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 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 Counsel & 

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

-iI. HAWAIIAN’S PROPOSED SERVICE TO KONA WILL SUCCEED 

COMMERCIALLY AND THEREFORE MAXIMIZE THE PUBLIC BENEFITS 

OF THE AVAILABLE HANEDA 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 Proceeding...................... 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 HANEDA-KONA SERVICE WILL BEST SERVE THE 

OBAMA ADMINISTRATION’S EXPRESS GOAL OF INCREASING 

FOREIGN TOURISM, EXPANDING THE ECONOMY AND 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. Hawaiian’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 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.................................................... 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-Seattle 

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 SHOULD REJECT AMERICAN’S INFLATED CLAIMS 

AND AWARD THE AVAILABLE FREQUENCY TO HAWAIIAN........................... 41
Table of Contents

(continued)

Page

-iiA. 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 HAWAIIAN’S APPLICATION WILL STRENGTHEN A 

SMALL COMPETITOR. ................................................................................................ 54

VI. AWARDING THE AVAILABLE FREQUENCY TO HAWAIIAN WILL BOTH 

PROMOTE INDEPENDENT COMPETITION AND PRESERVE THE 

COMPETITIVE BALANCE AMONG THE MAJOR ALLIANCE’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 UNIQUE INCENTIVE TO MAKE ITS KONA SERVICE 

A SUCCESS. ................................................................................................................... 62

VIII. HAWAIIAN OFFERS SUPERIOR CUSTOMER SERVICE. ....................................... 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 HAWAIIAN 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 demonstrated 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 Department. 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 competition 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 greater 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 frequencies. 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. 

Hawaiian 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), hereinafter “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 providing 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 between 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 compels the result in this proceeding. On the merits, the 

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 bilateral, make operating 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.

• The 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 load factors are 

lower than for comparable NRT services at mainland gateways).
DOT-OST-2010-0018

2015 Answer of Hawaiian Airlines, Inc.

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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-2015A708.

• Although we have repeatedly heard in each proceeding about the benefit of connecting 

traffic (New York, Detroit and Seattle), those benefits have proven to be a mirage.

11

HND connecting flights on U.S. flag carriers have all averaged less than 3% share of 

connecting markets. See HA-2015A-916. Nothing has changed that would lead us to 

expect a different result this time.

• Los Angeles (“LAX”) has ample Haneda capacity,12 but American proposes 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-927, 930.

Adding capacity into 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. Its combined passenger 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 Narita with much of the same appeal as the massive TokyoHonolulu market. See HA-2015A-109, 505. 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 checking 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 global 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 opportunity to achieve that 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. 

Their 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 Hawaiian’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 service, 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 cutbacks by either American 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-916-19.

Fifth, an award to Hawaiian will fulfill the Congressional mandate 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 more 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, see HA-2015A-115, even on routes between Tokyo and Hawaii. See HA2015A-707. In the face of a consolidating industry, Hawaiian 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 Answer 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, the 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 (“NRT”), 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 this 

proceeding.

I. Hawaiian’s Proposed 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 the State of Hawaii. This market is huge, much 

larger than the market between Tokyo and any other U.S. state, including California. See HA2015A-301-04. While the 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 successful 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. Connecting service 

will be limited,21 but market experience demonstrates that the amount of connecting service 

available has not been particularly important in the success of a particular Haneda gateway. See 

HA-2015A-916-19. Instead, success has been highly correlated with local market demand, see

HA-2015A-102, which will be the backbone of the proposed Kona service. Accordingly, an 

award of the Kona route 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 applicants 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 HA2015A-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 percent 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 Tokyomainland markets). No other state comes close to the popularity of Hawaii, as Hawaii attracted 

more than three times as many visitors as the second most popular state, California. See HAHAWAII 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. See HA-2015A-301. 

