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entitled 'Airline Deregulation: Reregulating the Airline Industry Would 
Likely Reverse Consumer Benefits and Not Save Airline Pensions' which 
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Report to Congressional Committees: 

United States Government Accountability Office: 

GAO: 

June 2006: 

AIRLINE DEREGULATION: 

Reregulating the Airline Industry Would Likely Reverse Consumer 
Benefits and Not Save Airline Pensions: 

Airline Deregulation: 

GAO-06-630: 

GAO Highlights: 

Highlights of GAO-06-630, a report to congressional committees. 

Why GAO Did This Study: 

The Airline Deregulation Act of 1978 phased out the government’s 
control over fares and service and allowed market forces to determine 
the price and level of domestic airline service in the United States. 
The intent was to increase competition and thereby lead to lower fares 
and improved service. In 2005, GAO reported on the tenuous finances of 
some airlines that have led to bankruptcy and pension terminations, in 
particular among those airlines that predated deregulation (referred to 
as legacy airlines). The House Report accompanying the 2006 Department 
of Transportation (DOT) Appropriation Act expressed concern about 
airline pension defaults and charged GAO with analyzing the impact of 
reregulating the airline industry on reducing potential pension 
defaults by airlines. GAO subsequently agreed to address the pension 
issue within a broad assessment of the airline industry since 
deregulation. Specifically, GAO is reporting on, among other things, 
(1) broad airline industry changes since deregulation, (2) fare and 
service changes since deregulation, and (3) whether there is evidence 
that reregulation of entry and fares would benefit consumers or the 
airline industry, or save airline pensions. 

DOT agreed with the conclusions in this report. GAO is making no 
recommendations in this report. 

What GAO Found: 

The airline industry has undergone significant change since the late 
1970s. Industry capacity and passenger traffic have tripled. At the 
same time, the industry’s profitability has become more cyclical, and 
the financial health of large legacy airlines has become more 
precarious. Legacy airlines emerged from a regulated environment with 
relatively high structural costs, driven in part by labor costs, 
including defined benefit pension plan costs. Over the last few years, 
facing intense cost pressures from growing low-cost airlines like 
Southwest, both United and US Airways entered bankruptcy, voided labor 
contracts, and terminated their pension plans costing the Pension 
Benefit Guaranty Corporation, the federal government insurer of defined 
benefit plans, $10 billion and beneficiaries more than $5 billion. In 
2005, two other legacy airlines entered bankruptcy leaving their 
pension plans in doubt. Only two airlines still have active defined 
benefit pension plans. 

Airfares have fallen in real terms over time while service—as measured 
by industry connectivity and competitiveness—has improved slightly. 
Overall, the median fare has declined almost 40 percent since 1980 as 
measured in 2005 dollars (see fig. below). However, fares in shorter-
distance and less-traveled markets have not fallen as much as fares in 
long-distance and heavily trafficked markets. Since 1980, markets have 
generally become more competitive; with the average number of 
competitors increasing from 2.2 per market in 1980 to 3.5 in 2005. 

Figure: Median Fare, 1980-2005: 

[See PDF for Image] 

[End of Section] 

The evidence suggests that reregulation of airline entry and fares 
would likely reverse much of the benefits that consumers have gained 
and would not save airline pensions. The change in fares and service 
since deregulation provides evidence that the vast majority of 
consumers have benefited, though not all to the same degree. Although a 
number of airlines have failed and some have terminated their pension 
plans, those changes resulted from the entry of more efficient 
competitors, poor business decisions, and inadequate pension funding 
rules. GAO has previously recommended that broad pension reform is 
needed. 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-630]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact JayEtta Z. Hecker at 
(202) 512-2834 or heckerj@gao.gov. 

[End of Section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Airline Deregulation Was Originally Intended to Encourage Competition, 
Thereby Lowering Fares and Improving Service: 

The Airline Industry Has Undergone Significant Change since 
Deregulation: 

Real Fares Have Declined and Service Has Expanded since 1980: 

Evidence Suggests That Reregulation of Airline Entry and Rates Would 
Reverse Consumer Benefits and Not Save Airline Pensions: 

Agency Comments: 

Appendix I: Scope and Methodology: 

Appendix II: GAO Contact and Staff Acknowledgments: 

Figures: 

Figure 1: Western Airlines (1962) and Eastern Airlines (1948) Route 
Map: 

Figure 2: Air Travel Capacity and Consumption, ASM and RPM growth 1968- 
2005: 

Figure 3: U.S. Airline Operating Revenue, Expenses, and Profits, 1968- 
2005: 

Figure 4: Airline Salaries and Benefits per Employee, 1968-2004: 

Figure 5: Airline Employee Compensation as a Share of Total Operating 
Expenses, 1968-2005: 

Figure 6: Airline Industry Employment and Capacity (ASM) Per Employee, 
1977-2005: 

Figure 7: Median Round-Trip Fare, 1980-2005: 

Figure 8: Round-Trip Median Fares, 1980-2005: 

Figure 9: Mean Fares by Market Size, 1980-2005: 

Figure 10: Dispersion of Yields within Routes (Coefficient of 
Variation), 1980-2005: 

Figure 11: Real Yield Trends, 1950-2004: 

Figure 12: Average Number of Effective Competitors, 1980-2005: 

Figure 13: Percentage of Markets by Number of Effective Competitors, 
1980-2005: 

Figure 14: Average Number of Effective Competitors by Distance 
Traveled, 1980-2005: 

Figure 15: Percentage of Airline City-Pair Markets with 80 Percent of 
Passengers, 1980-2005: 

Figure 16: Number of City-Pair Markets with at Least 130 Passengers per 
Quarter, 1980-2005: 

Figure 17: Percentage of Markets and the Minimum Number of Connections, 
1980-2005: 

Figure 18: Flight Distance Ratio, 1980-2005: 

Abbreviations: 

ASM: available seat miles: 
CAB: Civil Aeronautics Board: 
DOT: Department of Transportation: 
DPFI: Domestic Passenger Fare Investigation: 
EAS: Essential Air Service: 
EPP: Employee Protection Program: 
FAA: Federal Aviation Administration: 
FTE: full-time equivalent: 
PBGC: Pension Benefit Guaranty Corporation: 
RPM: revenue passenger miles: 
SIFL: Standard Industry Fare Level: 

United States Government Accountability Office: 

Washington, DC 20548: 

June 9, 2006: 

The Honorable Jerry Lewis: 
Chairman: 
The Honorable David R. Obey: 
Ranking Minority Member: 
Committee on Appropriations: 
United States House of Representatives: 

The Honorable Thad Cochran: 
Chairman: 
The Honorable Robert C. Byrd: 
Ranking Minority Member: 
Committee on Appropriations: 
United States Senate: 

In 1978, Congress deregulated the airline industry. The Airline 
Deregulation Act of 1978 phased out the government's control over fares 
and service and allowed market forces to determine the price and level 
of domestic airline service in the United States. We have previously 
reported that overall fares have declined and service has increased 
since deregulation, but that these benefits have not been evenly 
distributed throughout all markets. More recently, we reported on the 
tenuous finances of some airlines that have led to bankruptcy and 
pension terminations,[Footnote 1] in particular among those airlines 
whose operations predated deregulation, referred to as legacy airlines. 
Critics of deregulation, including some academics and some in Congress, 
have pointed to industry instability that has resulted in industry 
layoffs and pension terminations along with declining service and high 
fares for some communities as evidence of negative effects of 
deregulation. 

The House report accompanying the 2006 Department of Transportation 
(DOT) appropriations legislation expressed concern about airline 
pension defaults and charged us with analyzing the impact of 
reregulating the airline industry on reducing potential pension 
defaults by airlines.[Footnote 2] In subsequent discussion with House 
appropriations offices, following our in-depth report on airline 
pensions and bankruptcy, we agreed to more broadly assess the airline 
industry since deregulation. Specifically, we agreed to report on (1) 
the original rationale for deregulating the airline industry in 1978, 
(2) broad airline industry changes since deregulation, (3) fare and 
service changes since deregulation, and (4) whether there is evidence 
that reregulation of airline entry and rates would benefit consumers 
and the airline industry, or save airline pensions. 

To address these objectives, we relied on historical documents, our 
past studies, and our analysis of DOT passenger ticket data. To assess 
the original intent of Congress in passing the Airline Deregulation 
Act, we reviewed the act and accompanying legislative materials and 
various other documents and studies. To evaluate past changes in the 
airline industry, we reviewed our past studies, reviewed DOT studies, 
analyzed financial and operational data, and interviewed industry 
experts. To analyze fare and service changes since deregulation, we 
used the DOT's Origin and Destination Survey, a database containing 
information on every tenth airline ticket sold. The survey includes the 
fare paid (including taxes) and itinerary, including flight segments. 
The survey does not provide information on frequency, type of aircraft, 
or operational performance. We excluded tickets with international, 
Hawaiian, or Alaskan destinations or origins so that we could examine 
changes within continental U.S. domestic markets. To simplify the 
analysis, we examined only tickets for flights during the second 
quarter of each year--generally considered neither the busiest nor the 
slowest quarter of the year. We limited our analysis of service 
measures to only those city-pairs with at least thirteen passengers in 
our sample (or about 130 actual flying passengers) in every quarter in 
order to ensure that the changes in service we observed in our sample 
reflected actual flow routes and were not due to sampling or data 
error. Even so, the vast majority of passengers were included in our 
analysis--for example, in 2005, excluding city-pair markets with less 
than 13 passengers per quarter excluded only one percent of passengers. 
In addition, for our analysis of competition in city pairs, to ensure 
the sampling confidence in each competitor airline, we limited our 
analysis to city pairs with at least 118 passengers in the sample (or 
about 1180 actual flying passengers) per quarter. No minimum passenger 
levels were imposed for our analysis of fares. Because the survey does 
not identify the destination airport, to ensure city-pair accuracy, we 
eliminated nonsymmetrical roundtrip tickets. We reviewed our methods 
and results with DOT and academic experts from the Massachusetts 
Institute of Technology's Global Airline Industry Program. To determine 
whether there is sufficient evidence to reregulate the airline 
industry, we considered our findings under the prior questions of this 
report, especially the changes in fares and service since deregulation. 
We also considered the findings of our earlier reports, especially 
those relating to small community air service and defined benefit 
pension terminations and regulation. We performed our work between 
September 2005 and May 2006 in accordance with generally accepted 
government auditing standards. 

