DCA Perimeter Rule: Could We See Some Changes?

DCA Perimeter Rule: Could We See Some Changes?

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A couple of weeks ago I wrote about how there were discussions going on about possibly adding more exemptions to DCA’s perimeter rule (this was initially flagged by Jake Sherman at Punchbowl News). There’s an update, as bipartisan legislation has been introduced to make this a reality. Let’s go over the details — personally I’m strongly in favor of this.

The basics of Washington National Airport’s perimeter rule

Reagan Washington National Airport (DCA) is the airport closest to Washington DC, and is therefore the favored airport for most politicians. The airport isn’t very large and there’s a lot of demand for it (given how lucrative government business can be for airlines), so it’s slot controlled.

The airport has what’s known as a perimeter rule, which has been around since 1966, when jets started flying to the airport. This rule generally prohibits airlines from operating routes longer than 1,250 statute miles nonstop.

However, there are a limited number of exemptions, whereby up to 40 daily flights (20 roundtrips) are allowed to destinations farther than that. Current destinations beyond the perimeter rule include Austin (AUS), Denver (DEN), Las Vegas (LAS), Los Angeles (LAX), Phoenix (PHX), Portland (PDX), Salt Lake City (SLC), San Francisco (SFO), San Juan (SJU), and Seattle (SEA).

What’s the logic for the perimeter rule? Well, this was initially intended to protect Washington Dulles Airport (IAD) as the transcontinental and international gateway for the area. The concern at the time was that Dulles Airport couldn’t thrive if National Airport wasn’t limited in this way.

By the way, there’s an honorable story about late Senator John McCain related to the perimeter rule. In 1999, he led an effort to repeal the perimeter rule. He wasn’t successful, but some exemptions (including one to his home airport of Phoenix) were allowed. He reportedly refused to take the nonstop flight and rather opted to connect, so that it didn’t appear that he was just trying to repeal the rule for his own interests.

Washington National Airport has a 1,250-mile perimeter rule

Legislation could alter DCA perimeter rule

A couple of weeks ago, the Capital Access Alliance started pushing for adjustments to the perimeter rule at DCA. This was backed by Delta Air Lines, and interestingly one of the lobbyists is a close friend of House Speaker Kevin McCarthy (you’ve gotta love how politics works).

We’ve now seen the introduction of legislation in support of this. The Direct Capital Access Act has been introduced in Congress by US Representatives Hank Johnson (D-GA) And Burgess Owens (R-UT). I first have to stop and acknowledge the extent to which Delta is clearly behind this. I’m sure it’s no coincidence that the politicians involved are both from states with big Delta hubs, and that they’ll almost certainly be getting some campaign contributions from the airline.

Anyway, this legislation would allow for an additional 56 daily slot exemptions (meaning 28 pairs, since two are required for a roundtrip) to the perimeter rule. 40 of those slots would be for existing airlines at the airport, while 16 of those slots would be for airlines that don’t currently have service at the airport.

Since Delta is supportive of this, it’s probably worth noting that Delta’s current exempted routes include service to Los Angeles (LAX) and Salt Lake City (SLC). I have to imagine that Delta would love to add additional flights in those markets, as well as service to Seattle (SEA), and maybe even to San Diego (SAN).

For what it’s worth, San Antonio (SAT) and San Diego (SAN) are the seventh and eighth largest cities in the United States, respectively, and they don’t currently have any exempt flights per the perimeter rule.

Delta is behind the proposal to add perimeter rule exemption flights

Why I’m in favor of DCA perimeter rule changes

I’m hugely in favor of the perimeter rule at DCA being eliminated altogether, but I guess adding some more exempted slots is a good start.

First of all, there’s not a risk of Washington Dulles Airport failing anymore. The airport is a major hub for United, Washington National would still be slot restricted (so wouldn’t actually see a net expansion in terms of number of flights), and the population in Northern Virginia has increased significantly over the years.

More importantly, though, airlines really aren’t operating service at Washington National Airport that’s in the best interest of consumers. A huge percentage of flights at the airport are in high frequency markets with regional jets.

