This is the accessible text file for GAO report number GAO-07-352 
entitled 'Reagan National Airport: Update on Capacity to handle 
Additional Flights and Impact on Other Area Airports' which was 
released on March 16, 2007. 

This text file was formatted by the U.S. Government Accountability 
Office (GAO) to be accessible to users with visual impairments, as part 
of a longer term project to improve GAO products' accessibility. Every 
attempt has been made to maintain the structural and data integrity of 
the original printed product. Accessibility features, such as text 
descriptions of tables, consecutively numbered footnotes placed at the 
end of the file, and the text of agency comment letters, are provided 
but may not exactly duplicate the presentation or format of the printed 
version. The portable document format (PDF) file is an exact electronic 
replica of the printed version. We welcome your feedback. Please E-mail 
your comments regarding the contents or accessibility features of this 
document to Webmaster@gao.gov. 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately. 

Report to Congressional Requesters: 

United States Government Accountability Office: 

GAO: 

February 2007: 

Reagan National Airport: 

Update on Capacity to Handle Additional Flights and Impact on Other 
Area Airports: 

GAO-07-352: 

GAO Highlights: 

Highlights of GAO-07-352, a report to congressional requesters 

Why GAO Did This Study: 

In 1999, GAO reported that Reagan National Airport could accommodate at 
least 36 more slots, which are authorizations from DOT for a takeoff or 
landing. In 2000 and 2003, two federal statutes, known as AIR-21 and 
Vision 100, permitted DOT to award 44 new slots to airlines, 24 of 
which could be used for flights to cities more than 1,250 miles, which 
was the statutorily mandated limit for non stop flights from Reagan 
National. The DOT awards went to airlines serving six cities (Denver, 
Las Vegas, Los Angeles, Phoenix, Salt Lake City, and Seattle). For this 
year’s reauthorization of the FAA, GAO was asked for an update on the 
capacity of Reagan National to accommodate additional slots and the 
effect of relaxing the perimeter rule. GAO updated its 1999 study to 
answer these key questions: (1) To what extent can Reagan National 
accommodate additional flights? (2) Since AIR-21 and Vision 100, what 
changes have occurred in market share and fares for flights operating 
between the six beyond-perimeter cities and the three Washington, D.C., 
area airports? In commenting on this report, DOT and the airports 
authority generally agree with our findings but with one exception, the 
airports authority disagrees with DOT’s estimate of slots because it 
disputes their methodological assumptions. We believe the department’s 
methodology for estimating airport capacity is appropriate. 

What GAO Found: 

Reagan National Airport can accommodate some additional in capacity, 
but airport infrastructure constrains how much can be added. FAA 
officials believe that some additional slots can be added, while 
airport officials have not made an estimate. FAA, using the results of 
a 1995 DOT capacity study, determined that the airport’s airside 
infrastructure (e.g., runways) could accommodate four additional slots 
per hour. Airport officials said they were unsure how many additional 
slots, if any, the airport could accommodate but cited several factors 
that could limit the airport’s capacity to absorb additional slots 
including the limited number of gates currently available for loading 
airplanes and other infrastructure constraints. GAO’s work shows that 
even if the number of slots is not increased, there is some opportunity 
to expand current capacity by filling unused slots and increasing the 
size of aircraft on existing slots to increase the number of flights 
and the number of passengers served. Currently, nearly 80 slots are 
unused because they are at early morning or late evening times and 
airlines have not applied to use these time slots. In addition, many of 
the slots reserved for large passenger jets are currently being used by 
smaller regional jets. 

Airlines awarded slots for direct flights between Reagan National and 
the six beyond-perimeter cities gained significant market share in 
those selected cities, but the effect of these slots on competing 
flights operating between these cities and the other Washington, D.C. 
area airports is not evident. For each of the six beyond-perimeter 
cities, the direct flights to and from Reagan National captured the 
majority of passengers flying between that city and Reagan National. In 
most cases, the airlines charged higher fares than competing connecting 
flights. GAO did not find evidence in passengers or fare data that 
would indicate that the new service between Reagan National and the six 
beyond perimeter cities had substantially affected service from Dulles 
or Baltimore-Washington International airports to these cities. 

Figure: Cities Served with Additional Reagan National Airport Slots 
Permitted under AIR-21 and Vision 100, Both beyond and within 1,250 
Miles: 

[See PDF for Image] 

Source: GAO analysis of DOT documents. 

[End of figure] 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-352]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Gerald Dillingham at 
(202) 512-4803 or dillinghamg@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

FAA Indicates Some Additional Capacity Could Be Added, but Airports 
Authority Cites Airport Infrastructure Constraints as an Obstacle: 

Airlines with Nonstop Service between Beyond-Perimeter Airports and 
Reagan National Gained Significant Market Share of Traffic in Those 
Markets, While the Effect on Flights to Other Area Airports Is Not 
Evident: 

Agency Comments: 

Appendix I: Scope and Methodology: 

Appendix II: Comments from the Metropolitan Washington Airports 
Authority: 

GAO Comment: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Slots Per Hour by Carrier: 

Table 2: Reagan National Slots Allocated and Used by Aircraft Type, 
August 2006: 

Table 3: Share of Passenger Traffic by Airline: 

Table 4: Average One-way Fares for Nonstop and Connecting Flights to 
Reagan National in Beyond-Perimeter Airports (2005): 

Figures: 

Figure 1: Layout of Reagan National Airport: 

Figure 2: Summary of Slot Exemptions Granted by DOT under AIR-21 and 
Vision 100 as of September 2006: 

Figure 3: Number of Flights at Reagan National By Aircraft, January 
2001-August 2006: 

Figure 4: Annual Percentage Change in Passengers for All Dulles Flights 
and Flights between Dulles and Six Beyond-Perimeter Airports, 1999- 
2005: 

Figure 5: Annual Percentage Change in Average Fares for All Dulles 
Flights and Flights between Dulles and Six Beyond-Perimeter Airports, 
1999-2005: 

Figure 6: Annual Percentage Change in Passengers for All BWI Flights 
and Flights between BWI and Six Beyond-Perimeter Airports, 1999-2005: 

Figure 7: Annual Percentage Change in Average Fares for All BWI Flights 
and Flights between BWI and Six Beyond-Perimeter Airports, 1999-2005: 

Abbreviation: 

AIR-21: Wendell H. Ford Aviation Investment and Reform Act for the 21ST 
Century: 
BWI: Baltimore-Washington Thurgood Marshall International Airport: 
DOT: Department of Transportation: 
DHS: Department of Homeland Security: 
FAA: Federal Aviation Administration: 
Vision 100: Vision 100 - Century of Aviation Reauthorization Act: 
IFR: Instrument Flight Rules: 
VFR: Visual Flight Rules: 
GAO: Government Accountability Office: 

United States Government Accountability Office: 
Washington, DC 20548: 

February 28, 2007: 

The Honorable John Mica: 
Ranking Republican Member: 
Committee on Transportation and Infrastructure: 
House of Representatives: 

The Honorable Tom Petri: 
Ranking Republican Member: 
Subcommittee on Aviation: 
Committee on Transportation and Infrastructure: 
House of Representatives: 