Results in Brief: 

Airline deregulation was premised on an expectation that an unregulated 
industry would attract new airlines and increase competition, thereby 
benefiting consumers with lower fares and improved service. The intent 
of Congress was to allow new and existing airlines to enter and serve 
any market they wanted (and provide service at whatever price they 
wanted) in order to boost competition, thereby lowering fares and 
expanding service. The framers of the act recognized that this approach 
could cause some airlines to fail and could lead to some communities 
losing some levels of service. As a result, the act created the 
Essential Air Service (EAS) program which subsidizes air service to 
small communities. The act also established the Employee Protection 
Program (EPP), which was ultimately repealed and never provided any 
assistance, but was intended to provide displaced airline employees 
with compensation and the right to be rehired by airlines before any 
other potential applicants. Even with deregulation, the federal 
government continues to play a role in air commerce in a variety of 
other ways--from the Federal Aviation Administration (FAA), which 
oversees air navigation, safety, and airport investment; to the 
Department of Homeland Security, which oversees passenger security; to 
DOT, which oversees international agreements and has a mandate to 
protect consumers from unfair and deceptive practices in air 
transportation and its sale. 

The airline industry has undergone significant change since the late 
1970s. Passenger traffic and, with it, industry revenues, have 
expanded. However, expenses have grown just as fast and profits have 
become increasingly cyclical. Airlines that predated deregulation, 
called legacy airlines, emerged from regulation with significant 
structural costs, including labor contracts that funded defined benefit 
pension plans. Legacy airlines dominated the industry during the 1980s 
and 1990s because of their size and a variety of business practices 
that made it difficult for new entrant airlines to compete. Industry 
employment, compensation, and efficiency have all grown since 
deregulation. However, with the major industry downturn that began in 
2000, new entrant airlines--unburdened by many of the structural costs 
of legacy airlines--were better able to compete for passengers with low 
fares and have gained market share. By 2003, we found that low-cost 
airlines served 2,304 out of the top 5,000 city-pair domestic markets, 
representing a presence in markets available to almost 85 percent of 
all passengers. In response to sizeable financial losses after 2000, 
both United and US Airways entered bankruptcy and terminated their 
pension plans, costing the Pension Benefit Guaranty Corporation (PBGC) 
nearly $10 billion and beneficiaries more than $5 billion. In 2005, two 
other legacy airlines entered bankruptcy, leaving their pension plans 
in doubt. Only two airlines, American and Continental, still have 
active defined benefit pension plans in place. 

As predicted by the framers of deregulation, airline markets have 
become more competitive and fares have fallen since deregulation. For 
consumers, airfares have fallen in real terms since 1980 while service 
has generally improved. Overall, median fares have declined in real 
terms by nearly 40 percent since 1980. However, fares in shorter- 
distance and less-traveled city-pair markets (e.g., those between 
smaller cities) have not fallen as much as fares in longer-distance and 
heavily-trafficked markets. While the competition brought about by 
deregulation likely played a significant role in bringing down fares, 
the extent to which these changes are directly attributable to 
deregulation as opposed to other factors, such as advances in 
technology or economic factors, is difficult to isolate. Various 
studies have attributed substantial consumer benefits to deregulation, 
but estimating the size of this benefit requires making several 
assumptions about what fares would be if they were still regulated. 
Furthermore, our analysis of airline service indicates that more 
passengers are flying between more city-pair markets, but that, on 
average, passengers are making more connections to reach their 
destinations. Service improvements have not been as evident in smaller 
markets as in larger ones. Since 1980, city-pair markets have generally 
become more competitive even while passenger traffic became more 
concentrated. Longer-distance and more heavily traveled markets in 
particular have become more competitive, with the average number of 
competitors growing from 2.2 per market in 1980 to 3.5 in 2005. Some 
DOT indicators of other aspects of service quality, such as rates of on-
time arrival or lost luggage, suggest that service quality may have 
eroded somewhat over the past few years; however, we did not evaluate 
these measures or other indicators of service quality, such as flight 
frequency, type of aircraft used, or in-flight amenities. 

The evidence suggests that reregulation of airline entry and fares 
would likely reverse much of the benefits that consumers have gained 
and would not save airline pensions. Our analysis of fares and service 
since deregulation provides evidence that consumers have benefited from 
lower fares since the airlines were deregulated. Since deregulation, 
competition has generally increased, traffic has expanded, and fares 
have declined. The primary dislocations that have occurred since 
deregulation--loss of service to some communities and the decline of 
legacy airlines' finances and pensions--are the result of competitive 
market forces. Therefore, attempting to resolve the dislocations that 
have occurred for some small communities or the loss of pension 
benefits for some airline workers by restraining these same forces 
could reverse some of the gains that have accrued. If Congress 
determines that service to small communities is inadequate, then direct 
subsidies--such as the Essential Air Service program provides--might be 
a more efficient solution than reregulating the industry and 
diminishing the benefits gained by a majority of consumers. The 
financial distress of some legacy airlines, while regrettable 
(especially for airline employees), was not unanticipated, and is 
evidence of a functioning market in which lower-cost airlines have 
emerged, generally benefiting consumers with lower fares. These 
financial problems also caused several legacy airlines to freeze or 
terminate their defined benefit pension plans, leaving only two 
airlines with active plans. The airlines' pension problems are no 
different from the pension problems occurring throughout the economy 
and, as we previously reported,[Footnote 3] can be traced to broad 
economic factors, poor management decisions, and inadequate pension 
regulation. Therefore, broad pension reform that is comprehensive in 
scope and balanced in effect, such as we previously recommended, would 
more logically address problems with airline pensions than more 
sweeping airline industry regulation, which could undo the benefits 
that deregulation has achieved. DOT generally agreed with this report's 
facts and conclusions, but did not provide written comments. DOT 
provided technical comments and suggestions that we incorporated as 
appropriate. 

Background: 

Industrywide regulation of the U.S. airline industry began in 1938 in 
response to congressional concern over safety, airlines' financial 
health, and perceived inequities between airlines and other regulated 
forms of transportation. The Civil Aeronautics Act of 1938 (P.L. 706) 
applied to interstate operations of U.S. airlines and gave the Civil 
Aeronautics Authority, redesignated as the Civil Aeronautics Board 
(CAB) in 1940, authority to regulate which airlines operated on each 
route and what fares they could charge. Airlines could not add or 
abandon routes or change fares without CAB approval. 

CAB also limited the number of airlines in the industry. In 1938, the 
interstate U.S. airline industry consisted of 16 "trunk" airlines, but 
this number contracted to 10 by 1974, despite 79 applications from new 
airlines to initiate service. Competition was limited on a route to one 
airline unless the CAB determined that demand was sufficient to support 
an additional airline. Airfares were based on a complex cost-based 
formula used by the CAB, though the exact formulas and process varied 
over the life of the CAB. Generally, though, airlines during this time 
had little incentive to reduce costs, since each was assured a fixed 
rate of return. As a result, the competition that existed among 
airlines was largely based on the quality of service. Airlines operated 
largely a point-to-point system, more similar to railroads than the 
airline networks that we know today. For example, as shown in figure 1, 
the route-maps of Eastern Airlines (1948) and Western Airlines (1962) 
show a system vastly different from today's hub-and-spoke networks. 

Figure 1: Western Airlines (1962) and Eastern Airlines (1948) Route 
Map: 

[See PDF for Image] 

[End of Figure] 

Airlines have traditionally relied on union labor, and labor relations 
have been covered by the Railway Labor Act since 1936. The union 
bargaining structure that developed within the airline industry has 
been highly decentralized and separated by craft (e.g., pilots, 
mechanics, etc.) Before deregulation, unions and airline management 
engaged in carrier-by-carrier bargaining whereby the last contract 
signed by one carrier generally served as the starting point for the 
next airline (known as "pattern bargaining"). During regulation, labor 
relations were generally good because CAB's fare-setting allowed 
airlines to pass increased labor costs on to passengers. Airlines' 
bargaining power was enhanced by the Mutual Aid Pact, a strike 
insurance plan created in 1958, through which a struck airline was 
compensated by nonstruck airlines based on increases in traffic the 
latter received during a strike. The Mutual Aid Pact was eliminated 
with deregulation, thereby enhancing airline labor's power in contract 
negotiations. 

Airline Deregulation Was Originally Intended to Encourage Competition, 
Thereby Lowering Fares and Improving Service: 

The Airline Deregulation Act phased out federal control over airline 
pricing and routes. Airline deregulation was premised on an expectation 
that an unregulated industry would attract entry and increase 
competition among airlines, thereby benefiting consumers with lower 
fares and improved service. The experience of unregulated (i.e., state- 
regulated) intrastate service in Texas and California provided support 
for this expectation. Moreover, prior to deregulation, industry 
analysts--on the basis of conventional economic reasoning--expected 
that opportunities for increased competition would increase the number 
of airlines operating in many markets, thereby lowering fares and 
expanding service. 

