FTC Staff Comment to the Hon. Jerry Bartos Concerning Potential Modification of the Restrictions on the Use of Dallas Love Field

, 00 N. Central Expr essway
Suite 500
Dallas. TX 75201
(214) 767·5503
V920014
l'~ITED STATES OF AMERICA 	COMMISSION 	AUTHORIZED
FEDERAL TRADE COMMISSION
DALLAS REGIONAL OFFICE
Office of the R egionaJ Director
June 	30, 	1992
2
Councilman 	Jerry 	Bartos
Chairman, 	Transportation 	Committee
Office 	of 	the 	City 	Council
City 	Hall
Dallas, 	Texas 	75201
Dear 	Councilman 	Bartos:
The 	staff 	of 	the 	Dallas 	Regional 	Office 	and 	the 	Bureau 	of
Economics 	of 	the 	Federal 	Trade 	Commission1 are 	pleased 	to 	submit
this 	letter 	in 	response 	to 	your 	request 	for 	comments 	on 	the
potential 	modification 	of 	the 	restrictions 	on 	use 	of 	Dallas 	Love
Field 	("Love 	Field"). 	Federal 	law 	now 	prohibits 	commercial
airlines 	from 	providing nonstop 	service, 	direct 	service,2 	or
connecting 	service 	between Love 	Field 	and 	destinations 	outside 	of
Texas, 	Louisiana, 	Arkansas, 	Oklahoma, 	and New Mexico 	(lithe 	five-
state 	area"). 	The 	proposal 	that 	you 	have 	outlined would 	maintain
the 	prohibition 	against 	nonstop 	service 	to 	points 	outside 	of 	the
five-state 	area 	but 	would 	permit 	carriers 	to 	publicize 	and
provide 	direct 	and 	connecting 	service 	to 	such 	destinations
through 	points 	within 	the 	five-state 	area.
These 	comments 	are 	offered 	for 	the 	limited purpose 	of
analyzing 	the 	effects 	on 	consumers, 	both 	inside 	and 	outside 	the
Dallas-Fort 	Worth 	area, 	that 	may 	result 	from 	such 	a 	modification.
One 	effect 	may 	be 	to 	increase -the 	competition .faced .. by air
carriers 	that 	utilize 	Dallas/Fort 	Worth 	International 	Airport
("D/FW") 	to 	serve 	locations 	outside 	the 	five-state 	area. 	Such
increased 	competition may 	lower 	air 	fares 	for 	consumers 	flying
between 	the 	Dallas-Fort 	Worth 	area 	and 	those 	locations. 	Another
effect 	may 	be 	to 	increase 	airport 	capacity 	in 	the 	area, 	as 	Love
These 	comments 	are 	the 	views 	of 	the 	staff 	of 	the 	Dallas
Regional 	Office 	and 	the 	Bureau 	of 	Economics 	of 	the 	Federal 	Trade
Commission. 	They 	are 	not 	necessarily 	the 	views 	of 	the 	Commission
or 	of 	any 	individual 	Commissioner.
"Direct 	service" 	is 	service 	that 	requires 	an
intermediate 	stop, 	but 	does 	not 	require 	passengers 	to 	change
planes.

Councilman 	Jerry 	Bartos
Page 	2·
Field may 	become 	more 	fully 	utilized, 	and 	this 	too 	may 	lead 	to
lower 	air 	fares 	for 	consumers. 	In 	addition, 	if 	some 	air 	carrier
traffic 	is 	shifted 	to 	close-in, 	under-utilized Love 	Field 	from
the 	more 	congested 	D/FW, 	then 	consumers 	who 	continue 	to 	use 	D/FW
may 	save 	time 	due 	to 	fewer 	delayed 	flights, 	while 	consumers 	who
shift 	to 	Love 	Field will 	also 	face 	fewer 	delays 	and 	may 	also 	save
money 	on 	parking 	and 	commuting 	expenses.
I. 	Interest 	and 	Experience 	of 	the 	Staff 	of 	the 	Federal
Trade 	Commission
The 	Federal 	Trade 	Commission 	is 	an 	independent 	regulatory
agency, 	which, 	for 	78 	years, 	has 	been 	charged with 	the
responsibilities 	of 	protecting 	competition and 	safeguarding 	the
interests 	of 	consumers. 3 In 	response 	to 	requests 	by 	federal,
state, 	and 	local 	governmental 	bodies, 	the 	staff 	of 	the 	FTC
assesses 	the 	competitive 	impact 	of 	legislative 	and 	regulatory
proposals 	in order 	to 	identify 	provisions 	that may 	benefit
consumers 	by promoting competition 	and 	reducing 	prices, 	and
provisions 	that 	may 	harm 	consumers 	by 	impairing 	competition 	or
increasing 	costs 	without 	offering 	offsetting 	benefits.
The 	staff 	of 	the 	Commission 	has 	had 	considerable 	experience
in 	evaluating 	competitive 	aspects 	of 	the 	air 	carrier 	industry 	and
related 	airport 	issues. 	The 	staff 	has 	studied 	and 	commented 	on
airline 	deregulation,4 	slot 	regulation,5 	airport
3 15 	U.S.C. 	S 	45.
4
5
Ogur, 	Wagner, 	and Vita, 	"The 	Deregulated Airline
Industry: 	A Review 	of 	the 	Evidence," 	Bureau 	of 	Economics, 	Staff
Report 	to 	the 	Federal 	Trade 	Commission, 	January 	1988; 	see 	also
Statement 	of 	James 	C. 	Miller, 	III, 	Chairman, 	Federal 	Trade
Commission, 	Before 	the 	Subcommittee 	on 	Aviation, 	Committee 	on
Public 	Works 	and 	Transportation, 	United 	States 	House 	of
Representatives, 	July 	26, 	1983.
Koran 	and 	Ogur, 	"Airport 	Access 	Problems: 	Lessons
Learned 	from 	Slot 	Regulation 	by 	the 	FAA," 	Staff 	Report 	to 	the
Federal 	Trade 	Commission, 	May, 	1983; 	"Slots 	Transfer 	Methods,"
Before 	the 	Federal 	Aviation 	Administration 	("FAA"), 	Docket 	No.
24105, 	1984. 	See 	also 	"Discussion Authority 	for 	Agreement 	to
Shift 	Schedules," 	Before 	the 	Department 	of 	Transportation, 	Docket
No. 	44634, 	1987; 	"Elimination 	of 	Airport 	Delays," 	Before 	the 	FAA,
Docket 	No. 	24206, 	1984; 	"High 	Density 	Traffic 	Airports: 	Slot
Allocation 	and 	Transfer Method," 	Before 	the 	FAA, 	Docket 	No.
25758, 	1991.

6
7
Councilman 	Jerry 	Bartos
Page 	3
charges,6 	and 	airline 	computer 	reservation 	systems. 7 In 	response
to 	your 	earlier 	invitation 	to 	comment, 	I 	testified 	before 	the
Transportation 	Committee 	of 	the 	Dallas 	City Council 	on 	September
5, 	1989. 	This 	comment 	applies 	the 	same 	basic 	principles 	as 	the
earlier 	testimony, 	updated 	to 	include 	additional 	information 	and
analysis.
II. 	The Wright Amendment
In 	the 	1960's, 	Love 	Field was 	the 	only 	Dallas 	airport 	served
by major 	commercial 	airlines. 	Concern 	about 	the 	capacity 	of 	Love
Field 	and 	other 	local 	airports 	to 	keep 	up with 	the 	region's
growth 	led 	the 	cities 	of 	Dallas 	and 	Fort 	Worth 	to 	develop 	jointly
a 	regional 	airport 	located midway 	between 	the 	two 	cities. 	In
1968, 	the 	cities 	authorized 	bonds 	for 	the 	construction 	of 	D/FW.
All 	of 	the 	airlines 	operating 	out 	of 	Love 	Field 	at 	the 	time
signed 	agreements 	that 	they would move 	their 	operations 	to 	D/FW.
By 	the 	time 	DfFW was 	completed, 	Love 	Field was 	operating 	at
its 	peak 	capacity. 	Also 	by 	that 	time, 	a 	new 	airline, 	Southwest
Airlines 	("Southwest"), 	had 	begun 	operations 	out 	of 	Love 	Field.
It 	offered 	flights 	between 	the 	four 	major 	cities 	in 	Texas.
Southwest 	never 	signed 	an 	agreement 	to 	move 	its 	operations 	to
D/FW, 	and 	on 	January 	13, 	1974, 	when 	all 	the 	other 	air 	carriers
moved 	theiF 	operations 	to 	D/FW, 	Southwest 	stayed 	at 	Love 	Field.
A lawsuit 	was 	instituted 	in 	an 	effort 	to 	force 	Southwest 	to 	move
to 	D/FW; 	however, 	Southwest 	prevailed and 	continued 	to 	operate
out 	of 	Love 	Field. 9
Responding 	to 	concern 	that 	unrestricted 	air 	travel 	out 	of
Love 	Field 	might 	endanger 	the 	success 	of 	the 	new 	airport 	and
prevent 	the 	cities 	from 	meeting 	their 	bond 	obligations, 	Congress
pa'S'Sed 	legislation 	to restrict the -use of'L-ove-Field • 	The
"Proposal 	for 	Airport 	Capacity 	Efficiency," 	Massport,
1988; 	"Charges 	for 	Use 	of 	Metropolitan Washington 	Airports,"
Before 	the 	FAA, 	Docket 	No. 	25204, 	1987.
"Airline 	Computer 	Reservation 	Systems," 	Before 	the 	CAB,
Docket 	No. 	41686, 	1983.
8 Love 	Field 	had 	446,160 	takeoffs 	and 	landings 	in 	1973.
9 City 	of 	Dallas 	v. 	Southwest 	Airlines 	Company, 	371 	F.
Supp. 	1015 	(N.D. 	Tex. 	1973) 	aff'd, 	494 	F.2d 	773 	(5th 	Cir. 	1974),
cert. 	denied, 	419 	U.S. 	1079, 	reh'g 	denied, 	420 	U.S. 	913 	(1975).