Ronald Reagan Washington National Airport's (Reagan National) central 
location in the Baltimore-Washington D.C.-Northern Virginia region and 
proximity to the Nation's capital makes it very popular for airlines 
and passengers. However, since the 1960's, the federal government has 
restricted air traffic at Reagan National to reduce congestion and spur 
growth at other nearby airports. This has been achieved by controlling 
the number of takeoffs and landings that can occur at Reagan National 
each day within hourly time periods. To take off or land during any 
given hour at Reagan National, an airline must first obtain a slot that 
is an authorization from the Federal Aviation Administration (FAA) 
under what is called the slot rule. Each slot equates to one takeoff or 
landing. The airport's growth has also been constrained by limiting the 
distance that flights are allowed to travel. Under what is called the 
perimeter rule, the distance of nonstop flights that serve the airport 
is limited to 1,250 miles. Under this rule, passengers wishing to fly 
to Reagan National from airports more than 1,250 miles away must first 
fly to an airport within 1,250 miles and then take another flight 
continuing on to Reagan National. The slot rule also grants 12 slots 
per hour to general aviation or other aircraft that do not operate on a 
scheduled basis, such as corporate jets or military planes. Prior to 
the terrorist attacks of September 11, 2001, there were over 40,000 
annual general aviation and unscheduled flights to and from Reagan 
National but since then, the Department of Homeland Security (DHS) 
restrictions on general aviation flights in the national capital region 
have drastically curtailed the use of these slots to about 200 over the 
past year. 

In 1999, we analyzed legislative proposals to increase the number of 
slots at Reagan National and reported that the airport could 
accommodate at least 36 more slots per day and that adding beyond- 
perimeter slots would have limited effects on nearby Dulles 
International (Dulles) and Baltimore-Washington Thurgood Marshall 
International Airport (BWI).[Footnote 1] The rule that governs the 
number of slots at Reagan National limits the number of takeoffs or 
landings to 48 commercial slots per hour occurs during an 18-hour 
period (6:00 a.m. to midnight) over the airport's 24-hour operating 
day.[Footnote 2] 

In 2000 and 2003, two federal statutes --AIR-21[Footnote 3] and Vision 
100[Footnote 4] increased the number of slots and for the first time 
allowed for exemptions to be granted to the perimeter rule. The 
statutes granted exemptions to the existing rules, adding 44 slots per 
day during a 15-hour period and allowing 24 of these slots for flights 
of more than 1,250 miles--flights longer than 1,250 miles are called 
beyond-perimeter flights.[Footnote 5] In effect, given the 15-hour 
period for these slot exemptions, this added on average three 
commercial slots per hour. The Department of Transportation (DOT) 
awarded these new slots exemptions to airlines and routes that best met 
specified criteria.[Footnote 6] The 24 beyond-perimeter slot exemptions 
were awarded to airlines operating flights from six airports-Denver 
International (Denver), Phoenix-Sky Harbor (Phoenix), McCarran 
International (Las Vegas), Los Angeles International (Los Angeles), 
Salt Lake City International (Salt Lake City), and Seattle-Tacoma 
International (Seattle). 

In anticipation of this year's reauthorization of FAA, you asked for an 
update of GAO's 1999 report on Reagan National's ability to accommodate 
additional capacity and the effect of relaxing the perimeter rule. To 
provide this update, we addressed these key questions: 

* To what extent can Reagan National accommodate additional flights? 

* Since AIR-21 and Vision 100, for the six beyond-perimeter airports, 
what changes have occurred in market share and fares at Reagan National 
and what changes have occurred in the number of passengers and fares at 
Dulles and BWI airports? 

To identify the number of additional slots Reagan National can 
accommodate and the factors affecting existing capacity, we reviewed 
FAA flight data and gate utilization data obtained from the 
Metropolitan Washington Airports Authority (airports authority) and we 
interviewed DOT, FAA and airport officials. To assess the changes in 
passenger levels and fares at Washington area airports and the six 
beyond-perimeter airports, we analyzed DOT origin and destination 
ticket data and interviewed officials at all three Washington, D.C., 
area airports. We reviewed the reliability of these data and concluded 
that they were sufficiently reliable for our purposes. We conducted our 
work from July 2006 to February 2007 in accordance with generally 
accepted government auditing standards. More details about the scope 
and the methodology of our work are presented in appendix I. 

Results in Brief: 

Reagan National Airport can accommodate some additional capacity, but 
airport infrastructure constrains how much can be added. FAA officials 
believe that some new slots for flights can be added. Based on DOT's 
1995 capacity study, FAA estimates that the airport's airside 
infrastructure--principally runways--could presently accommodate four 
additional slots per hour or 60 daily slots based on a 15-hour 
operating period. Airport officials disagree with FAA's method of 
measuring capacity and said they were unsure how many additional slots, 
if any, the airport could accommodate and cited several factors as 
contributing to their uncertainty. For example, officials said that the 
airport's ability to absorb the slot exemptions granted under AIR-21 
and Vision 100 has been aided by the near absence of general aviation 
flights. Whether general aviation will return to the previous levels is 
currently unknown; but in its absence, airport officials said that some 
runway capacity remains unutilized. Airport officials also said that if 
additional slots are added, the airport's ability to accommodate more 
aircraft will be limited by such factors as the lack of gates for 
loading airplanes and other infrastructure constraints. Our analysis 
shows that even if the number of slots is not increased, there is some 
opportunity for expanding capacity under current rules. Currently, 78 
existing slots remain unused--mostly during the early morning and late 
evening hours--and airlines have not applied to use these slots. In 
addition, the capacity of the existing slots could also be increased by 
using larger planes to carry more passengers. Currently, smaller 
commuter aircraft, carrying a maximum of 76 passengers, are being 
widely used in slots designated for larger jets. 

Airlines awarded slot exemptions for direct flights between Reagan 
National and the six beyond-perimeter airports gained a significant 
market share of traffic for those selected routes, but the effect of 
these flights on competing flights operating between these airports and 
the other Washington, D.C., area airports is not evident. For most of 
the six beyond-perimeter airports, the direct flights to and from 
Reagan National captured the majority of passengers flying between that 
airport and Reagan National. In most cases, the airlines charge higher 
average fares than on competing connecting flights. For example, in the 
Salt Lake City market, Delta Airlines (both nonstop and connecting 
flights) carries nearly 60 percent of the passenger traffic serving 
Reagan National and charges on average nearly $50 more for a direct 
flight than competing airlines charge for connecting flights between 
Salt Lake City and Reagan National. We did not find evidence about 
passengers or fares at Dulles or BWI for the six beyond-perimeter 
airports that would indicate that the new beyond-perimeter service to 
Reagan National had substantially affected flights between these two 
airports and the six beyond-perimeter airports. 

DOT and the airports authority provided comments on a draft of this 
report and generally agree with our findings with one exception. While 
the airports authority believes it can accommodate some additional 
capacity it disagrees with the department's estimate of how many 
additional slots it can accommodate because it disputes its 
methodological assumptions. DOT believes its methodology, which 
attempts to consider capacity under a variety of weather conditions, is 
more appropriate than the airport authority's preference to estimate 
capacity only under poor weather conditions. We believe the 
department's methodology for estimating airport capacity is more 
appropriate because the airport authority's approach would leave large 
amounts of airfield capacity unused because a significantly higher 
capacity could be achieved during better weather conditions. DOT and 
the airports authority provided overall comments and technical 
clarifications in some areas of this report. We have addressed these 
comments and clarifications where appropriate. The airport authority's 
comments and our responses are presented in appendix II. 