The Airline Deregulation Act established specific goals of encouraging 
competition by attracting new entrant airlines and allowing existing 
airlines to expand. According to the act, competition was expected to 
lower fares and expand service, the chief aims of 
deregulation.[Footnote 4] At the same time, Congress recognized that 
deregulation could lead to economic dislocations for some communities 
and workers as service patterns adjusted and airlines entered and 
exited markets and the industry overall. As a result, the EAS program 
and the EPP were established. 

* The EAS program was put into place to guarantee that small 
communities served by commercial airlines before deregulation would 
maintain a minimal level of scheduled air service. DOT currently 
subsidizes commuter airlines to serve approximately 150 rural 
communities across the country that otherwise would not receive any 
scheduled air service. According to DOT, EAS subsidizes 39 communities 
in Alaska and 115 more in the rest of the United States. The EAS budget 
ranged from about $100 million early in the program down to about $25 
million, before rising in recent years to $100 million. In Fiscal Year 
2006, EAS was funded at $109 million. 

* EPP was created, first, to compensate airline workers who lost their 
jobs or received lower pay as a result of bankruptcies or major 
contractions whose major cause was airline deregulation and, second, to 
grant such workers first-hire rights. However, the Department of Labor 
delayed the establishment of regulations to administer these rights, 
Congress did not appropriate funds to compensate displaced employees, 
and airlines fought the requirements in court. On August 7, 1998, the 
statute authorizing the EPP was repealed.[Footnote 5] No compensation 
was ever provided to displaced employees, and the first-hire right was 
never enforced. 

While the practice of setting of airline entry and rates was 
deregulated, the federal government is still involved in many facets of 
the airline industry, including many aspects that affect the economics 
of the industry. For example, the federal government still influences 
financing and investment decisions affecting the nation's aviation 
infrastructure, including airports and air navigation systems. In 
addition to the various taxes and user fees on commercial airline 
tickets, which averaged 15.5 percent of the base fare in 2002, the 
federal government also provides support from its general fund for FAA 
operations.[Footnote 6] In 2007, the Airport and Airways Trust Fund, 
which finances the nation's aviation infrastructure, will be up for 
renewal. The federal government also provided commercial airlines with 
$7.4 billion in financial assistance and $1.6 billion in loan 
guarantees for six airlines as a result of the September 11, 2001, 
terrorist attacks. Finally, PBGC has assumed almost $12 billion in net 
airline pension obligations since 1991.[Footnote 7] 

The Airline Industry Has Undergone Significant Change since 
Deregulation: 

The airline industry has undergone significant change since the late 
1970s. Air travel, and along with it industry revenues and expenses, 
have tripled since 1978. However, industry profits have become 
increasingly cyclic, with the most recent downturn leading to almost 
$28 billion in operating losses since 2001. Airline employee 
compensation grew following deregulation, even though many studies have 
found that employees earned a premium under regulation. Nevertheless, 
employee compensation as a share of total expenses has declined, 
especially in recent years. During regulation, airlines operated almost 
as regulated monopolies, encountering little competition and facing 
little pressure to restrain costs because fares were based on the 
airlines' costs plus a fixed rate of return. Following deregulation, 
legacy airlines were able to stave off new entrant competition through 
various operating barriers, such as FAA-imposed take-off and landing 
times at congested airports (slot controls), perimeter rules at 
Washington Reagan National Airport, and airlines' exclusive-use control 
of gate leases; and business practices, such as frequent flyer programs 
and ticket distribution systems. The market downturn that began in 2000 
exposed legacy airlines' precarious financial condition, allowing low- 
cost airlines the opportunity to compete more aggressively. Owing to 
financial instability since deregulation, airlines operating in 
bankruptcy have become more common, but we found that bankruptcy 
protection has not adversely affected nonbankrupt airlines. More 
troubling has been the use of bankruptcy to terminate defined-benefit 
pension plans, costing the PBGC and airline employees billions of 
dollars. Only two airlines still offer defined benefit pension plans. 

The U.S. Airline Industry Has Expanded since Deregulation: 

The U.S. airline industry has expanded threefold since deregulation. 
Figure 2 shows that the consumption of airline travel as measured by 
revenue passenger miles (RPM) grew from 188 billion RPMs in 1978 to 584 
billion RPMs in 2005, while airline capacity grew at a similar pace-- 
from 306 billion available seat miles (ASM) in 1978 to 758 billion ASMs 
in 2005. Over the same period, revenue passenger enplanements[Footnote 
8] increased from 254 million in 1978 to 670 million in 2005. 

Figure 2: Air Travel Capacity and Consumption, ASM and RPM growth 1968- 
2005: 

[See PDF for Image] 

Note: U.S. domestic airlines, excluding cargo. 

[End of Figure] 

Owing to the growth of air travel, U.S. airlines' revenues grew almost 
fourfold in real terms (see fig. 3). However, expenses also grew at a 
similar pace, sometimes outpacing industry revenues. While profits were 
relatively stable under regulation, earnings have been increasingly 
cyclical since deregulation. One explanation for this cyclicality is 
that, with revenues closely tied to the business cycle, high fixed 
costs for aircraft, and a rigid and costly labor structure, outside 
shocks--such as the September 11, 2001, attacks or high fuel prices-- 
make it difficult for the industry to adjust its capacity. The industry 
has incurred operating losses of nearly $28 billion since 2001, most of 
this by legacy airlines.[Footnote 9] These airlines have compensated by 
taking on additional debt, using all (or nearly all) of their assets as 
collateral and limiting future access to capital. 

Figure 3: U.S. Airline Operating Revenue, Expenses, and Profits, 1968- 
2005: 

[See PDF for Image] 

Note: U.S. domestic airlines, excluding cargo. 

[End of Figure] 

Airline Salaries, Compensation, and Efficiency Have Grown since 
Deregulation: 

There have been significant changes to airline employee compensation, 
employment, and productivity since deregulation. Prior to deregulation, 
labor was highly unionized and wage demands were typically met. 
Regulation allowed for increases in labor costs to be passed on to 
consumers through the regulated fare system. Several studies have 
estimated that airline wages were greater under regulation than they 
would have been in a competitive deregulated market.[Footnote 10] Even 
so, industry growth, barriers to entry, and union bargaining strength 
allowed labor to protect its compensation following deregulation. Since 
1978, airline industry salaries and total compensation experienced real 
increases, though with some decline since 2002 (see fig. 4). Inflation- 
adjusted benefits per employee grew on average from $14,703 in 1979 to 
$24,852 in 2004, a real increase of almost 70 percent. Meanwhile, 
inflation-adjusted salaries per employee grew from $52,295 in 1979 to 
$54,848 in 2004 on average, a real increase of less than 5 percent. 
Despite this increase in compensation costs, employee compensation as a 
share of total operating costs has declined since deregulation, 
especially since 2002 (see fig. 5). This decline in compensation costs 
as a share of total operating expense is attributable to falling 
employment levels, to large increases in capacity, and increases in 
other costs (especially for fuel). Employment began to decline with the 
industry downturn that began in 2000. As a result, measures of overall 
industry efficiency (as illustrated by available seat miles per 
employee in fig. 6) increased significantly. This is attributable to 
efficiency gains by legacy airlines during and under the threat of 
bankruptcy, and to more efficient low-cost carriers providing more 
capacity than previously. 

Figure 4: Airline Salaries and Benefits per Employee, 1968-2004: 

[See PDF for Image] 

Note: U.S. Domestic airlines, excluding cargo. 

[End of Figure] 

Figure 5: Airline Employee Compensation as a Share of Total Operating 
Expenses, 1968-2005: 

[See PDF for Image] 

Note: U.S. Domestic airlines, excluding cargo. 

[End of Figure] 

Figure 6: Airline Industry Employment and Capacity (ASM) Per Employee, 
1977-2005: 

[See PDF for Image] 

Note: Domestic airlines, excluding cargo. The total for full-time 
equivalencies (FTE) are the sum of all full-time employees and one-half 
of all part-time employees. 

[End of Figure] 

Legacy Airlines Remained Dominant until 2000, When Low-Cost Airlines 
Increased Market Share: 

Following deregulation, legacy airlines were considerably larger and 
better financed than the host of small new airlines that entered the 
market place. Most of the new entrant airlines during the 1980s and 
1990s failed. Large legacy airlines were generally able to retain 
market share despite new entrant airlines because of operating 
barriers--such as slot controls--and business practices--such as 
frequent flyer programs--that gave them competitive advantages. Larger 
and better-capitalized legacy airlines seeking to increase market share 
acquired weaker airlines--for example, American Airlines' acquisition 
of Reno Air. Legacy airlines built up their hub-and-spoke networks, 
which allowed them to build their traffic flows and fend off potential 
competitors. We and others reported on the higher fares experienced by 
passengers that had to use these "fortress hubs." Legacy airlines also 
developed regional, national, and international code-sharing 
arrangements to extend their networks and compete for domestic and 
international passenger traffic. During the 1990s, we repeatedly 
reported on these and other barriers to entry that limited competition 
in the U.S. airline industry.[Footnote 11] 

Since the industry downturn that began in 2000, there has been a shift 
in the airline industry: a weakening of the financial condition of 
legacy airlines and an increasing market share for low-cost carriers. 
The consequences of an overburdened cost structure for legacy airlines 
became apparent after 2000 when demand fell, especially demand from 
premium-fare business travelers. Low-cost airlines, which generally did 
not have these cost structures, have been able to increase their market 
share, while legacy airlines have struggled to bring their costs down. 
As we reported in 2004, low-cost airlines increased their presence in 
the top 5,000 domestic city-pair markets by 44.5 percent; from 1,594 
markets in 1998 to 2,304 markets in 2003.[Footnote 12] In 1998, low- 
cost airlines operated in 31.5 percent of markets served by legacy 
airlines, providing a low-cost airline alternative to 72.5 percent of 
passengers. By 2003, low-cost airlines competed directly with legacy 
airlines in 45.5 percent of markets served by legacy airlines, serving 
84.6 percent of passengers in the top 5,000 markets. While legacy 
airlines began to reduce their operating costs starting in 2001, they 
did so through capacity reductions and were not able to reduce their 
unit costs vis-à-vis low-cost airlines that were adding 
capacity.[Footnote 13] We warned that legacy airlines could not survive 
with continued losses. In 2005, two legacy airlines (Delta and 
Northwest) entered bankruptcy and are currently attempting to 
reorganize. 