The
that
and
10
11
Councilman 	Jerry 	Bartos
Page 	4
legislation, 	commonly 	referred 	to 	as 	the 	"Wright 	Amendment," 10
prohibits 	non-stop 	flights 	to 	or 	from 	Love 	Field 	and 	cities 	that
lie 	in 	states 	other 	than 	Texas, 	Arkansas, 	Louisiana, 	New Mexico,
and 	Oklahoma. 	The 	Wright 	Amendment 	also 	prohibits 	direct 	or
connecting 	service 	beyond 	the 	five-state 	area. 	For 	example, 	not
only 	are 	airlines 	prohibited 	from 	flying 	non-stop 	from 	Love 	Field
to 	Kansas 	City, 	but 	they 	are 	also 	prohibited 	from 	writing 	a
single 	ticket 	for 	travel 	between 	Love 	Field 	and 	Kansas 	City.
prohibition would 	apply 	both 	to 	a 	direct 	flight, 	such 	as 	one
lands 	in 	Oklahoma 	City 	and 	then 	continues 	on 	to 	Kansas 	City,
even 	to 	connecting 	service, 	which 	requires 	the 	passenger 	to
change 	planes 	en 	route.
Despite 	the 	Wright Amendment, 	passengers 	can 	travel 	from
Love 	Field 	to 	destinations 	outside 	the 	five-state 	area,l1 	but
only 	if 	they 	are 	willing 	to 	overcome 	a 	number 	of 	obstacles.
For 	example, 	instead 	of 	purchasing one 	roundtrip 	ticket 	to 	Kansas
City, 	a 	passenger would 	have 	to 	buy 	two 	roundtrip 	tickets, 	one
from 	Dallas 	to 	Oklahoma 	City 	and 	a 	second 	from 	Oklahoma 	City 	to
Kansas 	City. 	In 	addition, 	the 	passenger would 	have 	to 	deplane 	in
Oklahoma 	City, 	claim 	luggage, 	and, 	following 	a 	45-minute minimum
wait, 	check-in 	and 	board 	the 	next 	available 	flight 	to 	Kansas
City. 	Use 	of 	this 	procedure 	is 	further 	discouraged 	by 	the 	fact
that 	the 	Southwest 	Airlines 	flight 	schedule 	cannot 	list 	this
service 	to 	Kansas 	City 	from 	Love 	Field.
III. 	Status 	of 	D/FW and Love 	Field
Dallas/Fort 	Worth 	International 	Airport 	has 	prospered 	in 	the
18 	years 	since 	it 	opened 	and 	is 	now 	the 	second busiest 	airport 	in
the 	nation. 	Indeed, 	it 	has 	begun 	to 	experience 	the 	problems 	with
flight 	delays 	that 	inevitably 	accompany 	such 	a 	large 	amount 	of
traffic. 	To 	help 	alleviate 	this 	problem'D/FW, 	which 	currently
has 	six 	commercial 	runways, 	is 	planning 	construction 	of 	two 	more
runways. 12 	The 	restrictions 	imposed 	by 	the 	Wright 	Amendment 	may
Pub. 	L. 	No. 	96-193, 	94 	Stat. 	50, 	Feb. 	18, 	1980; 	see
also 	S. 	Henigson 	and 	R. 	Dodge, 	"House 	passes 	bill 	limiting--
interstate 	flights 	at 	Love," 	Dallas 	Time 	Herald, 	Feb. 	1, 	1980.
The 	Department 	of 	Transportation 	held 	that 	Continental
Airlines 	could 	provide 	service 	from 	Love 	Field 	to 	Houston, 	if
such 	service 	did 	not 	list 	connecting 	flights 	to 	restricted
destinations. 	DOT 	Order 	85-12-81 	(July 	26, 	1985); 	aff'd,
Continental 	Airlines 	v. 	Dept. 	of 	Transportation, 	483 	F.2d 	1444
(D.C. 	Cir. 	1988).
12 	D/FW Metroplex, 	Air 	Traffic 	System 	Plan 	Briefing 	for
City 	of 	Dallas 	Transportation 	Committee 	FAA, 	May 	23, 	1991.

Councilman 	Jerry 	Bartos
Page 	5
have 	been 	helpful 	in 	assuring 	D/FW's 	success 	initially, 	but
D/FW's 	success 	is 	now 	well 	established.
From 	its 	opening 	in 	1974 	through 	1987, 	D/FWoperations
(takeoffs 	and 	landings) 	increased 	at 	a 	rate 	of 	5 	percent 	per
year. 13 	Operations 	there 	have 	continued 	to 	increase, 	from 	a 	1988
total 	of 	about 	675,000 	(of 	which 	approximately 	75 	percent 	were
commercial 	airline 	operations)14 	to 	a 	1991 	total 	of 	735,059. 15
The 	FAA 	has 	projected 	that 	total 	operations 	at 	D/FW 	could 	reach
1,030,740 	by 	the 	year 	2000 	and 	1,146,330 	by 	2005. 16
Love 	Field, 	on 	the 	other 	hand, 	has 	a 	significant 	amount 	of
unused 	capacity. 	In 	1991, 	Love 	Field 	had 	only 	264,688
operations, 	of 	which 	approximately 	90,000 	were 	commercial
operations. 17 	The 	FAA 	1990-91 	Aviation 	System Capacity 	Plan
listed 	the 	unused 	capacity of 	Love 	Field 	at 	83,000 	operations
(allowing 	for 	an 	increase 	of 	approximately 	30 	percent).18
Consultants 	for 	the 	City of 	Dallas 	estimated 	in 	1989 	that 	the
total 	capacity of 	Love 	Field may 	be 	as 	high 	as 	435,000 	operations
per 	year. 19 	At 	the 	present 	time, 	Southwest 	Airlines, 	the 	only
major 	commercial 	airline 	operating 	out 	of 	Love 	Field, 	uses 	only
13 	gates, 	on one 	of 	the 	three 	concourses. 	Prior 	to 	the 	opening
13 	"Planning Today 	for 	2005," 	D/FW Metroplex Air 	Traffic
System 	Plan, 	FAA 	(undated).
14 Daily Aircraft 	Operations, 	FAA 	(undated) •
. 15
17
18
19
Daily 	Delays 	by 	Cause, 	Air 	Traffic 	Operations
Management 	System, 	Dallas 	Love 	Field 	and 	D/FW, 	FAA, 	January 	1990-
March 	1992. 	As 	we 	discuss 	later, 	these 	levels 	of 	operations
often 	exceed 	the 	capacity of 	D/FW 	to 	handle 	operations 	without
significant 	flight 	delays.
16 	D/FW Metroplex Air 	Traffic 	System 	Plan, 	Briefing 	for
City 	of 	Dallas 	Transportation 	Committee, 	FAA, 	May 	23, 	1991.
Daily 	Delays 	by Cause, 	Air 	Traffic 	Operations
Management 	System, 	Dallas 	Love 	Field 	and 	D/FW, 	FAA, 	January 	1990-
March 	1992.
"1990-91 	Aviation 	System 	Capacity 	Plan," 	FAA, 	Table 	5-
3, 	p. 	5-8.
Interview, 	Danny 	L. 	Bruce, 	Director 	of 	Aviation, 	City
of 	Dallas, 	August 	1, 	1989. 	This 	total 	is 	slightly below 	the
total 	operations 	in 	1973; 	see 	n. 	8.

20
21
22
23
24
Councilman 	Jerry 	Bartos
Page 	6
of 	D/FW, 	55 	gates 	were 	in 	operation 	at 	Love 	Field. 20 At 	the 	time
of 	our 	earlier 	testimony, 	there 	was 	ample 	space 	available 	for
additional 	airline 	ticket 	counters 	and 	recent 	improvements 	had
expanded 	the 	airport's 	parking 	capacity.21 	At 	that 	time 	the 	city
estimated 	that, 	even 	during 	peak 	periods, 	approximately 	40
percent 	of 	the 	airport's 	garage 	and 	surface 	lot 	parking was
unused. 22 	The March 	1990 	Peat 	Marwick 	Report 	prepared 	for 	the
D/FW 	Airport 	Board 	("Peat 	Marwick 	Report") 	confirmed 	that 	there
were 	adequate 	gate, 	terminal, 	and 	parking 	facilities 	at 	Love
Field 	to 	handle 	a 	substantial 	increase 	in 	operations. 23
Modifying 	the 	restrictions 	on Love 	Field would 	allow
airlines 	that 	serve 	Love 	Field 	to 	compete 	more 	effectively with
carriers 	based 	at 	D/FW. 	It 	would 	immediately 	allow 	Southwest
Airlines 	to 	provide 	through 	service 	from 	Dallas 	to 	the 	18
restricted 	destinations 	that 	it 	now 	serves 	from 	other 	airports. 24
In 	addition, 	two 	other 	carriers, 	Continental 	Airlines 	and America
West 	Airlines, 	can 	be 	expected 	to 	initiate 	service 	from 	Love
Letter 	dated August 	3, 	1989, 	with 	enclosures, 	from
Danny L. 	Bruce, 	Director 	of 	Aviation, 	City of 	Dallas, 	to 	Thomas
B. 	Carter, 	Director, 	Dallas 	Regional 	Office, 	Federal 	Trade
Commission. 	According 	to 	Mr. 	Bruce, 	there 	were 	at 	least 	nine
elevated 	gates 	that 	could 	be 	used 	immediately. 	In 	addition, 	some
gates 	that 	have 	been 	converted 	to 	other 	uses 	since 	D/FW 	opened
could 	be 	reconverted 	to 	airline 	gates, 	subject 	to 	certain
lessees' 	interests.
Interview, 	Danny 	Bruce, 	supra 	note 	21. 	In 	1988, 	the
City 	of 	Dallas 	spent 	$21.5 	million 	on Love 	Field 	to 	renovate 	the
terminal 	and 	provide more 	parking 	spaces. 	D. 	Dillon, 	"The 	New
Look 	of 	Love," 	Dallas 	Morning 	News, 	Feb. 	4, 	1988, 	p. 	1C.
Id. 	Moreover, 	there 	exist 	additional 	sites 	where
parking 	facilities 	have 	been 	located 	in 	the 	past.
See 	"Final 	Report: 	Evaluation 	of 	the 	Potential 	Effects
of 	Changing 	the 	Air 	Service 	Restrictions 	at 	Love 	Field 	(Wright
Amendment 	Study)" 	March 	1990, 	at 	ES-IO.
Those 	destinations 	are 	Kansas 	City, 	St. 	Louis,
Nashville, 	Birmingham, 	Chicago, 	Detroit 	(two 	airports),
Cleveland, 	Indianapolis, 	Phoenix, 	Las 	Vegas, 	Reno, 	San 	Diego, 	Los
Angeles, 	Burbank, 	Ontario, 	San 	Francisco, 	Oakland, 	and
Sacramento.

25
Councilman 	Jerry 	Bartos
Page 	7
Field. 25 Finally, 	there 	is 	some 	possibility 	that 	American
Airlines, 	Delta 	or 	another 	airline 	now 	using DjFW might 	institute
service 	at 	Love 	Field 	if 	the 	Wright 	Amendment 	were 	modified;
however, 	the 	Peat 	Marwick Report 	finds 	this 	less 	likely 	if 	the
Wright 	Amendment 	is 	not 	repealed 	completely, 	but 	instead 	is 	only
modified 	to 	permit 	through-ticketing. 26
IV. 	Benefits 	to Consumers 	in Removing Restrictions
Modifying 	the 	restrictions 	on 	the 	use 	of 	Love 	Field would
likely 	increase 	airline 	competition, 	increase 	airport 	capacity,
provide 	added 	convenience, 	and 	reduce 	congestion 	at 	DjFW. 	As 	a
result, 	consumers 	in 	Dallas, 	Fort 	Worth 	and 	elsewhere 	could
benefit 	substantially. 	Some 	of 	the 	benefits 	that 	could 	result
include 	lower 	airfares 	to 	certain 	locations, 	lower 	parking 	and
commuting 	cost, 	and 	reduced 	delays.
We 	do 	not 	specifically 	address 	how 	the 	modification 	of 	the
Wright 	Amendment 	might 	change 	noise 	levels 	in 	the 	Dallas 	area.
We 	note, 	however, 	that 	imposing 	restrictions 	on 	flight
destinations 	may 	not 	be 	an 	effective method 	for 	controlling 	noise
pollution. 	Changes 	in 	noise 	levels 	will 	be 	determined 	largely by
changes 	in 	the 	aggregate 	number 	of 	operations 	performed 	at 	the
Testimony of 	Mark Drusch, 	Director, 	Strategic 	Planning,
Continental 	Airlines 	and 	John W. 	Timmons, 	Vice 	President,
Government 	Affairs, 	America West 	Airlines, 	Before 	the
Subcommittee on Aviation 	of 	the 	Committee 	on 	Public 	Works 	and
Transportation, 	U.S. 	House 	of 	Representatives, 	September 	24,
1991. 	See 	also 	M. 	Zimmerman, 	"Field of 	Dreams," 	Dallas 	Morning
News, 	July 18, 	1989, 	p.1D; 	B. 	Roth, 	"Continental Wins 	Love 	Field
Battle," 	Dallas 	Times 	Herald, 	March 	31, 	1988, 	p. 	lB. 	See,~,
City 	of 	Dallas 	v. 	Continental 	Airlines, 	Inc., 	735 	S.W.2d 	496
(Tex. 	Ct. 	App. 	1987). 	See 	also 	"The 	Impact 	on Air 	Traffic
Activity 	at 	Dallas 	Love 	Field Resulting 	from 	Repeal 	of 	the 	Wright
Amendment," 	Reese 	& Company, 	July 	31, 	1989.
Airlines 	that 	operate 	out 	of 	DjFW may 	be 	limited 	in 	their
use 	of 	Love 	Field 	by 	the 	terms 	of 	their 	use 	agreements 	with 	DjFW
and 	the 	requirements 	of 	the 	1968 	Regional 	Airport 	Concurrent 	Bond
Ordinance 	adopted 	by 	the 	City Councils 	of 	Dallas 	and 	Fort 	Worth.
Section 	9.5 	of 	the 	Bond 	Ordinance 	requires 	the 	cities 	to 	phase
out 	the 	use 	of 	other 	airports, 	including Love 	Field, 	by
commercial 	air 	carrier 	services. 	The 	extent 	of 	the 	limitation 	on
carriers 	operating 	out 	of 	DjFW 	has 	not 	been 	fully 	determined.
26 	See 	supplemental 	Peat Marwick 	submission 	to 	Dallas 	City
Council, 	Notes 	on 	"Compromise" 	Proposal 	to 	Relax 	Wright 	Amendment
Restrictions, 	April 	26, 	1990.

