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 ) 

____________________________________) 

SUR-REPLY OF HAWAIIAN AIRLINES, INC. TO UNITED AIRLINE’S REPLY 

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 M. Berlin 

Dow Lohnes LLP 

1200 New Hampshire Ave., NW 

Suite 800 

Washington, DC 20036 

(202) 776-2000 

(202) 776-4725 (fax) 

jhill@dowlohnes.com 

perkmann@dowlohnes.com 

bberlin@dowlohnes.com 

Counsel for Hawaiian Airlines, Inc. 

December 18, 2013
DOT-OST-2010-0018 

2013 Sur-Reply of Hawaiian Airlines, Inc. 

 Page 1 of 3 

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 ) 

____________________________________) 

December 18, 2013 

SUR-REPLY OF HAWAIIAN AIRLINES, INC. TO UNITED AIRLINE’S REPLY 

Hawaiian Airlines, Inc. (“Hawaiian”) moves to file this sur-reply in response to United 

Airlines’ (“United”) Reply to correct important factual errors in United’s pleading. 

In its Reply, United incorrectly alleged that the Kona-Tokyo market has decreased by 

34% since the last case. See UA-R-103. United erroneously compared the Kona MIDT sample 

numbers from the last case, which had been expanded to reflect the full market size, with the raw 

current MIDT numbers that have not been similarly expanded in this case. Had United 

compared the correct Kona numbers from the last case with the correct numbers from the present 
DOT-OST-2010-0018 

2013 Sur-Reply of Hawaiian Airlines, Inc. 

 Page 2 of 3 

case, it would have found that the Kona market is, as Hawaiian has shown, larger now than it 

was in the last case.1

Additionally, United’s comparison of the change in Kona’s share of total Hawaii traffic is 

wrong for the same reason. United incorrectly showed that Kona’s share of Hawaii has dropped 

from 6.8% in the last case to 4.0% in the current. The correct numbers are 4.4% for the last case 

and 4.0% for the current case.2

 Since the Kona market is growing, the explanation for the 

change is simply that Honolulu is growing faster. Honolulu, of course, has enjoyed the benefits 

of nonstop service and added capacity, while Kona has had none of these advantages. 

United has attempted to persuade the Department by comparing apples to oranges in the 

hope that the Department would not catch United’s sleight of hand. There is no question that 

Hawaiian’s proposed Kona service maximizes public benefit and should be selected for the 

available Haneda slot pair. 

                                                            

1

 See Exhibit HA-2012A-408 for both the unadjusted and the adjusted MIDT numbers for KOATYO from the 2012 case. See Exhibit HA-2013A-619 from the 2013 case. Comparing 

unadjusted to unadjusted, KOA-TYO passengers have increased during this period. 

2 The correct calculation for 2012 is as follows (4.4%), the unadjusted MIDT for KOA-TYO 

from Exhibit HA-2012A-408 (57,641) divided by the unadjusted MIDT between Hawaii and the 

U.S. (1,295,832) from Exhibit HA-2012A-306. The correct calculation for 2013 is as follows 

(4.0%), the unadjusted MIDT for KOA-TYO from Exhibit HA-2013A-619 (58,847) divided by 

the unadjusted MIDT between Hawaii and the U.S. (1,481,928) from Exhibit HA-2013A-306. 

Note that these numbers are not expanded to account for direct bookings but that the KOA share 

would be the same if the MIDT was expanded. 
DOT-OST-2010-0018 

2013 Sur-Reply of Hawaiian Airlines, Inc. 

 Page 3 of 3 

 Respectfully submitted, 

___________________________ ___/s/_____________________ 

Jonathan B. Hill 

J. Parker Erkmann 

Benjamin Berlin 

Dow Lohnes LLP 

1200 New Hampshire Ave., NW 

Suite 800 

Washington, DC 20036 

(202) 776-2000 

(202) 776-4725 (fax) 

jhill@dowlohnes.com 

perkmann@dowlohnes.com 

bberlin@dowlohnes.com 

Hoyt H. Zia 

Senior Vice President, General Counsel 

& Corporate Secretary 

Hawaiian Airlines, Inc. 

P.O. Box 30008 

Honolulu, HI 96820-0008 

Hoyt.Zia@hawaiianair.com 

 Counsel for Hawaiian Airlines, Inc. 