Bankruptcy Has Been Used to Terminate Defined Benefit Pension Plans: 

In 2005, we examined the issue of airline bankruptcy and, in 
particular, how some airlines were using bankruptcy to terminate their 
defined benefit pension plans. We found that bankruptcy has been 
endemic to the airline industry since deregulation, with 162 bankruptcy 
filings since 1978, owing to the fundamental financial weaknesses of 
the airline industry. Despite the prevalence of bankruptcy, however, we 
found no evidence that bankruptcy harmed the airline industry by 
contributing to overcapacity or by underpricing. Nevertheless, we 
expressed concern about the use of bankruptcy to terminate defined 
benefit pension plans because of the costs to the federal government as 
well as to employees and beneficiaries. USAirways and United, subjected 
to intense cost pressures from growing low-cost airlines like 
Southwest, entered bankruptcy and terminated their labor contracts and 
pension plans. The pension plan terminations cost PBGC nearly $10 
billion and plan participants lost more than $5 billion in promised 
benefits that are not covered by PBGC.[Footnote 14] If Delta and 
Northwest, which entered bankruptcy in 2005, similarly terminate their 
pension plans, the costs to PBGC and plan participants will be even 
greater. At present, only American Airlines and Continental have active 
defined benefit pension plans, while the remaining airline plans are 
either terminated or frozen.[Footnote 15] In total, active and frozen 
airline plans were underfunded by almost $15 billion at the end of 
2005, according to Securities and Exchange Commission filings. 

Real Fares Have Declined and Service Has Expanded since 1980: 

Airfares have fallen in real terms over time, with round-trip median 
fares almost 40 percent lower since 1980.[Footnote 16] However, fares 
in short-distance markets (less than 250 miles) and "thin" markets (the 
bottom 20 percent of passenger traffic) have not fallen as much as 
those for longer distances or in heavily traveled markets. Price 
dispersion--that is, the extent to which passengers in the same city- 
pair market pay different fares--has also declined since 2003, likely 
indicating consumers' unwillingness to pay the very high fares airlines 
were able to charge in the late 1990s. The extent to which these 
benefits are attributable to deregulation as opposed to other factors, 
such as advances in technology, is uncertain. Various studies have 
attributed significant consumer benefit to deregulation, but estimating 
this benefit depends on several major assumptions and is not free of 
controversy. The decline in fares coincided with a growth in passenger 
traffic and increased competition over the period. While large 
communities and markets have experienced large gains in the number of 
passengers and service, as well as increased competition, small 
communities and markets have experienced much smaller gains. On 
average, however, the number of competitors in city-pair markets grew 
from 2.2 in 1980 to 3.5 in 2005. 

Real Fares Have Declined, but Declines Have Varied by Market: 

Our analysis of DOT's ticketing data from 1980 to 2005 shows 
substantial decreases in median fares since 1980, with an overall 
decrease of nearly 40 percent for median round-trip fares since that 
time. In addition, our analysis shows a convergence of fares across 
trip distances, although substantial differences in fares by trip 
length and by market size remain. In recent years, passengers flying 
long distances or in medium to large markets have paid much lower fares 
as compared with 1980 fares, while those flying in smaller markets or 
over shorter distances today have seen a smaller reduction in fares as 
compared with 1980 fares. Finally, the difference between the fares 
paid by customers flying within the same routes began to decline in 
2003, after increasing in the years following deregulation. 

Overall, median round-trip fares have declined 38 percent since 1980, 
falling from $414 to $256.[Footnote 17] The largest decreases occurred 
in the late 1980s, but the overall trends have continued down in 
subsequent years.[Footnote 18] Figure 7 provides information about 
median round-trip fares. 

Figure 7: Median Round-Trip Fare, 1980-2005: 

[See PDF for Image] 

[End of Figure] 

Median fares have converged when compared by the distance traveled 
since deregulation. In 1980, median fares ranged from $680 for trips 
longer than 1,500 miles to $230 for trips of 250 miles or less-- 
reflecting the pricing structure in place under regulation, which 
linked fares to costs while subsidizing shorter routes.[Footnote 19] 
Since that time, however, fares have converged toward the low end of 
this range, with the longest trips now averaging just $326, a drop of 
52 percent. Median fares for the shortest trips, in contrast, have not 
fallen as much. For trips of 250 miles or less, median fares have 
fallen 13 percent to $201. Figure 8 provides information about median 
fares by distance categories. 

Figure 8: Round-Trip Median Fares, 1980-2005: 

[See PDF for Image] 

[End of Figure] 

The size of the market has also affected how fares have changed since 
deregulation.[Footnote 20] The smallest markets continue to have the 
highest average fares, and have seen the smallest reduction in these 
fares (see fig. 9). In 1980, passengers flying in the smallest markets 
paid $412 on average for their tickets, while those flying in the 
largest markets paid $329. By 2005 average fares in the smallest 
markets had fallen 16 percent to $348, while passengers in the other 
markets we analyzed saw their fares fall 26 percent or more on average. 
Examples of city pairs in the smallest-market category in both 1980 and 
2005 include the Atlanta, Georgia-Joplin, Missouri route; and the Great 
Falls, Montana-Sacramento, California route. In contrast, the Boston, 
Massachusetts-New York, New York route; and the Chicago, Illinois-Los 
Angeles, California route, were in the largest-market category in both 
1980 and 2005. 

Figure 9: Mean Fares by Market Size, 1980-2005: 

[See PDF for Image] 

[End of Figure] 

While median fares trended down steadily after deregulation, the 
differences in the prices paid by individual customers in the same city-
pair market grew, most notably in the 1990s with the increased use of 
yield-management systems by airlines.[Footnote 21] The dispersion of 
fares began to decline in 2003, however, when changes in the overall 
economy and a decline in the willingness of some passengers to pay 
higher fares for premium service--notably business passengers--likely 
combined with the increased use of the Internet for ticket purchases to 
reverse some of the prior increases in ticketing variation. Since then, 
the variability of fares has decreased, meaning that fares for most 
tickets sold are now generally more similar to average fares.[Footnote 
22] Figure 10 illustrates the coefficient of variation, or dispersion, 
of round-trip yields.[Footnote 23] 

Figure 10: Dispersion of Yields within Routes (Coefficient of 
Variation), 1980-2005: 

[See PDF for Image] 

Note: The coefficient of variation is the standard deviation divided by 
the mean. 

[End of Figure] 

Studies Have Found Fare Reductions but Vary in the Degree to Which They 
Credit Deregulation: 

Many studies have estimated that consumers have benefited from 
deregulation. Assessments of these benefits, however, vary 
substantially as have the methodologies used. One approach is to 
calculate the difference between actual fares and a benchmark proxy 
measure of what fares might have been had the industry remained 
regulated. Any differences are then attributed to the effects of 
deregulation. Some studies using this approach have used the Standard 
Industry Fare Level (SIFL) to approximate the regulated fare and 
concluded that consumers as a whole have benefited from lower fares 
resulting from deregulation.[Footnote 24] For example, in 2005 Rose and 
Borenstein compared postderegulation fares to the SIFL and estimated 
that 2004 fares were about 30 percent lower than what the comparative 
regulated fares would have been, resulting in a $5 billion savings to 
passengers that year.[Footnote 25] Likewise, Winston and Morrison used 
the same proxy in 1995 and estimated that real fares declined about 33 
percent from 1976 to 1993. After adjusting the SIFL data to account for 
presumed productivity gains and increased load factors,[Footnote 26] 
they estimated that, on average, deregulation led to fares 22 percent 
lower than they would have been in a regulated environment, resulting 
in an annual savings of about $12.4 billion in 1993 dollars over the 
same period.[Footnote 27] While pointing to declines in overall fares, 
these studies also indicated that benefits have been unevenly 
distributed by market size and route length. In fact, those traveling 
on heavily traveled routes are likely to be paying less than they would 
have paid under a regulated system, and those flying on shorter- 
distance routes are likely to be paying more. 