That’s because airlines don’t want to lose their slots (and slots have a use ’em or lose ’em clause), so they basically just fly regional jets nearly hourly in many markets. Being able to operate nonstop flights to more destinations would almost certainly cause airlines to increase capacity in some existing markets, and in turn upgrade aircraft on existing routes.

For example, rather than American operating 12 regional jets per day between Washington and New York, wouldn’t it be better to have eight flights with larger jets, and then four flights to new destinations that aren’t currently served?

While I understand the general need for slots at some airports, I think the current system used for these restrictions simply isn’t in the best interest of consumers. When airlines do slot squatting by flying regional jets into heavily congested airports, that keeps fares high. As far as I’m concerned, slots being awarded should factor in the total number of seats an airline is willing to offer to a destination, rather than just the total number of frequencies.

There are way too many regional jets at Washington National Airport

Bottom line

Legislation has been introduced that’s intended to create more perimeter rule slot exemptions at Washington National Airport. Delta is behind this lobbying effort, and it’s no surprise that this legislation has been introduced by politicians from Georgia and Utah.

With this legislation, we could see 56 additional daily slots (or 28 slot pairs) added, allowing more nonstop flights between the airport and destinations that are 1,250+ statute miles away.

It’s anyone’s guess if this proves successful. Personally I think the perimeter rule should be eliminated altogether, as the concept is so outdated, and doesn’t benefit consumers. This isn’t just in the best interest of politicians, it’s in the best interest of the public as well.

What do you think — should the DCA perimeter rule DCA be abolished, or should we at least see exemptions expanded?

Conversations (101)
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  1. Paco Guest

    And still no proper rail and bus connections to IAD and BWI ...

  2. DCAFlyer Guest

    More flights in/out of DCA? That means more diverts into IAD at the slightest irregularity... this may work out just great for IAD.

  3. Matt Guest

    The biggest issue with removing the perimeter rule at DCA is the size of the airport and associated roadways. The airport is actually really small and somewhat crowded. Adding lots of bigger planes will make the airport more crowded. Also note the slot rule is you have to use slots 80% of the time over all your slots. This means you can have slots you never use but meet the rule because you use 80%...

    The biggest issue with removing the perimeter rule at DCA is the size of the airport and associated roadways. The airport is actually really small and somewhat crowded. Adding lots of bigger planes will make the airport more crowded. Also note the slot rule is you have to use slots 80% of the time over all your slots. This means you can have slots you never use but meet the rule because you use 80% your slots 100% of the time. This also wouldn't rule out more international flying to the airport via US preclearance from places like Dublin Ireland.

  4. iamhere Guest

    Like many of your articles just from your prospective to serve customers or as an avgeek and not considering the other aspects

  5. Zymm Guest

    I would love it if there were more direct flights to National. It's not as much of an issue now that the Silver line is running, but it's still the easiest airport for me to fly into and direct flights from the west coast run at a premium right now.

  6. Eskimo Guest

    People on ground thinks the airport is crowded, politicians disagree.
    Let's see who wins.
    Congress, after you pass this bill, see you next time we need to bailout airlines.

    But if we're going to overload DCA why not dream big.
    Next are we going to see more DCA-Europe, perhaps a boom in SNN?

    Maybe with Tony Douglas gone and news of EY growing again we could see a new bold move?
    ...

    People on ground thinks the airport is crowded, politicians disagree.
    Let's see who wins.
    Congress, after you pass this bill, see you next time we need to bailout airlines.

    But if we're going to overload DCA why not dream big.
    Next are we going to see more DCA-Europe, perhaps a boom in SNN?

    Maybe with Tony Douglas gone and news of EY growing again we could see a new bold move?
    AUH-DCA-XXX-AUH. A fully loaded 787 might not make it to AUH, but should be able to load more than enough to reach Europe. That is we're ignoring the limited space of DCA, like the politicians, that because the 787 can land and have enough gates, it wouldn't be blocking the way of CRJs E75s 737s or 320s trying to taxi.

    Then let's ask for an immigration facility or more pre-clearance in Europe.

    2 more replies
  7. Jason Guest

    Thanks for the update, but please be specific.
    Does the proposed legislation add 56 net new slots, or is the proposal to convert 56 current slots to beyond perimeter slots? There's a big difference.