Indeed, the 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-2015A303-04. The 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 and TokyoCalifornia markets is attributable to the fact that Hawaii-Tokyo traffic is growing while traffic to 

the California markets is actually shrinking. See HA-2015A-406. 

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 passengers 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 over twice the second-largest U.S. 

state, California – even though California has an additional Haneda frequency. See HA-2015A309.
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 HA2015A-310.

The size 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-409-11. Moreover, the higher load factors are on larger 

aircraft 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 number 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

service 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-2015A408. This performance blew away the other U.S. gateways, which 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

-50,000 -28,247

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 diversion 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. 

Success 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 residents are most likely to understand the convenience of their downtown airport, 

Haneda, and make purchasing decisions accordingly. Kona is a similarly 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.

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19

DESPITE NOT HAVING NONSTOP SERVICE TO TOKYO, 

KONA HAS MORE POINT OF SALE JAPAN PASSENGERS 

THAN 13 MARKETS WITH TOKYO NONSTOP SERVICE22

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-2015A508-09. 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.

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20

passengers, will outperform all of the other single frequency Haneda gateways. See HA-2015A510. Better than that, it will outperform all current or previous mainland Haneda 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 Japanese U.S. tourist destination promises 

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.

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21

mainland visitors. See HA-2013A-604-06. Despite the huge numbers of Japanese visiting 

Hawaii, Kona, the 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, which 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 calculated by the number of MIDT 

passengers per flight.24

Kona already is a strong market with significant existing traffic from Tokyo. See HA2015A-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 350% percent more new visitors 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.

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22

HAWAIIAN’S KONA FLIGHT WILL BRING IN OVER 350%

MORE NEW U.S. VISITORS THAN A THIRD LAX GATEWAY25

But even before accounting for growth, Hawaiian estimates that the resulting traffic on the HNDKOA route would amount to over 160,000 onboard passengers per year. See HA-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.

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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. 

Considering 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.

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24

C. Hawaiian Proposes to Fly the Largest Aircraft in this Proceeding. 

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 proposed 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% larger. 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 Evidence 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.

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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 A330 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 Proposals 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.

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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 accommodate 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. American’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 gateway. 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 no 

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, Hawaiian initiated its Haneda service, which proved to be three 

months prior to when the other U.S. carriers started their respective Haneda services. See HA2015A-207. The remaining U.S. carriers requested extensions of the time to start their respective 

 30 Order Show Cause 2, at 6
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2015 Answer of Hawaiian Airlines, Inc.

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27

services.31 Since initiating its service, Hawaiian has operated it continuously, even throughout 

the tragic events of the Japanese earthquake, tsunami and associated nuclear disaster—in stark 

contrast to other U.S. carriers. See HA-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 Hawaiian has stood up to the competition provided by the Japanese 

carriers by operating consistently and flying a competitive number of segments. See HA-2015A205, 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 HA2015A-104. United’s San Francisco service has only survived by utilizing the smallest available 

aircraft and cutting capacity from Narita.

Hawaiian’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.

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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. 

Indeed, 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.

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29

HA-2015A-209. To the extent the Department considers commitment to Haneda service in its 

decision making, that factor tips 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.

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30

behind the administration’s efforts to increase international tourism to the United 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 our 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-618. Under American’s standard, this route proceeding is a 

laydown case for Hawaiian.

 35 President Barack Obama, Barack. Remarks by the President on Creating Jobs Through 

Tourism, The White House, Office of the Press Secretary (2014), 

http://www.whitehouse.gov/the-press-office/2014/05/22/remarks-president-creating-jobsthrough-tourism.

36 Jeff Zients and Valerie Jarrett 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-takepresident-obamas-national-travel-and- .
DOT-OST-2010-0018

2015 Answer of Hawaiian Airlines, Inc.

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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 Hawaii. Unlike the competing proposals, Hawaiian’s Kona 

service focuses on bringing in visitors and spending to Hawaii and the United States. Money 

spent in the United States, and more specifically on the island of Hawaii, by Japanese passengers 

is the functional equivalent of increased U.S. exports. See HA-2015A-610. To the extent 

American and Delta will operate their proposed services, they will have a comparatively 

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 proposed gateways in this proceeding. 

