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OST-98-4025

Airport Competition Plans - Air Fare Data 2000

Please read a more thorough description of the Air Fare Data before using.

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Request for Public Comment on Competitive Issues Affecting Domestic Airline Travel

OST-98-4025 | July 13, 1998

document.gif (123 bytes)Notice

The Department of Transportation is gathering information on airport practices and whether they may affect competition among air carriers. We intend to meet with airport and airline professional associations and other interested participants, review data and information provided by industry organizations, review of comments filed in this docket, and use other means as appropriate. Specifically, we seek to determine:

(1) Whether airports have used Passenger Facility Charges in ways that have enhanced competition;

(2) whether the types of issues raised in complaints to the Department regarding airport practices have prevented competition among air carriers;

(3) whether leasing agreements and financing arrangements at airports limit access and thus competition; and

(4) whether airport planning, development, and commercial practices limit access.

Comments should be received by September 1, 1998. Comments that are received after that date will be considered to the extent possible.

By: Rosalind A Knapp, DOT, {Taken from the Federal Register}


Competitive Issues Affecting the Domestic Airline Industry

OST-98-4025 | August 6, 1998

pdficon.gif (87 bytes)Petition of the Air Transport Association of America to Extend Comment Period

Since the Notice was published, ATA has been working internally and with its members to craft an appropriate survey and questionnaire that will develop meaningful1 data regarding the questions posed by the Notice. For example, the Notice raises questions about the availability and allocation of gates at airports. In order to provide data that is useful, ATA believes that data from as many as forty airports may be necessary. Obtaining those data will be labor-intensive and will require the cooperation of airport management and individual airlines. However, even before the survey can be distributed, additional consultation with ATA member airlines is required. Moreover, the work would have to be done at a time when personnel resources are scarce due to summer vacation schedules. Thus, realistically, ATA estimates it will not have the necessary data until late September or early October, at best.

Counsel:  ATA, David Berg, 202-626-4000


Competitive Issues Affecting the Domestic Airline Industry

OST-98-4025

pdficon.gif (87 bytes)Comments of Metropolitan Nashville Airport Authority - July 20, 1998

The Authority has taken back three gates from the airlines when the American Airlines hub was discontinued. The Authority has also worked with existing incumbent carriers to allow for the expansion of other incumbent carriers. We have experienced no difficulty in working with other carriers to provide this additional space.

By:  William Moore, President

pdficon.gif (87 bytes)Comments of City of San Antonio - August 3, 1998

Do airports involve themselves in monitoring subleasing/use agreements among air carriers?

The SAT signatory airline agreement (attached Article XIV) prohibits subleasing without the City's prior approval. Subleasing is also not permitted if the City has space available (e.g. gates and ticket counters). This is intended to protect the City's interests by precluding airlines from getting into the real estate business. It is not meant to deter competition. However, if the signatory airline defines the use of its leased areas by a non-signatory airline as a handling agreement, such is permitted regardless of space availability. Submission of copies of the sublease and handling agreements to the City is required.

Of the four international gates, two are leased under the signatory airline agreement to Mexicana and Northwest. A mild example of limiting access to airport facilities may be seen in the recent start-up of American and Continental's service to Mexico City. They negotiated a handling agreement with Northwest to use its gate to deplane passengers into the FIS area since Mexicana is a competitor in that market and had one of its flights scheduled at the same time as an arriving American flight. Of the four international gates, only the two leased to Mexicana and Northwest have loading bridges.

Attachment:  Airline Agreement, Article XIV, Assignment and Subletting

By:  Efren Gonzalez, Acting Aviation Director


Public Comment on Competitive Issues Affecting the Domestic Airline Industry

OST-98-4025 | August 12, 1998

pdficon.gif (87 bytes)Answer of the Air Carrier Association of America in Opposition to the Petition of the Air Transport Association of America to Extend Comment Period

In what is now predictable behavior, the ATA parties have again waited until the end of a comment period to request a last-minute delaying tactic to extend the comment period. It is just another part of a planned process to perpetuate the large carriers' strategy of eliminating competition and raising fares. The ATA parties claim that they do not have the resources to submit comments, yet they were able to spend millions of dollars to hire multiple law firms, public relations firms, and analysts to try to prevent the Department of Transportation from addressing anti-competitive issues and to propose legislative action that would strip the Department of its basic authorities. Moreover, ATA members seem to have the resources necessary to implement alliances/marketing agreements with domestic and foreign carriers, expand fleet sizes, and extend control over hub airports. In addition, we would suggest the ATA be reminded that vacation schedules are not recognized grounds for which a comment period is extended.