 
Exhibits from Hawaiian Airlines, Inc.’s 2012 Answer 
CALCULATION OF STIMULATION

Exhibit HA-2012A-408

Docket OST-2010-0018

Page 1 of 2

KONA

1 YE Feb. 2012 HNL-TYO Onboard Passengers 1,829,384

2 KOA Share of NRT-KOA When Both HNL and KOA Had Nonstop Service 8%

3 Estimated KOA Passengers With Service 146,351

4 Current Unadjusted MIDT KOA-TYO 57,641

Adjustment Factor to Account for Direct 

Bookings /1 0.35

5 Adjusted KOA-TYO Passengers 77,815

6 Stimulated passengers 68,536 ( Row 3 - Row 5)

1/ For purposes of comparability HA has used DL’s 35% MIDT adjustment factor. 
CALCULATION OF STIMULATION

(A) Year Ended Feb. 2012 scheduled passenger service only from U.S. DOT, T-100 Data.

(B) (A) plus 1 new daily flight. For SFO Bay Area ANA-SJC service is 5 roundtrips per week.

(C) (B)/(A) -1

(D) Uses standard DOT QSI formula: Stimulation = ((Future Flights/Current Flights)/(0.3741 + 0.5561(Future Flights/Current Flights)))/1.075. 

(E) Year Ended Feb. 2012 scheduled passenger service only from U.S. DOT, T-100 Data.

(F) (E) x (D)

(A) (B) (C) (D) (E) (F)

Current Proposed Current Stimulated

Annual Annual QSI Onboard Onboard

Between TYO and: Flights Flights % Change Stimuation Passengers Passengers

Los Angeles (LAX) 6,320 7,005 11.6% 4.4% 1,309,284 57,608

SFO Bay Area - With ANA Service /1 3,181 3,701 16.3% 6.0% 659,580 39,575

SFO Bay Area - With ANA and UA Service 3,701 4,431 19.7% 7.1% 699,155 49,640

Seattle (SEA) - With ANA Service /2 1,411 2,141 51.7% 15.9% 306,178 48,682

Seattle (SEA) - With ANA and DL Service 2,141 2,871 34.1% 11.4% 354,860 40,454

1/ ANA announced SJC-NRT service (5 RTs per week) is factored in before adding in UA proposed service.

2/ New ANA SEA service is factored in before adding in DL proposed service.

Exhibit HA-2012A-408

Docket OST-2010-0018

Page 2 of 2

MAINLAND GATEWAYS
THE HAWAII-TOKYO O&D MARKET IS 

MUCH LARGER THAN THE SECOND LARGEST U.S. STATE

793,773

326,558

94,183 88,841 87,748

1,295,832

86,634 86,201

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

Hawaii

California

New York

Illinois

Florida

Nevada

Washington

Texas

YE June 2012 Tokyo MIDT Passengers

Exhibit HA-2012A-306

Docket OST-2010-0018

Page 1 of 1

Hawaii Has Almost Twice the Tokyo 

Passengers as California with the 

Same Number of Designations

Current HND

Designations: 3 3 1

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

Source: MIDT, via Travelport.
Exhibits from Hawaiian Airlines, Inc.’s 2013 Answer 
CALCULATION OF KONA STIMULATION

Exhibit HA-2013A-619

Docket OST-2010-0018

Page 1 of 1

KONA

1 YE Apr. 2013 HNL-TYO* Onboard Passengers 2,008,298

2 KOA Share of NRT-KOA When Both HNL and KOA Had Nonstop Service 8%

3 Estimated KOA Passengers With Service 160,664

4 Current Unadjusted MIDT KOA-TYO* 58,847

Adjustment Factor to Account for Direct 

Bookings /1 0.35

5 Adjusted KOA-TYO* Passengers 79,443

6 Stimulated passengers 81,221 ( Row 3 - Row 5)

Note: The HNL-TYO market increased 211,993 in the first year after HND service and 

365,087 through April 2013.

* Includes HND and NRT.

1/ For purposes of comparability HA has used a 35% MIDT adjustment factor throughout the Haneda cases. 
THE HAWAII-TOKYO O&D MARKET IS 

MUCH LARGER THAN THE SECOND LARGEST U.S. STATE

779,736

357,440

103,124 102,277 90,640

1,481,928

89,186 84,561

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

Washington

Nevada

Illinois

Texas

Florida

YE September 2013 Tokyo* MIDT Passengers

Exhibit HA-2013A-306

Docket OST-2010-0018

Page 1 of 1

Hawaii Has Almost Twice the Tokyo 

Passengers as California with the 

Same Number of HND Designations

Current HND

Designations: 3 3 1 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.
CERTIFICATE OF SERVICE

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

this 18th day of December 2013 via email transmission or U.S. mail 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 

Ambassador Kenichiro Sasae 

Embassy of Japan 

2520 Massachusetts Ave., NW 

Washington, DC 20008 

 _/s/____________________ 

 Benjamin Berlin