Op-Ed: DCA’s Perimeter Rule Needs Beyond Inside The Beltway Thinking

Any FAA Reauthorization bill is guaranteed to engender debate about whether to permit more nonstop air service at Washington Reagan National airport (DCA) to points beyond the mandated 1,250-mi. limit. 

This year is no different. The Big 3 U.S. airlines, Alaska Airlines, and ULCC Spirit Airlines have put forth three starkly different ideas. A nuanced approach to designate slots for non-large hub airports beyond the DCA Perimeter is needed. Otherwise, further concentration in the hands of a few is likely.

The Big 3 U.S. carriers—American Airlines, Delta Air Lines, and United Airlines—have been reducing commercial air service to small communities in a significant and structural way, beginning in 2007 and accelerating in 2020. Yet the Big 3 are ostensibly using the once relevant scare tactic that they will have to reduce air service even further to those smaller nodes “inside of DCA’s 1,250 Perimeter Rule” because Delta wants to significantly increase service to nodes “beyond that legislatively mandated Perimeter.”  

To keep history’s small community air service narrative in focus, American and United have partnered in The Coalition to Protect America’s Regional Airports.  Its purpose is to unite smaller airports to oppose Delta’s push increase its flying at DCA. On the other side is the Delta-backed Capital Access Alliance (CAA). It released an elaborate economic analysis of many esoteric issues that did not say where the 25 slot pairs created might come from nor the size of airports Delta would serve. 

Intriguingly, American and United, the two airlines with connecting complexes inside the Washington Metro Area, are employing protectionism to tactically slow any new Delta competition. Today, Delta has exemptions to fly between DCA and Los Angeles and Salt Lake City. Delta wants to aggressively open DCA so it can make a grab for opportunities (slots) that it does not own, or it did not choose to acquire. Delta is a large market focused airline. Its western hub in Seattle is only served by competitor Alaska. The Senate draft provides for the potential to make another political contribution as well.

Full disclosure: I have defended United’s protection of Washington Dulles (IAD) twice. The last was in 2018, immediately after assisting the Virginia Gov. McAuliffe administration’s decision to invest $50 million in a vulnerable IAD. The genesis of this compromise was a collaboration with the Airport Director in Boise, Idaho—a thriving airport and city.  

Unless authorized by FAA, the High-Density Rule (HDR) at DCA is limited to 60 IFR slots/operations (arrivals and departures) per hour for specified aircraft classes: 37 Air Carriers; 11 Commuter/Regional Carriers; and 12 Other. In practice, there are 67 operations per hour as there are five slot exemptions and two slot slides per the Secretary of Transportation.

There is no guarantee that additional beyond Perimeter flying will be part of the pending Reauthorization bill. If it is, critical to this compromise is that any proposed changes do not negatively impact other airports—inside or outside the Perimeter—that have nonstop DCA service. Today, 18 of the legislated 20 exemptions to fly beyond DCA’s Perimeter limitation have been awarded to large hub airports. Airports and Metro Areas that have nonstop service today should not get more.

Air-21 and Vision-100 are the laws enabling beyond Perimeter flying at DCA today. Air-21 designated certain slots for inside the Perimeter flying and is the template for this alternative. The FAA Modernization and Reform Act of 2012 specified criteria for DOT to use in granting any beyond-perimeter exemptions. Those criterions were that flights are beneficial for connecting communities beyond the 1,250-mi. perimeter; increase airline competition; don’t reduce travel options within the perimeter; and don’t increase travel delays at DCA. This proposal checks these boxes.

Most importantly, this alternative presumes no change to the HDR. Rather it proposes to allocate 10 slot pairs dedicated for nine non-large hub and one new large hub airport. The slot pairs represent less than 10% of the non-commercial slots permitted by the HDR. This is in complete contrast to Delta’s proposition, and it would increase competition too.

The theme of this FAA Reauthorization year is improving the customer experience. If Congress allows more beyond Perimeter service at DCA, designating underused non-commercial slots to fly 10 unserved points would improve the customer experience for myriads of new customers. Other proposals are a win for airlines—not consumers. 

This is 2023’s best air service enhancement and customer focused idea.

William Swelbar is the chief industry analyst at The Swelbar-Zhong Consultancy specializing in commercial air transport economics. These opinions are his alone.