Background: 

Reagan National Airport was built by the federal government and opened 
on June 16, 1941, on the western bank of the Potomac River, across from 
Washington, D.C.[Footnote 7] Reagan National currently has three 
runways and two terminals with a total of 44 gates or passenger loading 
ramps for use by air carriers. The airport currently handles 400 daily 
departures to 75 cities, offered by 20 different airlines (this 
includes commuter airlines, which operate solely for the major 
carriers). Terminal A, the original terminal, has 9 gates, and Terminal 
B/C, which opened in 1997, has 35 gates, 100 ticket counters, and 12 
baggage claim areas. In 2005, 17.8 million passengers used Reagan 
National. The airline with the largest number of flights at Reagan 
National is US Airways, which controls 44 percent of the commercial 
slots. The next largest operators are Delta Airlines and American 
Airlines, which have 14 percent of the commercial slots each. During 
2005, these three airlines together accounted for nearly 60 percent of 
total passenger enplanements at the airport. 

Figure 1: Layout of Reagan National Airport: 

[See PDF for image] 

Source: FAA. 

[End of figure] 

In 1969, FAA applied special air traffic rules to certain airports 
facing increasing delays and congestion that it designated as high-
density airports: Chicago-O'Hare; New York's LaGuardia and Kennedy; 
Newark, New Jersey; and Reagan National (DOT dropped Newark's 
designation as a high-density airport in October 1970). Because of the 
restricted number of allowable flights, these airports are generally 
known as slot-controlled, and the special air traffic rules governing 
the allowable number of flights are referred to as slot rules, or high- 
density rules. 

The number of hourly slots at Reagan National is controlled by the 
federal government. Since 1969, the federal government has restricted 
the number of commercial takeoffs and landings at Reagan National. 
Currently, the number allowed is 48 per hour: 37 for air carriers and 
11 for commuter aircraft.[Footnote 8] Table 1 shows the number of slots 
per hour by type of aircraft permitted under the slot rule. FAA 
authorizes general aviation or unscheduled aircraft to make an 
additional 12 takeoffs or landings during each hour for a total of 60 
slots per hour. 

Table 1: Slots Per Hour by Carrier: 

Type: Air carrier[A]; 
Slots per hour: 37[B]. 

Type: Commuter; 
Slots per hour: 11. 

Type: General aviation/unscheduled; 
Slots per hour: 12. 

Total; 
Slots per hour: 60. 

Source: GAO analysis of DOT documents. 

[A] Can be used by commuter but not vice versa (14 C.F.R. § 93.123). 

[B] The original limit on the number of air carrier slots was 40 per 
hour. FAA reduced it to 37 in 1981 and increased the number of commuter 
slots from 8 to 11. 

[End of Table] 

A perimeter rule has been in place at Reagan National since May 1966 
restricting airlines from operating nonstop flights between Reagan 
National and airports further than a specified distance. The FAA 
previously had concerns that allowing long-range jets to fly into 
Reagan National would create a noise problem and hamper growth of the 
newly built Dulles International Airport. As a result, with the 
airlines agreeing, the Civil Aeronautics Board approved a 650-mile 
perimeter, with exceptions of seven cities between 650 and 1,000 miles 
away that enjoyed grandfather status as of December 1, 1965. 

In 1986, the Congress codified the slot and perimeter rules into 
federal statute as part of the Metropolitan Washington Airports Act of 
1986.[Footnote 9] The act led to the transfer of authority over Reagan 
National and Dulles from the federal government to the Metropolitan 
Washington Airports Authority and set the perimeter at 1,250 miles, 
which allowed nonstop flights as far as Houston and Dallas. 

Two federal statutes enacted in 2000 and 2003 modified the slot and 
perimeter rules at Reagan National Airport. AIR-21 and Vision 100 
effectively added up to three commercial slots per hour and for the 
first time designated some slots for flights beyond the 1,250 mile 
perimeter. AIR-21 and Vision 100, combined, allowed the Secretary of 
Transportation to award 22 roundtrips, 12 with service to airports 
beyond the perimeter and 10 with service to airports within the 
perimeter. Figure 2 shows each market by number of slots and airline. 

Figure 2: Summary of Slot Exemptions Granted by DOT under AIR-21 and 
Vision 100 as of September 2006: 

[See PDF for image] 

Source: GAO analysis of DOT documents. 

[End of figure] 

Two other commercial airports serve the Baltimore-Washington 
metropolitan area--Dulles International Airport and Baltimore- 
Washington International Thurgood Marshall Airport (BWI). Dulles opened 
on November 19, 1962. The federal government built Dulles, located 
approximately 30 miles west of Washington, D.C., in part to provide a 
facility for nonstop and connecting and international air carrier 
traffic into the Washington, D.C. area. In 2005, Dulles handled 27 
million passengers. BWI, built by the city of Baltimore and originally 
named Friendship International Airport, was opened on June 24, 1950. 
BWI, which is owned and operated by the state of Maryland, is located 
10 miles southwest of Baltimore and approximately 30 miles northeast of 
Washington, D.C. In 2005, BWI handled 19.7 million passengers. 

FAA Indicates Some Additional Capacity Could Be Added, but Airports 
Authority Cites Airport Infrastructure Constraints as an Obstacle: 

According to FAA officials, whose estimate is based on airside capacity 
(principally runways) and not landside infrastructure (such as 
terminals and parking facilities), Reagan National can presently 
accommodate four additional slots per hour. Airport officials disagree 
on the basis for FAA's estimate and cite the unknown future course of 
general aviation at the airport and the limited capacity of airport 
infrastructure (such as gates, baggage handling areas, and parking) to 
handle more commercial flights. Airport officials were unsure of how 
many additional flights, if any, the airport could accommodate. Even 
without increasing the number of slots, there are opportunities to 
accommodate more flights and passengers. Some current slots remain 
unused during early morning or late evening hours, and some slots 
designated for air carriers are being used for smaller commuter 
aircraft. 

FAA Estimates Airport Can Accommodate Additional Slots: 

According to FAA, Reagan National's overall runway capacity can 
presently accommodate about four additional hourly slots above the 
current slot allocation under the high-density rule.[Footnote 10] FAA 
continues to rely on the DOT's study of the high-density rule that it 
conducted in 1995.[Footnote 11] The study estimated that the airport's 
balanced capacity is 67 flights per hour, or 4 more than what is 
currently in place, resulting in an additional 60 flights per day based 
on an 15-hour operating period.[Footnote 12] The study predated the 
exclusion of general aviation after September 11. The study concluded 
that FAA's traffic programs and procedures could safely accommodate the 
increase, but it also said the increase was likely to result in more 
delays. In 2004, the most current year for which this data are 
available, Reagan National experienced an average delay time of 5 
minutes, one of the lowest in the nation for large hub commercial 
airports.[Footnote 13] 

Airports Authority Questions Reagan National's Capacity to Accommodate 
Additional Slots: 

Airport officials disagree with FAA's estimate because it assumes 
balanced capacity, whereas the airport prefers to measure capacity 
differently. Airport officials stated any measurement of capacity 
should be based on poor weather conditions and Instrument Flight Rules 
(IFR).[Footnote 14] FAA and GAO believe balanced capacity is a more 
appropriate method for determining an airport's capacity than the 
method suggested by the airports authority. The 1995 DOT study points 
out that estimating capacity under IFR conditions, when the airfield is 
at the lowest level of available capacity does not ensure steady 
airfield availability. In practice, this approach would leave large 
amounts of airfield capacity unused because a significantly higher 
capacity could be achieved during the better weather conditions under 
which Visual Flight Rules (VFR) apply.[Footnote 15] According to data 
from DOT, less than 1 percent of air traffic operations at Reagan 
National from November 2005 to November 2006 were delayed because of 
weather conditions. 