Because service to Kona would introduce true nonstop service in a large O&D market, Hawaiian 

projects, on a very conservative basis, that it will stimulate a significant number of incremental 

Japanese visitors, 39,008, or nearly four times American’s proposed gateway and more than ten 

times Delta’s proposed gateway. See HA-2015A-613, 619. Japanese visitors spend a significant 

amount of money during their trips, so Hawaiian’s Kona service will have an even greater

economic impact. See HA-2015A-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-2015A-615.
DOT-OST-2010-0018

2015 Answer of Hawaiian Airlines, Inc.

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32

HAWAIIAN’S KONA FLIGHT WILL INCREASE U.S. EXPORTS BY $64.8 MILLION37

Accounting for typical economic multipliers, this incremental spending will result in an 

additional $116.7 million in U.S. GDP growth, more than 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.
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2015 Answer of Hawaiian Airlines, Inc.

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33

earnings will increase by over $35.4 million 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 worthy 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 Hawaiian’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-2015A-608. 

These additional visitors to Hawaii spent money and supported the economy of the United States 

and the State of Hawaii. Hawaiian’s Haneda flight accounted for $455.3 million in U.S. exports, 

see HA-2015A-610, accounted for over $826 million in U.S. gross domestic product, see HA2015A-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 specific 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.

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34

HA-2015A-618. When flying 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 with 

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 proposed service would 

“serve Japan’s interest while sacrificing the broader U.S. interest.”38 This isn’t just wrong, it’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 heed the President’s directive 

to make stimulation of international travel to the United States a top priority and award the 

available 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 kept that commitment for just 37 days. Hawaiian’s Answer to Petition 

 38 Supplemental Comments of Los Angeles World Airports, Operator of Los Angeles 

International Airport, In Support of American Airlines LAX–Tokyo Haneda Proposal, DOTOST-2010-0018 (Jan. 5, 2015), at 6.
DOT-OST-2010-0018

2015 Answer of Hawaiian Airlines, Inc.

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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 the Detroit 

service having provided only 26% of the proposed seats. See id.

• In Seattle, after 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 cancelled 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 doubt. 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 

market is not large enough to support Haneda service. In 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 will 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 support 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.

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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 is clear -- continuation of the present failed service and perpetuation of Delta’s

unwillingness to put the frequency to its highest and best use. 

B. Delta’s Promise 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 

Detroit 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 compared to Honolulu at 82.7%. See HA-2015A203. 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.

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37

proposed service would further 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 taking 

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 look 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 time when Delta 

suspended Haneda service, November 2014, to March 2015 when the service purportedly will 

restart, the only cities that gain a new connection to and from Haneda via Seattle during 

September to December 2015 are: Anchorage (“ANC”), which still will not connect 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 has 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 significant 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.

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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 tentatively 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 spectacularly wrong – as Delta’s share of connecting markets 

has hovered below 2% in its proposed connecting markets. See HA-2015A-917. 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 was not only the smallest aircraft in Delta’s international fleet but the smallest aircraft 

proposed in that proceeding. See Hawaiian 2012 Answer at HA-2012A-109. This 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 schedule 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, the 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 flights 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, this load factor is lower 

than other failed Haneda gateways. See HA-2015A-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 projections submitted to the Department. The chart below demonstrates 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 support and enhance the success of the SeattleHaneda flight.”).
DOT-OST-2010-0018

2015 Answer of Hawaiian Airlines, Inc.

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40

See HA-2015A-1007. In contrast Hawaiian has kept its promises and delivered stellar 

performance. Hawaiian, with one designation, has carried more Haneda passengers 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 Angeles 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

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IV. The Department Should Reject American’s Inflated Claims and 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 Hawaii does 

not exist. While several of American’s exhibits 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 TokyoHonolulu/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-908.
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The size of the Los Angeles market is not the only delusion in American’s Application. 