27
28
Councilman 	Jerry 	Bartos
Page 	8
airport,27 	not 	by 	the 	flights' 	origins 	and 	destinations. 	The
council 	may 	wish 	to 	consider whether 	the 	goals 	of 	improved 	air
service 	and 	noise 	abatement 	can 	be 	better 	served 	through 	other
means, 	such 	as 	measures 	that 	directly 	affect 	flight 	frequency 	and
aircraft 	choice. 	For 	example, 	noise 	abatement 	might 	be 	dealt
with 	by making 	landing 	fees 	depend 	on 	the 	type 	of 	aircraft 	or
hour 	of 	operation, 	restricting 	hours 	of 	airport 	use, 	or 	requiring
the 	use 	of 	certain 	types 	of 	aircraft.
A. 	Potential 	Reductions 	in 	the 	Price of 	Airline 	Travel
from 	D/VW
There 	are 	several 	reasons 	why 	the 	proposal 	to 	permit
through-ticketing 	from 	Love 	Field 	to 	destinations 	beyond 	the
five-state 	area 	could 	result 	in 	lower 	airline 	ticket 	prices 	at
O/FW. 	First, 	easing 	the 	restrictions 	on 	Love 	Field would
increase 	the 	number 	of 	competitors 	faced 	by 	airlines 	at 	O/FW
operating 	flights 	to 	destinations 	that 	cannot 	currently 	be 	served
through 	single 	ticket 	flights 	from 	Love 	Field. 	The 	modification
would 	allow 	Southwest 	and 	other 	potential 	Love 	Field 	entrants 	to
offer 	through 	services 	to 	these 	destinations. 	Any 	impact 	on
price 	would depend, 	in 	part, 	on 	the 	extent 	of 	existing
competition among 	airlines 	providing 	service 	to 	these
destinations 	from 	O/FW 	and 	the 	degree 	to 	which 	these 	airlines,
which 	can 	offer 	nonstop 	service 	to 	such 	destinations, 	would
respond 	to 	the 	introduction 	of 	through 	service 	to 	these
destinations 	from 	Love 	Field.
Second, 	when 	O/FW 	operates 	at 	capacity, 	airline 	ticket
prices 	and 	profits 	could 	increase 	in 	response 	to 	a 	shortage 	of
gates 	and 	other 	scarce 	airport 	facilities. 28 Removing
restrictions 	at 	Love 	Field would 	increase 	available 	airport
The 	modification would 	not 	permit 	the 	addition 	of 	new
nons tops 	to 	currently 	restricted 	destinations. 	Although
passenger 	traffic 	at 	Love 	Field 	is 	likely 	to 	increase, 	some 	of
that 	increase may 	be 	absorbed 	by 	higher 	load 	factors. 	In 	other
words, 	instead 	of 	adding 	additional 	flights, 	Southwest 	passengers
may 	be 	able 	to 	use 	existing 	flights 	to 	unrestricted 	destinations
as 	the 	first 	"leg" 	of 	their 	trip 	to 	destinations 	outside 	the
five-state 	area.
When 	an 	input 	that 	is 	needed 	to 	produce 	a 	good 	or
provide 	a 	service, 	such 	as 	an 	airport 	gate 	needed 	to 	provide 	air
travel 	service, 	is 	in 	fixed 	supply, 	increasing 	demand 	for 	the
product 	or 	service 	is 	likely 	to 	cause 	the 	output's 	price 	to 	rise.
The 	additional 	revenue 	generated 	by 	this 	price 	increase 	is 	termed
a 	"scarcity 	rent."

29
Councilman 	Jerry 	Bartos
Page 	9
facilities, 	which 	in 	turn 	is 	likely 	to 	lead 	to 	lower 	prices 	of
airline 	tickets 	at 	D/FW. H
Examination 	of 	existing 	ticket 	prices 	may 	help 	suggest 	the
potential 	price 	reductions 	that 	might 	occur 	if 	the 	restrictions
at 	Love 	Field 	are 	modified. 	The 	discussion 	that 	follows 	is 	not
based 	on 	a 	sophisticated 	analysis 	of 	airline 	ticket 	prices 	in
which 	we 	control 	for 	all 	the 	determinants 	of 	prices.
Consequently, 	the 	price 	differences 	that 	we 	focus 	on 	below 	should
be 	viewed 	as 	illustrative 	of 	potential 	fare 	reductions 	that 	might
occur 	rather 	than 	conclusive 	evidence 	that 	fares 	will 	decline.
Moreover, 	we 	do 	not 	attempt 	to 	measure 	what 	part 	of 	these
conjectured 	fare 	reductions 	is 	attributable 	to 	easing 	capacity
constraints 	at 	D/FW 	and 	what 	part 	is 	due 	to 	increased competition
from 	carriers 	operating 	from 	Love 	Field.
Because 	Southwest 	Airlines 	is 	the 	major 	carrier 	at 	Love
Field and 	American Airlines 	("American") 	is 	the 	major 	carrier 	at
D/FW, 	we 	compare 	American 	and 	Southwest 	prices 	in 	the 	analysis
that 	follows. 	We 	first 	compare 	prices 	on 	routes 	on which 	both
American 	and 	Southwest 	are 	permitted 	to 	provide 	service 	in 	order
to 	examine 	whether 	the 	two 	airlines 	price 	similarly when 	serving
the 	same 	destinations. 	We 	make 	these 	comparisons 	for 	assorted
flights 	originating 	from 	both 	the 	Dallas 	and 	the 	Houston 	areas.
If 	the 	two 	airlines' 	prices 	are 	the 	same 	for 	city-pair 	routes
that 	they 	both 	serve 	now, 	it 	suggests 	that 	their 	prices 	would 	be
similar on 	routes 	that 	Southwest 	would 	serve 	if 	the 	restrictions
at 	Love 	Field were 	removed. 	This 	prediction 	assumes 	that 	one-
stop 	service 	competes 	effectively with 	nonstop 	service.
We 	then 	compare American's 	prices 	from 	D/FW 	to 	destinations
that 	Southwest 	cannot 	serve 	from 	Love 	Field with 	American 	and
Southwest 	prices 	from 	the 	Houston 	area to these 'same
destinations. 3o Service 	to 	the 	listed destinations 	from 	D/FW 	and
from 	Houston 	is 	similar, 	in 	that 	both 	Dallas 	and 	Houston 	have 	a
newer 	regional 	airport 	and 	an 	older 	in-town 	airport, 	the
distances 	of 	the 	routes 	to 	the 	listed 	destinations 	are
Capacity 	constraints 	may 	be 	eased 	to 	some 	extent 	by
expansion 	of 	facilities 	at 	D/FW, 	planned 	for 	the 	relatively 	near
future.
30 There 	are 	no 	destination 	restrictions
leaving 	from 	Houston; 	therefore, 	it 	is 	possible
Southwest 	fares 	and 	American 	fares 	from 	Houston
that 	Southwest 	cannot 	serve 	from 	Love 	Field.
on 	flights
to 	compare
to 	destinations

31
32
33
34
Councilman 	Jerry 	Bartos
Page 	10
comparable, 	and 	the 	cities 	are 	of 	comparable 	size 	and 	location. 31
Consequently, 	provided 	that 	no 	significant 	remaining 	differences
exist 	between 	flights 	originating 	in 	Dallas 	and 	Houston 	that
might 	affect 	fares, 	differences 	in 	fares 	may 	reflect 	the 	impact
that 	the 	restrictions 	at 	Love 	Field 	have 	on 	D/FW 	prices.
We 	have 	taken 	four 	separate 	benchmark 	price 	comparisons 	to
show 	that 	the 	higher 	prices 	faced 	by 	Dallas 	consumers 	have
extended 	over 	time, 	in 	both 	peak 	summer 	periods 	and 	during 	slower
winter 	months 	when 	the 	industry 	traditionally 	lowers 	airfares.
Tables 	1 	through 	4 	provide 	price 	comparisons 	for 	the 	following
time 	periods: 	August 	1989, 	February 	1990, 	September 	1991, 	and
April 	1992.
The 	American 	prices 	were 	obtained 	from 	one 	of 	the 	computer
reservation 	systems 	used 	by 	travel 	agents 	allover 	the 	United
States. 32 The 	Southwest 	prices 	were 	obtained by 	contacting
Southwest 	reservation 	services 	directly. 	Consequently, 	prices
obtained 	are 	likely 	to 	be 	accurate 	indicators 	of 	what 	consumers
actually 	pay 	for 	their 	airline 	tickets. 	We 	provide 	data 	on 	the
lowest 	available 	fare 	and 	on 	unrestricted 	fares 	for 	weekday
travel 	(" full 	fare"). 33 	These 	latter 	fares 	are 	provided 	to
estimate 	the 	typical 	fares 	business 	travelers 	are 	likely 	to 	face
when 	flying 	during 	weekdays 	without 	advance 	reservations. 34
The 	price 	comparisons 	in 	these 	Tables 	suggest 	that 	for
routes 	unaffected 	by 	the 	Wright 	Amendment, 	American 	tends 	to
offer 	the 	same 	range 	of 	prices 	as 	Southwest. 	This 	is 	true 	for
virtually 	all 	flights 	from 	Dallas 	in 	all 	four 	time 	periods. 	For
example, 	in August 	1989, 	the 	lowest 	price 	for 	a 	roundtrip
The 	American 	prices 	are 	for 	"coach" 	travel 'whic'h 	is 	the
closest 	comparable 	service 	to 	that 	offered 	by 	Southwest.
A sample 	of 	"Full 	Fare" 	prices 	was 	double 	checked 	by
contacting American 	reservations 	directly.
Some 	of 	the 	American 	unrestricted 	fares 	have 	limits 	on
the 	number 	of 	stopovers 	and 	may 	require 	a 	roundtrip 	booking. 	It
is 	interesting 	to 	note 	that 	these 	limitations 	may 	have 	the 	effect
of 	prohibiting 	Dallas 	passengers 	from 	taking 	advantage 	of 	the
lower 	fares 	on 	flights 	out 	of 	Houston 	that 	stop 	in 	Dallas 	before
continuing 	to 	destinations 	that 	cannot 	be 	served 	from 	Love 	Field.
Except 	for 	these 	limitations, 	American's 	full 	fares 	reflect 	the
lowest 	fare 	a 	passenger 	could 	obtain without 	any 	conditions 	on
advance 	purchases, 	minimum 	stay, 	time 	of 	day 	travel, 	etc.
Since 	we 	do 	not 	have 	information on 	how many 	tickets
were 	purchased 	at 	these 	and 	other 	prices, 	our 	discussion 	is 	based
on 	comparisons 	of 	list 	prices, 	not 	average 	prices.