Assuming capacity under IFR conditions, airport officials raised two 
issues that would limit growth at the airport. The first issue is the 
potential return of general aviation flights. Airport official said the 
absence of general aviation flights helped the airport to absorb the 
additional slots that were authorized under AIR-21 and Vision 100. 
After September 2001, DHS banned general aviation flights around the 
national capital region.[Footnote 16] Prior to the September 11 
terrorist attacks, the airport handled 40,000 to 50,000 unscheduled 
aircraft flights including general aviation, annually. 

Since October 2005, general aviation flights have been allowed to 
return, but only under very restrictive conditions, resulting in very 
little activity at Reagan National.[Footnote 17] According to airport 
officials, between October 2005 and August 2006, for example, the 
airport had fewer than 200 general aviation flights. Figure 3 shows the 
level of flights of all types of aircraft since January 2001. As the 
figure shows, traffic for all types dropped after September 11, 2001, 
but commercial traffic (commuter and air carrier) has basically 
returned to pre-September 11 levels. By contrast, general aviation has 
not done so. 

Figure 3: Number of Flights at Reagan National By Aircraft, January 
2001-August 2006: 

[See PDF for image] 

Source: GAO analysis of FAA tower data. 

[End of figure] 

According to airport officials, as a result of the significantly 
diminished presence of general aviation, some airside capacity remains, 
but commercial aviation might not be able to use it all. A key reason 
is that commercial aircraft require the longer main runway for takeoff 
and landings, while many general aviation aircraft can use the shorter 
runways for takeoff and landing. 

The second issue airport officials raised as limiting capacity is 
infrastructure limitations. These limitations involve several aspects 
of the airport's infrastructure. 

* Passenger Loading Gates. According to airport officials, the number 
of gates affects the ability to add more slots. Every gate at the 
airport is currently leased to airlines with flights at the airport, 
known as tenant airlines. Airlines wishing to begin flights at the 
airport, known as new entrants, can make arrangements with tenant 
airlines to share a gate, but a tenant airline is not required to share 
its gate if its schedule does not allow it.[Footnote 18] A recent 
analysis by the airport shows that some gates are available during 
certain parts of the day. For example, during October 2006, some gates 
were unused during both peak and nonpeak times, primarily those in the 
older and less desirable terminal A. During the 18-hour operating 
period, gates in terminal A were unused 46 percent of the time, while 
gates in terminal B/C were unused 22 percent of the time. Most of the 
available time periods are during nonpeak hours. 

* Terminal Facilities. Officials said Reagan National has limited 
capacity to expand terminal facilities such as ticket counters and 
baggage handling areas due to the lack of space on the airport 
property. If additional slots are permitted, existing tenant airlines 
might be able to use their existing facilities more fully, but new 
entrant airlines may have difficulty obtaining the necessary terminal 
facilities, especially at peak periods during the day. For the recent 
slots awarded under AIR-21 and Vision 100, the airports authority has 
been able to accommodate new entrants with gates and other facilities. 
However, airport officials said that such accommodation has become 
increasingly difficult. Officials from Alaska Airlines, one of the 
newer airlines at Reagan National, told us that its experience in 
getting the needed facilities has been positive. 

* Parking Facilities. According to airport officials, limited parking 
at the airport could make it difficult to accommodate additional 
passengers, resulting from increased slots. Passengers have a variety 
of ways to access the airport terminal, including rail transit, taxis, 
shuttle services, and private car. For those who drive their own cars, 
the airport provides over 7,900 parking spaces. According to airport 
officials, the parking facility is running at or near capacity with the 
existing flight schedule. For example, over a 12-month period from 
November 2005 to October 2006, two of the four parking garages reached 
capacity 100 days or more. In order to help mitigate some of this 
pressure, the airport plans to add an additional deck to the current 
parking structure. This additional parking deck would provide 850 more 
spaces and is slated for completion in 2010. 

Opportunities Exist to Expand Current Capacity at Reagan National: 

In two ways, Reagan National's current capacity under the existing slot 
limits could be expanded. First, the airport has available slots during 
certain parts of the day, though they are for less desirable times. Of 
the total 912 daily slots available for airlines, 834 are currently 
allocated and approximately 78 slots are unused.[Footnote 19] Each of 
these unused slots falls either in the early morning (between 6:00 and 
7:00) or in the late evening (between 9:00 and midnight), which 
suggests that no existing airlines and most likely no new entrants wish 
to initiate new service with a schedule limited to these 
hours.[Footnote 20] According to airport officials, these slots remain 
unallocated because there is less demand for passenger service during 
these hours and because noise restrictions after 10 p.m. require 
quieter aircraft.[Footnote 21] 

The second way in which current capacity could be expanded is to reduce 
the number of smaller commuter planes using slots that are allocated 
for larger jet planes that carry more passengers. For example, FAA data 
show that in August 2006, commuter flights used nearly double the slots 
that were designated for commuter flights (see table 2). For example, 
on one route, between Raleigh-Durham and Reagan National, DOT data show 
that in November 2006, two carriers operated an average of 26 daily 
flights using commuter jets, which have a maximum capacity of 76 seats, 
although larger jets were designated for the slots used for the 
commuter flights. FAA and airport officials acknowledged that commuter 
aircraft often use air carrier slots, but noted that this practice is 
permissible under federal regulation. 

Table 2: Reagan National Slots Allocated and Used by Aircraft Type, 
August 2006: 

Type: Air carrier; 
Total monthly number of slots: 22,320[A]; 
Actual flights: 13,333; 
Percentage of slots utilized: 60%. 

Type: Commuter; 
Total monthly number of slots: 6,138; 
Actual flights: 10,681; 
Percentage of slots utilized: 174%[B]. 

Source: GAO analysis of FAA tower data. 

[A] Includes slot exemptions added under AIR-21 and Vision 100. 

[B] Commuter reflects both commuter slots and air carrier slots used by 
commuters. 

[End of table] 

Airlines with Nonstop Service between Beyond-Perimeter Airports and 
Reagan National Gained Significant Market Share of Traffic in Those 
Markets, While the Effect on Flights to Other Area Airports Is Not 
Evident: 

Airlines awarded slots for nonstop service between Reagan National and 
airports beyond the 1,250 mile perimeter have been able to gain a 
significant market share of traffic for routes. The price they charge 
for this direct service is generally higher than the price for flights 
requiring a connection. We did not find evidence that Dulles or BWI 
traffic or fares were affected by the beyond perimeter flights to 
Reagan National. 