The self-proclaimed “largest U.S. airline” has portrayed itself as an upstart seeking a tender 

foothold in Japan: 
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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 the 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, please. 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-115.

Even dismissing the puffery in American’s application, 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 Hawaiian’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/i18n/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-aglance.jsp.
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44

introduction of more LAX-Tokyo capacity into a saturated market will require service 

cutbacks. Even if American’s service does survive, it is likely 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 deserving 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 authority 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, 
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including Haneda service offered by both Sky Team’s Delta and Star’s ANA. See HA-2015A904. A significant number of the total Tokyo-LAX services are offered by oneworld, which 

provides 14 of the weekly roundtrips. See HA-2015A-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-2015A-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 schedule as Delta’s 

HND-LAX service and will depart Haneda about the same time as ANA’s service. See HA2015A-910. Indeed, Delta’s service has survived only because it has repeatedly downgauged its 

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-2015A-912-14. 

Indeed, Delta’s LAX-HND results demonstrate that the market cannot 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 service 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. 
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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 Haneda allocation proceeding. Upon receiving HND-JFK authority, 
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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-HND Proposal Will Reduce 

Load Factors so Low that the Service Will Fail.

Because LAX-HND 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 (estimating 

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 projects 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.
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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 Are 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.
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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. 

The number of Haneda passengers making connections at U.S. gateways is insignificant. 

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 HA2015A-916. This has held true for Delta’s LAX service, see HA-2015A-918; Delta’s Seattle 

service, see HA-2015A-918; 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 unrealistic 

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 connecting markets plummets to 12. 

See HA-2015A-922.

 50 See American Application, at 4, 6, 12.

51 Id., at 2.
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AMERICAN’S ROUNDTRIP CONNECTIONS DROP FROM 32 TO 12

WHEN CONNECTING TIMES ARE LIMITED TO REASONABLE LEVELS52

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 SFO SJC

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

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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-924. 

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
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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 than 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 
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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 market). A comparison 

between the number of MIDT passengers per flight in both Kona and Los Angeles yields the 

same result.

EVEN BEFORE STIMULATION KONA IS UNDERSERVED RELATIVE TO LAX53

(YE SEPTEMBER 2014 TOKYO MIDT PASSENGERS PER FLIGHT)

The Department should 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.
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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 HA2015A-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 YorkFlorida Case, 24 C.A.B. 94 (1956). 
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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 has 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 would 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-2015A-115. 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 offers. See 

 54 Order Show Cause 1, at 8.
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HA-2015A-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 their 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 challenge the global behemoths. If the 

Department 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 
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57

indeed wants to promote competition from non-aligned 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 Application 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 advantages” 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 adverse impact of replicating what the three 

alliances have achieved across the Atlantic, where the oneworld, Sky Team and Star alliances 

have sufficient market power to stifle the entry and expansion of non-aligned airlines. In this 

proceeding, the Department should aim for achieving a higher public interest goal and promote 

independent competition, and Hawaiian is the only applicant providing an alternative to the 

dominance of the aligned carriers with their historical advantages of incumbency. See HA2015A-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.
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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 markets highly concentrated. The Sky Team, oneworld and 

Star alliances control 98 percent of the U.S.-Tokyo frequencies, 98 percent of passengers and 92 

percent of Tokyo-Honolulu frequencies. See HA-2015A-702, 704, 707. American’s oneworld 

alliance already has a significant market share at Haneda, where it controls 31 percent of the 

seats. See HA-2015A-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 would still be dominated by 

the alliances, see HA-2015A-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 experience since 2010 demonstrate that Hawaiian can, 

and will, take advantage of this opportunity. 

