United States securities and exchange commission logo
September 6, 2022
Shannon Okinaka
Executive Vice President, Chief Financial Officer and Treasurer
Hawaiian Holdings Inc.
3375 Koapaka Street, Suite G-350
Honolulu, HI 96819
Re: Hawaiian Holdings
Inc.
Form 10-K for
Fiscal Year Ended December 31, 2021
Response dated
August 19, 2022
File No. 001-31443
Dear Ms. Okinaka:
We have reviewed your August 19, 2022 response to our comment
letter and have the
following comments. In some of our comments, we may ask you to provide
us with information
so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your response to these comments, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
July 13, 2022 letter.
Response dated August 19, 2022
Risk Factors, page 11
1. We note your response
to prior comment 2. However, it does not appear that you have
addressed all of the
specific elements of our prior comment or explained the basis for your
conclusion regarding
materiality with respect to each such element. Please expand your
disclosure to discuss
risks related to climate change technological changes and
investments that may
affect your financial condition and operating results, as well as any
limitation on credit
related to climate change.
Shannon Okinaka
Hawaiian Holdings Inc.
September 6, 2022
Page 2
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
35
2. We note your response to prior comment 5. However, it does not appear
that you have
addressed the specific elements of our prior comment or explained the
basis for your
conclusion regarding materiality. Please explain in greater detail how
you considered
providing disclosure regarding the following indirect consequences of
climate-related
regulations or business trends:
decreased demand for services that produce significant greenhouse gas
emissions or
are related to carbon-based energy sources;
increased demand for services that result in lower emissions than
competing
products;
increased competition to develop innovative new products that result
in lower
emissions; and
increased demand for generation and transmission of energy from
alternative energy
sources.
3. We note your response to prior comment 6 states that the costs associated
with the
physical effects of climate change were less than 1% of your total
capital expenditure
during 2021, 2020 and 2019. Please quantify for us any costs related to
the physical
effects of climate change that were expensed during these periods and
subsequent to year-
end. In addition, describe any weather related impacts on the
availability of insurance,
quantify your insurance expense for each of the periods noted in our
prior comment, and
explain whether changes are expected in future periods. Also, please
revise to provide
disclosure discussing the potential for indirect financial and
operational impacts to you
from disruptions to your customers or suppliers from severe weather.
4. We note your response to comment 8. Please quantify purchases of carbon
credits or
offsets since the end of your most recent fiscal year and for any future
periods.
You may contact Michael Purcell at 202-551-5351 or Karina Dorin at
202-551-3763 with
any questions.
Sincerely,
FirstName LastNameShannon Okinaka
Division of
Corporation Finance
Comapany NameHawaiian Holdings Inc.
Office of Energy &
Transportation
September 6, 2022 Page 2
cc: Tony Jeffries
FirstName LastName