For each of the six beyond-perimeter airports, the airlines awarded 
slots for nonstop service between Reagan National and those airports 
gained significant market share of passenger traffic over a short 
period of time. For example, in the Denver market, Frontier Airlines, 
had no nonstop passenger traffic between Denver and Reagan National 
before it was awarded two slots (one daily roundtrip) in August 2000 
and four additional slots (two more daily roundtrips) in 2004, and it 
now has garnered nearly 60 percent of the passenger traffic to Reagan 
National from Denver (see table 3). United Airlines, which was awarded 
two slots (one daily roundtrip) in the same market in 2004, now has 15 
percent of the market. Between Frontier and United Airlines, the two 
carriers' nonstop routes have nearly three-fourths of the Denver-Reagan 
National traffic. 

Table 3: Share of Passenger Traffic by Airline: 

Market: Denver; 
Airline: Frontier; 
Year slot award service initiated: 2000; 
Before slot award average market share[A]: 0%; 
Current average market share (1[ST] qtr 2006): 59%. 

Market: Denver; 
Airline: United; 
Year slot award service initiated: 2004; 
Before slot award average market share[A]: 0.5%; 
Current average market share (1[ST] qtr 2006): 15%. 

Market: Los Angeles; 
Airline: Alaska; 
Year slot award service initiated: 2004; 
Before slot award average market share[A]: 0%; 
Current average market share (1[ST] qtr 2006): 43%. 

Market: Las Vegas; 
Airline: America West; 
Year slot award service initiated: 2000; 
Before slot award average market share[A]: 0%; 
Current average market share (1[ST] qtr 2006): 23%. 

Market: Phoenix; 
Airline: America West; 
Year slot award service initiated: 2000; 
Before slot award average market share[A]: 12%; 
Current average market share (1[ST] qtr 2006): 61%. 

Market: Salt Lake City; 
Airline: Delta; 
Year slot award service initiated: 2003; 
Before slot award average market share[A]: 0%; 
Current average market share (1[ST] qtr 2006): 59%. 

Market: Seattle; 
Airline: Alaska; 
Year slot award service initiated: 2001; 
Before slot award average market share[A]: 0%; 
Current average market share (1[ST] qtr 2006): 62%. 

Source: GAO analysis of DOT's origin and destination survey. 

[A] Average market share data based on the year before award. 

[End of table] 

Airlines with beyond-perimeter slots generally charge higher fares than 
are charged for connecting flights to and from Reagan National (see 
table 4). In half of the cases the nonstop fare was on average $25 to 
$50 higher than the connecting flight fares to and from Reagan 
National. Los Angeles is the only market in which the average direct 
fare is less than the average fare for flights with connections. 

Table 4: Average One-way Fares for Nonstop and Connecting Flights to 
Reagan National in Beyond-Perimeter Airports (2005): 

Market: Denver; 
Airline: Frontier; 
Nonstop flight: $159; 
Connecting flight: n/a. 

Market: Denver; 
Airline: United; 
Nonstop flight: $237; 
Connecting flight: $151. 

Market: Los Angeles; 
Airline: Alaska; 
Nonstop flight: $178; 
Connecting flight: $190. 

Market: Las Vegas; 
Airline: America West; 
Nonstop flight: $180; 
Connecting flight: $176. 

Market: Phoenix; 
Airline: America West; 
Nonstop flight: $251; 
Connecting flight: $176. 

Market: Salt Lake City; 
Airline: Delta; 
Nonstop flight: $250; 
Connecting flight: $201. 

Market: Seattle; 
Airline: Alaska; 
Nonstop flight: $247; 
Connecting flight: $226. 

Source: GAO analysis of DOT's origin and destination survey. 

[End of table] 

The Effect of Beyond-Perimeter Slots on Area Airports Is Not Evident: 

We did not find evidence that beyond-perimeter flights to and from 
Reagan National affected flights from the same airports to or from 
Dulles or BWI. We analyzed fare and passenger data for flights between 
Dulles and BWI and those airports and for all traffic serving Dulles 
and BWI. In doing so, we observed that the data did not produce any 
distinguishable trends or patterns that would indicate that beyond- 
perimeter slots at Reagan had any effect on fares or passenger levels 
at either Dulles or BWI. 

Overall, Dulles has experienced growth in traffic and a decline in 
fares, while BWI has experienced little overall change in traffic or 
fares from 1999 to 2005. To assess whether the introduction of new 
nonstop beyond-perimeter routes into Reagan National affected service 
between the same six airports and Dulles or BWI, we compared the 
percentage change in average fares and total passengers, from 1999 
through 2005 for travel between each of the six beyond-perimeter 
airports and Dulles and BWI against the overall percentage change in 
annual average fares and passengers for all traffic serving Dulles and 
BWI. As the figures below illustrate, some routes experienced greater 
or lesser changes relative to overall changes at the airport, but no 
consistent trends were apparent. 

* Dulles annual airport passenger traffic grew from 1999 to 2005, from 
19.7 million to 27 million, a 37 percent increase. We did not find any 
patterns or trends that would suggest that the changes to the perimeter 
rule at Reagan National had affected fares or service between Dulles 
and these six airports. (See figs. 4 and 5). Airports authority 
officials stated they had no reason to believe that these limited 
beyond-perimeter awards affected Dulles. Rather, the officials noted, 
the airport's fares and passenger traffic were significantly affected 
by its experience with low-fare carrier, Independence Air, which had a 
large growth of flights at Dulles but has now gone out of business. 

For overall passenger traffic between Dulles and the six airports, as 
figure 4 shows, we did not find evidence that the beyond-perimeter 
slots at Reagan National affected passenger levels. For example, 
passenger traffic between Dulles and some airports grew faster than 
overall airport traffic despite the introduction of nonstop flights to 
Reagan National. 

Figure 4: Annual Percentage Change in Passengers for All Dulles Flights 
and Flights between Dulles and Six Beyond-Perimeter Airports, 1999- 
2005: 

[See PDF for image] 

Source: GAO analysis of DOT's origin and destination survey. 

[End of figure] 

Figure 5: Annual Percentage Change in Average Fares for All Dulles 
Flights and Flights between Dulles and Six Beyond-Perimeter Airports, 
1999-2005: 

[See PDF for image] 

Source: GAO analysis of DOT's origin and destination survey. 

[End of figure] 

* BWI airport passenger traffic grew from 17.4 million in 1999 to 19.7 
million in 2005. But, similar to Dulles, we found no patterns or trends 
in passengers or fares between BWI and the six airports that would 
suggest that changes to the beyond-perimeter rule at Reagan National 
had an impact on flights at BWI. (See figs. 6 and 7). Officials from 
BWI stated that changes to the slot and perimeter rule did not 
adversely affect BWI and noted other factors, notably US Airways 
reduction of its commuter service at BWI. 

Figure 6: Annual Percentage Change in Passengers for All BWI Flights 
and Flights between BWI and Six Beyond-Perimeter Airports, 1999-2005: 

[See PDF for image] 

Source: GAO analysis of DOT's origin and destination survey. 

[End of figure] 

Figure 7: Annual Percentage Change in Average Fares for All BWI Flights 
and Flights between BWI and Six Beyond-Perimeter Airports, 1999-2005: 

[See PDF for image] 

Source: GAO analysis of DOT's origin and destination survey. 