Indeed, in the 2010 proceeding, Hawaiian represented that the award of a Haneda 

frequency would allow it to establish a platform from which to grow. See Consolidated Reply of 

Hawaiian Airlines, Inc., 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 Agreement with Japan. For years, 

Hawaiian’s presence in Japan had been limited to charter service and the marketing of its InterIsland services to tourists who traveled to Hawaii on other carriers. The introduction of 
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Hawaiian’s Haneda service established it as a legitimate competitive provider of travel between 

Japan and the Hawaiian Islands. The increased awareness resulting from Hawaiian’s marketing 

efforts among the Japanese public and tour operators has facilitated Hawaiian’s introduction of 

its own services to additional cities in Japan, including Osaka, 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 the 

alliance carriers between Tokyo and Honolulu has had procompetitive effects. Hawaiian’s 

service has resulted in significantly more traffic than the mainland routes to Tokyo from the 

United States. See HA-2013A-403. In fact, Honolulu generated approximately twenty-five times 

the passengers than all other gateways combined. See HA-2015A-404. The public benefit of 

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

opportunity to expand upon its successful platform through the award of an additional slot 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). 
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those factors in this proceeding.57 Because Delta has been unable or unwilling to use its 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 to be allocated to U.S. 

carriers, the Star and oneworld alliances already hold five of the eight available slot pairs. ANA 

and United 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 that alliance members 

would coordinate schedules and fares to act, for the purposes of the applicable routes, as a single 

carrier. Further, in granting the oneworld and Star applications for antitrust immunity, the 

Department found the “intended commercial effects of the[se] . . . joint venture agreements are 

similar to those resulting from a merger.” Id. at 3. 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 

equivalent 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 10.
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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 lower than two failed 

Haneda routes.

DELTA’S SEATTLE-HANEDA LOAD FACTOR IS BELOW THE

AVERAGE LOAD FACTOR OF TWO HANEDA ROUTES THAT HAVE FAILED61

 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.
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Accordingly, this valuable air service right is being wasted. Under Delta’s stewardship, the 

benefits of five of seven Haneda 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 

nonaligned 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 this valuable frequency right to the JAL-American joint venture. 

VII. Hawaiian has a Unique Incentive to Make its Kona Service a Success.

Only 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 dominated by the alliance 

carriers, which have huge commitments to that airport. The JAL-American joint venture

operates 36 segments from Narita, including 14 weekly frequencies to LAX. See HA-2015A901, 903. Delta operates 17 segments from Narita, including 135 weekly departures. See HA2015A-1001. 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-2015A-109. Both the American-JAL joint venture and Delta have 

significant investments in their operations at Narita. See HA-2015A-901, 1001. In fact, the fear 

of diversion from existing Narita services has likely been a major contributor to the periodic 

suspensions of all the mainline routes from the alliance carriers. With the substantial investment 

of 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 ending October 2014, 

Hawaiian again led its legacy airline competitors in on-time arrivals, see HA-2015A-801, 

extending its winning streak to a full decade. See HA-2015A-805. Hawaiian also bests Delta 

and American in the rate of mishandled bags, see HA-2015A-802. By a substantial margin, 

Hawaiian has a much lower rate of passengers denied boarding. See HA-2015A-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 rate. See HA2015A-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 nonstop service and the only gateway proposed in this 

proceeding that will result in a viable commercial service rather than a subsequent return or 

request to transfer the award. 