  8. JB Guest

    Ben, I am not sure you appreciate the LGA-DCA dynamic. It serves business travelers that need hourly flights because we don’t know when our meeting ends etc. I’d just take the Acela if I had to wait more than an hour at the airport.

  9. M. Casey Guest

    BWI & IAD are connecting airports that serve the D.C. area. DCA is a destination - and should never allow fares with connections to a third point, and no international flights - if the airlines can do this, then break perimeter rule. Currently AS is the only carrier to fly from 3 major west coast cities into DCA; UA serves 2; AA 2 flights from LAX only. None of them are from the capital of...

    BWI & IAD are connecting airports that serve the D.C. area. DCA is a destination - and should never allow fares with connections to a third point, and no international flights - if the airlines can do this, then break perimeter rule. Currently AS is the only carrier to fly from 3 major west coast cities into DCA; UA serves 2; AA 2 flights from LAX only. None of them are from the capital of these west coast states - Seattle, San Francisco, and Los Angeles.

    We’ll see if the airlines would want all the n/s flights if they don’t allow travel to a 3rd point.

    4 more replies
  10. DCJoe Guest

    Come on, you can't go by city population when talking about potential airline passengers, you have to go by total metro area population. San Diego metro area is 17th biggest in the US, and San Antonio is 24th.

    3 more replies
  11. TravelinWilly Diamond

    The WaPo had a piece on this yesterday as well: https://wapo.st/3LTBxJD

  12. DFWFlyer Guest

    It is my life goal to see LHR open a customs facility in T3 (or T5C) and an exemption made for a daily LHR - DCA flight run by AA in an all premium A321. If Delta opens this door, that’d be great, thanks!

    1 more reply
  13. booji90 Guest

    Re: the comment that RJs are all DCA can handle, do you think the carriers care? As the author said, they're just squatting on slots. Landing fees are the culprit. Airlines pay based on the max landing weight of their flights into DCA. Start charging a flat rate landing fee and you'll see bigger planes replacing RJs immediately.

  14. atcsundevil Guest

    Ben, I love your articles, but as a DC native and an air traffic controller that works arrivals to the DC metro airports, you're wrong here. DCA is currently leading the nation in the frequency at which airborne holding is required. More than Newark, more than LaGuardia, more than Kennedy. That's in large part due to ramp congestion, and specifically the new concourse built for American. A321s pushing from the new concourse are blocking taxiways...

    Ben, I love your articles, but as a DC native and an air traffic controller that works arrivals to the DC metro airports, you're wrong here. DCA is currently leading the nation in the frequency at which airborne holding is required. More than Newark, more than LaGuardia, more than Kennedy. That's in large part due to ramp congestion, and specifically the new concourse built for American. A321s pushing from the new concourse are blocking taxiways and forcing airborne holding multiple times each day. We held six times for 20-45 minutes in a single day last week. The airport has a high percentage of regional jets **because that's all it can handle**. It's already running beyond its capabilities with no possibility for further expansion of the airfield. Dulles was built for a reason. It has four runways with plans for a fifth and capacity to spare. Relaxing or eliminating the DCA perimeter even with slot controls will make the airport even less manageable. It limits the effectiveness of ground stops and EDCTs during high demand periods because more flights will already be in the air. The airport is barely coping as it is, and messing with the perimeter rules again will only cause significantly worse problems. Just to give you an idea of how bad things are right now — I refuse to fly out of DCA despite its convenience. Holdings and diversions for volume, ramp congestion, and VIP movements simply make it unpredictable and unreliable, in my opinion.

    12 more replies
  15. DesertGhost Guest

    One minor obstacle to getting rid of regional aircraft at DCA is Congress. It would have to approve the change. And part of that change would be to get rid of commuter slots. I'm not sure of the exact number, but a large percent (close to half, I believe) of American's DCA slots are limited to commuter aircraft (defined as seating 76 or fewer passengers). One of the concerns with eliminating commuter slots is that...