[End of figure] 

Agency Comments: 

We provided copies of this report to DOT and the airports authority. We 
received comments from the Office of the Deputy Assistant Secretary for 
Aviation and International Affairs, Department of Transportation. DOT 
acknowledges that all available slots at Reagan National Airport are 
not used to maximum effect and agreed that there are a number of 
reasons for this, including curfew restrictions, the commercial 
viability of slots in the early morning or late evening under current 
regulations, and the concentration of the majority of slot holdings 
among a relatively small number of carriers. DOT also recognizes that 
the underutilization of slots is exacerbated by the fact that carriers 
can use commuter aircraft in slots designated for large aircraft but 
are legally prohibited from using large aircraft in slots designated 
for commuter aircraft. In addition, other statutory restrictions, such 
as the perimeter rule, contribute to the underutilization of slots and 
prevent market forces from producing the maximum public benefit from 
these scarce assets. For example, the early departure and late arrival 
times at other airports are often used by airlines to operate overnight 
"red eye" or other long-haul flights. Regulations governing operations 
at Reagan National, such as the perimeter rule, prevent carriers from 
using such scheduling and fleet assignment techniques to maximize the 
value of slots and facilities at that airport. While we do not disagree 
with DOT's observations, we also recognize that any changes in the 
commuter slot or perimeter rules at Reagan National would have 
competitive implications for airlines and the communities they serve. 
Assessing these effects was beyond the scope of our study. Finally, DOT 
offered technical comments, which we have incorporated as appropriate. 

The airports authority commented that with one exception the report 
accurately reflects the situation at Reagan National. While the 
airports authority believes that the airport can accommodate some 
additional capacity, it is something less than the 4 slots per hour as 
suggested by DOT. The airports authority still disagrees with the basis 
for DOT's 1995 estimate of 67 slots per hour under the High-Density 
Rule, just as it did in response to our 1999 report on this matter. The 
airports authority believes that maximum capacity should be based on 
IFR conditions, that is, capacity under adverse weather conditions. 
Instead, DOT bases its estimate of maximum capacity on a mix of IFR and 
VFR traffic, a methodology that we endorsed in 1999 and still do today. 
We believe, as does DOT, that balanced capacity is a superior method 
for determining the airport's capacity because it accounts for the 
operation of aircraft during all weather conditions. The airports 
authority offered technical comments, which we have incorporated as 
appropriate. The airports authority's comments, along with our 
responses to them appear in appendix II. 

As agreed with your office, unless you publicly announce the contents 
of this report earlier, we plan on no further distribution until 3 days 
from the date of this letter. At that time, we will send copies of this 
report to the Secretary of Transportation and the Administrator of the 
FAA. We will also make copies available to others upon request. In 
addition, the report will be available at no charge on the GAO Web site 
at [Hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-4803 or dillinghamg@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. Staff who make key contributions to 
this report are listed in appendix II. 

Signed by: 

Gerald L. Dillingham, Ph.D. 
Director, Physical Infrastructure Issues: 

[End of section] 

Appendix I: Scope and Methodology: 

To determine how many additional slots Reagan National Airport can 
accommodate, we analyzed Federal Aviation Administration (FAA) and 
Metropolitan Washington Airports Authority (airports authority) 
operational data, reviewed prior capacity studies, and interviewed 
airports authority, FAA, and Department of Transportation (DOT) 
officials. This analysis included reviewing data on the number and type 
of aircraft using the slots and how this usage was dispersed during the 
day and by which runway. We also reviewed the data contained in the 
1995 study done by the DOT on the high-density rule and reviewed the 
basis for DOT's capacity estimates. In addition, we analyzed airports 
authority gate utilization data and airline leases to determine the 
extent to which gate space at the airport is unused. Finally, we 
interviewed officials from the DOT, FAA, airports authority and other 
stakeholders about Reagan National's current and future capacity. 

To assess traffic between Washington, D.C., area airports and the six 
beyond-perimeter airports for which nonstop service to Reagan National 
was awarded since 1999, we analyzed DOT's Origin and Destination ticket 
data; we used these data to examine changes in fares and passenger 
levels between Reagan National, Dulles International (Dulles) and 
Baltimore-Washington Thurgood Marshall International Airport (BWI), and 
these airports. We also interviewed airports authority and BWI 
officials. For this analysis, we conducted a historical look at traffic 
between the six airports and the three Washington-Baltimore area 
airports. We obtained the ticket data from BACK Aviation Solutions, a 
private contractor that provides these data to interested parties. We 
used these data to examine trends in passenger and fares to identify 
any changes in traffic and fares between the six beyond-perimeter 
airports and Reagan National, Dulles and BWI airports. To assess the 
reliability of these data, we reviewed the quality control procedures 
applied to these data, and subsequently determined that the data were 
sufficiently reliable for our purposes. We conducted our review from 
July 2006 through February 2007 in accordance with generally accepted 
government auditing standards. 

[End of section] 

Appendix II: Comments from the Metropolitan Washington Airports 
Authority: 

Note: GAO comment supplementing those in the report text appear at the 
end of this appendix. 

Metropolitan Washington Airports Authority: 

February 1, 2007: 

Dr. Gerald Dillingham: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Dr. Dillingham: 

On behalf of the Metropolitan Washington Airports Authority 
(Authority), I thank you for the opportunity to review the draft of the 
report entitled "Reagan National Airport-Update On Capacity to Handle 
Additional Flights and Impact on Other Area Airports." I want to 
commend the staff of the Government Accountability Office (GAO) for 
taking the time to explore the complex issues of airport capacity and 
to discuss the unique Reagan National issues with the Authority staff. 
I am pleased that the report reflects an understanding of the evolution 
of the restrictions at Reagan National and the issues raised by the 
Authority staff, although I do believe that the report should place 
additional emphasis on several points. 

As you know, the Authority is charged by law with operation of Reagan 
National and Washington Dulles International Airports. We have 
endeavored to improve and to operate these airports in the public 
interest since the Authority was formed in 1987. Reagan National came 
to us with restrictions on the number of flights, the length of nonstop 
flights, night time noise levels and flight paths. These restrictions 
were adopted by the United States Department of Transportation and 
ultimately by the United States Congress in the legislation that 
authorized the transfer of the airports to the Authority. The 
restrictions were intended to resolve longstanding issues over the 
roles of Reagan National and Dulles, community concerns about aircraft 
noise and particularly whether National should grow in activity. The 
limits on activity created a stable environment for Reagan National. 
They brought about community acceptance and enabled the Authority to 
proceed with the modernization of the airport. The limitations on 
Reagan National, specifically the flight limitations in the High 
Density Rule, have always been reflected in the Authority's planning 
and development of the gates and other facilities at the airport. 

We are of course aware of the value of airport capacity and the need to 
efficiently use it. We are also very much aware of the need to control 
airport congestion that diminishes efficiency and undermines the 
reliability of air transportation and does not serve the traveling 
public. We are pleased that Reagan National is among the more efficient 
airports in the United States and, as the report notes (page 11), 
Reagan National enjoys one of the lowest average delay times of any 
large airport in the nation. Reliability of air service is a very 
valuable attribute of Reagan National and a great benefit to both the 
scheduled airlines and their passengers coming to and going from 
Washington. 