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 the Best Use of the U.S.’s 4th Haneda Frequency

600 Economic Impact

700 Alliance Carriers Dominate the Tokyo Market

800 Hawaiian’s Record of Outstanding Performance

900 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 50 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 data, 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

• All service suspended in Sept. 2012

• Service started 94 days late

• Aircraft downgraded to smaller B777 in June 2011

• Aircraft downgraded to smaller A330 in 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

• All 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 51x
3,324

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 HAWAIIAN
507

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

HAHNLJLSFOJLHNLNHLAXNHHNL

DLLAXAAJFKDLSEADLDTW

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-2010-0018

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

272,456
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

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 MainlandHaneda 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 SITUATION
Exhibit 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

+370,927
Exhibit 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

-8,231
Exhibit 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

+10,602
370,927

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%

HNLNHHNL-JL LAXNHHNLHALAX-DL JFKAASFO-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

HNLJLHNLHAHNLNHLAXNHLAXDLSFOJLSEADLJFKAA

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 4TH HANEDA FREQUENCY
500 Series Exhibits

KONA IS THE BEST USE OF THE U.S.’s 4TH 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 2nd 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 1

55,094

44,235

38,408

36,992

13,131

9,004

56,385

25,971

18,159

23,720

24,978

21,201

21,179

26,319

0

10,000

20,000

30,000

40,000

50,000

60,000

KOA SEA BOS IAD SANEWR 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 2nd 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 operated 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

/2
Source: 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 1st 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 1st Year of Service
160,602

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 1
Hawaii

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 1
Exhibit 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 LAX
Exhibit 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-ToGateway 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 1
ANA

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 American 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 AA

10 UA DL UA

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

ITMITMITMITM FUK FUK FUK FUK

PUS PUS PUS PUS

NGO NGO NGO

ICN ICN ICN ICN

DLC DLC DLC DLC CDG CDG CDGFRA 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

SINSIN SINSIN

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 data, 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 service. 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-11

Dec-11Feb-12

Apr-12

Jun-12

Aug-12

Oct-12

Dec-12Feb-13

Apr-13

Jun-13

Aug-13

Oct-13

Dec-13Feb-14

Apr-14

Jun-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

Actual
Exhibit 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

Westbound
0

50

100

150

200

250

300

350

400

450

January MarchMay

July September November January MarchMayJuly September November January MarchMayJuly September November January MarchMayJuly 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

DL

TokyoU.S.

Load

Factor

Current

TokyoU.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

JunOct ‘11

Oct ’11-

Mar –’13

Since

Mar ‘13
83% 84%

81%

63%

72%

81%

84%

88% 89%

67%

73%

82%

58%

52%

48%

63% 64%

58% 60%

52%

45%

58% 59% 60%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Jul13

Aug13Sep13Oct13Nov13Dec13Jan14Feb14

Mar14Apr14May14Jun14

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 ROUTES
TPA TPA TPA TPA

MCO MCO MCO MCO

HNL HNL HNL HNL

OGG OGG OGG OGG

LIH LIH LIHLIH LIH LIHLIH LIH LIH

CVG CVG CVG CVG

LAX LAX

KOA KOA KOA KOA

BOI BOI BOI BOI

SEA SEA GEG GEG GEG GEG 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

INDIND INDIND

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 LIHLIH LIH LIHLIH 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

IADIAD IADIAD

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

IAHIAH IAHIAH

INDIND INDIND

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 1
Source: 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-HND
Source: 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 Points
TPA

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 Points
FAT FAT FAT FAT SFO SFO SJC SJC SJC SJC 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

IADIAD IADIAD

IAHIAH IAHIAH

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 LAXTOKYO 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 SFO SFO SJC SJC SJC SJC 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

IADIAD IADIAD

IAHIAH IAHIAH

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

IAHIAH IAHIAH

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-107 
SJC SJC SJC SJC

LAX LAX

SFO SFO

DEN DEN DEN DEN

IAHIAH IAHIAH

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 Options
SAT 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 share 

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

BKK BKK BKK GUM GUM GUM

SINSIN SINSIN

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

PDX PDX PDX PDX MSP MSP MSP

SEA SEA SEA SEA

SPN SPN SPN SPN
0

5

10

15

20

25

30

35

June

July

August

September

October

November

December

January

February

March

April

May

June

July

August

September

October

November

December

January

February

March

April

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

NovemberDecember

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 direction. 

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