36
Councilman 	Jerry Bartos
Page 	11
Southwest 	flight 	from 	Love 	Field 	to 	either 	Little 	Rock, 	Houston,
Austin 	or 	San Antonio 	was 	$38. 	American's 	lowest 	priced 	fares
from 	D/FW 	to 	these 	cities 	was 	also 	$38 	(see 	Table 	1). 	As 	of
April 	28, 	1992, 	American 	and 	Southwest 	continue 	to 	price 	their
lowest 	fares 	from 	Dallas 	to 	these 	destinations 	very 	closely 	(see
Table 	4). 	Similarly, 	for 	three 	out 	of 	the 	four 	Houston
benchmarks, 	both 	Southwest's 	and 	American's 	lowest 	available
fares 	to 	Nashville, 	Birmingham, 	St. 	Louis, 	and 	Kansas 	City were
all 	very 	closely 	priced 	(see 	Tables 	1, 	2 	and 	3). 	Only 	in 	the
most 	recent 	time 	period 	has 	American 	failed 	to 	match 	Southwest
fares 	from 	Houston 	to 	these 	destinations 	(see 	Table 	4).35
Comparisons 	of 	full 	fares 	shown 	in 	Tables 	1 	through 	4 	suggest
that 	the 	airlines 	also 	price 	these 	types 	of 	fares 	similarly,
though 	significant 	differences 	exist 	between American's 	and
Southwest's 	fares 	from 	Houston 	to 	certain 	destinations 	at 	certain
times.
Overall, 	these 	price 	comparisons 	suggest 	that 	when 	Southwest
and 	American 	serve 	the 	same 	city-pairs, 	the 	two 	airlines 	often
tend 	to 	offer 	a 	similar 	range 	of 	fares. 	This 	suggests 	that 	if
Southwest 	were 	permitted 	to 	serve 	destinations 	that 	it 	cannot
presently 	serve 	from 	Love 	Field, 	American 	is 	likely 	in many
instances 	to 	price 	similarly 	to 	Southwest 	on 	flights 	from 	D/FW 	to
those 	destinations.
Next, 	we 	compare 	American 	prices 	on 	routes 	from 	D/FW 	to
destinations 	that 	Southwest 	cannot 	serve 	from 	Love 	Field with
prices 	on 	routes 	from 	Houston 	to 	these 	same 	destinations. 	In
particular, 	we 	present 	American 	fares 	from 	D/FW 	to 	Kansas 	City,
Nashville, 	Birmingham, 	and 	St. 	Louis 	as 	well 	as 	American 	and
Southwest 	fares 	from 	Houston 	to 	these 	same 	cities. 	The 	Tables
show 	that 	the 	lowest 	available 	fares 	from 	Houston 	to 	Kansas 	City,
Nashville, 	Birmingham, 	and 	St. 	Louis 	are 	significantly 	below 	the
fares 	from 	D/FW 	to 	these 	destinations. 	For 	example, 	in August
1989, 	the 	lowest 	available 	fare 	from 	the 	Houston 	area 	to 	St.
Louis 	was 	$98 36 and 	the 	lowest 	available 	fare 	from 	Dallas 	to 	St.
Louis 	was 	$200. 	In 	April 	1992, 	although 	the 	differences 	in
American's 	fares 	from 	Dallas 	and 	Houston were 	not 	nearly 	as
great, 	Houston consumers 	continued 	to 	enjoy 	lower 	fares 	to 	these
four 	destinations 	primarily because 	they 	could 	fly 	to 	them 	on
35 	American 	routes 	these 	flights 	through 	D/FW. 	American
may 	have 	few 	passengers 	traveling 	from 	Houston 	to 	these
destinations 	since 	consumers 	are 	unlikely 	to 	choose 	higher 	prices
for 	nondirect 	flights. 	'
The 	$98 	fare 	was 	available 	on 	both 	American 	and
Southwest 	flights 	to 	St. 	Louis.

Councilman 	Jerry 	Bartos
Page 	12
Southwest. 	For 	example, 	the 	lowest 	fare 	to 	Birmingham 	from
Houston was 	$152 37 and 	from 	Dallas 	it 	was 	$260.
The 	Tables 	show 	that 	for 	full 	fares 	the 	disparity 	is 	even
larger, 	with 	full 	fares 	from 	D/FW 	being 	sometimes 	as 	much 	as 	four
times 	more 	than 	full 	fares 	on 	routes 	originating 	in Houston.
Thus, 	in August 	1989, 	American's 	full 	fare 	roundtrip 	from 	Houston
to 	Nashville 	was 	$168, 	and 	its 	full 	fare 	from 	Dallas 	to 	Nashville
was 	$672. 	As 	recently 	as 	October 	1991, 	American 	charged 	a 	$309
full 	fare 	roundtrip 	rate 	from 	Houston 	to 	Birmingham while
charging 	a 	$864 	full 	fare 	rate 	from 	Dallas. 	American's 	April
1992 	full 	fares 	to 	all 	four 	destinations 	were 	about 	the 	same 	from
Dallas 	and 	Houston. 	However, 	Southwest 	continued 	to 	offer
significantly 	lower 	fares 	from 	Houston 	to 	each 	of 	these
destinations 	that 	cannot 	be 	reached 	by 	Southwest 	out 	of 	Love
Field.
Another way 	to 	demonstrate 	the 	modification's 	potential
benefits 	to 	consumers 	is 	to 	review American's 	per mile 	charge
from 	D/FW 	to 	destinations 	inside 	the 	five-state 	area 	versus 	its
per 	mile 	charge 	to 	destinations 	outside 	that 	area. 	Table 	5 	lists
American's 	April 	1992 	lowest 	available 	fares 	and 	full 	fares 	from
Dallas 	to 	selected destinations 	that 	can 	be 	served 	from 	Love
Field 	and 	to 	selected destinations 	that 	cannot 	be 	served 	from
Love 	Field. 	A second column 	lists 	the 	approximate 	roundtrip
distance 	between 	Dallas 	and 	each 	destination. 	The 	third column
is 	a 	calculation of 	the 	price 	per mile 	to 	fly 	to 	each
destination. 	An 	average 	price 	per 	mile 	is 	calculated using 	the
destinations 	shown 	in 	each 	of 	the 	categories. 	As 	this 	table
shows, 	American's 	per mile 	charge 	is 	significantly higher 	to
destinations 	that 	cannot 	be 	served 	from 	Love 	Field. 	The 	lowest
available 	fares 	are 	77 	percent 	higher 	and 	the 	full 	fares 	are 	36.7
percent 	higher, 	on 	average. 	For 	example, 	it 	costs 	20.4
cents/mile 	to 	fly 	American's 	lowest 	available 	fare 	roundtrip 	from
D/FW 	to 	Birmingham, 	a 	distance 	of 	1,270 	miles 	and 	only 	11.3
cents/mile 	to 	fly 	American 	roundtrip 	to 	Albuquerque, 	which 	is 	18
miles 	further. 	Similarly, 	a 	1,034 	mile 	roundtrip 	from 	Dallas 	to
New 	Orleans 	on 	an 	American 	full 	price 	fare 	costs 	19.1 	cents/mile
while 	traveling 	1,010 	miles 	to 	Kansas 	City 	costs 	39.6
cents/mile.~
In 	summary, 	our 	analysis 	suggests 	that 	when 	serving 	the 	same
city-pairs 	Southwest 	and 	American 	often 	tend 	to 	offer 	similar
37 The 	$152 	fare 	was 	available 	on 	Southwest.
American 	fare 	from 	Houston 	to 	Birmingham was 	$192.
The 	lowest
38 Many 	elements 	enter 	into 	determining 	the 	costs 	and
prices 	of 	serving 	a 	city 	pair, 	so 	cents 	per mile 	is 	only 	a 	rough
measure 	for 	comparing 	competitive 	conditions.

39
Councilman 	Jerry 	Bartos
Page 	13
fares 	and 	that 	prices 	from 	D/FW 	to 	destinations 	that 	cannot 	be
served 	by 	operations 	from 	Love 	Field 	are 	significantly 	higher
than 	fares 	from 	Houston 	to 	these 	same 	destinations. 	Moreover, 	a
review 	of 	fares 	from 	D/FW 	reveals 	a 	large 	disparity 	in 	the 	per
mile 	charge 	and 	the 	relative 	average 	fare 	to 	destinations 	that
can 	and 	those 	that 	cannot 	be 	served 	from 	Love 	Field. 	This
evidence, 	although 	illustrative 	rather 	than 	conclusive, 	suggests
that 	permitting 	through-ticketing 	from 	Love 	Field 	to 	destinations
outside 	the 	five-state 	area 	would 	tend 	to 	increase 	competition
faced 	by 	airlines 	serving 	D/FW 	and 	increase 	airport 	capacity, 	and
may, 	therefore, 	reduce 	airfares 	for 	consumers 	flying 	into 	and 	out
of 	DjFW 	airport. 39
B. 	Potential 	Reductions 	in 	the 	Price 	of 	Airline 	Travel
from 	Love 	Field
There 	are 	several 	reasons 	why 	permitting 	through-ticketing
to 	destinations 	beyond 	the 	five-state 	area 	could 	save 	money 	for
consumers 	already 	using Love 	Field. 	First, 	passengers 	who
currently must 	purchase 	two 	roundtrip 	tickets 	to 	fly 	from 	Love
Field 	to 	destinations 	outside 	the 	five-state 	area 	would 	be
permitted 	to 	fly 	to 	those 	destinations 	on 	a 	less 	expensive 	single
ticket. 	Second, 	increased 	competition 	between 	Southwest 	and
additional 	airlines, 	which may 	choose 	to 	serve 	Love 	Field, 	could
A study 	of 	airfares 	conducted by America 	West 	Airlines
supports 	the 	findings 	of 	our 	analysis 	("The 	Economic 	Consequences
of 	the 	Wright 	Amendment 	on 	Texas 	Travelers," 	Planning 	Division,
March 	25, 	1991). 	After 	controlling 	for 	service 	quality 	(the
average 	number 	of 	coupons 	used 	per 	city-pair 	-- 	nonstop 	and
single-plane 	passengers 	use 	one 	coupon, 	while 	connecting
passengers 	use 	two 	coupons) 	and 	mileage, 	the 	America 	West 	study
finds 	that 	Dallas 	passengers 	pay 	significantly 	higher 	fares 	than
passengers 	in 	Houston when 	flying 	to 	cities 	served by 	Southwest
that 	are 	outside 	the 	five-state 	area. 	Moreover, 	the 	study 	finds
that 	fares 	from 	Dallas 	to 	these 	cities 	are 	above 	the 	industry
average 	fare 	for 	the 	particular 	quality 	and 	distance 	of 	the
flights.
When 	examining 	fares 	to 	cities 	within 	the 	five-state 	area,
however, 	the 	study 	indicates 	that 	Dallas 	and 	Houston 	airfares 	are
comparable 	and 	below 	the 	industry 	average 	fare 	for 	the 	quality
and 	distance 	of 	the 	flights. 	Consequently, 	this 	study
corroborates 	the 	conclusions 	based 	on 	the 	fare 	comparisons
developed 	by 	the 	staff 	of 	the 	FTC. 	The 	America 	West 	study 	is
broader 	in 	scope 	than 	the 	staff 	analysis 	because 	it 	includes
price 	comparisons 	to 	all 	major 	domestic 	destinations 	and 	uses 	a
weighted 	average 	fare 	actually 	paid 	by 	passengers 	during 	the
third 	quarter 	of 	1990.