The High Density Rule limits on scheduling, or slots, are a major 
factor in that reliability. National is essentially a single runway 
airport. More than 95 percent of its operations occur on one runway. 
The short cross wind runways are not frequently used by larger air 
carrier aircraft or even most of the commuter air carrier aircraft 
which today are regional jets. An analysis of capacity has to consider 
this. The GAO report cites the Federal Aviation Administration (FAA) 
report of 1995 which concluded that the airport could handle increased 
number of operations, from 60 (which had been the rule since 1969) to 
67 an hour. Three slots an hour have effectively been added already by 
the legislation enacted in 2000 and 2003. As you know we were critical 
of that 1995 report and so advised GAO in our letter of August 1999. 
Our principal concerns about that FAA report remain today. The 1995 
report does not reflect today's fleet mix. It assumed a greater 
availability of the cross wind runways than we believe is realistic for 
today's all jet fleet. 

The 1995 report also assessed capacity using a "balanced" or blended 
capacity analysis. This is a blend of Instrument Flight Rules (IFR) and 
Visual Flight Rules (VFR) capacity. Clearly, that will yield a higher 
number than IFR alone. It will also lead to greater congestion, delays 
and unreliability when the airport is experiencing IFR conditions. The 
High Density Rule is an IFR rule. Its limits were set to assure 
efficient operations in IFR conditions. We believe that the limits on 
National need to remain close to that number in order to avoid the 
congestion and assure the reliability, particularly in poor weather, 
that we have come to value so much. One need only look to the airports 
where the High Density Rule was in place and then lifted, i.e., 
LaGuardia and O'Hare Airports, for examples of where demand will 
quickly outstrip capacity and diminish dependability to the point that 
the government has had to reassert controls. We recognize the concern 
about planning for reliability in poor weather leaves capacity unused 
in good weather. But we continue to believe that the creation of 67 
slots an hour, i.e., the addition of another 4 per hour over today's 
activity, will lead to significant, and unwarranted, delays in IFR 
conditions, the very situation that the rule was enacted to prevent. 

Our concern is well articulated in the GAO's own 2002 report National 
Airspace System: Long-term Capacity Planning Needed Despite Recent 
Reduction in Flight Delays (GAO-02-185). This report was prepared in 
response to the delays experienced in the summer of 2000 where 28 
percent of all flights at 31 of the Nation's busiest airports were 
delayed, a truly unacceptable rate of delay. The report discussed 
methods of controlling delay and, with respect to the High Density Rule 
reported, "These slots have been somewhat effective in controlling 
delays at these airports " (Appendix III; Measure 2: Using 
Administrative or Regulatory Methods; Using Slot Restrictions; page 
54). 

GAO Report 02-185 referenced the FAA's Airport Capacity Benchmark 
Report 2001 that studied capacity at the 31 airports, which included 
Reagan National. Key, and in contrast to the their 1995 balanced 
capacity figure, in the Benchmark report the FAA indicated that adverse 
weather capacity was somewhere between 62 and 66 operations per hour 
under the most favorable IFR conditions, i.e., when operations are to 
the north using the instrument landing system and arrivals and 
departures are approximately equal. But FAA added disclaimers in the 
report including: 

* "Half of the time during adverse weather, only the main runway can be 
used which reduces capacity to approximately 45 operations per hour." 

* Any capacity gains through new technology (yet to be realized) may be 
"more than offset by reduced use of the shorter, crosswind runway as 
turboprop aircraft are replaced by regional jets. Any change in the 
fleet mix that reduces the number of aircraft able to use these 
[crosswind] runways will reduce the overall capacity of the airport." 
FAA "Airport Capacity Benchmark Report 2001" Emphasis added. 

To these disclaimers we add that Reagan National's capacity in adverse 
weather is reduced when arrivals exceed departures and when the winds 
dictate the use of the non-precision, curved, river approach from the 
north to Runway 19 rather than the straight-in precision approach to 
Runway 1 from the south. 

As the draft report recognizes, but should emphasize more, the 
appearance of available capacity, i.e., the appearance that slots can 
be added without a negative impact, on the capacity of the airfield, is 
masked considerably by the absence of general aviation from the 
airport. Twelve slots per hour, nearly 20 per cent of today's total, 
are not being used due to Department of Homeland Security restrictions 
thereby creating the impression that slots can be added without 
contributing to congestion. However, if general aviation returns to 
Reagan National, some percentage of that activity will also be on the 
main runway. We can only reiterate our concern that the addition of up 
to 4 new air carrier slots per hour coupled with the return of the 
general aviation, totaling 67 operations an hour at Reagan National is 
likely to create the airfield congestion. 

I am grateful that the report acknowledges the significant landside 
infrastructure issues that confront the airport. The creation of 4 new 
slots an hour could easily result in 400 more passengers, and perhaps 
500 more passengers an hour. This would place stress upon the 
infrastructure. In terms of aircraft gates, the number at the airport 
is in balance with the number of slots, although there are a number of 
airlines that are sharing gates that would prefer to have their own. 
There is not enough gate capacity to absorb the addition of four slots 
an hour at all hours of the day. Also, gates are associated with back 
of the house operations such as ticket counter, baggage make up, office 
space and operational facilities. An airline needs to acquire the 
entire package to operate. The ticket counter situation at National is 
particularly acute since it is all leased and heavily used. Also, much 
of the once open space on the ticketing level at Reagan National has 
been taken up by TSA for its security equipment. 

Finally, as the report notes the automobile parking facilities at 
National have become inadequate due in no small part to the demand 
generated by the added flights authorized by the recent legislation. 
The parking lots are regularly at capacity and travelers are turned 
away. The Authority is undertaking expensive and complicated parking 
garage expansions that should be available in 2010 and which are 
expected to add 1,380 spaces. Even with the additional garage parking, 
we anticipate that there will still be shortages of parking at Reagan 
National because passenger activity levels will grow under the present 
slot rules as larger aircraft are introduced. 

In 2006, 18.5 million passengers used Reagan National Airport, a single 
year record for the airport, and up from 15.8 million in 2000, when 
slots were added by the "Air21" legislation. Working with the airlines 
and the TSA we have been able to accommodate that growth, maintain 
efficiency, and provide the level of service and the type of experience 
travelers to and from the Nation's Capital expect. The capacity to 
continue to do so in the face of significant added activity is not 
available, in our judgment. In sum, we agree with the statement in the 
report: "Reagan National Airport can accommodate some additional 
capacity but airport infrastructure constrains how much can be added." 
I am going further and saying that the Airports Authority, based on our 
experience and knowledge of our facilities and operational realities, 
believes strongly that an increase of four air carrier aircraft 
operations per hour as the report implies cannot be accommodated at 
Reagan National without serious negative impacts on the airport 
facilities and passenger service levels. 

Thank you again for sharing the draft report and for your careful 
consideration of this important issue. 

Sincerely, 

Signed by: 

James E. Bennett: 
President and Chief Executive Officer: 

JEB:mdw: 

The following is GAO's comment on the Metropolitan Washington Airports 
Authority's (airports authority) February 1, 2007, letter. 

