,000 10,000 15,000 20,000 25,000 30,000



### KOA Total of All AA Proposed “New” Roundtrip Points Behind LAX

### HAWAIIAN WILL PROVIDE 19% MORE ANNUAL SEATS THAN AMERICAN

247 294

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

### Proposed Seats per Aircraft



### Hawaiian American

(A330) (777) +19% +34,310 Annual Seats Exhibit HA

- 2015A

- 926 Docket OST

- 2010

- 0018 Page 1 of 1

Note: Assumes AA operates the aircraft type and the number of flights in its proposal. Only Hawaiian has operated the number of flights and aircraft it committed to in its original HND proposal. Source: Applications.

### AN AMERICAN LAX - HND SERVICE WOULD EXPERIENCE DISASTROUS LOAD FACTORS

1/ Unadjusted MIDT, via Travelport, YE Q3 2014. 2/ See Exhibit HA - 2015A - 621. 3/ American proposes to provide 180,310 seats. Total current TYO - LAX seats are 1,641,849. 180,310/ (1,641,849 + 180,310) = 9.9 %. This is adjusted to 8.4% based on the fact that the U.S. flag carrier mainland HND onboard share of TYO is 85% of the seat sha re using YE June 2014 T - 100 data. This reflects the fact that NRT is preferred to the mainland. 4/ With very similar size at LAX, AA’s flow ratio should be similar to Delta’s. Source: U.S. DOT, T - 100 data and MIDT. Exhibit HA

- 2015A

- 927 Docket OST

- 2010

- 0018 Page 1 of 1



### Estimate of AA LAX - HND Onboards Unadjusted LAX - TYO Local Passengers /1 443,032 Adjustment Factor to Account for Direct Bookings 1.35 Adjusted Local LAX - TYO Passengers 598,093 Stimulation Based on QSI /2 24,810 Local LAX - TYO After Stimulation 622,904 AA Seat Share LAX - TYO /3 8.4% Forecast AA Locals 52,324 DL LAX - HND Flow to Local Ratio /4 0.74 Forecast AA Flow 38,720 Total Passengers 91,044 Total AA Seats 180,310 Predicted Load Factor 50.5%

### ALMOST 85% OF AMERICAN’S PROPOSED LAX - HND CAPACITY COULD BE OFFSET BY DELTA FULFILLING ITS 2010 LAX - HND COMMITMENT

Source: U.S. DOT, T - 100 data: Docket OST - 2010 - 0018, Exhibit DL - ANS - 201.

. 

### 180,310 151,331

0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000 180,000 200,000 220,000

AA Proposed LAX Seats Additional DL Seats If DL Fulfilled 2010 Commitment /1 Exhibit HA

- 2015A

- 928 Docket OST

- 2010

- 0018 Page 1 of 1

1/ Delta proposed 294,190 seats in 2010. It operated 142,859 seats in YE June 2014. The difference is 151,331.

### THE LAX - HND MARKET CANNOT SUPPORT THREE NONSTOP CARRIERS

1/ U.S. DOT, T - 100, YE June 2014. 2/ From Exhibit HA - 2015A - 621. 3/ YE June 2014 seats of 305,600 + 180,310 seats proposed by AA. Source: U.S. DOT, T - 100 data YE June 2014. Exhibit HA

- 2015A

- 929 Docket OST

- 2010

- 0018 Page 1 of 1



### YE June 2014 LAX - HND Onboards /1 249,732 Stimulated Passengers from AA HND Nonstop /2 24,810 Total LAX - HND After Stimulation 274,542 Total LAX - HND Seats Including AA Proposed /3 485,910
Estimated LAX - HND Load Factor with 3 carriers 56.5%

### WITH THREE CARRIERS THE LAX - HND MARKET WILL JOIN JFK, DTW AND SEA AS THE NEXT FAILED HND DESIGNATION



### 81.7%

50.5% 56.5% 56.6%

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

Current LAXHND Load Factor (2 Carriers) Forecast AA LAX-HND Load Factor Forecast LAX-HND Load Factor After AA (3

Carriers) Current SEAHND Load

Factor 

### LAX - HND Load Factor – YE June 2014

Source: U.S. DOT, T - 100 data and Exhibits HA - 2015A - 927 and HA - 2015A - 929. Exhibit HA

- 2015A

- 930 Docket OST

- 2010

- 0018 Page 1 of 1

### AMERICAN USED ITS CURRENT NRT - LAX FLIGHT NUMBERS IN ITS OCTOBER 2014 HND - LAX APPLICATION

Source: American Airlines October Application and Innovata Schedule data for January 2015. Exhibit HA

- 2015A

- 931 Docket OST

- 2010

- 0018 Page 1 of 1

Schedule Weekly Extract Report for AA all Passenger (All) flights from NRT to LAX for travel in January 2015

Mktg Al Alliance Orig Dest Miles Flight Equip Seats Dep Time Arr Time Op Days Ops/Week Seats/Week