Councilman 	Jerry'Bartos
Page 	14
further 	reduce 	fares 	to 	cities 	both 	inside 	and 	outside 	the 	five-
state 	area.
As 	described 	earlier, 	under 	the 	current 	federal
restrictions, 	passengers 	who 	wish 	to 	fly 	from 	Love 	Field 	to
destinations 	outside 	the 	five-state 	area 	may 	do 	so 	by 	purchasing
two 	roundtrip 	tickets 	-- 	one 	to 	a 	point 	inside 	the 	five-state
area 	and 	the 	second 	from 	that 	point 	to 	their 	desired 	destination.
Although 	no 	accurate 	records 	are 	kept 	of 	the 	number 	of 	passengers
who 	follow 	this 	procedure, 	it 	may 	be 	significant 	in 	light 	of 	the
substantial 	savings 	passengers 	can 	achieve. 	Table 	6 	lists
Southwest's 	April 	1992 	double 	ticket 	fares 	from 	Love 	Field 	to
selected 	destinations 	that 	cannot 	be 	served using 	a 	single 	ticket
due 	to 	the 	Wright 	Amendment. 	These 	fares 	are 	contrasted with
American's 	April 	1992 	single 	ticket 	fares 	from 	D/FW 	to 	these 	same
destinations. 	As 	Table 	6 	indicates, 	even 	compared 	to 	America's
new 	lower 	fare 	structure, 	passengers 	can 	save 	up 	to 	30 	percent 	by
flying 	Southwest 	out 	of 	Love 	Field 	and 	using 	two 	tickets.
An 	analysis 	of 	Southwest's 	April 	1992 	single 	versus 	double
ticket 	fares 	to 	selected 	destinations 	from 	Houston Hobby 	suggests
that 	modifying 	the 	Wright 	Amendment 	to 	permit 	single 	ticket 	.
through 	service 	from 	Love 	Field 	to 	destinations 	outside 	the 	five-
state 	area 	would 	likely 	save 	Southwest 	passengers 	even more.
Table 	7 	lists 	single 	ticket 	prices 	that 	Southwest 'charges 	Houston
passengers 	traveling 	to 	four 	selected 	destinations 	outside 	the
five-state 	area. 	Also 	shown 	are 	the 	double 	ticket 	costs 	that
Houston 	passengers 	would 	face 	if 	the 	same 	restriction 	currently
placed 	on 	Southwest 	flights 	at 	Love 	Field were 	placed 	on
Southwest 	flights 	from 	Houston. 	Ticket 	prices 	are 	given 	for 	21-
day 	advance 	fares 	for 	both peak 	and 	off 	peak 	travel 	and 	for 	no
advance 	fares 	for 	peak 	and 	off 	peak 	periods. 	In 	all 	but 	one
instance 	the 	double 	ticket 	fares 	were 	higher 	than 	the 	single
ticket 	fares. 	Often 	they were 	substantially 	higher. 	For
example, 	the 	single 	ticket 	21-day 	advance 	off 	peak 	fare 	from
Houston 	to 	Nashville 	was 	$152, 	while 	the 	double 	ticket 	fare 	from
Houston 	through 	New 	Orleans 	would 	have 	been 	$286. 	The 	added 	cost
of 	the 	restrictions 	in 	that 	case 	would 	have 	been 	$134, 	an 	88
percent 	increase 	over 	the 	single 	ticket 	fare. 40
There 	is 	also 	some 	evidence 	to 	suggest 	that 	easing 	the
Wright 	Amendment's 	restrictions 	on Love 	Field would 	cause
Southwest 	to 	reduce 	its 	already 	low 	fares 	if 	there 	is 	entry 	into
40 	The 	added-cost 	figures 	in 	Table 	7 	are 	probably 	upper-
bound 	estimates 	of 	possible 	savings 	that 	Dallas 	consumers 	might
realize, 	because 	current 	Southwest 	double 	ticket 	prices 	at
Houston 	might 	be 	less 	likely 	than 	its 	prices 	at 	Love 	Field 	to
take 	account 	of 	competition with 	single 	ticket 	prices.

41
42
Councilman 	Jerry 	Bartos
Page 	15
Love 	Field 	by 	other 	low 	fare 	carriers 	such 	as 	Continental 	and
America 	West.
America 	West 	contends 	that 	the 	current 	"legislative
monopoly" 	t~at Southwest 	enjoys 	at 	Love 	Field 	has 	allowed
Southwest 	to 	charge 	higher 	per mile 	fares 	on 	its 	Love 	Field
routes 	than 	on 	routes 	where 	Southwest 	has 	more 	direct 	and 	heated
competition. 	To 	support 	this 	contention, 	America 	West 	has
developed 	a 	study, 	based on 	Department 	of 	Transportation 	data,
that 	compares 	Southwest's 	third-quarter 	1991 	average 	air 	fares
between various 	destinations. 41 The 	study 	indicated, 	for
example, 	that 	Southwest's 	Dallas 	fares 	were 	about 	50 	percent
higher 	than 	its 	fares 	from 	the 	more 	competitive 	Phoenix 	Airport.
This 	study 	suggests 	that 	if 	Southwest 	faced 	competition 	at 	Love
Field 	similar 	to 	that 	faced 	at 	other 	airports 	which 	Southwest
serves, 	Southwest's 	fares 	might 	be 	even 	lower.
c. 	Potential 	Reductions 	in 	Delay 	Time
There 	are 	other 	potential 	benefits 	to 	modifying 	the
restrictions 	on 	traffic 	into 	and 	out 	of 	Love 	Field. 	There 	are
times 	when 	the 	demand 	for 	operations 	at 	D/FW 	exceeds 	the
airport's 	capacity. 	During 	these 	peak 	use 	periods, 	the 	cost 	of
an 	aircraft 	using 	terminal 	gate 	space, 	taxiway, 	and 	runways
consists 	of 	the 	actual 	resource 	costs 	incurred 	(~, 	the 	use 	of
air 	and 	ground 	traffic 	controllers) 	plus 	the 	additional 	cost 	that
the 	operation 	imposes 	on other 	operations 	that 	would 	have 	used
the 	airport 	facilities. 	The 	costs 	associated 	with 	preventing
other 	aircraft 	from 	using 	airport 	facilities 	are 	known 	as
congestion 	costs. 	During peak 	use 	periods 	when many 	aircraft
want 	to 	use 	the 	limited 	airport 	facilities 	at 	the 	same 	time, 	the
congestion 	costs 	for 	any 	single 	operation 	can be 	significant.
If 	modifying 	the 	Wright 	Amendment 	caused 	some 	shift 	in
operations 	from 	D/FW 	to 	Love 	Field, 	then 	such 	a 	modification
could 	benefit 	consumers 	by 	reducing 	congestion 	costs 	at 	D/FW. 42
T. 	Maxon, 	"Wright 	Amendment 	Unfairly Keeps 	Airline 	In
Black 	Rival 	Claims," 	Dallas 	Morning 	News, 	April 	19, 	1992. 	See
also 	"The 	Economic 	Consequences 	of 	the 	Wright 	Amendment 	on 	Texas
Travelers," 	America 	West 	Airlines, 	Inc., 	Planning 	Division, 	March
25, 	1991.
A shift 	in 	operations 	could 	occur because 	Southwest
would expand 	its 	operations 	to 	routes 	that 	were 	previously
restricted, 	thereby 	reducing 	the 	demand 	for 	operations 	at 	D/FW.
In 	addition, 	air 	carriers 	other 	than 	Southwest may wish 	to 	shift
some 	of 	their 	operations 	from 	D/FW 	to 	Love 	Field. 	Note 	that 	our
analysis 	would 	be 	similar 	if 	instead 	of 	existing 	operations
(continued ... )

44
45
46
Councilman 	Jerry 	Bartos
Page 	16
There 	are 	data 	suggesting 	that 	the 	congestion 	costs 	at 	DjFW 	are
significant 	and 	becoming more 	severe 	over 	time. 	For 	example, 	one
important 	cost 	is 	the 	delay 	time 	imposed 	on 	passengers 	on 	flights
waiting 	to 	use 	a 	runway.
FAA 	delay 	data 	indicate 	that 	during 	1988 	there 	were 	over
10,000 	delays 	at 	DjFW 	and 	that 	many 	of 	these 	delays 	were
attributable 	to 	airport 	volume. 	The 	FAA 	data 	indicate 	that
during 	the 	six-month 	period 	from 	March 	through 	July 	1989, 	18
percent 	of 	delays 	were 	attributed 	to 	airport 	volume. 	By 	1991,
there 	were 	over 	25,000 	delays 	at 	DjFW, 	and 	over 	30 	percent 	of
these 	delays 	were 	attributed 	to 	traffic 	volume. 43 These 	data
imply 	that 	a 	reduction 	in 	operations, 	when 	an 	airport 	is 	near 	its
capacity, 	can 	have 	a 	significant 	impact 	on 	delay 	time. 	It 	has
been 	estimated, 	for 	example, 	that 	if 	there 	were 	20 	departures 	per
runway 	per 	hour, 	a 	1 	percent 	increase 	in 	commercial 	air 	carrier
departures 	would 	cause 	an 	increase 	in 	average 	departure 	delay 	of
2.9 	percent. 	Similarly, 	if 	there 	were 	20 	arrivals 	per 	runway 	in
the 	same 	hour, 	a 	1 percent 	increase 	in 	air 	carrier 	arrivals 	per
runway would 	increase 	departure 	delay 	by 	an 	additional 	1.6
percent. 44 	As 	discussed 	below, 	recent 	FAA 	data 	suggest 	that 	at
the 	current 	level 	of 	operations 	at 	DjFW, 	the 	sensitivity of 	delay
time 	to 	changes 	in 	operations 	might 	be 	even more 	pronounced 	than
these 	estimates. 	Thus, 	given 	traffic 	volume 	at 	peak 	hours 	at
DjFW, 	any 	reduction 	in 	the 	number 	of 	operations 	is 	likely 	to
cause 	a 	significant 	reduction 	in 	delays.
Love 	Field, 	by 	contrast, 	does 	not 	appear 	to 	be 	capacity
constrained. 	The 	FAA 	estimates 	that 	from 	March 	through 	July 	1989
Love 	Field 	experienced 	only 	349 	delays,45 	none 	of 	which 	was
attributable 	to 	airport 	volume. 46 In 	1991, 	there 	were 	over
264,000 	operations 	at Love 	Field. 	Yet, 	there 	were 	only 	309
42( ... continued)
shifting 	from 	DjFW 	to 	Love 	Field, 	Love 	Field 	received 	a 	greater
proportion 	of 	any 	growth 	in 	the 	demand 	for 	operations.
43 	Daily 	Delays 	by 	Cause, 	Air 	Traffic 	Operations
Management 	System, 	DjFW, 	FAA, 	January 	1990-March 	1992.
S. 	Morrison 	and 	C. 	Winston, 	"Enhancing 	the 	Performance
of 	the 	Deregulated Air 	Transportation 	System," 	Brookings 	Papers
on 	Economic 	Activity, 	M. 	Bailey 	and 	C. 	Winston, 	Ed., 	Brookings
Institution, 	Washington, 	D.C., 	1989.
In 	1988, 	the 	number 	of 	delays 	per 	thousand 	operations
at 	DjFW was 	almost 	six 	times 	greater 	than 	at 	Love 	Field.
Daily 	Delays 	by 	Cause, 	Air 	Traffic 	Operations
Management 	System, 	Dallas 	Love 	Field 	and 	DjFW, 	FAA, 	1989.