Some experts have questioned the extent to which deregulation can be 
credited for decreases in airfares since 1978, and draw attention to 
the difficulty in measuring impact. First, a former CAB and DOT 
official, who participated in CAB route awards and fare determinations 
and later calculated the SIFL for DOT, points out that the fare 
ceilings used by CAB under regulation--calculated as the Domestic 
Passenger Fare Investigation (DPFI)--were more complicated than their 
proxies. Rose and Borenstein also acknowledged that using the SIFL as a 
proxy for the CAB regulated fare may be increasingly implausible, given 
that it is unlikely that the same cost assumptions would have been used 
for the 27 years following deregulation. As a result, using the SIFL to 
approximate airline fares under regulation may overestimate the savings 
resulting from deregulation. For example, while the DPFI fare 
calculations took several factors into account, including depreciation 
and capacity, the SIFL calculations primarily consider airline 
costs.[Footnote 28] The former DOT official further noted that the DPFI 
calculations allowed for discounted fares if load factors were 
increased to offset the fare reduction, something not reflected by the 
SIFL fare. Second, some experts have pointed out that fares were 
already declining before deregulation, thus making it difficult to 
attribute changes in the industry to deregulation rather than 
improvements in productivity and other factors.[Footnote 29] In fact, 
real average fares paid per mile (yields) since 1962 do show a steady 
decline, reflecting both CAB fare setting flexibility and cost-savings 
following the introduction of jet service in the early 1960s, but 
without a sharp break in 1978 following the deregulation of the 
industry (see fig. 11). 

Figure 11: Real Yield Trends, 1950-2004: 

[See PDF for Image] 

[End of Figure] 

Airline Traffic Has Grown and Markets Are More Competitive, Though to a 
Lesser Degree in Small Markets: 

As predicted by deregulation, airline city-pair markets have become 
more competitive since deregulation. As shown in figure 12, the average 
number of effective competitors (any airline that carries at least 5 
percent of the traffic in that market) in any city pair increased from 
2.2 in 1980 to 3.5 in 2005.[Footnote 30] By 2005, 76 percent of the 
city-pair markets we analyzed had three or more carriers compared with 
34 percent of all city-pair markets in 1980 (see fig. 13). By contrast, 
the percentage of city-pair markets with only one carrier decreased 
from 20 percent in 1980 to 5 percent in 2005. As these two figures 
show, most of the increase in competition occurred during the 1980s, 
just after deregulation. 

Figure 12: Average Number of Effective Competitors, 1980-2005: 

[See PDF for Image] 

Note: Because of statistical sampling issues, we only analyzed 
competition in city pairs with at least 118 passengers in our sample in 
any given quarter. This equates to about 1,180 actual flying passengers 
per quarter. 

[End of Figure] 

Figure 13: Percentage of Markets by Number of Effective Competitors, 
1980-2005: 

[See PDF for Image] 

Note: Because of statistical sampling issues, we only analyzed 
competition in city pairs with at least 118 passengers in our sample in 
any given quarter. This equates to about 1,180 actual flying passengers 
per quarter. 

[End of Figure] 

Longer-distance markets are more competitive than shorter-distance 
markets, some of which have lost competitors since 1980. While city 
pairs with a distance of over 1,500 miles have seen an increase in the 
average number of carriers from 2.3 in 1980 to 4.2 in 2005, markets 
shorter than 250 miles have seen a decrease from 1.6 in 1980 to 1.4 in 
2005 (see fig. 14). This difference exists in large part because longer-
distance markets have more viable options for connecting over more 
hubs. For example, a passenger on a long-haul flight from Harrisburg, 
Pennsylvania, to Seattle, Washington (a distance of over 2,000 miles), 
would have options of connecting through six different hubs, including 
Cincinnati, Chicago, and Detroit. By comparison, a passenger from 
Harrisburg to Rochester, New York (a distance of just over 200 miles), 
has three viable connecting options. 

Figure 14: Average Number of Effective Competitors by Distance 
Traveled, 1980-2005: 

[See PDF for Image] 

Note: Because of statistical sampling issues, we only analyzed 
competition in city pairs with at least 118 passengers in our sample in 
any given quarter. This equates to about 1,180 actual flying passengers 
per quarter. 

[End of Figure] 

Passenger Traffic Is More Concentrated despite Growth in the Number of 
City Pairs since 1980: 

Passenger traffic, already concentrated in relatively few city-pair 
markets in 1980, has become more concentrated. In 1980, 80 percent of 
passenger traffic occurred in the largest 14.1 percent of all city-pair 
markets, but by 2005, that same percentage of traffic occurred in the 
largest 10.7 percent of all city-pair markets (see fig. 15). While 
large markets have seen substantial gains in traffic, smaller markets 
have not, and in many cases have actually seen declines in traffic 
since deregulation. For example, while the number of passengers flying 
between Washington, D.C., and Los Angeles grew 327 percent between 1980 
and 2005 in our sample, the number traveling between Boston and Cedar 
Rapids, Iowa, decreased 49 percent. 

Figure 15: Percentage of Airline City-Pair Markets with 80 Percent of 
Passengers, 1980-2005: 

[See PDF for Image] 

Note: Because of statistical sampling issues, we only analyzed service 
in city pairs with at least 13 passengers in our sample in any given 
quarter. This equates to about 130 actual flying passengers per 
quarter. 

[End of Figure] 

The number of city-pair markets has increased modestly since 1980. 
Largely owing to an overall growth in traffic, the number of city pairs 
with at least 13 passengers in the sample per quarter (which equates to 
about 130 actual passengers per quarter) increased by over 3,800 city- 
pair markets between 1980 and 2005, from about 8,500 to over 12,300 
(see fig. 16).[Footnote 31] However, few cities have gained air service 
since deregulation because the airport system was already largely 
developed at the time of deregulation, so the number of cities that 
could be connected would not be expected to have changed much since 
deregulation. Instead, many city-pair markets that could be connected 
did not have enough actual passengers reflected in the sample data to 
be counted.[Footnote 32] 

Figure 16: Number of City-Pair Markets with at Least 130 Passengers per 
Quarter, 1980-2005: 

[See PDF for Image] 

Notes: 

(1) Our analysis includes only one-way tickets with a maximum of three 
coupons and round-trip tickets with two, four, or six coupons. A coupon 
is issued for each segment of an itinerary so that a passenger 
connecting once on a one-way flight is issued two coupons. 

(2) Because of statistical sampling issues, we only analyzed service in 
city pairs with at least 13 passengers in our sample in any given 
quarter. This equates to about 130 actual flying passengers per 
quarter. 

[End of Figure] 

Smaller Communities Have Not Experienced Comparable Benefits since 
Deregulation: 

Smaller communities, in general, have not experienced the same 
increases in traffic and air service as larger cities since 
deregulation--particularly in recent years, when many small cities lost 
service or experienced a decline in the number of departures. For 
example, we reported in 2005 that while large, medium, and small-hub 
airports have seen traffic rebound since September 11, 2001, nonhub 
airports had 17 percent fewer flights in July 2005 than in July 
2000.[Footnote 33] Additionally, we reported in 2002 that traffic at 
EAS communities decreased 20 percent from 1995 to 2002. However, lack 
of service for small communities is not solely a problem of the 
deregulated era. We reported in 1985 that in the 10 years leading up to 
deregulation, 137 small communities lost all commercial air service. 

The primary reason for diminished service to smaller communities is the 
lack of a population base to support that service. Local air traffic is 
directly related to both local population and employment. For small 
communities located close to larger cities, these demand reductions are 
exacerbated because local passengers drive to airports in larger cities 
to access better service and lower fares. We reported in 2002 that some 
EAS airports serve only about 10 percent of the intercity traffic to 
and from their city because many travelers instead drive to alternative 
airports or to their destination. Small communities have not benefited 
from the service of low-cost carriers; as we reported in 2005 only 5 of 
over 500 nonhub airports received low-cost carrier service. Lack of 
service from low-cost airlines can partially explain why small cities 
also face relatively higher fares than larger cities do. 

Similarly, longer-distance markets have seen greater gains in traffic 
than shorter-distance markets. Passengers on routes of 1,500 (or more) 
miles increased 312 percent between 1980 and 2005, while passengers on 
routes between 250 and 499 miles grew 68 percent in our sample. For 
example, while traffic between Dallas-Fort Worth, Texas, and Hartford, 
Connecticut--a distance of 1,470 miles--grew 477 percent between 1980 
and 2005, traffic between New York and Raleigh-Durham, North Carolina-
-a distance of 427 miles--fell 19 percent in our sample. Short-distance 
markets lost a large share of their passengers after September 11, 
2001, in part because the increased time required for security measures 
makes driving a more viable alternative. The frequency of short-haul 
flights has also decreased. DOT found that the number of scheduled 
flights under 250 miles decreased 26 percent between July 2000 and July 
2005, while the number of flights of over 1,000 miles increased by 15 
percent during that time[Footnote 34].: 

The Average Number of Connections per City-Pair Market Has Increased 
Since Deregulation: 

Our analysis indicates that the average number of connections needed, 
at a minimum, to connect any two cities has increased since 1980. 
Figure 17 shows the percentage of all city-pair markets in our sample 
with at least 13 passengers per quarter (or 130 actual passengers) that 
can be connected nonstop, with one connection, or with two 
connections.[Footnote 35] Very few city-pair markets currently require 
two connections. The average number of connections needed to connect 
any two city-pair markets increased from 1.6 in 1980 to 1.7 in 2005, 
which is likely attributable to the development of hub-and-spoke 
networks to connect airline traffic. For some passengers this 
development has increased the number of connections needed. For 
example, in 1980, passengers traveling between Philadelphia, 
Pennsylvania, and Tulsa, Oklahoma, could fly nonstop, but by 2005 one 
connection was required. While there may have been declines in nonstop 
connectivity for many small city-pair markets, the overall ability of 
passengers to connect to wider markets through hubs has likely 
improved. The shift from shorter-range turboprop planes to longer-range 
regional jets has allowed cities that are too small to support mainline 
jet service, but too far from hubs for turboprop service, to be 
connected to hubs, increasing the number of one-connection city-pair 
opportunities.[Footnote 36] 

Figure 17: Percentage of Markets and the Minimum Number of Connections, 
1980-2005: 

[See PDF for Image] 

Note: Because of statistical sampling issues, we only analyzed service 
in city pairs with at least 13 passengers in our sample in any given 
quarter. This equates to about 130 actual flying passengers. 