AA oneworld LAX NRT 5,451 169 777 247 1125 1630 1...... 1 247 AA oneworld LAX NRT 5,451 169 777 247 1130 1630 .234567 6 1,482 AA oneworld NRT LAX 5,451 170 777 247 1705 1000 .234567 6 1,482 AA oneworld NRT LAX 5,451 170 777 247 1705 1010 1...... 1 247 

### Original AA LAX - HND Schedule in

October 2014 Application

Actual Current AA LAX - NRT Schedule

### 1000 SERIES: ANSWER TO DL

• DL Has A Large Commitment to Narita (Exhibit 1001)
• Delta Has Wasted 248 Available SEA - HND Flights (Exhibit 1002)
• Delta’s Average SEA - HND Load Factor Is Only 57% (Exhibit 1003)
• Delta’s Haneda Load Factor Is Below The Average Load Factor Of The Two HND Routes That Have Failed (Exhibit 1004)
• Hawaiian’s Proposed Aircraft Size Is 41% Larger Than The Aircraft Delta Is Using For SEA - HND (Exhibit 1005)
• Hawaiian Is Proposing Over 200% More Seats Than Delta Has Scheduled For HND - SEA (Exhibit 1006)
• Delta Has Not Honored Its Previous HND Commitments (Exhibit 1007)
• With One Designation Hawaiian Has Carried More Haneda Passengers Than Delta Has With Two Designations (Exhibit 1008)
• Despite Not Having Nonstop Service To Tokyo, Kona Has More Point Of Origin Japan Passengers Than Seattle With Nonstop Service (Exhibit 1009)
• Even Before Stimulation KOA Is Underserved Relative To SEA (Exhibit 1010)
• Delta’s Proposed Future Schedules from SEA Provide New HND Connections via SEA in Only Eight Markets

– Clearly Not Enough to Save SEA - HND (Exhibit 1011) Exhibit HA

- 2015A

- 1000 Docket OST

- 2010

- 0018 Page 1 of 1

### DL HAS A LARGE COMMITMENT TO NARITA

DL’s 17 Narita Segments - 135 Weekly Departures Atlanta (ATL) Bangkok (BKK) Detroit (DTW) Guam, (GUM) Honolulu (HNL) Koror, Palau Isl (ROR ) Las Vegas (LAS) Los Angeles (LAX) Manila (MNL) Minneapolis/St. Paul (MSP) New York Kennedy (JFK) Portland (PDX ) Pu Dong (PVG) Saipan, Mariana Isl (SPN) Seattle (SEA) Singapore (SIN) Taipei (TPE)

Source: Innovata schedule for the week of January 5 - 11, 2015. Exhibit HA

- 2015A

- 1001 Docket OST

- 2010

- 0018 Page 1 of 1

GUM GUM GUM BKK BKK BKK

SIN SIN SIN SIN MNL MNL MNL ROR ROR ROR TPE TPE TPE TPE PVG PVG PVG PVG NRT NRT NRT ATL ATL ATL ATL DTW

HNL HNL HNL HNL JFK JFK JFK JFK LAS LAS LAS LAS LAX LAX LAX LAX MSP MSP MSP PDX PDX PDX PDX SEA SEA SEA SEA

SPN SPN SPN SPN0 5 10 15 20 25 30 35JuneJulyAugustSeptemberOctoberNovemberDecemberJanuaryFebruaryMarchAprilMayJuneJulyAugustSeptemberOctoberNovemberDecemberJanuaryFebruaryMarchApril 

### DELTA HAS WASTED 248 AVAILABLE SEA - HND FLIGHTS

Delta SEA - HND Designated Roundtrips Not Operated

Source: Innovata schedule data. Exhibit HA

- 2015A

- 1002 Docket OST

- 2010

- 0018 Page 1 of 1



### 2013 2014 2015 Total Unused SEA - HND Roundtrips =248

### 56% 72% 74% 62%

33% 34% 61% 66%
52% 55% 45% 49% 60%

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

June July August September October November December January February March April May June 

### DELTA’S AVERAGE SEA - HND LOAD FACTOR IS ONLY 57%
Delta SEA - HND Load Factor

Source: U.S. DOT, T - 100 data. Exhibit HA

- 2015A

- 1003 Docket OST

- 2010

- 0018 Page 1 of 1



### 2013 2014 

### Average Load Factor = 57%

### 72% 65% 57%

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

AA-JFK Failed Route DL-DTW Failed Route DL- SEA Failing Route 

### DELTA’S HANEDA LOAD FACTOR IS BELOW THE AVERAGE LOAD FACTOR OF THE TWO HND ROUTES THAT HAVE FAILED
HND Load Factors

Source: U.S. DOT, T - 100 data. Exhibit HA

- 2015A

- 1004 Docket OST

- 2010

- 0018 Page 1 of 1

### HAWAIIAN’S PROPOSED AIRCRAFT SIZE IS 41% LARGER THAN THE AIRCRAFT DELTA IS USING FOR SEA - HND

294

208

0 50 100 150 200 250 300



### Proposed HA-KOA Actual DL-SEA Average Current Aircraft Size

Source: Innovata schedule through June 2015. 

### Aircraft Type: A330 B767 Exhibit HA

- 2015A

- 1005 Docket OST

- 2010

- 0018 Page 1 of 1



### +41%

### HAWAIIAN IS PROPOSING OVER 200% MORE SEATS THAN DELTA HAS SCHEDULED FOR HND - SEA

214,620

69,956

0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000 180,000 200,000 220,000



### Proposed HA-KOA Actual DL-SEA Average Current Aircraft Size

Source: Innovata schedule. 

### YE April 2015 Exhibit HA

- 2015A

- 1006 Docket OST

- 2010

- 0018 Page 1 of 1



### +207%

### DELTA HAS NOT HONORED ITS PREVIOUS HND COMMITMENTS

75,674 294,190

150,176 294,190

69,956 164,250 217,540

0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000 180,000 200,000 220,000 240,000 260,000 280,000 300,000

Delta DTW-HND

2010 Proposal /1 Actual DTW-HND YE Sept

2012 Delta LAX-HND

2010 Proposal /1 Actual LAX-HND YE April

2015 Delta SEA-HND

2010 Proposal /1 Delta SEA-HND

2012 Proposal /1 Actual SEA-HND YE April

2015 

### Delta Promised and Actual Annual HND Seats

1/ From Docket OST - 2010 - 0018,Exhibit DL - ANS - 201. Source: Innovata schedule data and proposals. Exhibit HA

- 2015A

- 1007 Docket OST

- 2010

- 0018 Page 1 of 1

### WITH ONE DESIGNATION HAWAIIAN HAS CARRIED MORE HANEDA PASSENGERS THAN DELTA HAS WITH TWO DESIGNATIONS

616,834

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



### HA DL Cumulative Onboard HND Passengers - November 2010 – June 2014

* = Failed Route Note: Since UA began nonstop service in November 2014, data is not yet available. Source : U.S. DOT, T - 100 data. 

### HNL LAX DTW* SEA 553,086



### Number of Designations 1 2 Exhibit HA

- 2015A

- 1008 Docket OST

- 2010

- 0018 Page 1 of 1

### DESPITE NOT HAVING NONSTOP SERVICE TO TOKYO, KONA HAS MORE POINT OF ORIGIN JAPAN PASSENGERS THAN SEATTLE WITH NONSTOP SERVICE

55,094 56,385

0 5,000 10,000 15,000 20,000 25,000 30,000 35,000 40,000 45,000 50,000 55,000 60,000

KOA SEA 

### YE September 2014 Tokyo MIDT Point of Origin Japan Exhibit HA

- 2015A

- 1009 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. Source: MIDT, via Travelport.

### EVEN BEFORE STIMULATION KOA IS UNDERSERVED RELATIVE TO SEA

43 81

0 10 20 30 40 50 60 70 80 90

KOA SEA 

### YE September 2014 Tokyo* MIDT Passengers per Flight

YE Q3 2014 Passengers Before Stimulation: 58,757 96,034 YE Q3 2014 Flights Scheduled Flights Including Proposed : 730 2,225 Passengers per Flight: 81 43 Exhibit HA

- 2015A

- 1010 Docket OST

- 2010

- 0018 Page 1 of 2

* 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
.

### EVEN BEFORE STIMULATION KOA IS UNDERSERVED RELATIVE TO SEA

0.19 0.27

0.00 0.05 0.10 0.15 0.20 0.25 0.30

KOA SEA 

### YE September 2014 Tokyo* MIDT Passengers per Seat

YE Q3 2014 Passengers Before Stimulation: 58,757 96,034 YE Q3 2014 Seats Scheduled Flights Including Proposed : 214,260 503,720 Passengers per Flight: 0.27 0.19 Exhibit HA

- 2015A

- 1010 Docket OST

- 2010

- 0018 Page 2 of 2

* 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
.

### DELTA’S PROPOSED FUTURE SCHEDULES FROM SEA PROVIDE NEW HND CONNECTIONS VIA SEA IN ONLY EIGHT MARKETS

– CLEARLY NOT ENOUGH TO SAVE SEA - HND Exhibit HA

- 2015A

- 1011 Docket OST

- 2010

- 0018 Page 1 of 1

* Includes new connections in either direction when a market previously did not have a DL connection via SEA in that same dir ect ion. Uses DL’s actual minimum connect times and a max connect time of 4 hours. Source: Innovata Schedules and Response of Delta to Evidence Request. ANC 

### Airports with New DL HND - SEA Connections* with Proposed DL Schedules Through 2015

To HND

SMF BOI DEN MSP JNU SIT KTN SEA