47
48
Councilman 	Jerry 	Bartos
Page 	17
delays, 	with 	only 	60 	delays 	being 	attributable 	to 	airport
volume. 47 Thus, 	the 	FAA 	data 	suggest 	that 	Love 	Field 	can
effectively handle 	more 	operations 	without 	significantly
increasing 	the 	number 	of 	delays.
Table 	8 	presents 	the 	most 	recent 	available 	delay 	data 	for
Love 	Field 	and 	D/FW. 	These 	data 	clearly 	show 	that 	on 	any 	given
day 	the 	probability 	of 	experiencing 	a 	delay 	at 	Love 	Field 	is
extremely 	small, 	while 	there 	is 	a 	significant 	chance 	of 	delay 	at
D/FW.
Based 	on 	these 	disparities 	in 	the 	effect 	of 	operations 	on
delay 	time 	at 	the 	two 	airports, 	the 	1989 	staff 	testimony 	provided
an 	illustrative 	example 	of 	the 	potential 	savings 	in 	delay 	time
that 	might 	be 	achieved 	if 	5 	percent 	or 	10 	percent 	of 	the
commercial 	traffic 	at 	D/FW 	shifted 	to 	Love 	Field. 48 The 	savings
Daily 	Delays 	by Cause, 	Air 	Traffic 	Operations
Management 	System, 	Dallas 	Love 	Field 	and 	D/FW, 	FAA, 	1991.
In March 	1990, 	Peat 	Marwick 	conducted 	an 	analysis 	of
the 	effect 	of 	repealing 	the 	Wright 	Amendment 	on 	delays 	at 	D/FW
and 	Love 	Field. 	See 	"Final 	Report: 	Evaluation of 	the 	Potential
Effects 	of 	Changing 	the 	Air 	Service 	Restrictions 	at 	Love 	Field. II
The 	Peat 	Marwick Report 	analyzes 	the 	effects 	of 	modifying 	the
Wright 	Amendment 	under 	several 	different 	scenarios. 	In 	1989, 	the
FTC 	staff 	analyzed 	the 	effect 	of 	shifting 	5 	percent 	or 	10 	percent
of 	D/FW's 	commercial 	operations 	to 	Love 	Field. 	Applying 	this
assumption 	to 	the 	Peat 	Marwick model 	yields 	results 	that 	are
consistent 	with 	the 	FTC 	analysis; 	delays 	at 	Love 	Field 	would 	not
be 	significantly 	altered 	by 	5 	or 	10 	percent 	of 	the 	commercial
aircraft 	switching 	operations 	to 	Love 	Field 	(in 	19B8, 	the 	10
percent 	shift 	would 	have 	increased 	operations 	at 	Love 	Field 	by
50,000 	resulting 	in 	260,000 	operations 	at 	Love 	Field). 	Actual
FAA 	data 	indicate 	that 	this 	assumption was 	correct. 	In 	1991,
Love 	Field 	had 	over 	264,000 	operations, 	yet 	delays 	actually
declined.
The 	Peat 	Marwick 	Report 	concludes, 	however, 	that 	larger
shifts 	in 	operations 	from 	D/FW 	to 	Love 	Field would 	result 	in
large 	increases 	in 	delays 	at 	Love 	Field. 	Under 	the 	assumption
that 	the 	Trinity 	River 	Departure 	("TRD") 	procedure 	would 	be 	in
use 	24 	hours 	a 	day, 	the 	study 	shows 	that 	large 	increases 	in 	the
number 	of 	operations 	at 	Love 	Field 	result 	in 	enormous 	increases
in 	delay 	time. 	The 	TRD 	procedure, 	however, 	is 	currently 	in 	use
only 	nine 	hours 	per 	day 	and 	according 	to 	Herbert 	Kelleher,
Chairman 	of 	the 	Board, 	President 	and 	Chief 	Executive 	Officer 	of
Southwest 	Airlines, 	"Peat Marwick 	assumes 	an 	unrealistic 	24 	hour
per 	day 	use 	of 	the 	TRD 	route." 	See Memorandum 	dated May 	2, 	1990,
( continued ... )

49
50
Councilman 	Jerry 	Bartos
Page 	18
in 	delay 	time 	were 	predicted 	to 	be 	significant 	because 	not 	only
would 	passengers 	moving 	to 	Love 	Field 	experience 	reductions 	in
delay, 	but 	passengers 	remaining 	at 	ojFW would 	also 	experience
reduced 	delays 	due 	to 	a 	reduction 	in 	the 	number 	of 	operations 	at
that 	airport.
Since 	the 	1989 	testimony, 	the 	number 	of 	delays 	at 	DjFW 	has
increased 	markedly, 	from 	10,377 	delays 	in 	1988, 	to 	19,216 	delays
in 	1990, 	to 	25,959 	delays 	in 	1991. 49 While 	operations 	of 	ojFW
also 	increased 	during 	this 	period, 	delays 	per 	operation 	rose
dramatically. 	In 	1988, 	there 	were 	678,247 	operations, 	so 	there
were 	15.3 	delays 	per 	thousand 	operations. 	By 	1991, 	there 	were
735,059 	operations, 	and 	35.3 	delays 	per 	thousand 	operations.
These 	data 	indicate 	that 	the 	benefits 	from 	shifting 	operations
from 	OjFW 	to 	Love 	Field 	are 	likely 	to 	be 	even more 	pronounced 	now
than 	they 	were 	in 	1989.
D. 	Potential 	Savings 	in 	Commuting 	Costs 	and 	Parking 	Fees
Love 	Field 	is 	closer 	to 	downtown 	Dallas 	than 	DjFW 	by
approximately 	10 	miles. 	Since 	a 	significant 	percentage 	of 	air
travellers 	are 	likely 	to 	be 	traveling 	to 	or 	from 	downtown 	Dallas,
shifting 	traffic 	from 	DjFW 	to 	Love 	Field will 	lower 	commuting
costs 	to 	these 	passengers. 50 For 	example, 	according 	to 	Yellow
Checker 	Cab 	the 	one-way 	fare 	from 	ojFW 	to 	downtown 	Dallas 	is
$27.90, 	while 	the 	charge 	from 	Love 	Field 	is 	approximately 	$11.00.
That 	difference 	results 	in 	a 	roundtrip 	saving 	of 	over 	$33.00.
Commuters 	using 	their 	private vehicles 	would 	also 	save 	a
significant 	amount 	if 	they were 	able 	to 	shift 	to 	Love 	Field.
Utilizing 	a 	conservative 	estimate 	of 	25 	cents 	per mile 	operating
cost, 	such consumers 	would 	experience 	a 	$5.00 	per 	roundtrip
.savings.
In 	addition, 	shifting 	traffic 	from 	ojFW 	to 	Love 	Field would
enable 	consumers 	to 	save 	on 	parking 	fees 	and 	save 	time 	getting 	to
48( ••• continued)
from 	Herbert 	Kelleher, 	Chairman 	of 	the 	Board, 	Southwest 	Airlines,
to 	Dallas 	City 	Council. 	Under 	the 	assumption 	that 	the 	TRD
procedure 	continues 	in 	its 	present 	use, 	the 	Peat 	Marwick 	Report
shows 	that 	if 	the 	Wright 	Amendment 	was 	repealed 	delays 	at 	Love
Field 	would 	be 	less 	than 	delays 	at 	ojFW 	without 	repeal.
See 	"Air 	Traffic 	Activity 	and 	Delay 	Report," 	Air
Traffic 	System Management, 	NAS 	Analysis 	Program, 	FAA, 	September
1991. 	ATM-300.
Note 	that 	commuters 	who 	live 	closer 	to 	Love 	Field 	than
DjFW 	will 	also 	experience 	lower 	commuting 	costs 	to 	the 	extent
they 	are 	able 	to 	make 	greater 	use 	of 	Love 	Field.

Councilman 	Jerry 	Bartos
Page 	19
and 	from 	the 	airport 	terminal. 	Close-in 	terminal 	parking 	at 	DjFW
costs 	$12.00 	per 	day. 	Parking 	close 	to 	the 	terminal 	at 	Love
Field 	is 	$6.00 	per 	day 	in 	the 	covered 	garage 	and 	$4.00 	per 	day 	in
the 	open 	lot. 	DjFW 	has 	remote 	parking 	at 	comparable 	rates 	to
parking 	at 	Love 	Field, 	but 	it 	is 	far 	from 	the 	terminals 	and
involves 	waiting 	for 	transportation 	to 	arrive 	and 	entails 	a
significant 	amount 	of 	travel 	time 	between 	the 	lots 	and 	the
terminal. 	Therefore, 	the 	ability 	to 	fly 	from 	Love 	Field 	could
save 	consumers 	money 	in 	parking 	fees 	and 	time 	expended 	getting
from 	the 	parking 	lot 	to 	the 	terminal.
v. 	Conclusion
This 	letter 	analyzes 	the 	potential 	impact 	of 	modifying 	the
restrictions 	at 	Love 	Field on 	airline 	ticket 	prices, 	commuting
costs, 	and 	delay 	time. 	The 	analysis 	shows 	that 	removing 	the
restrictions 	may 	result 	in 	lower 	air 	fares 	both 	at 	DjFW 	and 	at
Love 	Field 	as 	well 	as 	reduced 	delays 	and 	commuting 	costs 	to 	air
passengers.
We 	appreciate 	the 	opportunity 	to 	comment 	on 	this 	matter.
Please 	feel 	free 	to 	contact 	us 	if 	we 	can 	be 	of 	further
assistance.
Sincerely,
~~'---" ~-?" ~ 	~...
Thomas 	B. 	Carter
Director
Dallas 	Regional 	Office

Table 1
Roundtrip Airline Fares on Selected Routes
August 1989
Destinations That Can Be Served From Love Field
Lowest Available Fares 	Full Price Fales
From Dallas! 	From Dallas
Destination 	AA(DFV) 	SV(Love) 	AA(DFV) 	SV(Love)
Little Rock, 	AR 	$38 	$38 	$122 	$122
Albuquerque, 	NM 	$76 	$76 	$164 	$164
Houston 	(Hobby), 	TX 	$38 	$38 	$122 	$122
Austin, 	TX 	$38 	$38 	$122 	$122
Oklahoma City, 	OK 	$38 	$38 	$102 	$102
San Antonio, 	TX 	$38 	$38 	$122 	$122
New Orleans, 	LA 	$76 	$76 	$164 	$164
Destinations That Can Not Be Served From Love Field
Lowest Available Fares
From Houston 	(Hobby>! Lowest Available Fares 	Fare 	Percent
From Dallas I 	DTff:'3 	Diff. 4
Destination 	AA 	SV 	AA 	SV
Kansas City, 	MO 	$108 	$108 	$198 	Restricted
Nashville, 	TN 	$ 98 	$ 98 	$200 	Restricted
Birmingham, 	AL 	$ 98 	$ 98 	$200 	Restricted
Saint Louis, 	MO 	$ 98 	$ 98 	$200 	Restricted
Full Price Fares 	Full Price Fa!es
From Houston 	(Hobby)2 	From Dallas
Destination 	AA 	SV 	AA 	SV
Kansas City, 	MO 	$230 	$236 	$476 	Restricted
Nashville, 	TN 	$168 	$188 	$672 	Restricted
_Birmingham, 	AL 	$238 	$198 	--.$672 	Res.tri.c.ted
Saint Louis, 	MO 	$162 	$178 	$630 	Restricted
$ 90 	83%
$102 	104%
$102 	104%
$102 	104%
Fare 	Percent
Diff. 3 	Diff. 4
$246 	106%
$504 	300%
~414 	239%
$468 	288%
lLowest fares 	offered by American 	(AA) 	and Southwest 	(5V) 	all
require 3 week advance purchase and are nonrefundable; 	other restrictions may
apply.
2Lowest unrestricted fares 	offered for 	ncoach· 	travel on weekdays;
they do not 	require advance purchase, 	minimum stay, 	time of day travel, 	and
are 	fully 	refundable; 	there may be a 	limit on stopovers and may 	require 	round
trip purchase.
3nFare Difference" 	is determined by 	subtracting the 	lowest Houston
fare 	(on either AA or 5V) 	from the AA Dallas 	fare 	to each destination.
4npercentage Difference" 	is determined by comparing the added cost
with the 	lowest Houston fare 	for each destination.