[End of Figure] 

The largest markets are generally served by nonstop service. In 2005, 
88 percent of passengers traveled in city-pair markets that included 
nonstop service and less than 1 percent of passengers traveled in city- 
pair markets that required two connections.[Footnote 37] However, 
because many passengers in directly connected markets may choose to fly 
with a connection (e.g., in exchange for a lower fare), the actual 
number of passengers flying without a connection is lower. For example, 
while passengers flying between Seattle and Tampa, Florida, could fly 
nonstop in 2005 (and were able to in 1980), they could also choose to 
connect through a number of hubs, including Chicago, Atlanta, and 
Denver, Colorado, for a number of reasons. Our data do not distinguish 
between passengers who flew with one or two connections out of 
necessity (e.g., because of no better option in their market) or 
voluntarily when a direct flight was available. Additionally, the 
development of hubs has helped bring about increases in flight 
frequencies, allowing some passengers taking connecting flights to 
benefit from better flight times and reduced connection times. 

As another means of measuring changes to connectivity over time, we 
calculated a flight distance ratio. This ratio, also known as 
"circuity," measures the total miles flown on a trip (adding up the 
distance of all segments of a flight) divided by the distance between 
origin and destination. A nonstop flight would have a ratio of 1, and a 
ticket with at least one stop would have a higher ratio the farther out 
of the way the connections were between origin and destination. Figure 
18 shows that, since 1980, the flight distance ratio has slowly risen. 
Much of this increase is likely due to the increased use of connecting 
flights. 

Figure 18: Flight Distance Ratio, 1980-2005: 

[See PDF for Image] 

[End of Figure] 

By other measures of airline service---not covered by DOT's Origin and 
Destination Survey data such as flight frequencies, flight delays, and 
amenities---service has been mixed. For example, in 1999 we reported 
that medium and large communities had significant improvements in their 
number of departures, nonstop destinations served, and use of jet 
service since deregulation.[Footnote 38] However, by other measures, 
service has deteriorated, especially in recent years as traffic has 
rebounded. For example, DOT has reported that 77.4 percent of flights 
arrived ontime in 2005, compared with 82.1 percent in 2002 and 79.4 
percent in 1990. Additionally, DOT reported that the agency received 
almost 7,000 consumer complaints in 2005, an increase of over 50 
percent from 2003.[Footnote 39] 

Evidence Suggests That Reregulation of Airline Entry and Rates Would 
Reverse Consumer Benefits and Not Save Airline Pensions: 

According to our analysis of the evidence, reregulation of airline 
entry and rates would not benefit consumers and the airline industry. 
Although some aspects of customer service might improve, reregulation 
would likely reverse many of the gains made by consumers, especially 
lower fares. While numerous industries have been deregulated over the 
last 30 years, very few have been reregulated. We found that the few 
instances in which an industry was reregulated stemmed from inadequate 
competition, such as occurred in the cable television industry after it 
was deregulated. Lack of competition has not been the case in the 
airline industry, where competition has been keen. Our analysis of 
fares and service since deregulation provides evidence that consumers 
have benefited over the intervening years. While it is impossible to 
accurately calculate these gains because no regulated system exists 
against which to compare deregulated fares, deregulation has 
corresponded with increased competition in the airline industry, which 
has likely contributed to lower fares and a larger airline market than 
might have prevailed without it. Reregulating the airline industry 
would have ramifications reaching far beyond the fare and service 
effects on airline passengers and communities. For example, the higher 
fares for airline travel that would likely result from reregulating the 
industry could shift some of the nation's 670 million domestic airline 
passengers to other modes of transportation that are neither as safe 
nor efficient as air travel, and considerable infrastructure investment 
would be required to handle the increased demand. 

Restoring service to some small communities is an insufficient reason 
to reregulate airline entry and rates. We previously reported that 
small communities face a range of fundamental economic challenges in 
attracting and retaining commercial air service. Among these challenges 
is the lack of a population base or economic activity that could 
generate sufficient passenger demand to make service profitable to 
airlines. Smaller communities located near larger airports may also 
face reduced demand because they do not have low-cost airlines or 
frequent service. Despite these challenges, smaller city-pair markets 
have generally experienced lower fares since deregulation--just not to 
the degree that the largest city-pair markets have. The smallest city- 
pair markets in our analysis have also experienced a net gain in the 
number of connections and in overall traffic since deregulation. If 
Congress determines that these markets are underserved, it might more 
directly address service to small communities through targeted 
legislation--such as increasing subsidies for EAS--than through 
wholesale reregulation. 

Finally, reregulating the airline industry would not salvage airline 
pensions. Legacy airlines' financial problems are the result of the 
same competitive forces that contributed to lower fares for consumers. 
The demise of airlines since deregulation has been endemic to the 
airline industry, as more efficient airlines have taken market share 
from less efficient airlines. As we found in our 2005 report on airline 
bankruptcies and pension problems, pension losses were attributable to 
market forces, poor airline management and union decisions, and 
inadequate pension funding rules--including insufficient funding 
requirements and the inadequate relationship between premiums paid by 
plan sponsors and PBGC's exposure to financial risk. These factors also 
led to the termination of pensions in other industries with large 
legacy pension costs, such as steel. Increasing fares via government- 
imposed price floors similar to those that existed prior to 1978 would 
be an inefficient means of ensuring that airlines would generate 
sufficient revenues to adequately fund their pension plans, especially 
when most airlines no longer offer defined benefit plans. Congress is 
currently considering changes to defined benefit pension regulation, 
including specific provisions that would grant airlines additional time 
to fund frozen defined benefit plans and thereby avoid plan 
terminations. We have previously recommended that Congress consider 
broad pension reform that is comprehensive in scope and balanced in 
effect. 

Agency Comments: 

We provided a draft of this report to DOT for its review and comment. 
DOT officials provided some clarifying and technical comments that we 
incorporated where appropriate. 

We provided copies of this report to the Secretary of Transportation 
and other interested parties and will make copies available to others 
upon request. In addition, this report will be available at no charge 
on our Web site at [Hyperlink, http://http://www.gao.gov]. 

If you or your staff have any questions on matters discussed in this 
report, please contact me on (202) 512-2834 or at heckerj@gao.gov. 
Contact points for our Offices of Congressional Relations and Public 
Affairs may be found on the last page of this report. Key contributors 
to this report can be found in appendix II. 

Signed by: 

JayEtta Z. Hecker: 
Director, Physical Infrastrucutre: 

[End of section] 

Appendix I: Scope and Methodology: 

To assess the original intent of Congress in passing the Airline 
Deregulation Act, we reviewed the act and accompanying legislative 
materials, and various other documents and studies. To ascertain the 
legislative intent of Congress in deregulating the airline industry, we 
reviewed the act, legislative reports, and floor debates. We also 
reviewed related court cases and studies and historical accounts of 
airline deregulation. 

To evaluate past changes in the airline industry, we reviewed 
Department of Transportation (DOT) studies, our own studies, analyzed 
financial and operational data, and interviewed industry experts. We 
analyzed airline financial and operational data from DOT's Form 41 data 
set. We obtained these data from BACK Aviation Solutions, a private 
contractor that provides online access to U.S. airline financial, 
operational, and passenger data that are reported by airlines to DOT. 
To assess the reliability of these data, we reviewed the quality 
control procedures applied to the data by DOT and BACK Aviation 
Solutions and subsequently determined that the data were sufficiently 
reliable for our purposes. 

To analyze changes to airline fares and service since deregulation, we 
used data from DOT's Origin and Destination Survey. Begun in 1979, the 
Survey captures airline-reported information about the full itinerary 
and fare paid from every tenth ticket to DOT. The survey does not 
include data on flight frequency, aircraft type, flight amenities, or 
other data that could be used to measure airline service. In the fourth 
quarter of 1998 DOT changed the name of the database from DB1A to DB1B 
and began collecting an additional data field to distinguish between 
the carrier that issued the ticket from the carrier that operated the 
flight (e.g., a flight operated by Air Wisconsin as a US Airways 
Express flight, connecting to a US Airways Express flight, connecting 
to a US Airways mainline flight--all issued by US Airways under the 
"US" code). To assess the reliability of these data, we reviewed the 
quality control procedures applied to the data by DOT and subsequently 
determined that the data were sufficiently reliable for our purposes. 

We analyzed these data for the period from 1980 through the second 
quarter of 2005. We did not include 1979 data in our analysis because 
DOT staff reported that these data were not reliable, since many 
airlines had difficulties reporting data in the first full year of 
deregulation. We limited our analysis to data reported for the second 
quarter of every calendar year in order to avoid data reflecting 
increased summer travel or reduced winter travel. Furthermore, we 
limited our analysis to passenger itineraries wholly within the 
continental 48 states; thereby excluding international itineraries and 
any travel to airports in Alaska, Hawaii, and U.S. dependencies. We 
excluded international fares and foreign carriers because international 
markets were not deregulated when domestic markets were. We excluded 
flights to or from Alaska, Hawaii and U.S. territories because of the 
long distances involved. 

