When politics are tightly intertwined in the operations of airports then perhaps it should not be surprising when the airport operators get political. In this case it is the Metropolitan Washington Airports Authority (MWAA) campaigning against an amendment to the FAA reauthorization bill. The proposal from Congressman Cuellar shifts slots from inside the perimeter rule to outside, targeted at adding a flight to San Antonio, near his district. And MWAA is not a fan of that move at all.
Amendments to the FAA reauthorization bill that alter the slot and perimeter rules governing DCA could mean your airport's connectivity to DC is at risk. Learn more: https://t.co/EKhigtDMsk
— Metropolitan Washington Airports Authority (@MWAAHQ) April 24, 2018
MWAA launched a microsite to warn travelers of risks posed by this amendment. That site suggests any destination within the perimeter is at risk should the amendment be adopted. But is that really the case??
Here’s the relevant text from Cuellar’s amendment (emphasis mine):
(2) BEYOND-PERIMETER OPERATIONS.—The Secretary shall make available, upon request, not more than 4 exemptions made available under paragraph (1) to each air carrier that—
(A) sells flights in its own name;
(B) has daily scheduled service at Ronald Reagan Washington National Airport as of the date of the enactment of this Act; and
(C) commits, in using such an exemption—
(i) to discontinue the use of a slot for service between Ronald Reagan Washington National Airport and a large hub airport within the perimeter restriction and to operate, in place of such service, service between Ronald Reagan Washington National Airport and a medium hub airport, small hub airport, or nonhub airport …
Section (2)(C )(i) requires an airline to drop service to a large hub airport inside the perimeter in order to convert a slot to the new perimeter-exempt operation. Fortunately “large hub airport” is defined, indicating an airport that serves more than 1% of the total passengers in the USA in a given year. There are only 30 airports that meet this qualification and only 17 are inside the perimeter (and not DCA/IAD/BWI):
- Miami International (MIA)
- Orlando International (MCO)
- Fort Lauderdale/Hollywood International (FLL)
- Tampa International (TPA)
- Hartsfield – Jackson Atlanta International (ATL)
- Chicago O’Hare International (ORD)
- Chicago Midway International (MDW)
- General Edward Lawrence Logan International (BOS)
- Detroit Metropolitan Wayne County (DTW)
- Minneapolis-St Paul International/Wold-Chamberlain (MSP)
- Charlotte/Douglas International (CLT)
- Newark Liberty International (EWR)
- John F Kennedy International (JFK)
- LaGuardia (LGA)
- Philadelphia International (PHL)
- Dallas-Fort Worth International (DFW)
- George Bush Intercontinental/Houston (IAH)
Flights to those 17 airports represent a significant proportion of the total departures from DCA on any given day. Most have more than 5 daily flights among the airlines serving the routes. Arguably dropping a flight to one of these airports in favor of a new destination is good news for passengers as they get more options from DCA.
MWAA’s counter point to this is a reasonable one:
There is nothing to prevent airlines from taking slots from large hub airports inside the perimeter initially, then backfilling that service with slots from smaller airports to maximize passenger load and profitability.
Put another way, an airline can drop the hub service today and add it back tomorrow – cutting service to a smaller airport along the way – without recourse. In similar scenarios related to mergers and slots at Heathrow there was typically a one year operation requirement. Delta Air Lines did this with a flight between London and Miami acquired after the American Airlines/British Airways joint venture was approved. The slot was allocated in 2010 and operated for a year before Delta dropped the service and moved the slot to its Atlanta hub. No similar requirement exists with the perimeter rules at DCA. And even if it did the one year timeline has proven easy for airlines to stomach.
So maybe one destination (or one flight to one destination) is at risk. Why does the airport authority care??
Balancing the DC Airports
Beyond the concern around swapping service from one small airport to another (which won’t substantively change the number of flights or passenger count at DCA), the MWAA believes that perimeter exceptions are the cause of passenger count declines at Dulles over the past decade.
Dulles International was planned as the growth airport and international gateway for the region’s aviation needs and for more than three decades, passenger volume at Dulles International grew while the slot rule at Reagan National kept flight activity relatively stable. Changes by Congress to the slot and perimeter rules in 2000, 2003, and 2012 have disrupted the system’s balance. Flight activity resulting from legislative loosening of the slot and perimeter rules have led to significant congestion and stress on Reagan National’s facilities and a decline in commercial domestic passenger volume at Dulles International. The impacts of additional modifications to existing law could financially destabilize Dulles International at a time when the airport is still recovering from previous slot and perimeter alterations.
The changes referenced in the statement are:
- 2000: 6 additional flights inside, 6 beyond the perimeter
- 2003: 5 additional flights inside, 5 beyond the perimeter
- 2012: 4 additional flights beyond the perimeter
If only 26 flights shifted over 12 years can affect the operational balance that much then further questions need to be asked and answered. Moreover, it is unclear that the four additional beyond perimeter flights added in 2012 truly are the cause of stress on DCA’s facilities or the drop of service at IAD. Looking at the BTS data back to 2006 for both airports it is clear that passenger count is growing at DCA and shrinking at Dulles. But the two do not appear linked. Dulles’ stats show a steady reduction of flights and total passenger count. Four daily flights added in 2012 does not explain continued declines through 2016.

Similarly, the passenger count at National was growing well before the four new beyond perimeter flights were added. Indeed, the growth started in 2011 when Delta and American Airlines closed on a deal to trade slots at National and LaGuardia, allowing each to operate more like a hub. Better connectivity brought larger planes. Larger planes brought more passengers (the passenger count increases even as total flights holds relatively steady). And that would’ve happened even without the four extra daily flights. Indeed, the upgauging started before those new routes were awarded.

Dulles appears to be stabilizing, at least in passenger count. It will eventually realize a proper mass transit connection to bring passengers to and from the airport more easily. That is more likely to shift the passenger numbers than adding a flight to San Antonio from National. So would coming to an agreement with United Airlines to fund and build a new terminal for the carrier’s hub operation at Dulles.
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I would ordinarily suggest that the invisible hand of the market should decide which destinations get served from DCA and then I am reminded of UA’s “Chairman’s flight” for EWR-CAE.
Perhaps that hand was a bit too invisible. 😀
I understand why the perimeter rule was created, both at DCA and LGA. I also think it may have outlived its purpose at both. I doubt it will change substantively any time soon, but I think it is worthy of a discussion.
It would undoubtedly be bad for some of the smaller communities that see service cuts. But if there is a compelling reason to keep the flights they’ll stick around. Or shift to Dulles.
What’s interesting with this particular amendment is that it is specifically designed JUST to benefit San Diego and San Antonio. Earmarks, much?
Thanks for your deep dive, Seth.
I feel like most of the perimeter exception limits are targeted at specific airports getting routes, though I know the last batch was more generic. Even without the rule specifically requiring destinations the Feds got to pick which airports won.
No doubt that this version played the health care center proximity as a sly way of trying to convince others to support it where normal “we want to be special, too” doesn’t cut it.
SAN was on the list last time, too, with Alaska Airlines proposing that service. They didn’t get the slot, though.
Seth Miller SAT has tried this amendment several times, in several different pieces of legislation.
And yes – not hard to match the Member of Congress with the beyond the perimeter route (see: DCA-PHX, Senator McCain)
Never a dull moment!
FYI – the amendment was pulled from the floor today prior to a vote. I would expect it to come up, in some form, when the Senate considers FAA Reauth.