BEFORE THE

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY

WASHINGTON, D.C. 

____________________________________

)

Applications of )

)

HAWAIIAN AIRLINES, INC. )

) Docket DOT-OST-2010-0018

UNITED AIRLINES, INC. )

)

in the matter of 2010 U.S.-Haneda )

Combination Services )

Allocation Proceeding )

____________________________________)

OBJECTION OF HAWAIIAN AIRLINES, INC.

Communications with respect to this document should be addressed to:

Mark B. Dunkerley

President & Chief Executive Officer 

Hoyt H. Zia

Senior Vice President, General Counsel & 

Corporate Secretary

Hoyt.Zia@hawaiianair.com

Mark K. Arimoto

Associate General Counsel

Mark.Arimoto@hawaiianair.com

Hawaiian Airlines, Inc.

P.O. Box 30008

Honolulu, HI 96820-0008

Jonathan B. Hill

J. Parker Erkmann

Benjamin Berlin

Cooley LLP

1299 Pennsylvania Ave., NW

Suite 700

Washington, DC 20004

(202) 842-7800

(202) 842-7899 (fax)

jhill@cooley.com

perkmann@cooley.com

bberlin@cooley.com

Counsel for Hawaiian Airlines, Inc.

March 10, 2014
DOT-OST-2010-0018

2014 Objection of Hawaiian Airlines, Inc.

Page 1 of 5

BEFORE THE

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY

WASHINGTON, D.C. 

____________________________________

)

Applications of )

)

HAWAIIAN AIRLINES, INC. )

) Docket DOT-OST-2010-0018

UNITED AIRLINES, INC. )

)

in the matter of 2010 U.S.-Haneda )

Combination Services )

Allocation Proceeding )

____________________________________)

March 10, 2014

OBJECTION OF HAWAIIAN AIRLINES, INC.

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

Department’s Order to Show Cause (Order 2014-2-23) issued on February 28, 2014 in the 

above-captioned docket tentatively awarding the single slot pair at issue in the proceeding to 

United Airlines’ proposed service from Tokyo’s Haneda Airport (“Haneda” or “HND”) to San 

Francisco over Hawaiian’s application to serve Haneda from Kona, Hawaii. Specifically, 

Hawaiian objects to the Department’s conclusion that its “tentative selection would best benefit 

the U.S. traveling public,” concluding that United would serve a “mix of business and leisure 

traffic originating in both the United States and Japan.” Order 2014-2-23 at 4-5. By focusing on 

the origin of United’s traffic, the Department moved the goal posts since the Order instituting 

this proceeding in which it declared: “Our principal objective in this proceeding will be to 
DOT-OST-2010-0018

2014 Objection of Hawaiian Airlines, Inc.

Page 2 of 5

maximize public benefits” without reference to the origin of the traffic to be served. Order 2013-

11-9 at 2, Nov. 14, 2013. Because Hawaiian’s proposed Kona service would attract significant 

numbers of Japan-originating passengers, it would stimulate the most traffic and spur the most 

economic growth.1 Indeed, in its Answer, Hawaiian submitted evidence that its proposed Kona 

service would result in $75.4 million in incremental spending in the United States compared to 

only $16.5 million in incremental spending resulting from United’s proposed service.2 Hawaiian 

therefore respectfully submits that grant of its application would maximize the public benefits by 

providing a viable service in a market that is not over served and providing the most economic 

benefit to the United States, as reflected in the record. 

In addition, in its final order, Hawaiian requests that the Department affirm the public 

interest benefits of foreign originating traffic and the tourism it facilitates. In 2012, President 

Obama expressly recognized the importance of promoting travel and tourism in the United States 

by issuing an Executive Order establishing a new Task Force on Travel and Competitiveness.3

 

The Task Force subsequently issued a report acknowledging the importance of transportation 

policy on the promotion of tourism.4

 The Department previously has recognized the importance 

 1 Consolidated Reply of Hawaiian Airlines, Inc.at 4-5, Dec. 16, 2013; Consolidated Answer of 

Hawaiian Airlines, Inc. at 28-31, Dec. 9, 2013).

2

 Consolidated Answer of Hawaiian Airlines, Inc. at 29-30, Exhibit HA-2013A-615. Hawaiian 

also submitted evidence that the incremental spending will increase U.S. GDP by $135.6 million 

and create an additional 1,393 U.S. jobs. See id. at HA-2013A-614, 616. Both figures are more 

than quadruple the benefits of United’s proposal. See id. 