In order to enjoy the advantages of a deregulated system, it must be open for all who are willing to compete. Unfortunately, this is not the case today. Consumers have fewer choices and, in many markets, no choice at all. The ATA parties represent carriers controlling approximately 95% of the domestic passenger market share. These are the carriers that are seeking to delay and ultimately prevent the opening of any opportunity for competition. There should be no mistake as to the objectives of the ATA parties -- to stop any oversight of barriers to entry and to allow large carriers to build upon their unprecedented control of this industry.

Counsel: Michelle Faust, ACAA, 202.778.4442


Competitive Issues Affecting the Domestic Airline Industry

OST-98-4025 | August 17, 1998

pdficon.gif (87 bytes)Reply of The Air Transport Association of America to Answer of the Air Carrier Association of America

Boiled down to its simplest terms, ACAA complains that it does not want the Department to delay this proceeding. The issue, however, is whether the comment period allows adequate time to provide meaningful information that is responsive to the Department's concerns. Given the nature and extent of the information requested by the Department, the overall importance of the issues the Department is addressing, and in light of the totality of the circumstances, the ATA believes that extending the -comment period by 120 days will assist, not delay, the Department's study. The public interest is served by allowing interested parties adequate time to respond to the Department's request for comments so that the Department is fully informed.

Counsel:  ATA, James Casey, 202-626-4000

pdficon.gif (87 bytes)Re:  Letter from Airports Council International Requesting Extension of Time

Counsel:  ACI-NA, Patricia Hahn, 202-293-8500

pdficon.gif (87 bytes)Comments of Maryland Aviation Administration

By:  Nicholas Schaus

pdficon.gif (87 bytes)Comments of Reno/Tahoe International Airport

By:  Tom Medland


Competitive Issues Affecting the Domestic Airline Industry

OST-98-4025 | August 10, 1998

pdficon.gif (87 bytes)Comments of Eugene Airport

By:  Mike Boggs, Manager


Competitive Issues Affecting Domestic Aviation Industry

OST-98-4025 | August 19, 1998

pdficon.gif (881 bytes)Comments of the Lee County Port Authority (Ft. Myers, FL)

By: Debra Lemke


Competitive Issues Affecting the Domestic Airline Industry

OST-98-4025 | August 19, 1998

pdficon.gif (881 bytes)Comments of Fort Wayne International Airport

By:  Lester Coftman


Competitive Issues Affecting the Domestic Airline Industry

OST-98-4025

pdficon.gif (881 bytes)Comments of The City of Airport Authority of the City of Omaha - August 25, 1998

By:  Donald Smithey


Comptetive Issues Affecting the Domestic Airline Industry

OST-98-4025 | August 26, 1998

pdficon.gif (87 bytes)Re: Comments of Boise, City of Trees

Most airports are desperately trying to gain more air service either through new entrants or more seats by incumbent air carriers. Having the DOT step into the business operations of airports will send us down the Jet Route to poor airport practices seen around the world when national governments try to operate the airports. Please stick to safety and security and leave local businesses practices with the states and local governments where it belongs.

By: John Anderson, Boise Airport Director


Competitive Issues Affecting the Domestic Airline Industry

OST-98-4025 | August 25, 1998

pdficon.gif (87 bytes)Comments of the Port of Portland

Current airport practices do not inhibit airline competition. PDX continues to have new start up carriers entering the market on a regular basis (Harbor Air, Air Portland, SkyWest, Southwest, Korean, etc.). We have not received complaints about our practices.

By: Tom Decker, Mgr., Federal Government Relations


Competitve Issues Affecting the Domestic Airline Industry

OST-98-4025 | August 28, 1998

pdficon.gif (87 bytes)Comments of Lincoln Airport Authority

One of our existing air carriers is United Airlines which has reduced service over the last three years from four flights per day to Chicago to two flights per day to Chicago currently. Each time the airline has informed us that this is not due to equipment or market conditions but to the need for the airline to utilize its slot capacity in Chicago in higher density, larger markets. Subsequently, Lincoln has lost service.