In general, we limited our analysis to a subset of round-trips and 
certain one-way trips between city pairs. We defined markets by city 
pairs rather than airport pairs. For cities served by multiple airports 
(e.g., the Dallas area includes both Dallas-Forth Worth International 
Airport and Dallas Love Field), we recoded all airports in the city to 
the one with the most enplanements. Thus, we identified round trips as 
those for which the final city on the ticket was the same as the 
originating city (even if the passenger record indicated, for example, 
that the trip originated at Dallas-Fort Worth and returned to Dallas 
Love Field). One-way trips were those in which no two cities in the 
ticket matched one another. 

We included only round trips involving two, four, or six flight 
segments (coupons). These represent round trip itineraries that have no 
stops, one stop, or two stops in both directions. In counting the 
number of coupons used in each direction of a flight (i.e., outbound or 
return), we relied on the "trip break" codes that DOT assigns. These 
codes indicate the point in a passenger's itinerary at which the 
passenger begins the return trip. Because the data originally reported 
by the airlines do not unambiguously identify the point on a round trip 
at which the passenger begins the journey home, DOT applies an 
arithmetic algorithm that identifies the point in the itinerary 
farthest from the point of origination. However, because DOT's trip 
break codes may incorrectly identify the destination airport, we 
eliminated any tickets that had an unequal number of coupons before and 
after the DOT-assigned trip break. Thus, we eliminated all 3-and 5- 
coupon round trip tickets (e.g., one in which a passenger flies nonstop 
from Boston to Phoenix, Arizona, then to Denver, and back to Boston). 
On the other hand, we included records for roundtrips that had equal 
numbers of outbound and return coupons, but connected over different 
airports on the outbound and return segments (for example, New York to 
Los Angeles connecting in Chicago westbound and in Dallas-Fort Worth 
eastbound). 

We analyzed changes in fares and yields in inflation-adjusted 2005 
dollars, using the chain-weighted price index for gross domestic 
product. To compute the yield for every ticket, we divided the 
inflation-adjusted fare paid by the total distance between origin and 
destination for a one-way ticket or by double the distance between 
origin and destination for a round-trip ticket. We excluded tickets 
with unusually high fares (i.e., those with yields in excess of $3 per 
mile in 2005 dollars), because according to industry researchers, these 
fares are likely to indicate data errors. We retained tickets in the 
analysis when the fare paid was $0, indicating trips "purchased" with 
frequent flyer rewards. 

For our analyses of changes in fares and service, we divided city pairs 
into categories based on distance or passenger density. To determine 
the distance between city pairs, we calculated the distance between 
airports using the latitude and longitude of their locations. We then 
grouped all city pairs into 250-mile or 500-mile increments. We also 
determined the total number of sample passengers in each market. We 
then ranked, for each year, all markets by the number of passengers and 
grouped the markets into quintiles, in which each quintile had an even 
number of passengers.[Footnote 40] Because the number of passengers in 
each market changed from year to year, the specific markets in each 
quintile also changed from year to year. Our analysis of service 
measures was conducted by only counting city-pair markets with at least 
13 passengers per quarter in our sample, which equates to about 130 
actual flying passengers. This was to increase the probability that 
changes in service we observed in our sample reflected actual flow 
routes and was not due to sampling or data error. 

We defined "service" in terms of connectivity and the number of 
competitors in a market. We measured connectivity in two ways: the 
minimum number of flight segments available to connect two cities and 
the extent to which passengers needed to connect over distant hubs to 
reach their destination. We identified the minimum number of 
connections needed to connect any two cities and also determined 
whether that number changed over time. Additionally, because some 
passengers will choose to connect between two cities rather than take 
nonstop flights (e.g., because fares may be cheaper or the schedules 
may be more convenient), we weighted the coupons by passenger traffic 
to establish how most passengers traveled in the city pair. To 
determine whether passengers could fly more or less directly to their 
destinations, we calculated the distance between origin and destination 
along with the distance of every segment on the ticket. We then divided 
the sum of the segment distances by the distance between origin and 
destination (or twice that distance if the flight was a round trip) to 
estimate how far out of the way the travelers went.  

To analyze competition within markets and over time, for every city 
pair, we determined the market share for each reporting carrier, based 
on ticketed passengers, and counted only those carriers with at least 5 
percent of the market as effective competitors. We excluded tickets 
with interlined flights in our analysis of city-pair competition. An 
"interlined flight" is one in which a passenger transfers from one to 
another unaffiliated carrier. That is, the passenger travels on at 
least two different reporting carriers. When analyzing city pairs for 
competition, we only analyzed those city pairs that, in any given 
quarter, had a minimum of 118 passengers in our sample (equaling a 
minimum of 1,180 real passengers in the market). This passenger minimum 
was derived to provide us an acceptably low probability of 
misclassifying carriers as effective competitors, that is, as having a 
5 percent market share. For various scenarios, with this market size 
threshold, the probability of correctly classifying carriers was at 
least 95 percent. 

We recognize that many other dimensions of service quality exist. In 
the past, we have reported changes in service quality in terms of 
available capacity out of particular cities, whether service was 
provided with jets or turboprop aircraft, and how many locations a 
passenger from a given city could reach on a nonstop basis. In 
addition, DOT collects other information on service quality, such as 
the percentage of on-time arrivals and departures and the number of 
consumer complaints about airlines. Because of time constraints on this 
engagement, we were unable to incorporate more of these dimensions in 
our analysis. 

When DOT began requiring the survey data by airlines, Southwest 
Airlines received a waiver that allowed it to report data differently, 
because of its unique ticketing procedures, whereby it issued only one- 
way tickets. Under the waiver, Southwest reported its round trips to 
DOT as two separate trips, which were included in DOT's DB1A or DB1B 
databases. Southwest maintained this waiver until the third quarter of 
1998, when it was required to report ticket data more accurately, 
including both directions of a ticket. During the period covered by the 
waiver, the number of one-way tickets in the sample was unnaturally 
high. Recognizing that the data could be biased as a result, we 
reanalyzed our sample data without the Southwest data and found that 
the results were only marginally different. Median round-trip fares 
since 1999 have been between $17 and $25 lower with the inclusion of 
the Southwest Airlines fares than they would have been without the 
Southwest fares. Therefore, we did not exclude Southwest tickets after 
1999 from our analysis of fares.[Footnote 41] 

To determine whether there is sufficient evidence to support 
reregulating the airline industry, we considered our findings under the 
prior questions and our earlier reports, especially those relating to 
pension regulation. We reviewed and updated the status of airline 
pension plans and assessed examples of deregulation and reregulation in 
other countries and in other industries. In addition, we reviewed our 
prior reports that have evaluated past problems in the airline 
industry, including small community service, barriers to entry, fare 
and service problems, and financial problems, including bankruptcy and 
pension issues. For this and the prior report questions, we reviewed 
our methods and results with DOT and academic experts from the 
Massachusetts Institute of Technology's Global Airline Industry 
Program. 

We performed our work between September 2005 and May 2006 in accordance 
with generally accepted government auditing standards. 

[End of section] 

Appendix II: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

JayEtta Z. Hecker (202) 512-2834 or heckerj@gao.gov: 

Acknowledgments: 

In addition to the contact named above, Steven C. Martin, Assistant 
Director; Paul Aussendorf; Jay Cherlow; David Hooper; Colin Fallon; 
Mitch Karpman; Molly Laster; Sara Ann Moessbauer; and Mathew Rosenberg 
made key contributions to this report. 

FOOTNOTES 

[1] GAO, Commercial Aviation: Bankruptcy and Pension Problems Are 
Symptoms of Underlying Structural Issues, GAO-05-945 (Washington, D.C.: 
Sept. 30, 2005). 

[2] House Report 109-153 accompanying P.L. 109-115, Departments of 
Transportation, Treasury, and Housing and Urban Development, The 
Judiciary, District of Columbia, and Independent Agencies 
Appropriations Act, 2006. 

[3] GAO-05-945. 

[4] Along with the airline industry, Congress deregulated rail, 
trucking, and telecommunications. Overseas, similar efforts to 
deregulate major industries have taken place in the world's major 
market economies. Generally, the intent in each case has been similar-
-to induce competition and thereby lower fares. In only a few cases, 
and in fairly narrow circumstances, has a deregulated industry been 
reregulated. For example, following cable television's deregulation, 
Congress established rate ceilings in cities that lacked sufficient 
competition. 

[5] Section 199(a)(6) of the Workforce Investment Act of 1998, P.L. 105-
220, 112 Stat. 1059. 

[6] GAO, Summary Analysis of Federal Commercial Aviation Taxes and 
Fees, GAO-04-406R (Washington, D.C.: March 12, 2004). 

[7] PBGC was established to encourage the continuation and maintenance 
of voluntary private pension plans and to insure the benefits of 
workers and retirees in defined benefit plans should plan sponsors fail 
to pay benefits. However, if a pension plan's assets are insufficient 
to pay accrued benefits, the plan can be terminated under certain 
conditions, and PBGC then assumes responsibility for paying retiree 
pensions. Airlines have used provisions of chapter 11 of the bankruptcy 
code to terminate labor contracts, including their defined benefit 
pension plans. 

[8] "Enplanement" is defined as one fare-paying passenger--originating 
or connecting--boarding an aircraft with a unique flight coupon. 

[9] Legacy airlines are generally considered to be those that predated 
deregulation, while low-cost airlines generally entered interstate 
service following deregulation. 