3 Executive Order 13,597, 77 Fed. Reg. 3373 (Jan. 24, 2012).

4 Task Force on Travel & Competitiveness, National Travel & Tourism Strategy (2012), at 3 

(available at: 

http://www.doi.gov/news/pressreleases/loader.cfm?csModule=security/getfile&pageid=295021 ) 
DOT-OST-2010-0018

2014 Objection of Hawaiian Airlines, Inc.

Page 3 of 5

of the promotion of tourism in this very docket. In tentatively awarding Hawaiian its initial 

Haneda slot pair in 2010, the Department found that the economic benefits of increasing Japanoriginating visitors justified the award of Haneda authority to Hawaiian: 

We have taken into account Hawaiian’s acknowledgement that the large majority 

of the Honolulu-Tokyo market consists of Japan-originating leisure traffic. 

However, we tentatively find that, in addition to the service and competitive 

benefits outlined above, Hawaiian’s service would benefit the local Hawaiian 

economy. Tourism is the dominant industry in the local economy, and Japanoriginating visitors comprise a significant percentage of travelers to Hawaii. 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.5

The nearly four years of experience since that initial award have proven the Department correct. 

Hawaiian’s existing Haneda-Honolulu service has been a smashing success with significant 

public and economic benefits.6 

The Show Cause Order appears to contradict the Department’s prior conclusion by 

disproportionately crediting U.S. originating traffic: “a more diverse mix of business and leisure 

traffic originating in both the United States and Japan” is “precisely the type of traffic that would 

benefit most from access to Tokyo’s downtown Haneda airport.” Order 2014-2-23 at 5. Indeed, 

 

(“Travel and tourism are critical to the American economy. This growing industry offers 

significant potential for job creation across all regions of the country. Federal policies on matters 

ranging from national security to transportation and from trade to natural resources management 

affect travel and tourism, and its potential for growth.”) (emphasis added).

5 Order 2010-5-7 at 9, May 7, 2010 (citing Expanded Air Services at Hawaii International 

Airports, Order 99-12-10, issued December 10, 1999).

6 Consolidated Answer of Hawaiian Airlines, Inc. at 12-13 and accompanying exhibits

(concluding that Hawaiian’s Haneda service has resulted in $365.1 million in U.S. exports, $657 

million in U.S. GDP growth and nearly 3,000 new U.S. jobs).
DOT-OST-2010-0018

2014 Objection of Hawaiian Airlines, Inc.

Page 4 of 5

United’s arguments7 and the Show Cause Order, at least by implication, suggest that U.S.

originating passengers provide greater benefits to the United States than foreign originating 

passengers. This is simply not true. Unlike foreign originating passengers, U.S. originating 

passengers spend dollars overseas for the benefit of the destination country. Foreign originating 

passengers spend in the United States for the benefit of the U.S. economy, and the government 

treats these expenditures as U.S. exports.8 Precisely because the bulk of Hawaiian’s traffic on 

the proposed Haneda-Kona route would be Japanese originating, the service would increase U.S. 

exports, generate economic growth and create jobs in the United States.9

 

Hawaiian therefore requests that the Department reverse its initial decision and award the 

Haneda frequency to Hawaiian for its proposed Kona service and, at the very least, affirm in its 

final order the public interest benefits of service that stimulates tourism and economic growth in 

the U.S.

Respectfully submitted,

 7 Answer of United Airlines, Inc. at 1, Dec. 9, 2013 (“Hawaiian proposes to serve a small 

gateway that would offer comparatively far less benefits to U.S. consumers”).

8

 Task Force on Travel & Competitiveness, National Travel & Tourism Strategy (2012), at 3 

n.4.

9 See Consolidated Answer of Hawaiian Airlines, Inc. at 12-13 and accompanying exhibits.

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Objection of Hawaiian Airlines, Inc. was 

served this 10th day of March 2014 via email transmission on the following:

francis.heil@aa.com

Robert.wirick@aa.com

sascha.vanderbellen@delta.com

chris.walker@delta.com

dan.weiss@united.com

Thomas.bolling@united.com

steve.morrissey@united.com

lhalloway@crowell.com

gmurphy@crowell.com

esta.rosenberg@dot.gov

robert.finamore@dot.gov

brett.kruger@dot.gov

paul.gretch@dot.gov

todd.homan@dot.gov

john.s.duncan@faa.gov

urskr@state.gov

cristinasa@state.gov

info@airlineinfo.com

/s/

Benjamin Berlin