By:  John Wood

pdficon.gif (87 bytes)Comments of Salt Lake City International Airport

We want to retain our current flexibility when our existing use agreements expire, and are considering how we can increase flexibility such as by retaining the right to recapture gates, avoiding long term exclusive arrangements, and possibly through some common use arrangements.

By:  Russell Widmar


Competitive Issues Affecting the Domestic Airline Industry

OST-98-4025 | September 1, 1998

Comments of Broward County Aviation, Fort Lauderdale, FL - available as soon as Docket Section scans

By:  William Sherry, Director of Airports


Competitve Issues Affecting the Domestic Airline Industry

OST-98-4025 September 3, 1998 pdficon.gif (87 bytes)Comments of Los Angeles World Airports    

By:  Jerald Kee

OST-98-4025 September 14, 1998 Comments of Roberts Roach Associates Response to ACI-NA Requesting Additional Time  

By:  Allan Sbarra

Above filings available as soon as Docket Section scans


Comment on Competitve Issues Affecting the Domestic Airline Industry

OST-98-4025 August 26, 1998 Comments of Boise Department of Aviation & Public Transportation
OST-98-4025 September 9, 1998 Comments of University of Denver College

Above documents available as soon as Docket Section scans


Competitive Issues Affecting the Domestic Airline Industry

OST-98-4025 December 18, 1998 pdficon.gif (87 bytes)Comments of Greater Orlando Aviation Authority Competitive Issues Affecting the Domestic Airline Industry

By:  Greater Orlando Aviation Authority


Competitive Issues Affecting Domestic Airline Industry

OST-98-4025 December 23, 1998 pdficon.gif (87 bytes)Massachusetts Port Authority - Comments Request for Public Comment on Competitive Issues Affecting the Domestic Airline Industry

Counsel:  Massachusetts Port Authority David Y. Bannard, Associate Chief Legal Counsel

OST-98-4025 December 23, 1998 Consolidated Natural Gas Company - Comments Request for Public Comment on Competitive Issues Affecting the Domestic Airline Industry

By:  Consolidated Natural Gas Company John J. Gia, Manager, Codes, Standard, Meters and Technical Training


Competitive Issues Affecting the Domestic Airline Industry

OST-98-4025 December 29, 1998 pdficon.gif (87 bytes)Comments of Orlando Sanford Intl Airport Competitive Issues Affecting Domestic Airline Industry

By:  Brendan Carmody, President & Managing Director


Competitive Issues Affecting the Domestic Airline Industry

OST-98-4025 December 30, 1998 Comments of The Airports Council International - North America and the American Association of Airport Executives

pdficon.gif (87 bytes)Part 1
pdficon.gif (87 bytes)Part 2

Competitive Issues Affecting Domestic Airline Industry

By:  Patricia A. Hahn, General Counsel

OST-98-4025 December 30, 1998 pdficon.gif (87 bytes)Comments of The Charter County of Wayne, Michigan Competitive Issues Affecting Domestic Airline Industry

By:  David M. Katz, Director of Airports Robert E. Murphy, Airport General Counsel Wayne County Division of Airports

OST-98-4025 December 30, 1998 pdficon.gif (87 bytes)Comments of The City of Chicago

pdficon1.gif (224 bytes)Comments of The City of Chicago

Competitive Issues Affecting the Domestic Airline Industry document.gif (123 bytes)HTML

Counsel:  Chicago, Mary Rose Loney, 312-744-6478

OST-98-4025 December 28, 1998 pdficon.gif (87 bytes)Comments of Houston Airport System Competitive Issues Affecting Domestic Airline Industry

By:  Richard Vacar

OST-98-4025 December 30, 1998 pdficon.gif (87 bytes)Comments of Lambert-St. Louis International Airport Competitive Issues Affecting Domestic Airline Industry

By:  Leonard L. Griggs, Jr., P.E. Director

OST-98-4025 December 23, 1998 pdficon.gif (87 bytes)Comments of The Metropolitan Airport Authority of Rock Island County, Illinois (Quad City International Airport) Competitive Issues Affecting Domestic Airline Industry

By:  Harvey A. Levin, General Counsel

OST-98-4025 December 29, 1998 pdficon1.gif (224 bytes)Comments of Miami International Airport Competitive Issues Affecting Domestic Airline Industry

Counsel:  Gail P. Fels

OST-98-4025 December 29, 1998 pdficon1.gif (224 bytes)Comments of The Port Authority of New York and New Jersey Competitive Issues Affecting Domestic Airline Industry