.J..
Table 2
Roundtrip Airline Fares on Selected Routes
February 1990
Destinations That Can Be Served From Love Field
Lowest Available Fares 	Full Price Fales
From Dallas! 	From Dallas
Destination 	AA(DFW) 	SW(Love) 	AA(DFW) 	SW(Love)
Little Rock, 	AR 	$38 	$38 	$138 	$138
Albuquerque, 	NM 	$92 	$82 	$190 	$204
Houston 	(Hobby), 	TX 	$38 	$38 	$138 	$138
Austin, 	TX 	$38 	$38 	$138 	$138
Oklahoma City, 	OK 	$38 	$38 	$118 	$118
San Antonio, 	TX 	$38 	$38 	$138 	$138
New Orleans, 	LA 	$82 	$82 	$180 	$180
Destinations That Can Not Be Served From Love Field
Lowest Available Fares 	Lowest Available Fares 	Fare 	Percent
From Houston 	(Hobby)! 	From Dallas! 	Diff. 3 	Diff. 4
Destination 	AA 	Sll 	AA 	Sll
Kansas City, 	HO 	$124 	$124 	$228 	Restricted 	$104 	83%
Nashville, 	TN 	$114 	$114 	$301 	Restricted 	$187 	164%
Birmingham. 	AL 	$114 	$114 	$280 	Restricted 	$166 	145%
Saint Louis, 	HO 	$145 	$114 	$260 	Restricted 	$146 	128%
Full Price Fares 	Full Price Fales 	Fare 	Percent
From Houston 	(Hobby)2 	From Dallas 	Diff. 3 	Diff. 4
Destination 	AA 	SW 	AA 	Sll
Kansas City. 	HO 	$262 	$262 	$600 	Restricted 	$338 	129%
Nashville. 	TN 	$228 	$218 	$722 	Restricted 	$504 	231%
Birmingham. 	AL 	$260 	$238 	,$722 	·Restricted 	·$484 	203%
Saint Louis. 	HO 	$446 	$208 	$678 	Restricted 	$470 	225%
lLowest 	fares 	offered by American 	(AA) 	and Southwest 	(SW) 	all
require 3 week advance purchase and are nonrefundable; 	other restrictions may
apply.
2Lowest unrestricted fares 	offered for 	·coach" 	travel on weekdays;
they do not 	require advance purchase, 	minimum stay. 	time of day 	travel, 	and
are 	fully 	refundable; 	there may be a 	limit on stopovers and may require 	round
trip purchase.
3"Fare Difference· 	is determined by subtracting the 	lowest Houston
fare 	(on either AA or SW) 	from the AA Dallas 	fare 	to each destination.
4"Percentage Difference· 	is determined by comparing the added cost
with the 	lowest Houston fare 	for each destination.

Table 3
Roundtrip Airline Fares on Selected Routes
October 1991
Destinations That Can Be Served From Love Field
Lowest Available Fares 	Full Price Fales
From Dallas! 	From Dallas
Destination 	AA(DFV) 	SV(Love) 	AA(DFV) 	SV(Love)
Little Rock, 	AR 	$ 58 	$ 58 	$158 	$158
Albuquerque, 	NM 	$156 	$136 	$254 	$220
Houston 	(Hobby), 	TX 	$ 58 	$ 58 	$158 	$158
Austin, 	TX 	$ 58 	$ 58 	$158 	$158
Oklahoma City, 	OK 	$ 58 	$ 58 	$144 	$144
San Antonio, 	TX 	$ 58 	$ 58 	$158 	$158
New Orleans, 	LA 	$108 	$108 	$198 	$198
Destinations That Can Not Be Served From Love Field
Lowest Available Fares 	Lowest Available Fares 	Fare 	Percent
From Houston 	(Hobby)! 	From Dallas! 	DI'f"f:"3 	Diff. 4
Destination 	AA 	SV 	AA 	SV
Kansas City, 	MO 	$150 	$150 	$178 	Restricted
Nashville, 	TN 	$150 	$150 	$198 	Restricted
Birmingham, 	AL 	$140 	$140 	$188 	Restricted
Saint Louis, 	MO 	$198 	$150 	$198 	Restricted
Full Price Fares 	Full Price Fales
From Houston 	(Hobby)2 	From Dallas
Destination 	AA 	SV 	AA 	SV
Kansas 	City, 	MO 	$359 	$300 	$708 	Restricted
Nashville, 	TN 	$272 	$272 	$864 	Restricted
Birmingham, 	AL 	$309 	$268 	-$864 	..Restricted
Saint Louis, 	MO 	$405 	$232 	$802 	Restricted
$ 28 	18%
$ 48 	32%
$ 48 	34%
$ 48 	32%
Fare 	Percent
Diff. 3 Diff. 4
$408 	136%
$592 	217%
.$596222%
$570 	245%
lLowest fares 	offered by American 	(AA) 	and Southwest 	(SV) 	all
require 3 week advance purchase and are nonrefundable; 	other restrictions may
apply.
2Lowest unrestricted fares 	offered for 	·coach" 	travel on weekdays;
they do not 	require advance purchase, 	minimum stay, 	time of day travel, 	and
are 	fully 	refundable; 	there may be a 	limit on stopovers and may 	require 	round
trip purchase.
3· Fare Difference" 	is determined by 	subtracting the 	lowest Houston
fare 	(on either AA or SV) 	from the AA Dallas 	fare 	to each destination.
4·Percentage Difference· 	is determined by comparing the added cost
with the 	lowest Houston fare 	for each destination.

Table 	4
Roundtrip Airline Fares on Selected Routes
April 1992
Destinations That Can Be Served From Love Field
Lowest Available Fares 	Full Price Fales
From Dallas! 	From Dallas
Destination 	AA(DFV) 	SV(Love) 	AA(DFV) 	SV(Love)
Little Rock, 	AR 	$ 78 	$ 78 	$158 	$158
Albuquerque, 	NM 	$146 	$146 	$220 	$220
Houston 	(Hobby), 	TX 	$ 68 	$ 68 	$158 	$158
Austin, 	TX 	$ 58 	$ 58 	$158 	$158
Oklahoma City, 	OK 	$ 58 	$ 58 	$144 	$144
San Antonio, 	TX 	$ 68 	$ 68 	$158 	$158
New Orleans, 	LA 	$120 	$120 	$198 	$198
Destinations That Can Not Be Served From Love Field
Lowest Available Fares 	Lowest Available Fares 	Fare 	Percent
From Houston 	(Hobby)! 	From Dallas! 	D'"I"f'f":'3 	Diff. 4
Destination 	AA 	SV 	AA 	SV
Kansas City, 	MO 	$260 	$160 	$210 	Restricted
Nashville, 	TN 	$260 	$152 	$260 	Restricted
Birmingham, 	AL 	$192 	$152 	$260 	Restricted
Saint Louis, 	MO 	$200 	$158 	$250 	Restricted
Full Price Fares 	Full Price Fales
From Houston 	(Hobby)2 	From Dallas
Destination 	AA 	SV 	AA 	SV
Kansas City, 	MO 	$400 	$300 	$400 	Restricted
Nashville, 	TN 	$500 	$272 	$500 	Restricted
Birmingham, 	AL 	$570 	$268 	$500 	Restricted
Saint Louis, 	MO 	$420 	$232 	$500 	,R~stricted
$ 50 	31%
$108 	71%
$108 	71%
$ 92 	58%
Fare 	Percent
Diff. 3 	Diff. 4
$100 	33%
$228 	83%
$232 	86%
$268 	115%
lLowest fares 	offered by American 	(AA) 	and Southwest 	(SV) 	all
require 3 week advance purchase and are nonrefundable; 	other restrictions may
apply.
2Lowest unrestricted fares 	offered for 	"coach· 	travel on weekdays;
they do not 	require advance purchase, 	minimum stay, 	time of day travel, 	and
are 	fully 	refundable; 	there may be a limit on stopovers and may 	require 	round
trip purchase.
3"Fare Difference" 	is determined by subtracting the 	lowest Houston
fare 	(on either AA or SV) 	from the AA Dallas 	fare 	to each destination.
4"Percentage Difference" 	is determined by comparing the added cost
with the 	lowest Houston fare 	for each destination.

Table 5
Price Per Mile For American Flights From Dallas
April 1992
Lowest Available Roundtrip Fares l
Destinations That Can Be Served From Love Field
Destination 	Fare 	Miles 2 	Cents Imile
Little Rock, 	AR 	$ 78 	632 	12.3
Albuquerque, 	NM 	$146 	1,288 	11.3
Houston 	(Hobby), 	TX 	$ 68 	490 	13.8
Austin, 	TX 	$ 58 	384 	15.1
Oklahoma City, 	OK 	$ 58 	414 	14.0
San Antonio, 	TX 	$ 68 	540 	12.5
New Orleans, 	LA 	$120 	1,034 	11.6
Average Price 	12.9
Destinations That Can Not Be Served From Love Field
Kansas City, 	MO 	$210 	1,010 	20.7
Nashville, 	TN 	$260 	1,318 	19.7
Birmingham, 	AL 	$260 	1,270 	20.4
Saint Louis, 	MO 	$250 	1,310 	19.0
Average Price 	19.9
Full Price ROundtrip Fares 3
Destinations That Can Be Served From Love Field
Little Rock, 	AR 	$158 	632 	25.0
Albuquerque, 	NM 	$220 	1,288 	17.0
Houston 	(Hobby) , 	TX 	$158 	490 	32.2
Austin, 	TX 	$158 	384 	41.1
Oklahoma City, 	OK 	$144 	414 	34.7
San Antonio, 	TX 	$158 	540 	29.2
New Orleans, 	LA 	$198 	1,034 	19.1
Average Price 	28.3
Destinations That Can Not Be Served From Love Field
Kansas City, 	MO
Nashville, 	TN
Birmingham, 	AL
Saint Louis, 	MO
Average Price
$400
$500
$500
$500
1,010
1,318
1,270
1,310
39.6
37.9
39.3
38.1
38.7
lLowest 	fares 	offered by American Airlines; 	all 	require 2 to 3 week
advance purchase and are nonrefundable; 	other restrictions may apply.
2Miles between cities are statute miles based on the Rand McNally Road
Atlas United States mileage chart. 	These are approximate distances 	between
cities. 	The exact distance between airports will vary somewhat.
3Lowest unrestricted fares 	offered for 	"coach" 	travel on weekdays; 	they
do not 	require advance purchase, 	minimum stay, 	time of day travel, 	and are
fully 	refundable; 	there may be a 	limit on stopovers and may 	require 	round trip
purchase.

Table 6
Selected Roundtrip Airline Fares 	From Dallas
Required Double Ticket Southwest Airline Fales
vs. 	Single Ticket American Airline Fares
April 1992
Lowest Available Roundtrip Fares From Dallas 2
Single Ticket 	Double Ticket 	Single Ticket 	Cost 	Percent
Destination 	(SW/Love Field) 	(SW/Love Field) 	(AA/DFW) 	Savings 3 Decrease 4
Kansas City, 	MO 	Restricted 	$126s COKC) 	$210 	$ 84 	40.0%
Nashville, 	TN 	Restricted 	$220~CBOU) 	$260 	$ 40 	15.3%
Birmingham, 	AL 	Restricted 	$198 CHSY) 	$260 	$ 62 	23.8%
Saint Louis, 	MO 	Restricted 	$156 	COKC) 	$250 	$ 94 	37.6%
Full Price Roundtrip Fares 	From Dallas 8
Kansas City, 	MO 	Restricted 	$302 	COKC) 	$400 	$ 98 	24.5%
Nashville, 	TN 	Restricted 	$430 	CHOU) 	$500 	$ 70 	14.0%
Birmingham, 	AL 	Restricted 	$376 	CHSY) 	$500 	$124 	24.8%
Saint Louis, 	MO 	Restricted 	$306 	COKC) 	$500 	$194 	38.8%
l"Single Ticket" 	refers 	to the price charged for a roundtrip ticket
between Dallas and the 	listed destinations. 	"Double Ticket" 	refers 	to 	the
price charged for the two roundtrip tickets 	that must be purchased for 	travel
between Dallas Love Field and the 	same destinations. 	Under the 	requirements
of the Wright Amendment a passenger is 	forced to purchase two 	roundtrip
tickets 	-- one between Love Field and an intermediate stop within the 	five
state area and a second ticket for 	travel between that stop and the desired
destination.
2Lowest fares 	offered by each airline; 	all 	require 2 to 3 week advance
pu't'ehase an-darenonrefundable; 	other -rest'rictions -may apply .
3"Cost Savings" 	is determined by comparing the 	lower cost Southwest
double 	ticket 	fare 	and the 	single ticket American fare 	to each destination.
4"Percentage Decrease" 	is 	determined by comparing the cost 	savings amount
with the American fare 	to each destination.
SBased on buying two roundtrip tickets 	-- one from Dallas Love Field to
Oklahoma City 	(OKe) 	and the other from Oklahoma City to Kansas City. 	The
total double 	ticket price would be approximately the 	same 	if passenger flew
via Tulsa.
6Via Houston Hobby Airport 	(HOU), 	the most direct 	route 	to Nashville 	from
Love Field under the Wright Amendment 	restrictions.
7Via New Orleans 	(MSY), 	the most direct 	route 	to Birmingham.
8Lowest unrestricted fares 	offered for 	"coach" 	travel on weekdays; 	they
do not 	require advance purchase, 	minimum stay, 	time of day travel, 	and are
fully 	refundable; 	there may be a 	limit on stopovers and may 	require 	round trip
purchase.