    One minor obstacle to getting rid of regional aircraft at DCA is Congress. It would have to approve the change. And part of that change would be to get rid of commuter slots. I'm not sure of the exact number, but a large percent (close to half, I believe) of American's DCA slots are limited to commuter aircraft (defined as seating 76 or fewer passengers). One of the concerns with eliminating commuter slots is that the airport can't physically handle the increased number of passengers. Another is that it would give American an undue advantage as it holds the vast majority of commuter slots. One possible soilution could be to change the definition of commuter aircraft to include those with, say, 135 or fewer seats.

    I do tend to agree that a relaxation of the perimeter rule at National (and LGA, but that's a different discussion) would be beneficial overall. A couple of possible compromises come to mind.

    First, extend the perimeter to 1625 statute miles. That would bring state and territorial capitals such as Denver, Austin and San Juan into the perimeter, not to mention Santa Fe, the capital of New Mexico. The airlines that currently have those exemptions would be able to use them elsewhere. State capitals like Sacramento, CA, Salem, Oregon, and Boise, Idaho could benefit from non-stop service to DCA.

    Next, add some new exemptions, and make most of them flexible, instead of the current practice of tying virtually all of them to particular routes. As with the current flexible exemptions, an airline would have to surrender an in-perimeter slot pair to get a beyond perimeter exemption.

    4 more replies
  16. Clay Duncan Guest

    In favor of this, but they need to let others into some markets besides AA DL etc. How about some Breeze And Avelo.

  17. Robert Fahr Guest

    If the perimeter rule was revoked yet remained slot controlled, all the RJ flights would be gone tomorrow. Those flights can move to Dulles.

  18. Randy Diamond

    I could see opening up a few more destinations, but not eliminate the rule. Years back - DFW was outside the perimeter, and the AA route to DFW - was DCA-IAD-DFW, only for pickup. Then they extended to 1250 miles and DFW and IAH opened.

    Originally when they added transcons they gave them to the non-major carriers - like Alaska Air, TWA, etc. When AA acquired US - they converted the DCA-SAN to a 2nd...

    I could see opening up a few more destinations, but not eliminate the rule. Years back - DFW was outside the perimeter, and the AA route to DFW - was DCA-IAD-DFW, only for pickup. Then they extended to 1250 miles and DFW and IAH opened.

    Originally when they added transcons they gave them to the non-major carriers - like Alaska Air, TWA, etc. When AA acquired US - they converted the DCA-SAN to a 2nd DCA-LAX and then cancelled 2 of the IAD-LAX flights.

    I could see AA doing the same. Although they do not have much to cancel out of IAD -as not much left. AA could add DCA-SAN, DCA-SEA.

  19. Terry Kozma Guest

    Close dca. And make Dulles world class

    2 more replies
  20. sunviking82 Guest

    If I were AA, I'd be in favor if I could get exclusive DCA - LHR route, the XLR could fly it and give AA a huge advantage in DC.

    2 more replies
  21. Jason Guest

    You really should look at the schedules. AA and DL long ago abandoned hourly shuttles to LGA. during peak times of day you might see that, but not all hours like there were 20 years ago.

    Boston is too far to take the train - at least 8 hours one way these days.

    People complain, but all of those smaller cities with flights to DCA actually have demand for nonstop flights to DCA. Most...

    You really should look at the schedules. AA and DL long ago abandoned hourly shuttles to LGA. during peak times of day you might see that, but not all hours like there were 20 years ago.

    Boston is too far to take the train - at least 8 hours one way these days.

    People complain, but all of those smaller cities with flights to DCA actually have demand for nonstop flights to DCA. Most people are not changing planes at DCA - they are coming to DC, not flowing over. Not sure how you can value one as higher than the other when legitimate demands are being served.

    1. shza Gold

      "Not sure how you can value one as higher than the other when legitimate demands are being served."

      It's theoretically possible that if this anticompetitive restriction were removed, nothing would change because the current use is (coincidentally) the most valuable. But that's highly unlikely and we aren't testing it now, since the restriction prevents that.

  22. Chris Guest

    DCA - PVR non-stop, please!

    1. ConcordeBoy Diamond

      DCA doesn't have CBP/FIS facilities sufficient to routinely process non-precleared international operations.... and there'll likely be icebergs in Hades before it ever does.

  23. dn10 Guest

    I don't see hourly shuttles between BOS/NYC/DCA stopping. Too much business travel where timing matters for those markets.