[10] For example, David Card estimated that relative wages in the 
airline industry fell 10 percent following deregulation. See 
"Deregulation and Labor Earnings in the Airline Industry" NBER Working 
Paper 5687, July 1996. Pierre-Yves Crémieux estimated that flight 
attendants' earnings were at least 12 percent lower by 1985 and 39 
percent lower by 1992 than if deregulation had not occurred, and that 
the corresponding shortfalls for pilots were 12 percent and 22 percent. 
See "The Effect of Deregulation on Employee Earnings: Pilots, Flight 
Attendants, and Mechanics, 1959-1992" Industrial and Labor Relations 
Review, Vol. 49, No. 2 (January 1996). Hirsch and Macpherson also 
estimated that airline wages decreased markedly during the later 1980s 
and early 1990s, despite continued union bargaining power. See 
"Earnings, Rents, and Competition in the Airline Labor Market" Journal 
of Labor Economics, Vol. 18, No. 1, January 2000, pp. 125-55. 

[11] GAO, Airline Competition: Effects of Airline Market Concentration 
and Barriers to Entry on Airfares, GAO/RCED-91-101 (Washington, D.C.: 
April 26, 1991); Airline Competition: Higher Fares and Less Competition 
Continue at Concentrated Airports, GAO/RCED-93-171 (Washington, D.C.: 
July 15, 1993); Airline Deregulation: Changes in Airfares, Service 
Quality, and Barriers to Entry, GAO/RCED-99-92 (Washington, D.C.: March 
4, 1999). 

[12] In 2003, the top 5,000 city-pair markets accounted for 92 percent 
of domestic passenger traffic. 

[13] GAO, Commercial Airlines: Legacy Airlines Must Further Reduce 
Costs to Restore Profitability, GAO-04-836 (Washington, D.C.: Aug. 11, 
2004). 

[14] PBGC may pay only a portion of the benefits originally promised to 
employees and retirees. For 2006, the maximum statutory limit of annual 
benefits guaranteed by PBGC is $47,659.08, for retirement at age 65. 
The amount paid decreases at earlier retirement ages. 

[15] Aloha, Alaska, Delta, Hawaiian, and Northwest airlines have frozen 
their defined benefit pension plans. Continental Airlines has frozen 
its pilots' plan. Freezing a plan means that no additional benefits 
accrue, but assets and liabilities (and, therefore, the plan's funded 
status) can change. USAirways and United's plans were terminated and 
the remaining assets and benefit obligations were assumed by PBGC. 

[16] We analyzed changes in fares in constant 2005 dollars. 

[17] We are reporting data for round-trip itineraries flown on domestic 
airlines as collected in DOT's Origin and Destination Survey. These 
data do not include information for tickets reported by Southwest 
Airlines before the third quarter of 1998, however. Until that time, 
the airline followed nonstandard reporting procedures and reported all 
itineraries as one-way trips. Thus, round-trip itineraries were 
reported as two separate one-way trips. Generally, median round-trip 
fares since 1999 have been between $17 and $25 lower with the inclusion 
of the Southwest Airlines fares than they would have been without the 
Southwest fares. For more information about the effects of Southwest's 
reporting process, see appendix I. 

[18] Median round-trip fares per mile, or yields, also dropped 
substantially, decreasing over 50 percent in the same time period from 
32 to 15 cents per mile. 

[19] Under regulation, shorter trips were effectively subsidized by 
longer-haul routes, given that CAB set fares relatively lower in short- 
haul markets in the belief that passengers traveling shorter distances 
would not choose air travel if they had to pay the full cost of 
service. 

[20] We divided city-pair markets into five categories based on the 
number of passengers in each with the number of passengers roughly 
equal in each category. In 1980, the quintiles averaged just over 
452,000 passengers, and the smallest quintile accounted for 85 percent 
of the 7,739 markets included in our analysis. By 2005, the categories 
averaged just over 1.1 million passengers, and nearly 90 percent of the 
12,090 markets were in the smallest quintile. 

[21] Yield management (also known as "revenue management" or "real-time 
pricing") is a pricing policy for optimizing profits generated by the 
sale of a product or service by segmenting markets, based on real-time 
modeling and forecasting of demand behavior per market micro-segment. 

[22] The dispersion or variability of fares is measured as the 
coefficient of variation, which is the standard deviation divided by 
the mean. It provides a measure of the difference from the mean--or 
average--fare. We examined the coefficient of variation within routes 
to account for variations in the price per mile paid by customers in 
the same city-pair markets. 

[23] Price per mile, or yield, standardizes revenue by distance, 
allowing for the comparison of fares paid without regard to the length 
of trip. 

[24] SIFL fare data are available at approximately 6-month increments 
from the Office of Aviation Analysis. They are updated to reflect 
changes in airline operating costs per available seat-mile (ASM), and 
are intended to approximate unrestricted coach fares. They are used by 
the Internal Revenue Service to impute the value of free transportation 
provided on corporate aircraft. 

[25] Severin Borenstein and Nancy Rose, "Regulatory Reform in the 
Airline Industry" (paper prepared for the National Bureau of Economic 
Research Conference on Regulation, Sept. 2005). 

[26] Load factor is a measure of the percentage of seats filled. Load 
factor is calculated by dividing RPM by ASM. 

[27] Winston and Morrison adjusted the provided SIFL data by 1.2 
percent, accounting for a 1.45 percent increase in costs from greater 
efficiency through 1983 and a 0.25 percent decrease for higher load 
factors. For more information, see Steven A. Morrison and Clifford 
Winston, The Evolution of the Airline Industry, first edition 
(Washington, D.C.: The Brookings Institution, 1995). 

[28] The DPFI fare calculations took several factors into account 
including revenue, expenses, depreciation, capacity, seating 
arrangement, equipment type, and load factors. They were based on 
reported traffic levels for any fare class accounting for at least 5 
percent of revenue passenger miles. The DPFI fare served as a fare 
ceiling based on a 55-percent load factor and a standard seating 
adjustment. 

[29] See Paul Stephen Dempsey, Flying Blind: The Failure of Airline 
Deregulation. (Washington, D.C.: Economic Policy Institute, 1990). 

[30] Because of statistical sampling issues, we analyzed competition 
only in city pairs with at least 118 passengers in our sample in any 
given quarter. This equates to about 1,180 actual flying passengers. 

[31] In analyzing service measures, we counted only city-pair markets 
with at least 13 passengers per quarter in our sample, which equates to 
about 130 actual flying passengers. This was to increase the 
probability that changes in service we observed in our sample reflected 
actual flow routes and was not due to sampling or data error. In 2005, 
99 percent of passengers in our sample were in those city-pair markets 
with at least 13 passengers in the sample. 


[32] For example, a passenger could fly between the two small EAS 
cities of Crescent City, California, and Presque Isle, Maine, with a 
sufficient number of connections, but it is unlikely that many 
passengers have done so or, if they have, that they would be in the 
sample. 

[33] The FAA classifies airports based on an airport's total 
enplanements as a percentage of the total in the United States in any 
year. Large hubs are those with at least 1 percent of total 
enplanements, medium hubs with between 0.25 percent and 1 percent of 
enplanements, small hubs with between 0.05 percent and 0.25 percent of 
enplanements, and nonhubs as those with less than 0.05 percent of total 
enplanements. 

[34] DOT, Aviation Industry Performance: Trends in Demand and Capacity, 
Aviation System Performance, Airline Finances, and Service to Small 
Airports, CC-2005-057 (Washington, D.C.: June 30, 2005), p. 13. 

[35] Our data counted the number of coupons, or "flight segments," per 
ticket. While a one-coupon trip would not require a passenger to 
connect between two different planes at an intermediate hub, it does 
not necessarily mean that the flight is nonstop. A passenger on a 
flight that makes a stop and then continues with the same flight number 
to a different destination would be considered as having been on a 
nonstop flight. There is no way to determine the number of passengers 
in our data sample that this scenario applies to. 

[36] GAO, Aviation Competition: Regional Jet Service Yet to Reach Many 
Small Communities, GAO-01-344 (Washington, D.C.: Feb. 14, 2001). We 
reported in 2001 on airlines' use of regional jets to provide service 
in new markets that were more distant than previous markets served with 
shorter-range turbuprop service. For example, regional jet service was 
used by American Airlines in 1999 to directly connect Grand Rapids, 
Michigan, to Dallas, Texas, whereas previously American only served 
Grand Rapids with turboprop service to Chicago, Illinois. These new, 
longer, nonstop markets have increased the flight opportunities for 
many communities by connecting them directly with a greater number of 
hub airports. 

[37] City pairs with under 13 passengers per quarter were not included 
in this analysis due to sampling issues. It is likely that many of 
those markets, due to their small size, require at least one 
connection. 

[38] This report defined large communities as those with metropolitan 
populations of over 1.5 million people, medium-large communities as 
those with metropolitan populations between 600,000 and 1.5 million 
people, medium communities as those with metropolitan populations 
between 300,001 and 600,000 people, and small communities as those with 
metropolitan populations of 300,000 or less. 

[39] The number reported by DOT is based on formal complaints filed by 
consumers with the DOT. 

[40] Quintile breaks did not always result in quintiles that were 
exactly equal because, often, the smallest pair in the quintile had too 
many passengers to make the total for the quintile exact. 

[41] Restrictions in place by the Wright Amendment still mean that 
Southwest passengers originating at Dallas Love Field and connecting in 
another airport must buy two separate tickets. As a result, tickets 
originating at Dallas Love Field will only indicate nonstop flights and 
may not always accurately reflect the true itineraries of travelers. 

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