Selected Table 7
Roundtrip Airline Fares From Houston on Southwest
Single Ticket vs. 	Double Ticket Fares l
April 1992
21 Day Advance 	(Off Peak)2
Airlines
Destination 	Single Ticket 	Double Ticket 	Added Cost 3 	Percent 	Incr. 4
Kansas City, 	MO 	$160 	$156 	(OKC)~ 	$(4) 	(2.5%)
Nashville, 	TN 	$152 	$286 	(HSY) 	$134 	88.1%
Birmingham, 	AL 	$152 	$156 	(HSY) 	$ 	4 	2.6%
Saint Louis, 	MO 	$158 	$186 	(OKC) 	$ 28 	17.7%
Average Percentage Increase 	27.7%
21 Day Advance 	(Peak)2
Kansas City, 	MO 	$168 	$186 	(OKC) 	$ 18
Nashville, 	TN 	$168 	$306 	(HSY) 	$138
Birmingham, 	AL 	$162 	$176 	(HSY) 	$ 14
Saint Louis, 	MO 	$168 	$206 	(OKC) 	$ 38
Average Percentage Increase
No Advance 	(Off Peak)2
Kansas City, 	MO 	$238 	$276 	(OKC) 	$ 38
Nashville, 	TN 	$218 	$400 	(HSY) 	$182
Birmingham, 	AL 	$218 	$272 	(HSY) 	$ 54
Saint Louis, 	MO 	$178 	$314 	(OKe) 	$136
Average Percentage Increase
10.7%
82.1%
8.6%
2.6%
26.0%
15.9%
83.4%
24.7%
76.4%
50.1%
IDSingle Ticket D refers 	to the price charged for a 	roundtrip ticket
between Houston and the 	listed destination. 	aDouble Ticket" 	refers 	to 	the
price that would be charged for 	roundtrip travel between Houston and the 	same
destination if, 	as 	in the case 	for passengers 	departing from Dallas Love
Field, 	the passenger were 	forced to purchase two 	round trip tickets 	-- one
between Houston and an intermediate stop within the 	five 	state area and a
second ticket for 	travel between that 	stop and the desired destination.
2The 21 Day Advance 	(Off Peak) 	Fare 	is 	the 	lowest available 	fare, 	it 	is
non refundable and certain restrictions may apply. 	The no advance 	(peak) 	fare
is 	the 	full 	price 	fare, 	it 	is 	for unrestricted coach travel on weekdays 	it
does not 	require minimum stay or time of day travel, 	and it 	is 	fully
refundable. 	"Off Peak" 	fares 	require 	travel on weekends or before 	6:00 am and
after 7:00 pm on weekdays. 	apeak D fares 	are 	required for all other times.
3"Added Cost" 	is determined by subtracting the 	single 	ticket 	fare 	from
the double 	ticket 	fare 	to each destination.
4apercentage IncreaseD 	is 	determined be comparing the added cost with the
single ticket fare 	to each destination.
5 Based on buying two 	roundtrip tickets 	-- one from Houston to Oklahoma
City 	(OKC) 	and the other from Oklahoma City to Kansas City. 	The 	total double
ticket price would be approximately the 	same 	if passenger flew via Tulsa.
6 Via New Orleans. 	(MSY)

Table 	7
(Continued)
Selected Roundtrip Airline Fares 	From Houston on Southwest Airlines
Single Ticket vs. 	Double Ticket Fares
April 1992
No Advance 	(Peak>
Destination 	Single Ticket 	Double Ticket 	Added Cost Percent 	Incr.
Kansas City, 	MO 	$300 	$388 	(OKC) 	$ 88 	29.3%
Nashville, 	TN 	$272 	$512 	(MSY) 	$240 	88.2%
Birmingham, 	AL 	$268 	$352 	(MSY) 	$ 84 	31.3%
Saint Louis, 	MO 	$232 	$392 	(OKC) 	$160 	68.9%
Average Percentage Increase 	54.4%

AIR TRAFFIC 	OPERATIONS MAHAOEMEHT SISTEM 	rAV6
29-Apr-1992 	Dallas 	Love 	Field
12:01:04 	DAILI 	DELAYS 81 CAUSB
UDOWll 	TOTAL 	Daily
DATE 	TOTAL DELAYS WEATHER 	VOLUME 	EQUIP. 	RWY/CLSR 	OTHER 	'l'M8 	TM8 	OPERATIORS
Ol-Har-92 	0 	0 	0 	0 	0 	0 	0 	0 	500
02-Har-92 	0 	0 	0 	0 	0 	0 	0 	0 	772
OJ-Har-92 	0 	0 	0 	0 	0 	0 	0 	0 	633
04-Har-92 	3 	3 	0 	0 	0 	0 	0 	1 	787
05-Har-92 	1 	0 	0 	0 	1 	0 	0 	1 	1,011
06-Har-92 	0 	0 	0 	0 	0 	0 	0 	0 	727
07-Har-92 	0 	0 	0 	0 	0 	0 	0 	0 	575
08-Mar-92 	2 	2 	0 	0 	0 	0 	0 	0 	441
09-Mar-92 	1 	1 	0 	0 	0 	0 	0 	1 	771
10-Mar-92 	0 	0 	0 	0 	0 	0 	0 	0 	901
11-Har-92 	0 	0 	0 	0 	0 	0 	0 	0 	978
12-Mar-92 	0 	0 	0 	0 	0 	0 	0 	0 	994
IJ-Har-92 	0 	0 	0 	0 	0 	0 	0 	0 	811
14-Mar-92 	0 	0 	0 	0 	0 	0 	0 	0 	SIS
15-Mar-92 	0 	0 	0 	0 	0 	0 	0 	0 	412
16-Mar-92 	0 	0 	0 	0 	0 	0 	0 	0 	702
17-Mar-92 	0 	0 	0 	0 	0 	0 	0 	0 	664
18-Mar-92 	0 	0 	0 	0 	0 	0 	0 	0 	920
19-Mar-92 	0 	0 	0 	0 	0 	0 	0 	0 	988
20-Har-92 	0 	0 	0 	0 	0 	0 	0 	0 	933
21-Mar-92 	0 	0 	0 	0 	0 	0 	0 	0 	386
22-Mar-92 	0 	0 	0 	0 	0 	0 	0 	0 	349
23-Har-92 	0 	0 	0 	0 	0 	0 	0 	0 	832
24-Mar-92 	0 	0 	0 	0 	0 	0 	0 	0 	843
25-Har-92 	0 	0 	0 	0 	0 	0 	0 	0 	1,010
26-Mar-92 	0 	0 	0 	0 	0 	0 	0 	0 	916
·27-Mar-92 	0 	0 	0 	0 	0 	0 	0 	0 	849
28-Mar-92 	0 	0 	0 	0 	0 	0 	0 	0 	406
29-Mar-92 	0:. 	0 	0 	0 	0 	0 	0 	0 	431
JO-Har-92 	0 	0 	0 	0 	0 	0 	0 	0 	758
31-Har-92 	0 	0 	0 	0 	0 	0 	0 	0 	939
MON'lBL1 TOTALS 1...._, _' 	-----.L.------"- 	.L.- 	--'- 	--1.__----J '--__3 	_

AIR 'rRAPFIC OPBRATIO.S MUlAGEMBft 81SDH 	PAGB 	Z
29-Apr-1992 	Dalla./Ft. 	Wortb 	Int'!
12:07:0. 	DAILI 	DELAIS 	BI CAUSB
UDONIf 	TOTAL 	Dail,
DATB 	totAL DBLAIS WEATHBR 	VOLUNB 	EQUIP. 	RWtLCLSR 	oraER 	TM8 	%HI 	OPERAtIONS
01-Har-92 	13 	0 	13 	0 	0 	0 	0 	0 	1,971
02-Mar-92 	17 	0 	17 	0 	0 	0 	0 	0 	2,054
OJ-Har-92 	204 	188 	16 	0 	0 	0 	0 	36 	2,050
04-Mar-92 	75 	59 	16 	0 	0 	0 	0 	21 	2,133
05-Har-92 	17 	17 	0 	0 	0 	0 	0 	5 	2,165
06-Mar-92 	13 	0 	13 	0 	0 	0 	0 	0 	2,099
07-Har-92 	10 	10 	0 	0 	0 	0 	0 	1 	1,915
08-Mar-92 	212 	162 	50 	0 	0 	0 	0 	11 	1,936
09-Har-92 	158 	158 	0 	0 	0 	0 	0 	3 	2,030
10-Har-92 	22 	0 	22 	0 	0 	0 	0 	0 	2,133
11-Har-92 	5 	0 	5 	0 	0 	0 	0 	0 	2,121
12-Har-92 	43 	0 	43 	0 	0 	0 	0 	0 	2,157
IJ-Mar-92 	0 	0 	0 	0 	0 	0 	0 	0 	2,135
• 14-Har-92 	26 	0 	26 	0 	0 	0 	0 	0 	1,904
lS-.Mar-92 	4 	0 	4 	0 	0 	0 	0 	0 	1,987
16-Mar-92 	13 	0 	13 	0 	0 	0 	0 	0 	2,068
17-Har-92 	233 	218 	15 	0 	0 	0 	0 	47 	2,109
18-Mar-92 	0 	0 	0 	0 	0 	0 	0 	0 	2,118
19-Har-92 	0 	0 	0 	0 	0 	0 	0 	0 	2,129
20-Mar-92 	6 	0 	6 	0 	0 	0 	0 	0 	2,170
21-Har-92 	0 	0 	0 	0 	0 	0 	0 	0 	1,905
22-Mar-92 	3 	0 	3 	0 	0 	0 	0 	0 	1,953
2J-Mar-92 	0 	0 	0 	0 	0 	0 	0 	0 	2,086
24-Mar-92 	307 	307 	0 	0 	0 	0 	0 	66 	2,068
25-Mar-92 	1 	1 	0 	0 	0 	0 	0 	1 	2,273
26-Mar-92 	10 	0 	10 	0 	0 	0 	0 	0 	2,158
27-Mar-92 	26 	5 	20 	0 	0 	1 	0 	8 	2,110
28-Mar-92 	16 	3 	13 	0 	0 	0 	0 	S 	1,864
29-Mar-92 	2S 	.. 	0 	25 	0 	0 	0 	0 	0 	1,965
30-Mar-92 	20 	0 	20 	0 	0 	0 	0 	0 	2,084
31-Mar-92 	52 	16 	36 	0 	0 	0 	0 	0 	2,139
MOIITRLI 'fO'lALSI 	1,5~1 	~ 	1,1•• 	I 	386 	I 	o 	I 	01 	1 	I 	o I 	2M 	63,989
. 	.' , 	-. 	~-