    4 more replies
  24. Tim Dunn Diamond

    Ben is right. Perimeter rules at both DCA and LGA limit competition, increase fares, and reduce service as they protect incumbents.

    DCA and LGA have much higher percentages of regional jets than other hubs because airlines are forced to use their slots on high frequency short flights instead of more efficient mainline aircraft.

    There is no reason why DCA and LGA can't handle more mainline service all across the country, esp. if ATC continues to...

    Ben is right. Perimeter rules at both DCA and LGA limit competition, increase fares, and reduce service as they protect incumbents.

    DCA and LGA have much higher percentages of regional jets than other hubs because airlines are forced to use their slots on high frequency short flights instead of more efficient mainline aircraft.

    There is no reason why DCA and LGA can't handle more mainline service all across the country, esp. if ATC continues to struggle to fully staff their centers.

    There is also a much more compelling case environmentally for larger aircraft on mainline than so many regional jets. There are no new regional jets in the US that use new generation aircraft while there are multiple versions of new generation powered mainline aircraft.

    4 more replies
  25. Hammer New Member

    The main issue I see with eliminating the perimeter rule is that I don’t think DCA could adequately handle the increase in passengers. MWAA, the airport authority that operates DCA and IAD shared that one of the reasons for the regional concourses that was finished two years ago was that DCA was already well over capacity and if the perimeter rule was eliminated, the terminal might not be able to handle all those new passengers....

    The main issue I see with eliminating the perimeter rule is that I don’t think DCA could adequately handle the increase in passengers. MWAA, the airport authority that operates DCA and IAD shared that one of the reasons for the regional concourses that was finished two years ago was that DCA was already well over capacity and if the perimeter rule was eliminated, the terminal might not be able to handle all those new passengers.

    I’m not saying that more exemptions shouldn’t be granted on a limited basis, I think San Antonio and San Diego have proved that they can support DCA flights without resulting in too many IAD cuts but completely eliminating the perimeter rule would make DCA much more unpleasant to travel from.

  26. BurritoMiles Guest

    How about we stop flights to NYC & Boston, make Amtrak actually work and use thode slots to fly to places outside the northeast? Win win for everyone.

    3 more replies
  27. TravelinWilly Diamond

    I would love for National to have the perimeter rule removed completely. IAD is a PITA to get to for everyone who lives in DC, NOVA, and SOMA, and National is a completely better airport experience. The only downside to DCA vs. IAD is that DCA doesn't have anywhere near the number of lounges available to people who aren't loyal to one airline (DL, AA, or UA), but aside from that, DCA is superior in...

    I would love for National to have the perimeter rule removed completely. IAD is a PITA to get to for everyone who lives in DC, NOVA, and SOMA, and National is a completely better airport experience. The only downside to DCA vs. IAD is that DCA doesn't have anywhere near the number of lounges available to people who aren't loyal to one airline (DL, AA, or UA), but aside from that, DCA is superior in every way.

    That said, I've not experienced the "new" DC departure experience, so I'm unclear on what that's like.

    1 more reply
  28. Eskimo Guest

    Some brainwashed person told me on another post that we have freedom and the free market. And either fairness or freedom is non sequitur.

    Perimeter rule and slot restriction doesn't look free to me. Might make it look fair to some airlines and IAD but definitely not a free market.

  29. Brian L. Guest

    Getting rid of the perimeter rule will be a tall order, largely because of the local NIMBYs who will scream about how flights to beyond perimeter destinations are somehow louder than flights to BOS/LGA.

    6 more replies
  30. Will Guest

    I agree with Ben, the perimeter rule should be eliminated.

    I think it's worth noting that until recently, DCA was also the only airport that had Washington Metro service. Now that Dulles has the Silver Line station, opened a few months ago, this aspect is no longer an issue for travelers who prefer not to rent a car or ride in cabs.

  31. Evan Guest

    In addition to the noted frequencies between DCA and LGA, the airport also has an obscene number of American Eagle nonstops to very small airports. (Wilmington, NC comes to mind.) AA has real pricing power for these routes, and they're assuredly more profitable than adding frequencies to LAX. That's not great for the consumer, but it explains AA's resistance.

    1 more reply
  32. Never In Doubt Guest

    SFO has one United and one Alaska RT per day, keeping prices high.

    Would love to see that expanded!

  33. eponymous coward Guest

    The airport we should REALLY have opened up to beyond perimeter operations is LGA… it’s a joke that the best airport for Manhattan gets DEN or once a week Saturday service beyond perimeter and that’s it.

    I’d guess Delta wants SEA/LAX-DCA slots for sure, but yeah, sure, add some beyond slots. SAN, SAT, SJC might be logical too. I’m

    2 more replies
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atcsundevil Guest

Ben, I love your articles, but as a DC native and an air traffic controller that works arrivals to the DC metro airports, you're wrong here. DCA is currently leading the nation in the frequency at which airborne holding is required. More than Newark, more than LaGuardia, more than Kennedy. That's in large part due to ramp congestion, and specifically the new concourse built for American. A321s pushing from the new concourse are blocking taxiways and forcing airborne holding multiple times each day. We held six times for 20-45 minutes in a single day last week. The airport has a high percentage of regional jets **because that's all it can handle**. It's already running beyond its capabilities with no possibility for further expansion of the airfield. Dulles was built for a reason. It has four runways with plans for a fifth and capacity to spare. Relaxing or eliminating the DCA perimeter even with slot controls will make the airport even less manageable. It limits the effectiveness of ground stops and EDCTs during high demand periods because more flights will already be in the air. The airport is barely coping as it is, and messing with the perimeter rules again will only cause significantly worse problems. Just to give you an idea of how bad things are right now — I refuse to fly out of DCA despite its convenience. Holdings and diversions for volume, ramp congestion, and VIP movements simply make it unpredictable and unreliable, in my opinion.

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atcsundevil Guest

@Tim Dunn Where did I say delays were worse at DCA than the NY metros? I said the frequency of airborne holding is significantly higher. I also don't know what you mean by, "ATC has to serve airlines and people, not the other way around." because I didn't say anything that would imply otherwise. I think you're reading things from my comment that aren't there. The whole point is that we're a service, but it negatively impacts that service when sectors become overloaded due to holding. AA creates their schedules, and currently there's a detrimental impact to airport operations. We aren't holding because we want to, we're holding because we have to. But sure, I guess you're the expert on my job, so we'll just go with what you said. @tom0706 More flights will already be in the air if they're coming from beyond the perimeter. Ground stops and ground delays are implemented in a first tier or internal basis. That means that all flights within a given distance of the airport (roughly 500 miles) or within that en route center's area of responsibility (in this case, Washington Center) will be stopped or delayed on the ground to manage or balance demand. Priority is obviously given to aircraft already in the air, so those on the ground will have to wait until there's a sufficient gap in the sky, and crucially, the airport can accept the traffic. Right now, it's easier to manage demand on short notice because so many flights are first tier. They can simply be kept on the ground while airborne volume is managed. If more of that traffic is coming from two, three, or four hours away, it renders those traffic management tools useless, because they will often have departed before the airport required flow management. There are other methods we can use to meter flights while they're enroute, but they aren't effective in some situations. At that point, holding becomes the only option, which is the last resort. It puts an added burden on the sector having to hold by increasing complexity, which is why the other tools exist to ideally prevent or limit that from happening. People seem to think that slot controls mean that airlines have a precise time for takeoff and landing, but that isn't how it works. DCA is heavily banked and, demand regularly exceeds the rate at which the airport can actually accept traffic. It's effectively a single runway field with the added complexity of a prohibited area, no ILS landing south, congested flows in and out, and limited taxiway and ramp space. There's no other single airport in the world that contends with the slew of complexities DCA deals with given the volume it's expected to handle. The current situation already isn't working, and making changes like these can only impact things for the worse because it takes more tools out of the traffic management toolchest. But I'm sure people like @Tim Dunn will still fight me in the comments, because how could I possibly know how any of this works..

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DesertGhost Guest

I'll give a working air traffic controller's opinion more weight than yours (and certainly mine) on the issue of airport congestion. As Mark Twain once observed, "There are three kinds of lies - lies, damned lies, and statistics."

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