By:  Robert Kelly, Director Aviation Department

OST-98-4025 December 30, 1998 pdficon1.gif (224 bytes)Comments of Tucson International Airport Competitive Issues Affecting Domestic Airline Industry

By:  Walter Burg


Competitive Issues Affecting the Domestic Airline Industry

OST-98-4025 December 31, 1998 pdficon.gif (87 bytes)Air Transport Association of America - Motion/Comment Competitive Issues Affecting the Domestic Airline Industry document.gif (898 bytes)HTML

Counsel:  Thompson Coburn, Patricia N. Snyder

OST-98-4025 December 31, 1998 pdficon.gif (87 bytes)Metropolitan Airports Commission Minneapolis-St. Paul Intl Airport - Comments Competitive Issues Affecting the Domestic Airline Industry

Counsel:  Thomas W. Anderson

OST-98-4025 December 30, 1998 pdficon.gif (87 bytes)Metropolitan Washington Airport Authority - Comments Competitive Issues Affecting the Domestic Airline Industry

Counsel:  Edward S. Faggen, Vice President and General Counsel

OST-98-4025 December 30, 1998 pdficon.gif (87 bytes)Orlando Sanford International - Comment Competitive Issues Affecting the Domestic Airline Industry

Counsel:  Brendan P. Camody, President & Managing Director


Competitive Issues Affecting the Domestic Airline Industry

OST-98-4025 January 20, 1999 pdficon.gif (87 bytes)Motion for Leave to File Late and Comments of The Air Carrier Association of America Competitive Issues Affecting the Domestic Airline Industry document.gif (123 bytes)HTML

Among the anti-competitive airport gate tactics employed by the US airlines are:

For the past decade, competition has been limited by lack of adequate airport facilities. The Department should continue this review and act decisively whenever airport practices limit competition and deprive travelers and communities of opportunities for competitive service. The Department's review should not be deterred by misleading statements by those who benefit from further airline consolidation.

Counsel:  ACA, Edward Faberman, 202-778-4422


Competitive Issues Affecting the Domestic Airline Industry

OST-98-4025 February 26, 1999 pdficon.gif (87 bytes)Motion for Leave to File an otherwise Unauthorizaed Document and Supplemental Comments of the Air Transport Association Competitive Issues Affecting the Domestic Airline Industry document.gif (123 bytes)HTML

The ACAA apparently wishes that every airport would have gates immediately available for any new entrant, even though maintaining spare capacity is inefficient and expensive. But even in such a utopia, airspace and runway constraints would still stop airlines from expanding as much as they and their customers would like. ACAA's Comments take no account of the airspace and runway constraints, which by definition limit capacity and are unrelated to the airport practices under review here. Second, even if there are a small number of cases in which gate constraints are a factor, the new entrants can do as airlines did before them: pay to build new gates.

Counsel:  Thompson Coburn, Patricia Snyder, 202.508.1000


Competitive Issues Affecting the Domestic Airlines Industry

OST-98-4025 April 20, 1999
Docketed May 3, 1999
pdficon.gif (881 bytes)Comments of The Air Transport Association of America Competitive Issues Affecting the Domestic Airline Industry

By:  ATA, Don Minnis, Airport Planning and Development


Air Carrier Association of American

OST-98-4025 July 15, 1999 Motion for Leave to File Comments Request for Public Comment on Competitive Issues Affecting the Domestic Airline Industry
    Exhibit:  Gateless in Detroit, Low-Fare Spirit Docks at Rivals' Convenience, Wall Street Journal, 7/12/99  

Multiple roadblocks continue to hinder new entry and competition. Publicly financed airports must not be under the sole control of a powerful few whose only interest is discouraging competition and entry. While there are many airports that have available facilities, the Department's responsibility is to ensure that all federally funded facilities are open to all carriers willing to compete, not just to ATA's members. Barriers at certain airports pose more significant hurdles than at others. Deregulation was not intended to apply only at some airports and in some areas of the country, nor was it enacted only for ATA's members. The Department has correctly decided that it should apply everywhere. The Department should continue this review and act decisively whenever and wherever airport or incumbent carrier practices limit competition and deprive travelers and communities of opportunities for competitive service.

Counsel:  Edward Faberman, Executive Director, Air Carrier Association of America, 202.639.37502


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