GAO Comment: 

We believe, as does DOT, that "balanced capacity" is a more appropriate 
method for determining an airport's capacity than the method suggested 
by the airports authority. While the airports authority contends that 
Instrument Flight Rules (IFR) should be used to measure capacity, DOT's 
Technical Supplement No. 3 to its 1995 report points out that IFR 
airfield capacity is indicative of the lowest level of available 
capacity, and thus virtually ensures constant availability of an 
airfield. In practice, this approach would leave large amounts of 
airfield capacity unused because a significantly higher capacity could 
be achieved during the better weather conditions under which Visual 
Flight Rules apply. According to data from FAA, less than 1 percent of 
all air traffic operations at Reagan National from November 2005 to 
November 2006 were delayed because of weather conditions. Because 
setting the number of slots on the basis of balanced capacity reflects 
both bad and good weather conditions, we did not revise our report. 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Gerald Dillingham, Ph.D., (202) 512-4803, or dillinghamg@gao.gov: 

Staff Acknowledgments: 

In addition to the individual named above, Ed Laughlin, Assistant 
Director; Paul Aussendorf; Jay Cherlow; Dave Hooper; Nick Nadarski; 
Josh Ormond; and Stan Stenersen made key contributions to this report. 

FOOTNOTES 

[1] GAO/RCED 99-234. 

[2] 14 C.F.R. § 93, Subpart K. 

[3] The Wendell H. Ford Aviation Investment and Reform Act for the 21st 
Century (AIR-21) Pub. L. No. 106-81 (Apr. 5, 2000). 

[4] The Century of Aviation Reauthorization Act (Vision 100) Pub. L. 
No. 108-176 (Dec. 13, 2003). 

[5] AIR-21 and Vision 100 permitted slots to operate during 7:00 a.m 
through 9:59 p.m. 

[6] Congress set forth slot exemption criteria, and DOT granted 
exemptions to airlines whose service would (for beyond-perimeter 
exemptions) (1) provide air transportation with domestic network 
benefits beyond the 1,250-mile perimeter, (2) increase competition by 
new entrant air carriers or in multiple markets, (3) not reduce travel 
options for communities served by small hub airports and medium hub 
airports within the 1,250-mile perimeter and, (4) not result in 
meaningfully increased travel delays. For within-perimeter slot 
exemptions, DOT distributed exemptions in a manner that promoted air 
transportation: (1) by new entrant air carriers and limited incumbent 
air carriers, (2) to communities without existing nonstop air 
transportation to Reagan National, (3) to small communities, (4) that 
will provide competitive nonstop air transportation on a nonstop route 
to Reagan National, or (5) that will produce the maximum competitive 
benefits, including low fares. 

[7] The airport's official name changed from Washington National to 
Ronald Reagan Washington National Airport under Pub. L. No. 105-154, 
112 Stat 3 (1998). 

[8] Commuter aircraft are generally turboprop or small jet aircraft 
seating 76 or fewer passengers. Within the past few years, several 
commuter airlines have begun using small jet aircraft (regional jets) 
in their fleets. To avoid confusion throughout the remainder of this 
report, we will refer to all commuter aircraft, regardless of whether 
they are regional jets or turboprops, as commuter aircraft. 

[9] Pub. L. No. 99-500, 100 Stat. 1783-375, Pub. L. No. 99-591, 100 
Stat. 3341-378. 

[10] The slot exemptions permitted by AIR-21 and Vision 100 used three 
of the seven additional slots DOT originally estimated in 1995. 

[11] U.S. DOT, Report to the Congress: A Study of the High Density 
Rule, May 1995. 

[12] "Balanced capacity" refers to the average ability of an airport's 
runways to support a certain number of operations per hour under 
varying weather and wind conditions. 

[13] A large hub enplanes (number of passengers boarded) at least 1 
percent of all passengers. 

[14] IFR governs procedures for conducting aircraft operations during 
weather conditions when the cloud ceiling is less than 1,000 feet and/ 
or visibility is less than 3 miles, requiring certain aircraft 
separations and other operating standards. 

[15] VFR governs procedures for conducting aircraft operations when the 
cloud ceiling is more than 1,000 feet and visibility is 3 miles or 
more. Airport capacity under these conditions is generally 
significantly higher than conditions under IFR. 

[16] Special flight restrictions in the National Capital Region, where 
Reagan National is located, have been in place since September 2001, 
primarily affecting general aviation. 

[17] According to FAA, airports authority, and the general aviation 
community, activity is low due to the DHS security requirements. 
National Business Aviation Association officials told us that the 
restrictions are onerous and force general aviation users to other area 
general aviation airports. As part of this reintroduction plan, DHS is 
required to conduct 1-year review of the first phase of the security 
program. To date, DHS has not conducted this review. We also asked if 
DHS had any time frame for further easing of the restrictions, but DHS 
did not have a date. 

[18] Under DOT grant requirements, airports unable to accommodate an 
airline's request for access to gates or other facilities shall submit 
a report to DOT outlining the nature of the request, why the request 
could not be accommodated, and a time frame when, if any, the airport 
will be able to accommodate the request. 

[19] Includes slot exemptions granted under AIR-21 and Vision 100. 

[20] FAA controls the allocation of available air carrier and commuter 
slots at Reagan National during an 18-hour period every day, from 6:00 
am until midnight. 

[21] Between 10 p.m. and 7 a.m. air carriers are required to meet the 
airports authority's noise regulation. 

GAO's Mission: 

The Government Accountability Office, the audit, evaluation and 
investigative arm of Congress, exists to support Congress in meeting 
its constitutional responsibilities and to help improve the performance 
and accountability of the federal government for the American people. 
GAO examines the use of public funds; evaluates federal programs and 
policies; and provides analyses, recommendations, and other assistance 
to help Congress make informed oversight, policy, and funding 
decisions. GAO's commitment to good government is reflected in its core 
values of accountability, integrity, and reliability. 

Obtaining Copies of GAO Reports and Testimony: 

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through GAO's Web site (www.gao.gov). Each weekday, GAO posts 
newly released reports, testimony, and correspondence on its Web site. 
To have GAO e-mail you a list of newly posted products every afternoon, 
go to www.gao.gov and select "Subscribe to Updates." 

Order by Mail or Phone: 

The first copy of each printed report is free. Additional copies are $2 
each. A check or money order should be made out to the Superintendent 
of Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 
more copies mailed to a single address are discounted 25 percent. 
Orders should be sent to: 

U.S. Government Accountability Office 441 G Street NW, Room LM 
Washington, D.C. 20548: 

To order by Phone: Voice: (202) 512-6000 TDD: (202) 512-2537 Fax: (202) 
512-6061: 

To Report Fraud, Waste, and Abuse in Federal Programs: 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm E-mail: fraudnet@gao.gov 
Automated answering system: (800) 424-5454 or (202) 512-7470: 

Congressional Relations: 

Gloria Jarmon, Managing Director, JarmonG@gao.gov (202) 512-4400 U.S. 
Government Accountability Office, 441 G Street NW, Room 7125 
Washington, D.C. 20548: 

Public Affairs: 

Paul Anderson, Managing Director, AndersonP1@gao.gov (202) 512-4800 
U.S. Government Accountability Office, 441 G Street NW, Room 7149 
Washington, D.C. 20548: