AVIATION

COMPETITION

Issues Related to the

Proposed United

Airlines-US Airways

Merger

United States General Accounting Office

GAO Report to Congressional Requesters

December 2000

P U.S. GOVERNMENT PRINTING OFFICE 1991-523-762

GAO-01-212 Printed copies of this document will be available shortly.

GAO Form 171 Rev. (3/99)
1

Contents

Page

Letter 3

Appendixes

I Scope and Methodology 26

II Combined Domestic and International Measures of Airline Size 30

III Selected Financial Data for Some Major U.S. Airlines, Calendar Year 1999 and First 9

Months, 2000 31

IV Markets in Which the Proposed Merger Could Reduce Competition to Only One or Two

Competing Airlines 32

V Markets in Which the Proposed Merger Could Increase Competition 41

VI GAO Contacts and Staff Acknowledgments 45

Figures

1 New United Would Carry Over One-Quarter of All U.S. Passengers 5

2 Map of Domestic Routes Scheduled to Be Flown by New United 7

3 Number of Markets and Passengers Subject to a Loss of Competition Due to the

Merger 13

4 Number of Markets and Passengers That Could Benefit From an Increase in

Competition 18

Tables
2

1 Measures of Airline Size for the 12 Months Ending June 30, 2000 10

2 Five Largest Markets in Which the Proposed Merger Could Leave Only Two

Competitors 14

3 Number and Size of Markets Dominated by Domestic Airlines 15

4 Market Shares of Nonstop Passenger Traffic Between United’s and US Airways’ Hubs 16

5 Analysis of Markets That Would Receive Online Service From New United 19

6 Comparison of Potential Competitive Impact of the Proposed United-US Airways Merger

and the Proposed Northwest--Continental Stock Acquisition and Alliance 21

7 DC Air’s Proposed and Other Airlines’ Scheduled Service From Reagan National to Nine

Competed Markets 23

8 DC Air’s Proposed Service Faces Significant Challenges Against Other Airlines in the

Washington, D.C., Area 24

Related GAO Products

Abbreviations

DOJ Department of Justice

DOT Department of Transportation

GAO General Accounting Office
United States General Accounting Office

Washington, DC 20548

December 15, 2000

The Honorable James L. Oberstar

Ranking Democratic Member

Committee on Transportation and

Infrastructure

House of Representatives

The Honorable Louise M. Slaughter

House of Representatives

In May 2000, two of the nation’s largest airlines, United Airlines (United) and US Airways,

proposed to merge.1

 As part of the overall agreement, United and US Airways also proposed

to divest some of US Airways’ assets at Ronald Reagan Washington National Airport (Reagan

National) to create an airline to be known as DC Air. Concern has arisen regarding the

possible effects that the merged airline (“new United”) would have on competition in the

airline industry and whether DC Air would be an effective competitor. The Department of

Justice is currently reviewing the proposal to determine if the merger would violate U.S.

antitrust laws and, if so, whether the proposed divestiture constitutes an adequate remedy.

In its review, Justice considers a number of factors, including increases in market

concentration; potential adverse effects on competition of the transaction; the likelihood of

new entry; possible efficiencies or other benefits; and whether, absent the merger, one of the

airlines will fail and exit the market and there is no less anticompetitive alternative.

At your request, we focused this report primarily on the potential competitive aspects of the

proposed merger and analyzed three issues: (1) how the proposed merger would alter the

U.S. domestic airline industry; (2) the potential harmful and beneficial effects of the proposed

merger on consumers, focusing on its effects on competition in specific markets; and (3) how

the service that DC Air is planning to offer compares with the service scheduled by other

airlines in the same markets.

To determine how the proposed merger would alter the U.S. domestic airline industry, we

analyzed how the combined airlines would compare with other major U.S. airlines using

common measures of market strength. To determine the potential impacts of the proposed

merger on competition in specific markets, we analyzed data on the 5,000 busiest domestic

airline markets. To compare the service that DC Air is planning to offer with the service

 

1

 Technically, United proposed to acquire US Airways for $11.6 billion, although the transaction is

generally referred to as a merger. For the remainder of this report, we will refer to the transaction as a

merger.
4

scheduled by other airlines, we analyzed each airline’s expected amount of service (e.g.,

flight frequency), along with the type of aircraft each anticipates using, to relevant

destinations. Further details on our objectives, scope, and methodology are discussed in

appendix I.

We recognize that other important factors must be carefully weighed before a complete

assessment of the proposed merger’s impact can be made. For example, as agreed with your

offices, this report does not examine in detail how the proposed merger would alter an

airline’s concentration at particular cities or how such a change in concentration could affect

potential competitors’ market entry. Similarly, the report does not include evaluations of the

proposed merger’s potential impacts on international competition, service to smaller

communities, or other concerns, such as the integration of the two airlines’ labor forces.

Although this report presents publicly available information from US Airways concerning

their financial condition and competitive position, we did not independently evaluate its longterm financial viability. We also did not attempt to determine the extent to which

competition in the domestic airline industry might change in the event that the merger does

not occur.

Results in Brief

The merger of United and US Airways as proposed, even with the divestiture of selected

assets to the new DC Air, would create an airline so large and with dominance in so many

markets that, according to airline officials and other industry observers, it would spur further

industry consolidation. New United would increase dominance in five times as many

markets and would affect nearly three times as many passengers as the proposed stock

acquisition and alliance between Northwest Airlines and Continental Airlines. Officials of

both airlines believe the merger will present substantial benefits to passengers and

communities, and US Airways officials have expressed concern regarding the airline’s ability

to compete as an independent carrier, given the current commercial aviation market. The

breadth of likely increases in market dominance, which is the primary focus of our review,

represents only part of the scope of the important issues that the Department of Justice

considers in evaluating proposed mergers. Ultimately, Justice has the responsibility to

evaluate the merger and the access to proprietary business information needed to determine

whether the merger violates the antitrust laws.

If the merger proceeds as proposed, it would significantly alter the current state of

competition in the domestic airline industry. New United would become the largest U.S.

airline as indicated by the usual measures of airline size. It would have over 25 percent of the

total U.S. domestic market and would take in almost $9 billion more in revenue than the next

largest U.S. airline. Figure 1 compares the percentage share of domestic passengers that new

United would carry relative to that flown by other major U.S. airlines. Industry analysts and

representatives of other major U.S. passenger airlines have said that new United’s size would

leave other airlines with little choice but to respond competitively, likely spurring further

industry consolidation. US Airways officials state that, with the airline’s high cost structure,

it has become increasingly difficult to compete profitably and that, absent the merger,

competition in the East Coast could be lessened.
5

Figure 1: New United Would Carry Over One-Quarter of All U.S. Passengers

Source: GAO’s analysis of Department of Transportation data on enplaned passengers, 1999.

Independent of the possibility that the merger could lead to further consolidation in the

airline industry and of the effects that such a change might exert on competition, the UnitedUS Airways merger would have both harmful and beneficial effects on consumers. New

United could reduce or eliminate competition in 290 markets, in which approximately 16

million passengers traveled in 1999. While United and US Airways currently control more

than half of the passenger traffic in (i.e., dominate) over 1,000 of the 5,000 most heavily

traveled domestic markets, new United could dominate another 126 of those markets. New

United would carry large portions of the nonstop traffic in all the markets between its eight

hub cities. At the same time, new United would increase competition and benefit consumers

in some markets. By combining the operations of the two airlines in markets where each

previously had a relatively limited presence, the merger could create an additional effective

competitor in 65 of the top 5,000 markets, in which about 2.9 million passengers flew in 1999.

In addition, service could improve and competition could increase in another 256 relatively

small markets after the merger created new on-line connections. Furthermore, United has

indicated that they plan to continue service for 2 years to all communities now served by US

Airways.

Concerning US Airway’s divestiture of certain of its assets to create DC Air, the airline would

face significant competitive challenges from other airlines that already provide service in the

Washington, D.C., area. DC Air would compete directly with other airlines in 9 of the 43

markets it plans to serve with nonstop flights from Reagan National. In those markets,

however, DC Air anticipates operating fewer flights with smaller aircraft than other airlines

have scheduled. And although DC Air would face no direct competition from airlines at

Reagan National in its other 34 markets, airlines operating at the other two Washington, D.C.-

area airports would offer competition in 28 of those markets. Again, those competing airlines

have scheduled more flights, more available seats, and larger aircraft than DC Air plans to
6

use in most of those markets. DC Air officials say that they will balance the difference in

service by offering lower fares than their competitors.

Background

United Airlines (United) operates nearly 2,300 flights per day to 134 destinations in 27

countries—including 91 cities in 49 states—with a fleet of about 600 jet aircraft. Within the

United States, United provides service between other cities and its hubs in Chicago, Denver,

Los Angeles, San Francisco, and Washington, D.C., using its aircraft and those of its

independently owned regional affiliates, which operate under the name of United Express.

As of March 31, 2000, United Express served another 133 cities in the country, producing a

combined domestic network of 224 cities.

In 1999, US Airways flew to 236 cities in 38 states in the continental United States, along with

nearly 30 other cities in 12 countries, territories, and commonwealths, using its own fleet of

over 400 aircraft and those of its regional affiliates, which operate as US Airways Express.

US Airways’ system is heavily concentrated in the eastern United States, with hubs located in

Charlotte, Philadelphia, and Pittsburgh. US Airways also has sizable operations at BaltimoreWashington International Airport and at Reagan National, where it operates an East Coast

shuttle service to Boston’s Logan International Airport and New York’s LaGuardia Airport.

On May 24, 2000, United and US Airways agreed to merge their operations. Under the terms

of their proposed merger, United would acquire US Airways in a transaction valued at $11.6

billion. Specifically, United would pay $60 for each share of common US Airways stock for a

total of $4.3 billion and would assume $1.5 billion in US Airways net debt and $5.8 billion in

aircraft operating leases. According to information from United, the combined company

would have approximately 145,000 employees. It would operate eight hubs in six states and

serve a total of 380 airports throughout the country, reaching communities in every state.

Figure 2 illustrates the cities that would obtain scheduled service from new United.
7

Figure 2: Map of Domestic Routes Scheduled to Be Flown by New United

Note: This map does not include routes flown by new United’s regional affiliate carriers.

Under the terms of the proposed merger, United plans to divest some of the assets US

Airways uses to provide air service to and from Reagan National. United and US Airways

entered into a Memorandum of Understanding to sell or transfer leases to certain US Airways

assets at Reagan National for approximately $141 million. These assets would be used to

create a new airline known as DC Air. They include 222 departure and arrival slots,2

 several

gates and related airport facilities, and the operations of an existing commuter airline. US

Airways is assembling the relevant assets in a newly licensed carrier that will be purchased

by DC Air contemporaneously with the closing of the United-US Airways merger.

DC Air has expressed a commitment to maintain service to essentially all of the cities

currently served by US Airways from Reagan National. DC Air will assume contracts between

US Airways and certain other airlines to provide DC Air with service using 19 50-seat regional

jet aircraft.3

 DC Air will operate its own turbo-prop aircraft on some routes. DC Air also

signed an agreement with United and US Airways under which it will lease 10 Boeing 737s.

 

2

The Federal Aviation Administration limits the number of operations (takeoffs and landings) that can

occur during certain periods of the day at four congested airports--O'Hare in Chicago; Reagan National

in Washington, D.C.; and Kennedy and LaGuardia in New York. The authority to conduct a single

operation during these periods at these four airports is commonly referred to as a “slot.”

3 Different statutory definitions of “regional jets” within the Wendell H. Ford Aviation Investment and

Reform Act for the 21st Century (AIR-21) (P.L. 106-181) variously define a “regional jet” as having a

maximum passenger seating capacity of “not less than 30 nor more than 75” (sec. 210) or “less than 71”

(sec. 231).” However, the term is generally applied to turbofan-powered aircraft seating between 30

and 70 passengers. We expect to publish a report in February 2001 on the markets in which U.S.

commercial airlines have deployed these aircraft and the effects they may have on air traffic

congestion and delays.
8

According to a representative for DC Air, this is a transitional arrangement. DC Air expects

to make its own arrangements for large jet aircraft as soon as possible after the merger.

However, new United plans to continue operating other important service to and from

Reagan National that US Airways currently operates. This includes the shuttle service to

New York and Boston, as well as service to Charlotte, Pittsburgh, and Philadelphia. DC Air

will also serve Charlotte, Pittsburgh, and Philadelphia, but not with as many frequencies as

new United would.

The consummation of the proposed merger is subject to various conditions set forth in the

agreement and approvals by various regulatory bodies.4

 US Airways stockholders approved

the merger on October 12, 2000. Both the U.S. departments of Justice (DOJ) and

Transportation (DOT) have responsibilities for reviewing airline mergers and acquisitions.5

DOJ has the authority to review mergers or stock acquisitions before they take place to

determine whether they violate antitrust laws. Under the Hart-Scott-Rodino Act, an

acquisition of voting securities above a set monetary amount must be reported to DOJ for

prior review. DOJ has the authority to institute judicial proceedings under the Clayton Act if

it determines that a merger or acquisition may substantially lessen competition in a relevant

market or if it tends to create a monopoly. If DOJ believes any agreement is anticompetitive

in whole or in part, it may seek to block the agreement in federal court.6

To analyze the potential effect of a merger under the Clayton act, DOJ follows the analytical

process set forth in the Horizontal Merger Guidelines, using a five-part analytical process.7

First, DOJ defines the markets in which the airlines operate and determines whether the

merger is likely to significantly increase market concentration.8

 Second, DOJ examines

potential adverse competitive effects of the agreement, such as eliminating existing

competition in hub-to-hub markets and potential competition in new markets. Third, DOJ

considers the extent to which new competitors are likely to enter the market in sufficient

 

4

 The agreement is set to terminate on December 31, 2000, although the parties can agree to extend it

to August 1, 2001 (Article VII Section 7.01(b)(i)).

5

 The merger may also be reviewed by the European Commission and state attorneys general.

6

 On November 6, 2000, DOJ announced a tentative settlement in its antitrust suit opposing

Northwest’s purchase of a controlling interest in Continental. Under the terms of the agreement in

principle, Northwest would divest all but 7 percent of the voting interest in Continental and would be

subject to significant restrictions on its ability to vote any stock it retains. We reported on the

competitive implications of the potential alliance between those two airlines in 1999. See Aviation

Competition: Effects on Consumers From Domestic Alliances Vary (GAO/RCED-99-37, Jan. 15, 1999).

7

 United States Department of Justice and Federal Trade Commission Revision to the Horizontal

Merger Guidelines (Apr. 8, 1997)(hereinafter, Merger Guidelines).

8

 To analyze a merger, DOJ defines both the product or service and geographic market in which the

merging parties compete. In the airline industry, the relevant market has been defined as scheduled

airline service between a point of origin and a point of destination. This is often, but not always,

defined as a city pair. In addition, DOJ recognizes that nonstop service between cities is important

because business travelers are less likely to regard connecting service as a reasonable alternative.

Thus, DOJ may see a transaction as competitively problematic because of its impact on nonstop citypair traffic. Some cities are served by more than one commercial airport. These cities include Los

Angeles, San Francisco, Chicago, New York, and Washington, D.C. In these cases, the relevant market

may be an airport pair. See app. I for more information on our definition.
9

numbers to counter the increased ability of incumbents to raise prices or reduce output

below competitive levels as a result of the merger. Fourth, DOJ examines the “merger

specific” efficiencies or other competitive benefits that may be generated by the agreement.

Finally, DOJ considers whether, absent the merger, one of the airlines is likely to fail, causing

its assets to exit the market, and there is no less anticompetitive alternative. After completing

these analyses, DOJ attempts to balance all of the factors in deciding whether the merger

raises any antitrust concerns.9

DOT conducts its own analysis of airline mergers and acquisitions and submits its views and

any relevant information in its possession to DOJ. In addition, before commencing

operations, new airlines generally must obtain separate authorizations from DOT—

“economic” authority from the Office of the Secretary and “safety” authority from the Federal

Aviation Administration (FAA). The Office of the Secretary is responsible for assessing

whether applicants have the managerial competence, disposition to comply with regulations,

and financial resources necessary to operate a new airline. In addition, when transactions

involve the transfer of international route authority, DOT is responsible for approving such

matters to ensure that they are consistent with the public interest. FAA is responsible for

certifying that the applicants’ manuals, aircraft, facilities, and personnel meet federal safety

standards.

New United Would Gain the Largest Market Share of Any Major U.S. Airline,

Potentially Spurring Further Industry Consolidation

If the United-US Airways merger proceeds as proposed, new United would have the largest

domestic market share of any U.S. carrier, according to several measures, including the total

number of passengers that an airline carries, the number of available seats flown by the

airline, the total number of departures, or the number of revenue passenger miles flown. 10

The merger proposal would join two of the largest airlines in the United States. Currently,

United ranks second among major U.S. passenger airlines, when ranked by the total number

of paying passengers flown, trailing only Delta Air Lines (Delta). US Airways ranks fifth. The

combined airline would be significantly larger than any other major U.S. airline. Table 1

shows the relative size of major U.S. passenger airlines as indicated by common measures of

airline market presence, along with the airlines’ 1999 total operating revenue. (Information

on the airlines’ total—domestic and international—operations appears in app. II.)

 

9

If DOJ concludes that a merger threatens to deprive consumers of the benefits of competitive air

service, they may seek a preliminary injunction to prevent consummation of the transaction pending

judicial proceedings. In some cases, the parties may agree to modify the proposal to address

competitive concerns identified by DOJ, in which case DOJ ordinarily files a complaint along with a

consent decree that embodies the agreed-upon changes.

10 Revenue passenger miles represent the number of paying passengers transported over each mile.

“Revenue passengers” do not include those who are flying on frequent flyer award tickets and others

who did not pay for their flights (e.g., airline employees).
10

Table 1: Measures of Airline Size for the 12 Months Ending June 30, 2000

Revenue passenger

enplanementsa

Revenue passenger

miles

Total operating

revenueb

Airline

Number in

thousands

Percent

of total

Number in

thousands

Percent

of total

Dollars in

millions

Percent

of total

Delta Air Lines 99,275 19.3 81,240,603 17.9 14,711 16.3

United Airlinesc77,365 15.0 81,629,552 18.0 18,027 20.0

American Airlinesd69,673 13.5 77,665,215 17.1 17,730 19.6

Southwest Airlines 69,056 13.4 39,378,468 8.7 4,736 5.2

US Airwayse54,442 10.6 37,076,149 8.2 8,595 9.5

Northwest Airlines 49,927 9.7 44,525,296 9.8 10,276 11.4

Continental Airlines 37,365 7.3 39,835,520 8.8 8,639 9.6

Trans World Airlines 25,448 4.9 23,047,434 5.1 3,309 3.7

America West Airlinesf19,171 3.7 18,218,790 4.0 2,211 2.4

Alaska Airlinesg12,719 2.5 10,814,906 2.4 2,082 2.3

Totalh514,441 100.0 453,431,933 100.0 90,316 100.0

New Unitedi131,807 25.6 118,705,701 26.2 26,622 29.5

a

”Revenue passenger enplanements” represent the total number of paying passengers boarding an aircraft. Thus, for example,

a passenger that must make a single connection between his or her origin and destination counts as two enplaned passengers

because he or she boarded two separate flights. “Revenue passengers” do not include those who are flying on frequent flyer

award tickets and others who did not pay for their flights (e.g., airline employees).

b

Figures for total operating revenue include revenue from international operations, except for Southwest Airlines, which

provides only domestic service. The time period for revenue information is Jan. 1, 1999 through Dec. 31, 1999.

c

Total operating revenues are for the parent (UAL Corporation).

d

Total operating revenues are for the parent (AMR Corporation).

e

Total operating revenues are for the parent (US Airways Group, Inc.).

f

Total operating revenues are for the parent (America West Holdings, Inc.).

g

Total operating revenues are for the parent (Alaska Air Group, Inc.).

h

Totals may not add to 100 percent due to rounding.

i

Totals for new United are not adjusted for those operations that might become part of DC Air.

Source: GAO’s analysis of data from DOT.

First, as measured by the number of revenue passengers (paying customers) enplaned,

United ranks second behind only Delta. In the 12 months ending June 30, 2000, United

carried over 77 million paying passengers, or about 15 percent of the total carried by all

major U.S. passenger airlines. US Airways carried over 54 million paying passengers and

ranked fifth, with about 11 percent of the total. If the two airlines had been merged (and no

allowances were made for passengers who, under a merger, might have been carried by DC

Air), new United would have carried nearly 132 million revenue passengers, or over 25

percent of the total U.S. domestic market. Under those terms, new United would be

significantly larger than any of the other major U.S. passenger airline: It would carry about 33

percent more revenue passengers than Delta and 89 percent more than American Airlines

(American) and Southwest Airlines (Southwest). New United would carry nearly the same

number of revenue passengers as Northwest Airlines (Northwest), Continental Airlines
11

(Continental), Trans World Airlines (TWA), and America West Airlines (America West)

combined.

In terms of revenue passenger miles, United currently is the largest U.S. major airline, with a

market share of 18 percent. US Airways ranks seventh among U.S. carriers with a market

share of about 8 percent. After the merger, new United’s market share would equal more

than 26 percent, making it 46 percent larger than Delta’s, 53 percent larger than American’s,

and nearly three times as large as Southwest’s.

New United would take in significantly more revenue than any other major U.S. airline.

According to 1999 year-end financial information, new United would have earned $26.6

billion in revenue, or $8.9 billion (33 percent) more than American and almost $12 billion (45

percent) more than Delta. New United’s revenue would exceed that generated by Southwest,

Northwest, Continental, and American West combined.

According to industry analysts and officials from several airlines, new United would so alter

the existing balance in the domestic market that, for the other major U.S. airlines to compete

successfully, they would have little choice but to consolidate as well. These analysts

generally depict the industry as divided into three segments: the large network airlines

(Delta, United, and American), the midsized network airlines (Continental, Northwest, and

US Airways), and the smaller major airlines (TWA, America West, Alaska, and American

Trans Air.) While carrying nearly as many passengers as American, Southwest is

characterized separately because it does not operate a traditional hub-and-spoke network.

Officials representing several of the larger airlines with whom we spoke said that new

United’s size would give it a significant competitive advantage. For example, according to an

analysis performed for one of the airlines, new United would have 97 percent more daily

departures than its closest competitor, Delta (8,401 compared with 4,260). An analysis for

another airline using available seat miles11 showed that new United would be almost 50

percent larger than its closest competitor (American). Consequently, the officials said that

unless their airlines also merged, they would be unable to compete with new United.

Officials from US Airways pointed to how domestic competition is changing and how those

changes are likely to affect their airline's success. US Airways officials have expressed

concern about whether the airline can survive over the longer term as an independent airline,

given the current commercial aviation market without growing substantially larger in size.

The Chairman of US Airways has characterized US Airways as the last of the "mature-cost"

midsized carriers, most of which (e.g., Braniff, PanAm, and Eastern) have gone bankrupt and

two of which (Continental and TWA) have reduced their costs through two bankruptcy

proceedings. Citing major competition from low-cost carriers (including Southwest, Jet Blue,

and AirTran), the Chairman testified that the airline needs to join with a partner that has a

more extensive network to expand into the global market.12

 

11 Available seat miles are defined as the number of aircraft miles flown in each inter airport hop (flight

segment) multiplied by the number of seats available on that flight for revenue passenger use on that

flight segment.

12 See the written testimony of Stephen M. Wolf, Chairman, US Airways Group, Inc., before the

Committee on Transportation and Infrastructure, United States House of Representatives, June 13,

2000.
12

US Airways officials note that as a result of the airline’s mature labor costs and

predominantly short-haul route structure, US Airways has the highest cost structure of any

domestic airline--nearly twice the cost per available seat mile of Southwest Airlines. They

note that these high costs make it increasingly difficult to achieve profitability,13 and that the

percentage of routes profitable on a fully allocated cost basis has steadily declined since

1998. US Airways officials believe other airlines recognize their weak position and see them

as competitively vulnerable. They note that their share of passenger traffic in the East Coast

is falling while their competitors' shares are rising. For example, they stated that Delta has

begun competing in nearly half of the cities that US Airways serves from New York's

LaGuardia Airport. Thus, these officials state that it has become increasingly difficult for US

Airways to compete profitably. United and US Airways officials believe that, absent their

merger, competition in the East Coast would be lessened to the detriment of the traveling

public.

Proposed Merger Would Reduce Competition in Some Key Markets but Provide

Some Benefits

The United-US Airways merger would have both harmful and beneficial effects on

consumers—that is, competition would decrease in some markets and increase in others.14

Harmful effects will occur if the merger reduces the number of effective competitors in a

market.15 The opportunity for harm increases with the number of overlapping markets and

the number of passengers flying in these markets. Additionally, the opportunity for harm

increases if the merger creates an airline that dominates particular markets (i.e., an airline

that achieves more than half of each of these markets), since that dominance may allow the

airline to impose higher airfares on passengers. Industry experts generally agree that if an

airline can capture significant market share, its revenue share will increase faster than its

market share; in other words, an airline can earn higher yields because, among other reasons,

it offers the high level of flight frequencies preferred, especially by business travelers.16 In

 

13 US Airways reported net income of $197 million in 1999 (about 3 percent of total operating revenue)

and a net loss of $168 million during the first 9 months of 2000. In 1999, UAL Corporation (the holding

company of United) reported net earnings of $1.2 billion (or 6.7 percent of operating revenue). In the

first 9 months of 2000, UAL Corp. reported net earnings of $121 million (or about 0.8 percent of

operating revenue). See app. III for information on total operating revenues and net income or

earnings for other major airlines.

14 Our analysis of the potential changes in competition is based on traffic flows and service patterns as

they existed in 1999. To the extent that competition in particular markets changes in the future, the

exact numbers of markets and passengers that might be positively or negatively affected by the

potential merger would be different than that cited here.

15 We define a competitor as an airline having at least 10 percent of a market. This level is used by DOT

and has been supported by some airline officials and industry experts. Accordingly, for the purposes

of this report, we are defining any airline as an “active competitor” if it carries 10 percent or more of

any given market. Conversely, if an airline or merger has less than 10 percent of any given market, we

are defining its market share as “limited.”

16 The extent to which airlines can achieve market dominance is particularly important in determining

the degree to which a merger may be harmful to consumers. Airlines that achieve a dominant market

position can drive out airlines with a small market share by making it unprofitable for them to

compete. Additionally, a number of studies—including our own--have shown that markets with fewer

competitors, especially those dominated by a single carrier, have higher fares. See, for example, Steven

A. Morrison, “New Entrants, Dominated Hubs, and Predatory Behavior,” Statement before the

Subcommittee on Antitrust, Business Rights, and Competition, Committee on the Judiciary, United

States Senate (Apr. 1, 1998). See also Airline Competition: Higher Fares and Less Competition

Continue at Concentrated Airports (GAO/RCED-93-171, July 15, 1993).
13

addition, especially in dominated markets, other operating and marketing features (such as

frequent flyer programs) would make entry into those markets by would-be competitors

more difficult. Conversely, the merger would also benefit consumers. In markets where

each of the two airlines now has limited market shares, the merger would allow them to

create competition against other airlines. Additionally, by extending the carriers’ operations

to city pairs where only one of the two airlines previously operated at each endpoint, the

merger would create new on-line service between those communities.17 Finally, the merger

would benefit members of each airline’s frequent flyer programs by expanding the number of

destinations that the members could reach. United and US Airways assert that the merger

would also deliver other benefits.

Merger Would Have Harmful Effects by Reducing or Eliminating Competition in Some Key

Markets

The United-US Airways merger could reduce or eliminate competition in 290 of the top 5,000

markets in the United States. About 16 million passengers traveled in those 290 markets in

1999, or about 5 percent of the passengers who flew in the top 5,000 markets in that year.

Figure 3 shows the number of markets and passengers that could potentially be affected by

an elimination of or reduction in competition due to the merger.

Figure 3: Number of Markets and Passengers Subject to a Loss of Competition Due to the Merger

Source: GAO’s analysis of DOT data on the top 5,000 markets in 1999.

 

17 On-line service provides passengers with connecting flight without requiring them to change airlines.

Service that requires passengers to change airlines to continue their flights (excluding those requiring

a passenger to transfer between a larger airline and its commuter affiliate or other airlines with which

it may have a code-sharing agreement) is referred to as “interline” service.
14

In 43 of these markets, in which 4.1 million passengers traveled, the merger could reduce the

number of competitors from two to one, eliminating effective competition. For example, new

United could achieve a market share of more than 90 percent between Boston and the

Washington, D.C. area (approximately 1.3 million passengers in 1999) and between Tampa

International Airport and the Washington, D.C. area (about 339,000 passengers).18 Another six

of those markets are between United’s and US Airways’ hub airports.

In 102 markets, the merger could reduce the number of competitors from three to two. Over

5.7 million passengers traveled in these markets in 1999. Table 2 shows the five largest

markets in which the merger could leave only two remaining competitors. Another 6.2 million

passengers traveled in 145 other markets that could lose competition as a result of the

merger. Appendix IV contains additional information on the markets in which the merger

could leave two or fewer competitors.

Table 2: Five Largest City Pair Markets in Which the Proposed Merger Could Leave Only Two

Competitors

Premerger market

shares

Market

Number of

passengers

in 1999 United US Airways

Postmerger

market

share

Remaining

competing airline

(market share)

Baltimore-Chicago 954,010 39.6 17.5 57.1 Southwest (38.3)

Chicago-Washington, D.C. 921,010 61.9 14.6 76.6 American (17.0)

Washington, D.C.-Orlando 642,630 16.6 36.3 52.9 Delta (45.0)

Baltimore-Los Angeles 468,810 18.3 40.4 58.8 Southwest (19.6)

Miami-Washington, D.C. 385,380 18.1 19.2 37.3 American (57.4)

Source: GAO’s analysis of DOT data on the top 5,000 markets in 1999.

New United Would Increase Number of Dominated Markets

The merger would increase the number of markets in the top 5,000 that are dominated by a

single airline. The major airlines already dominate about two-thirds of the top 5,000 markets,

in which over 200 million passengers flew in 1999. Delta then dominated more markets than

any other airline (849), but the 289 markets that Southwest dominated carried more

passengers (48.8 million). America West dominated the fewest markets (41) in which the

smallest number of passengers traveled. Table 3 summarizes the number of markets in the

top 5,000 that the major airlines dominated in 1999, the number of passengers who traveled in

those markets, and the number of markets and passengers that might be affected by the

proposed merger.

 

18 Previous GAO work indicates that Reagan National, Washington Dulles, and Baltimore-Washington

International airports appear to represent distinct markets for certain time-sensitive business

travelers. For leisure passengers, however, the airports have served somewhat as substitutes for one

another. See Reagan National Airport: Capacity to Handle Additional Flights and Effect on Other Area

Airports (GAO/RCED-99-234, Sept. 17, 1999).
15

Table 3: Number and Size of Markets Dominated by Domestic Airlines

Airline with dominant

market share

Number of

markets

Total passengers,

1999

Percent of

total

Alaska 92 8,840,140 2.7

America West 41 2,530,250 0.8

American 242 16,052,840 4.9

Continental 126 9,699,080 3.0

Delta 849 40,219,160 12.4

Northwest 396 19,319,310 5.9

Southwest 289 48,827,510 15.0

Trans World 149 6,535,530 2.0

United 349 26,020,450 8.0

US Airways 681 28,145,970 8.6

None 1,786 119,442,930 36.7

Total 5,000 325,633,170 100.0

New United 1,156 61,089,380 18.8

Net increase 126 6,922,960 2.1

Note: Dominant markets are those with more than 50-percent market share.

Source: GAO’s analysis of DOT data on the top 5,000 markets in 1999.

New United would increase the number of markets that the two airlines currently dominate.

Before combining their market shares, United and US Airways dominate a total of 1,030

markets. New United could dominate another 126 markets, potentially affecting the

approximately 6.9 million passengers who traveled there in 1999. The number of annual

passengers in those 126 markets ranges from 4,850 to 954,010. Thus, following the merger,

new United could dominate a total of 1,156 markets, affecting 61.1 million passengers. New

United’s 1,156 dominated markets would be more than 36 percent larger than those

dominated by Delta and could affect 12.3 million (or over 25 percent) more passengers than

those dominated by Southwest.

Merger Would Increase Domination Between United’s and US Airways’ Hubs

Of the 1,156 markets that new United could dominate after the merger, 28 join United’s and

US Airways’ hubs, in which over 7.7 million passengers traveled in 1999. In 26 of those 28

markets, United or US Airways already dominated nonstop travel in 1999. United dominated

all nonstop traffic in the 10 markets between its hubs, and US Airways carried nearly all of

the nonstop passenger traffic in the 3 markets between its hubs. In the 15 markets between

United’s hubs and US Airways’ hubs, one of the carriers already dominated the nonstop travel

in 13. For example, US Airways controlled 99 percent of the nonstop traffic between

Charlotte and Denver, and United controlled 62 percent of the nonstop traffic between

Philadelphia and Denver.

New United could gain market dominance in the two other markets in which neither airline

already dominated nonstop traffic in 1999, allowing it to dominate nonstop travel in all hub

markets. Those markets connect US Airways’ hub in Philadelphia with United’s hubs in

Chicago (O’Hare) and San Francisco. Table 4 summarizes nonstop market share data for

both United and US Airways in each of the 15 markets between United’s and US Airways’

hubs.
16

Table 4: Market Shares of Nonstop Passenger Traffic Between United’s and US Airways’ Hubs

Hub markets United US Airways New United Total passengers, 1999

Charlotte-Denver 0.6 99.3 99.9 47,140

Charlotte-Washington Dulles 0.1 99.9 100.0 53,350

Charlotte-Los Angeles 0.1 99.9 100.0 96,970

Charlotte-Chicago O’Hare 38.4 61.6 100.0 203,010

Charlotte-San Francisco 0.1 99.9 100.0 97,330

Philadelphia-Denver 61.8 29.5 91.3 156,850

Philadelphia-Washington Dulles 53.5 46.5 100.0 18,060

Philadelphia-Los Angeles 41.0 56.0 97.0 229,240

Philadelphia-Chicago O’Hare 46.8 26.3 73.1 580,610

Philadelphia-San Francisco 46.5 47.6 94.1 243,400

Pittsburgh-Denver 0.2 99.3 99.5 69,550

Pittsburgh-Washington Dulles 2.1 97.9 100.0 22,270

Pittsburgh-Los Angeles 0.3 99.7 100.0 90,820

Pittsburgh-Chicago O’Hare 37.7 56.7 94.4 273,030

Pittsburgh-San Francisco 0.1 99.4 99.5 98,620

Source: GAO’s analysis of DOT data on the top 5,000 markets in 1999.

In eight of those markets, the merger would have no impact on competition because United’s

market shares are so small that we did not define United as a competitor. For example, in

the market between Pittsburgh and Washington Dulles, United would not be defined as a

competitor because it carries only 2 percent of the nonstop passenger traffic. Thus, merging

its share with US Airways’ 98-percent share would not decrease the number of competitors.

However, in 7 of the 15 markets between United’s and US Airways’ hubs, the proposed

merger could eliminate or reduce competition. In six of those markets, in which about 1.1

million passengers traveled in 1999, the only two competing airlines were United and US

Airways. The largest of these 6 markets is Pittsburgh to Chicago O’Hare, in which over

270,000 passengers flew in 1999. In the market between Philadelphia and Chicago O’Hare, in

which 580,000 passengers flew in 1999, the merger would leave only one other competitor in

the market.

New United’s shares of the nonstop passenger traffic in the more broadly defined city-pair

markets would differ relatively little from its shares in the airport-pair markets. For example,

between Charlotte and San Francisco, the combination of United and US Airways carried

nearly 100 percent of the nonstop traffic in 1999, virtually the same as the percentage of

passenger traffic that the airlines carried between Charlotte Douglas International Airport

and San Francisco International Airport. Similarly, the two airlines’ share of the nonstop

passenger traffic between Pittsburgh and Los Angeles was also near 100 percent in 1999, the

same as the share of traffic between Pittsburgh and Los Angeles International Airport. On

the other hand, in the market between Pittsburgh and Chicago, the two airlines’ market share

decreased from 94.4 percent (on an airport-pair basis) to 69.2 percent, because Vanguard

Airlines operates between Pittsburgh and Chicago’s Midway Airport.

Merger Could Increase Operating and Marketing Barriers to Entry

To the extent that a merger or acquisition creates barriers to market entry, it can limit

competition. If entry is easy, a single firm cannot charge monopoly prices over the long term

because other firms will enter and provide competition. However, if entry is difficult, then

the firm may be able to hold prices above competitive levels. Traditional hub-and-spoke

airlines are recognized as having a range of advantages that serve to restrict the likelihood

that new carriers will enter certain markets. For example, their dominance in the market

enables them to offer more flights, thus attracting business travel. As we have reported in the
17

past, operating barriers such as gate constraints (long-term leases for one airline’s exclusive

use) make entry by new competition into markets more difficult and have thereby

contributed to higher fares on routes to and from some airports.19

We have previously reported on how certain marketing practices, such as frequent flyer

programs, can act as barriers to entry.20 Under a merger, such a combination could present a

formidable barrier to entry for new-entrant airlines and point-to-point carriers lacking

extensive networks. According to an official with Charlotte’s airport, where US Airways

dominates passenger traffic in most markets, competing airlines have been reluctant to begin

any significant amount of service there, in part because of the economies of scale that US

Airways experiences and the advantages that US Airways brings with local businesses

through its sales and marketing programs.

Combined with the increase in the number of dominated markets, these operating and

marketing barriers would make potential entry by new airlines in key markets more difficult.

DOJ noted in its complaint filed in the Northwest/Continental case that effective new entry

for nonstop service in hub-to-hub markets is unlikely by any airline without a hub at one of

those cities.

Merger Would Produce Various Benefits

The merger would benefit consumers in three major ways. First, by combining the two

airlines’ operations in markets where each airline previously had a relatively limited

presence, the merger would create an additional effective competitor in those markets.

Second, consumers in some markets would benefit from having access to new on-line service

(i.e., being able to stay on one carrier for a multiple-stop itinerary). Third, the merger would

benefit members of United’s and US Airways’ frequent flyer programs by expanding the

number of destinations that they could reach under the program.

Merger Would Increase the Number of Effective Competitors in Some Markets

According to United and US Airways officials, new United could be a significant competitor

on 534 routes where neither United nor US Airways currently competes. Based on our

analysis of data for the top 5,000 markets in 1999 and our definition of an “effective

competitor” as one that carries at least 10 percent of the passenger traffic, we identified 65

markets in which the merger could increase the number of competitors. About 2.9 million

passengers traveled in these markets (or about 0.9 percent of all passengers who traveled in

the top 5,000 markets in 1999). Figure 4 illustrates the number of markets and passengers

that could benefit from an increase in competition as a result of the merger.

 

19 See Airline Deregulation: Barriers to Entry Continue to Limit Competition in Several Key Domestic

Markets (GAO/RCED-97-4, Oct. 18, 1996).

20 See Aviation Competition: International Aviation Alliances and the Influence of Airline Marketing

Practices (GAO/T-RCED-98-131, Mar. 19, 1998).
18

Figure 4: Number of Markets and Passengers That Could Benefit From an Increase in Competition

Source: GAO’s analysis of DOT data on the top 5,000 markets in 1999.

Eight of those 65 markets (all of which were relatively small, serving a total of 232,620

passengers in 1999) are currently dominated by a single airline. New United could create a

second competitor in those eight markets. In another 31 of the 65 markets (1.4 million

passengers), new United could increase the number of competitors from two to three.

Appendix V contains additional information on the markets in which the merger could create

competition.

Merger Would Improve Service for Some Consumers

The chairmen of the two merging airlines suggest that by combining what they describe as

the largely East-West structure of United with the largely North-South structure of US

Airways (in the Eastern United States), new United would bring more choice, more

destinations, and more convenience to millions of their passengers. United and US Airways

officials told us that new United would serve 256 new domestic routes. New United’s

presence in those markets could provide the 759,000 passengers who traveled them in 1999

with an additional choice of airlines and improved service.

New United would be able to serve these markets by connecting cities now served by one of

the airlines (e.g., Sacramento, to which United flies) with a city not served by that airline

(e.g., Erie, Pennsylvania, to which US Airways flies). Most of these new connecting markets

are relatively small. For example, in all of 1999, about 1,080 passengers traveled between

Sacramento and Erie. Of the 256 markets to which the airlines would offer new on-line

service, 198 (77 percent) had fewer than 2,000 passengers traveling in them in 1999.

However, because most of these markets currently have only one or two competitors,

passengers traveling there could benefit from additional competition introduced by new

United. In addition, the competition that new United could stimulate additional passenger

traffic, allowing those markets to grow. Table 5 provides additional details on the 256 on-line

routes.
19

Table 5: Analysis of Markets That Would Receive Online Service From New United

Number of competitors

(pre-merger)

Number of

markets

Average number of

passengers per year, 1999

Average number of

passengers per day, 1999

a

2

b a a

1 188 2,071 6

2 56 2,756 8

3 9 16,210 44

4 1 69,200 190

aNot applicable.

bNo carriers provided on-line service in these markets in 1999.

Source: GAO’s analysis of data from BACK Aviation Solutions.

According to information from United and US Airways, new United plans to add 31 new daily

domestic nonstop flights. Except for seven flights that would originate in either Boston or

Baltimore, those routes would originate in either a current United or a current US Airways

hub. Either United or US Airways already provides nonstop service in 12 of those markets.

For example, new United would add another nonstop flight between Charlotte and Denver,

although US Airways already schedules several daily nonstop flights in that city-pair market.

The new United’s proposed nonstop service in four markets (e.g., Boston—San Diego) would

compete with that provided by other airlines. New United would thus offer truly new

nonstop service in 15 markets—that is, new United would provide nonstop service in 15

markets where no airline currently schedules nonstop flights. Some of the totally new

nonstop domestic routes include flights between Philadelphia and Portland, Oregon;

Washington Dulles and Orange County, California; and Charlotte and Austin, Texas. The new

nonstop service would represent upgrades from the connecting service that the airlines now

provide.

Merger Could Affect Members of United’s and US Airways’ Frequent Flyer Programs

Customers of United and US Airways could also benefit from the combination of the two

airlines’ frequent flyer programs. United and US Airways officials report that the merger

would create 100 new destinations for United passengers and 147 new destinations for US

Airways passengers. According to information from officials with the two airlines, United

has approximately 39 million members of its frequent flyer program and US Airways has

approximately 20 million members of its frequent flyer program.

On the other hand, merging those frequent flyer programs would also possibly harm some

existing program members, as partners in United’s and US Airways’ frequent flyer programs

withdraw. For example, American, which has an agreement with US Airways under which

passengers traveling on US Airways can earn American frequent flyer miles, has announced

that it will terminate the agreement in 2001. Similarly, officials from Delta told us that it

would terminate a similar agreement with United if the merger were approved.

Merger May Present Other Benefits

The merger may also present other benefits to consumers, employees, and other groups.

United and US Airways assert that the merger would also provide a range of other important

benefits to consumers. For example, according to a representative of United, passengers

would experience certain benefits, such as the convenience of having one ticket and one
20

baggage claim. In addition, employees and certain communities may also benefit from the

merger. For example, United’s and US Airways’ presidents testified that under the merger,

United would furlough no employees and would continue service to all cities served by US

Airways for at least 2 years. In addition, United pledged to hold certain categories of airfares

steady over the period, apart from an allowance for increases due to rising fuel prices and

overall inflation. We did not independently evaluate these potential benefits.

Proposed United-US Airways Merger Would Have a Greater Potential Impact Than the

Proposed Stock Acquisition and Alliance of Northwest and Continental

To create a frame of reference for analyzing the competitive significance of the proposed

merger, we compared it with our analysis of the proposal by Northwest to acquire a majority

of the voting stock in, and enter into an alliance with, Continental. Northwest and

Continental announced in January 1998 that Northwest was to acquire 8.7 million shares of

Continental’s stock. These shares gave Northwest 51 percent of the voting rights in

Continental. In addition, the two airlines were entering into an alliance that would connect

their route systems. A variety of industry analysts told us they believed that Northwest and

Continental would not act as independent competitors over the long run. As a result, our

analysis of the potential competitive effects of the stock acquisition and alliance assumed

that Northwest and Continental would behave as though they had merged. Because our

analysis in this report largely parallels our analysis of the Northwest-Continental stock

acquisition and alliance, we can outline some comparisons of possible competitive effects.

In general, the proposed United-US Airways merger would potentially reduce competition in

more than four times as many markets as the Northwest-Continental stock acquisition and

alliance. (See table 6.) New United would increase dominance in five times as many

markets, potentially affecting three times as many passengers. Overall, new United would

dominate more than twice the total number of markets, potentially affecting 20 million more

passengers. In contrast, the Northwest-Continental stock acquisition and alliance would

have increased competition in more than four times as many markets as the United-US

Airways merger, benefiting more than five times as many passengers.
21

Table 6: Comparison of Potential Competitive Impact of the Proposed United-US Airways Merger and the

Proposed Northwest-Continental Stock Acquisition and Alliance

Northwest-Continental

(1997 data)

United-US Airways

(1999 data)

Competitive factor

Numbers of

markets

Passengers

affected

(millions)

Numbers of

markets

Passengers

affected

(millions)

Markets where competition would

decline 63 2.0 290 16.0

Newly dominated markets 25 2.4 126 6.9

Total dominated markets 492 40.7 1,156 61.1

Percent increase in dominated

markets 5% 12%

Markets where competition would

increase 286 15.1 65 2.9

New markets with on-line service 145 0.6 256 0.8

Note: The number of passengers potentially affected in newly dominated markets could exceed the number of passengers in

markets where competition would decline if the premerger market share for one of the two airlines was less than 10 percent, in

which case the airline would not be defined as a competitor, but the shares for both of the airlines exceed 50 percent.

Source: GAO’s analysis.

On October 23, 1998, DOJ filed a civil antitrust complaint to prevent Northwest from

acquiring or holding a majority of Continental's voting stock. DOJ said in its complaint that

Northwest's gaining voting control would lessen competition in interstate trade and

commerce and unreasonably restrain trade. DOJ identified potentially anticompetitive

effects in seven hub-to-hub city-pair markets where the two airlines would dominate. DOJ

recently agreed to a proposal by the airlines that, if carried out, would resolve their suit. The

proposal requires Northwest to sell back to Continental a substantial part of its voting stock,

divesting itself of its controlling interest in Continental. Northwest would own 7 percent of

Continental's voting power, down from its current 55 percent. The two airlines would

maintain a separate alliance agreement.

Proposed DC Air Would Generally Offer Smaller Aircraft and Less Frequent Service

Than Other Airlines but Would Seek to Compete With Lower Prices

Current airline schedules indicate that DC Air would face competition from other airlines

providing nonstop service from Reagan National in 9 of the 43 markets it plans to serve.21

These nine markets are, however, among the more heavily traveled that DC Air would serve.

Moreover, the service offered by the competing airlines appears to be of generally higher

quality (as indicated by the number of flights, number of seats available for sale, and type of

aircraft to be used) than that proposed by DC Air. In DC Air’s other 34 planned markets, it

would face no direct competition from other airlines at Reagan National. However, in 28 of

those markets, other airlines would compete against DC Air with nonstop service from either

Washington Dulles or Baltimore-Washington International.22 Moreover, the service that the

 

21 DC Air also plans to serve one other community—Clarksburg, West Virginia—with one-stop service.

22 In general, our analysis assumed that the service competing airlines would provide from the

Washington, D.C., area to the locations DC Air intends to fly would remain unchanged after the

merger. For example, we assumed that new United’s service would equal the sum of the flight

frequencies United and US Airways provided in November 2000, after allowing for the reduction in
22

competing airlines are scheduled to provide in many of those 28 markets will generally be of

higher quality than DC Air’s planned service. DC Air expects to address the differences in

quality by offering airfares that are, on average, lower than those offered by its competitors.

Other Airlines Would Compete With Larger Aircraft and More Frequent Service Against DC

Air in Nine of Its Larger Markets to and From Reagan National

DC Air would face significant competition from other airlines in 9 of the 43 markets to which

it intends to provide nonstop service from Reagan National. In three of those markets

(Charlotte, Pittsburgh, and Philadelphia), DC Air would compete on a nonstop basis only

with new United. It would compete with nonstop service against other airlines to six other

destinations—Atlanta, Columbus, Detroit, Fort Lauderdale, Kansas City, and RaleighDurham. In general, more passengers travel in these contested markets than in the other 34.

In the four quarters ending March 31, 2000, about 1.4 million passengers traveled in these

nine markets, ranging from about 29,000 passengers in the Reagan National-Philadelphia

market to nearly 360,000 passengers in the Reagan National-Atlanta market.

Given the type of aircraft that each airline intends to use and its capacity in each market (a

product of the number of seats available for sale on each type of aircraft and the expected

daily flight frequency), DC Air’s proposed service would appear to be of lesser quality than

that being offered by other airlines in the nine markets where DC Air would face

competition.23 Table 7 summarizes the differences in the type of aircraft and total available

capacity in those markets.

 

service and frequencies divested to DC Air. See app. I for additional information on the assumptions

included in the analysis of DC Air’s competitiveness.

23 In general, we define higher quality service as that using larger aircraft (e.g., a large jet rather than a

turboprop aircraft) and/or with greater capacity. See app. I for additional information on our

definition.
23

Table 7: DC Air’s Proposed and Other Airlines’ Scheduled Service From Reagan National to Nine

Competed Markets

DC Air’s proposed service Competitor’s scheduled service a

Reagan National

to

Daily flight

frequencies Aircraft type b

Total daily

available

seatsc

Daily flight

frequencies Aircraft type b

Total daily

available

seats

Atlanta 4 RJ 200 13 Large jet 2,244

Charlotte 2 Turboprop 74 9 Large jet 1,256

Columbus 3 RJ 150 2 RJ and Turboprop 447

Detroit 3 RJ 150 6

Large jet and

Turboprop 1,051

Ft. Lauderdale 2 Large jet 236 2 Large jet 259

Kansas City 3 Large jet 354 5 Large jet 635

Philadelphia 2 Turboprop 74 3

Large jet and

Turboprop 438

Pittsburgh 2 Turboprop 74 4

Large jet and

Turboprop 897

Raleigh-Durham 3 RJ 150 6

Large jet, RJ, and

Turboprop 527

a

Because United has not announced the type of aircraft it would use to serve some of these markets (e.g., Charlotte), we

assumed that they would use the same type of aircraft currently used by US Airways.

b

“RJ” refers to 50-seat regional jets. “Turboprops” are turbo jet aircraft. According to information from DC Air, it intends to

operate 37-seat Dash-8 turboprops. “Large jet” refers to other large jet aircraft like Boeing 737s, DC-9s, or Airbus A320s.

cRepresents seats available on flights departing from Reagan National.

Source: GAO’s analysis of information from DC Air and the Kiehl Hendrickson Group.

DC Air would likely compete against no airline at Reagan National in its other 34 markets.24

Many of those markets are smaller (i.e., less heavily traveled) than those in which it would

face competition. For example, in 1999, about 30,000 passengers flew between Reagan

National and Birmingham, Alabama. US Airways currently schedules nonstop service to

those markets (except for Little Rock, Arkansas, to which no airline currently flies nonstop

from Reagan National) and faces no nonstop competition in them.

DC Air Would Face Competition in Most Markets From Airlines Operating at Other Airports

in the Washington, D.C., Area

DC Air will compete against other airlines in many more markets when the Washington, D.C.,

area market is defined to include not just Reagan National, but also Washington Dulles

International Airport and Baltimore-Washington International Airport. Moreover, the airlines

operating at these other airports will generally provide more flights, more available seats, and

larger aircraft than DC Air plans to provide.

Of the 34 cities that DC Air intends to serve from Reagan National without facing any direct

competition from that airport, other airlines—including new United—will provide competing

service to 28 from either or both Washington Dulles and Baltimore-Washington. In most

markets in which other airlines compete with DC Air, they will also be using aircraft that are

generally considered to be of higher quality than the aircraft that DC Air plans to use. For

 

24 Of the markets where DC Air has no nonstop competition, Clarksburg and Morgantown, West

Virginia, receive scheduled service under DOT’s Essential Air Service program, which guarantees that

certain communities will continue to receive a minimum level of scheduled service and subsidizes that

service if necessary.
24

example, Southwest Airlines—widely known for its all-Boeing 737 fleet and competitive

airfares--provides competing service in 14 of those markets.

Table 8 summarizes the competition that DC Air may face in its markets from other airlines at

all three airports in the Washington, D.C., area.

Table 8: DC Air’s Proposed Service Faces Significant Challenges Against Other Airlines in the

Washington, D.C., Area

Capacity of DC Air’s proposed service

compared with that of competing airlines’

scheduled service

Number of

markets

Average number of

passengers per day per

marketa

Same or greater 17 533

Less 26 956

a

Average number of passengers per day based on total numbers of passengers in those markets at Reagan National,

Washington Dulles, and Baltimore-Washington for the 4 quarters ending with the first quarter of 2000.

Source: GAO’s analysis of flight capacity information from the Kiehl Hendrickson Group and DC Air and passenger traffic data

from BACK Aviation Solutions.

Competing airlines have more large-jet service in 10 of the 13 markets in which DC Air

expects to use Boeing 737s. In four of those cities--Dayton, Indianapolis, Jacksonville, and

Providence—DC Air plans to operate its 737s only once a day, supplementing them with

additional flights using regional jets. Rochester and Buffalo are to receive twice-daily 737

service, also supplemented with flights using regional jets.

DC Air intends to serve 17 markets solely with regional jets and 2 other markets with a

combination of regional jets and turboprop aircraft. Competing airlines would provide more

and higher-quality service, given the available capacity and type of aircraft to be used, in nine

markets. DC Air’s proposed regional jet service would provide the same or greater capacity

(using similar or better aircraft) than competing airlines in 10 of those markets—Burlington,

Vermont; Charleston and Columbia, South Carolina; Greensboro, North Carolina; Huntsville,

Alabama; Knoxville, Tennessee; Little Rock, Arkansas; Norfolk, Virginia; Portland, Maine; and

Syracuse, New York.

DC Air plans to serve its remaining 11 markets only with turboprop aircraft. In six of those

markets, competing airlines would provide more and higher-quality service, assuming they

used their currently available capacity and type of aircraft. DC Air’s proposed service would

provide the same or greater capacity than competing airlines to Lewisburg and Morgantown,

West Virginia, and White Plains, New York. In two markets (Charleston, West Virginia, and

Greenville/Spartanburg, South Carolina), competing airlines would operate slightly less total

capacity but use regional jets instead of turboprops.

DC Air Representatives Believe New Carrier Will Emerge as a Low-Cost Carrier, Competing

Effectively on Price

DC Air representatives told us that the new carrier will emerge as a low-cost carrier. The

carrier is committed to serving a network inherited from US Airways and officials say there is

potential to grow and enhance competition in those markets. These representatives assert

that DC Air will have lower labor costs, and they cite general data that regional carriers

historically have costs 20 percent below those of major airlines. According to information

from their representatives, DC Air projects an immediate average reduction in airfares of 17
25

percent, compared with the average fares US Airways charges for those routes. They told us

that they have developed fares for all their markets but could not share that proprietary

information. To substantiate their belief that DC Air will be able to offer lower fares than US

Airways, they noted that DC Air can operate aircraft more appropriately sized to their

markets. Whereas US Airways may now operate a 128-seat 737 on particular routes, DC Air

may use a 50-seat regional jet. Because DC Air would not share its proprietary business

information with us, we cannot evaluate the airline’s potential to offer lower prices, which we

agree is likely to be a critical factor in the extent to which DC Air can compete in the markets

it is inheriting from US Airways.

Agency Comments

We provided representatives of United, US Airways, and DC Air with draft copies of the

sections of the report describing the merger agreement and other factual descriptions of their

existing and planned service. We also provided draft copies of the report to DOJ and DOT.

Representatives of the airlines and officials in those departments offered technical

comments, which we incorporated into the report as appropriate.

As arranged with your offices, unless you publicly announce its contents earlier, we plan no

further distribution of this report until 30 days after the date of this letter. At that time, we

will send copies to the Honorable Rodney E. Slater, Secretary of Transportation; the

Honorable Janet Reno, Attorney General; United Airlines, US Airways, DC Air, and other

interested parties. We will send copies to others upon request.

If you have any questions, please call me at (202) 512-8984. Key contacts and major

contributors to this report are listed in appendix VI.

JayEtta Z. Hecker

Director, Physical Infrastructure Issues
Appendix I

26

Scope and Methodology

At the request of the Ranking Democratic Member of the House Committee on Transportation

and Infrastructure and Representative Louise Slaughter, we addressed three issues relating to the

proposed acquisition of US Airways by United Airlines (United). Specifically, our objectives

were to determine (1) how the proposed merger would alter the U.S. domestic airline industry;

(2) what potential harmful and beneficial effects the proposed merger could have on consumers,

focusing on how the proposed merger would alter competition in specific markets; and (3) how

the service that DC Air is planning to offer compares with the service scheduled by other airlines

in the same markets.

To determine how the merger would alter the U.S. domestic airline industry, we examined what

the merger would do to the overall market shares of major U.S. passenger airlines. We analyzed

changes in various measures of market size, including the number of passengers carried by the

airlines, the number of miles flown by paying passengers, and the airlines’ total revenue. We also

discussed with various industry experts and other major airlines what their likely competitive

responses would be. We did not evaluate those likely competitive responses at this time because

they have not been discussed publicly in sufficient detail for analysis.

To determine the merger’s potential beneficial and harmful effects on consumers, we separately

examined the possible service benefits associated with the merger and the potential harm to

consumers that might stem from a loss of competition in various markets. To examine the

potential harm from the acquisition, we determined the extent to which each airline’s routes

overlap by analyzing 1999 data from the Department of Transportation (DOT) on the 5,000

busiest domestic city-pair origin and destination markets or markets for air travel between two

cities. These 5,000 markets accounted for approximately 85 percent of the total U.S. domestic

passengers in 1999. We recognize that this analysis is based on traffic flows and service patterns

as they existed in 1999. We have no reasonable basis for determining the extent to which

competition or service levels in the domestic airline industry might change with the entry or exit

of different carriers.

To obtain other data on passenger traffic for this report, we contracted with BACK Aviation

Solutions (BACK), an aviation consulting firm, which obtains operational and financial

information submitted by all U.S. airlines to DOT. These data include the Origin and Destination
Appendix I

27

Survey (O&D) based on a 10-percent sample of tickets containing itinerary and pricing

information; T-100 on-flight data;1

and 298C T-1 data, which supplement the T-100 data with data

on commuter and small certified air carriers. BACK makes certain adjustments to these data,

such as correcting recognized deficiencies in the air carriers’ O&D data submissions, which have

not met DOT’s standard of 95-percent accuracy. We did not independently assess the reliability

of BACK’s data.

We examined whether the acquisition might reduce or enhance competition within given airline

markets. DOT defines a “competitor” as an airline that has a market share of at least 10 percent,

and we adopted DOT’s definition. To provide additional insight into markets where a merger

may exert additional or disproportionate market influence, we further refined our analysis to

focus on those markets where new United would have a dominant share—more than 50 percent.

Various studies support the finding that airlines holding dominant shares of a market reap

disproportionate amounts of the revenue available in that market, because they are able to

provide far more frequent service, which is important for time-sensitive, high-yield business

travelers.

We generally defined a market as one involving city pairs rather than airport pairs. This is an

important distinction in those cities, such as New York and Chicago, that are served by more

than one airport. To provide additional information on how the merger might affect certain

passengers who may not regard an area’s multiple airports as substitutes, however, we also

examined changes in market share based on airport pairs. Previous GAO work indicates that

Ronald Reagan Washington National (Reagan National), Washington Dulles International, and

Baltimore-Washington International airports appear to represent distinct markets for certain

time-sensitive business travelers.2

To analyze the merger’s possible benefits to consumers, we examined the airlines’ statements on

their routing and connection benefits. To evaluate these statements, we analyzed airline flight

schedule information submitted by all U.S. airlines for November 2000 that we purchased from

 

1

14 C.F.R. 241 prescribes the collection of scheduled and nonscheduled service traffic data from the

domestic and international operations of U.S. air carriers. The schedules submitted by the air carriers to

DOT under this requirement collect nonstop segment data and on-flight market information by equipment

type and by service class. This report is known as the “T-100” report.

2

 See Reagan National Airport: Capacity to Handle Additional Flights and Effect on Other Area Airports

(GAO/RCED-99-234, Sept. 17, 1999).
Appendix I

28

the Kiehl Hendrickson Group, an aviation consulting firm, along with passenger traffic data that

we purchased from BACK.3

 We did not at this time independently verify the 259 markets that

United officials told us would benefit from new on-line service. To estimate the number of

passengers who might benefit from the new service, we then matched the new origins and

destinations against the 1999 passenger traffic in these markets.

To determine how the service that DC Air is planning to offer compares with the service

scheduled by other airlines in the same markets, we analyzed the service that DC Air announced

for its markets with the service other airlines had scheduled for those markets. We separately

examined competing airlines’ scheduled service from Reagan National, Washington Dulles

International, and Baltimore-Washington International airports. Absent any information to the

contrary, we assumed that United and US Airways would continue to operate the same amount

and type of service that they had offered from each of those airports to DC Air’s 43 nonstop

markets, with an allowance for the shift in service from that now provided by US Airways to DC

Air. Finally, we examined whether competitors provided service that is of higher or lesser

quality to these destinations. Equivalent-quality service would be that provided with the same

frequency and type of aircraft (e.g., turboprop, regional jet, or large jet). Higher-quality service

would be that in which one airline provides either (1) more capacity (where capacity is

calculated by multiplying the number of seats available for sale on a given aircraft type by the

number of departures that the airline would make) in a market with the same type of aircraft or

(2) the same capacity in a market with a higher-quality aircraft. In general, we consider regional

jets to be of higher quality than turboprops but of lower quality than large jets. Lesser-quality

service would be that in which one airline provides (1) less capacity in a market with the same or

lower-quality aircraft or (2) the same capacity in a market with lower-quality aircraft.

We interviewed officials from DOT, DOJ, United, US Airways, and four other major U.S.

passenger airlines. We also interviewed recognized industry experts, including Wall Street airline

financial analysts. We asked for their views on how the acquisition might affect domestic airline

competition and consumers.

Other important issues may be relevant to an analysis of the merger’s impact but are beyond the

scope of this review. For example, this report does not examine in detail how the proposed

merger would alter an airline’s concentration at particular cities or how such concentration

 

3 We did not independently assess the reliability of the Keihl Hendrickson Group’s original data.
Appendix I

29

would affect market entry by potential competitors. Similarly, the report does not include

evaluations of the proposed merger’s potential effect on international aviation competition or its

impact on service to smaller communities. This report also does not independently evaluate the

long-term financial viability of either airline, which may affect its ability to maintain employment

and service to small communities.

We conducted our work from May 2000 through December 2000 in Washington, D.C., in

accordance with generally accepted government auditing standards.
Appendix II

30

Combined Domestic and International Measures of Airline Size

Revenue passenger

enplanementsa

Revenue passenger

miles

Total operating

revenue

Airline

Number in

thousands

Percent

of total

Number in

thousands

Percent

of total

Dollars in

millions

Percent

of total

Delta Air Lines 106,218,000 18.8 106,849,814 17.0 14,711 16.3

United Airlinesa87,113,000 15.4 127,455,682 20.3 18,027 20.0

American Airlinesb85,400,000 15.1 114,832,223 18.3 17,730 19.6

Southwest Airlinesc69,056,000 12.2 39,641,182 6.3 4,736 5.2

US Airwaysd56,417,000 10.0 42,898,817 6.8 8,595 9.5

Northwest Airlines 56,003,000 9.9 77,324,776 12.3 10,276 11.4

Continental Airlines 44,868,000 7.9 60,980,078 9.7 8,639 9.6

Trans World Airlines 26,271,000 4.7 26,650,717 4.2 3,309 3.7

America West Airlinese19,523,000 3.5 18,558,027 3.0 2,211 2.4

Alaska Airlinesf13,694,000 2.4 11,962,007 1.9 2,082 2.3

Total g 564,563,000 100.0 627,153,323 100.0 90,316 100.0

New United h143,530,000 25.4 170,354,499 27.2 26,622 29.5

Note: Measures shown include international operations.

a

“Passenger enplanements” represent the total number of passengers boarding an aircraft. Thus, for example, a passenger that

must make a single connection between his or her origin and destination counts as two enplaned passengers because he or she

boarded two separate flights.

a

Total operating revenues are for the parent (UAL Corporation).

b

Total operating revenues are for the parent (AMR Corporation).

c

Southwest Airlines provides only domestic service.

d

Total operating revenues are for the parent (US Airways Group, Inc.).

e

Total operating revenues are for the parent (America West Holdings, Inc.).

f

Total operating revenues are for the parent (Alaska Air Group, Inc.).

g

Totals may not add to 100 percent due to rounding.

h

Totals for new United do not make any allowance for those operations that might become part of DC Air.

Sources: GAO’s analysis of DOT data.
Appendix III

31

Selected Financial Data for Some Major U.S. Airlines, Calendar Year 1999 and First 9

Months, 2000

Airline

Total operating

revenue,

calendar year

1999

Net income (loss),

calendar year

1999

Total operating

revenue for 9

months ended

September 30, 2000

Net income (loss),

9 months ended

September 30, 2000

American Airlinesa$17,730 $985 $14,844 $766

America West Airlinesb$2,211 $119 $1,771 $49

Continental Airlines $8,639 $455 $7,470 $298

Delta Air Lines $14,833 $1,208 $12,725 $810

Northwest Airlines $10,276 $300 $4,345 $325

United Airlinesc$18,027 $1,235 $14,559 $121

US Airwaysd$8,595 $197 $6,912 ($168)

Trans World Airlines $2,736 ($353) $3,309 ($115)

a

Total operating revenues and net income are for parent (AMR Corporation).

b

Total operating revenues and net income are for parent (America West Holdings Corporation).

c

Total operating revenue and net income are for parent (UAL Corporation).

d

Total operating revenue and net income are for parent (US Airways Group, Inc.).

Sources: GAO’s analysis of data from airline annual reports and quarterly reports filed with the U.S. Securities and Exchange

Commission.
Appendix IV

32

Markets in Which the Proposed Merger Could Reduce Competition to Only One or Two

Competing Airlines

Markets in Which the Proposed Merger Could Leave No Airlines Competing Against

New United

Atlanta, Georgia--Binghamton, New York

Atlanta, Georgia--State College, Pennsylvania

Baltimore, Maryland--San Francisco, California

Bangor, Maine--San Francisco, California

Binghamton, New York--Chicago, Illinois

Binghamton, New York--Denver, Colorado

Binghamton, New York--Los Angeles, California

Boston, Massachusetts—Charleston, West Virginia

Boston, Massachusetts---Charlottesville, Virginia

Boston, Massachusetts---State College, Pennsylvania

Boston, Massachusetts---Newport News/Williamsburg, Virginia

Boston, Massachusetts---Roanoke, Virginia

Boston, Massachusetts---Washington, D.C. area

Burlington, Vermont--San Diego, California

Charleston, West Virginia--San Francisco, California

Charlotte, North Carolina--Chicago, Illinois
Appendix IV

33

Charlottesville, Virginia—New York, New York

Charlottesville, Virginia--Los Angeles, California

Chicago, Illinois--Lynchburg, Virginia

Chicago, Illinois--Roanoke, Virginia

Chicago, Illinois--Scranton, Pennsylvania

Denver, Colorado—State College, Pennsylvania

Denver, Colorado--Philadelphia, Pennsylvania

Denver, Colorado--Pittsburgh, Pennsylvania

Denver, Colorado--Scranton, Pennsylvania

Hartford, Connecticut--Richmond, Virginia

Hartford, Connecticut--Roanoke, Virginia

Hartford, Connecticut--Washington, D.C. area

Los Angeles, California--Philadelphia, Pennsylvania

Los Angeles, California--Scranton, Pennsylvania

Louisville, Kentucky--San Francisco, California

Louisville, Kentucky--Tampa, Florida

Madison, Wisconsin--San Francisco, California

Midland/Odessa, Texas—New York, New York

Philadelphia, Pennsylvania--Salinas/Monterrey, California
Appendix IV

34

Philadelphia, Pennsylvania--San Francisco, California

Philadelphia, Pennsylvania—Seattle, Washington

Philadelphia, Pennsylvania--Washington, D.C. area

Phoenix, Arizona--Scranton, Pennsylvania

Pittsburgh, Pennsylvania--San Francisco, California

Rochester, New York--Washington, D.C. area

San Francisco, California--Scranton, Pennsylvania

Tampa, Florida--Washington, D.C. area
Appendix IV

35

Markets in Which the Proposed Merger Could Leave One Other Airline Competing

Against New United

Abilene, Texas--St. Louis, Missouri

Allentown, Pennsylvania--Dallas/Fort Worth, Texas

Allentown, Pennsylvania—Minneapolis, Minnesota

Allentown, Pennsylvania--San Diego, California

Allentown, Pennsylvania--San Francisco, California

Allentown, Pennsylvania—Seattle, Washington

Atlanta, Georgia--Charlottesville, Virginia

Atlanta, Georgia--Scranton, Pennsylvania

Baltimore, Maryland—Chicago, Illinois

Baltimore, Maryland--Los Angeles, California

Baltimore, Maryland--Salinas/Monterrey, California

Baltimore, Maryland--Santa Barbara, California

Bristol/Kingsport/Johnson City, Tennessee--Chicago, Illinois

Bristol/Kingsport/Johnson City, Tennessee--Denver, Colorado

Bristol/Kingsport/Johnson City, Tennessee--Detroit, Michigan

Bristol/Kingsport/Johnson City, Tennessee--Los Angeles, California

Buffalo, New York--St. Louis, Missouri

Burlington, Vermont--Denver, Colorado
Appendix IV

36

Burlington, Vermont--Houston, Texas

Burlington, Vermont--Las Vegas, Nevada

Burlington, Vermont--Los Angeles, California

Burlington, Vermont--Minneapolis, Minnesota

Burlington, Vermont--Phoenix, Arizona

Burlington, Vermont--San Francisco, California

Burlington, Vermont--Seattle, Washington

Charleston, South Carolina--Denver, Colorado

Charleston, South Carolina---San Francisco, California

Charleston, West Virginia--Denver, Colorado

Charleston, West Virginia--Kansas City, Missouri

Charleston, West Virginia--Las Vegas, Nevada

Charleston, West Virginia--San Diego, California

Charleston, West Virginia--Seattle, Washington

Charlotte, North Carolina--Denver, Colorado

Charlotte, North Carolina--Fort Wayne, Indiana

Charlottesville, Virginia—Chicago, Illinois

Charlottesville, Virginia--Denver, Colorado

Charlottesville, Virginia—Orlando, Florida
Appendix IV

37

Chicago, Illinois--State College, Pennsylvania

Chicago, Illinois--Newport News/Williamsburg, Virginia

Chicago, Illinois--Harrisburg, Pennsylvania

Chicago, Illinois--Pittsburgh, Pennsylvania

Chicago, Illinois—Washington, D.C. area

State College, Pennsylvania--Los Angeles, California

Columbia, South Carolina-Denver, Colorado

Columbus, Georgia--San Francisco, California

Denver, Colorado—Greensboro, North Carolina

Denver, Colorado--Harrisburg, Pennsylvania

Denver, Colorado--Norfolk, Virginia

Denver, Colorado—Portland, Maine

Denver, Colorado--Roanoke, Virginia

Denver, Colorado--Wilmington, North Carolina

Grand Rapids, Michigan--Washington, D.C. area

Harrisburg, Pennsylvania--Kansas City, Missouri

Harrisburg, Pennsylvania--Los Angeles, California

Harrisburg, Pennsylvania--Milwaukee, Wisconsin

Harrisburg, Pennsylvania--San Diego, California
Appendix IV

38

Harrisburg, Pennsylvania--San Francisco, California

Harrisburg, Pennsylvania--Santa Ana, California

Hartford, Connecticut—Indianapolis, Indiana

Hartford, Connecticut--Los Angeles, California

Hartford, Connecticut--San Francisco, California

Indianapolis, Indiana--Rochester, New York

Kalamazoo, Michigan--Washington, D.C. area

Kansas City, Missouri--Portland, Maine

Kansas City, Missouri--Richmond, Virginia

Kansas City, Missouri--Rochester, New York

Las Vegas, Nevada--Pittsburgh, Pennsylvania

Las Vegas, Nevada--Roanoke, Virginia

Lincoln, Nebraska--Philadelphia, Pennsylvania

Los Angeles, California--Richmond, Virginia

Los Angeles, California--Roanoke, Virginia

Los Angeles, California--Rochester, New York

Los Angeles, California--San Diego, California

Los Angeles, California--Santa Barbara, California

Los Angeles, California--Savannah, Georgia
Appendix IV

39

Manchester, New Hampshire--Milwaukee, Wisconsin

Manchester, New Hampshire--Minneapolis, Minnesota

Manchester, New Hampshire--Seattle, Washington

Miami, Florida--Washington, D.C. area

Minneapolis, Minnesota--Portland, Maine

New Orleans, Louisiana--Washington, D.C. area

Omaha, Nebraska--Pittsburgh, Pennsylvania

Orlando, Florida—Washington, D.C. area

Palm Springs, California--Los Angeles, California

Philadelphia, Pennsylvania--Santa Barbara, California

Philadelphia, Pennsylvania--South Bend, Indiana

Philadelphia, Pennsylvania--Wichita, Kansas

Phoenix, Arizona--Roanoke, Virginia

Pittsburgh, Pennsylvania--Sacramento, California

Pittsburgh, Pennsylvania--Wichita, Kansas

Portland, Maine--San Diego, California

Providence, Rhode Island--South Bend, Indiana

Richmond, Virginia--San Francisco, California

Roanoke, Virginia--San Francisco, California
Appendix IV

40

Rochester, New York--San Diego, California

Rochester, New York--San Francisco, California

Rochester, New York--Santa Ana, California

San Francisco, California--Savannah, Georgia

San Francisco, California--Wilmington, North Carolina

Savannah, Georgia--Seattle, Washington

South Bend, Indiana--White Plains, New York

Tulsa, Oklahoma--San Francisco, California
Appendix V

41

Markets in Which the Proposed Merger Could Increase Competition

Albany, New York--Memphis, Tennessee

Atlanta, Georgia--Fort Wayne, Indiana

Atlanta, Georgia--Lansing, Michigan

Baltimore, Maryland--Las Vegas, Nevada

Baltimore, Maryland–-Saginaw/Bay City/Midland, Michigan

Baltimore, Maryland–-Phoenix, Arizona

Birmingham, Alabama--Denver, Colorado

Birmingham, Alabama--Milwaukee, Wisconsin

Birmingham, Alabama--San Francisco, California

Boston, Massachusetts--Springfield, Missouri

Bristol/Kingsport/Johnson City, Tennessee--Las Vegas, Nevada

Buffalo, New York--Minneapolis, Minnesota

Cincinnati, Ohio—Providence, Rhode Island

Cleveland, Ohio--San Diego, California

Columbus, Ohio--Kansas City, Missouri

Columbus, Ohio--Los Angeles, California

Columbus, Ohio--Memphis, Tennessee

Dayton, Ohio--Houston, Texas
Appendix V

42

Dayton, Ohio--Milwaukee, Wisconsin

Denver, Colorado--Jacksonville, Florida

Denver, Colorado–West Palm Beach, Florida

Fort Lauderdale, Florida--Grand Rapids, Michigan

Fort Lauderdale, Florida--New Orleans, Louisiana

Fort Lauderdale, Florida--Milwaukee, Wisconsin

Fort Lauderdale, Florida--San Francisco, California

Fort Myers, Florida--Grand Rapids, Michigan

Fort Myers, Florida--Los Angeles, California

Fort Wayne, Indiana--Miami, Florida

Fort Myers, Florida--Milwaukee, Wisconsin

Fort Myers, Florida--San Diego, California

Fort Myers, Florida--Seattle, Washington

Fort Myers, Florida--South Bend, Indiana

Grand Rapids, Michigan--Jacksonville, Florida

Grand Rapids, Michigan--Nashville, Tennessee

Grand Rapids, Michigan--New Orleans, Louisiana

Grand Rapids, Michigan--Orlando, Florida

Grand Rapids, Michigan--West Palm Beach, Florida
Appendix V

43

Greensboro/High Point, North Carolina--Las Vegas, Nevada

Greenville-Spartanburg, South Carolina--Seattle, Washington

Hartford, Connecticut--Houston, Texas

Hartford, Connecticut--Milwaukee, Wisconsin

Hartford, Connecticut--Palm Springs, California

Jacksonville, Florida--Seattle, Washington

Jacksonville, Florida--Sacramento, California

Kalamazoo, Michigan--New York, New York

Kalamazoo, Michigan--Orlando, Florida

Kalamazoo, Michigan--Miami, Florida

Kansas City, Missouri--Miami, Florida

Kansas City, Missouri--Tampa, Florida

Knoxville, Tennessee--Phoenix, Arizona

Lansing, Michigan--Phoenix, Arizona

Las Vegas, Nevada--Tampa, Florida

Las Vegas, Nevada--Norfolk, Virginia

Las Vegas, Nevada--Raleigh-Durham

Las Vegas, Nevada--Newburgh, New York

Milwaukee, Wisconsin--New Orleans, Louisiana
Appendix V

44

Milwaukee, Wisconsin--Tampa, Florida

Newark, New Jersey--Saginaw/Bay City/Midland, Michigan

Orlando, Florida--Knoxville, Tennessee

Orlando, Florida--Saginaw/Bay City/Midland, Michigan

Philadelphia, Pennsylvania--Saginaw/Bay City/Midland, Michigan

Phoenix, Arizona--Raleigh/Durham, North Carolina

Raleigh/Durham, North Carolina--Wichita, Kansas

San Diego, California--Tampa, Florida

Newburgh, New York–-San Diego, California
Appendix VI

45

GAO Contacts and Staff Acknowledgments

GAO Contacts JayEtta Z. Hecker (202) 512-8984

Steve Martin (202) 512-3389

Acknowledgments

In addition to those named above, Triana Bash, Aaron Casey, David Hooper, Joseph Kile,

and Charles Wilson, Jr., made key contributions to this report.
46

Related GAO Products

Reagan National Airport: Capacity to Handle Additional Flights and Effect on Other Area

Airports (GAO/RCED-99-234, Sept. 17, 1999).

Aviation Competition: Effects on Consumers From Domestic Alliances Vary (GAO/RCED-99-37,

Jan. 15, 1999).

Aviation Competition: Proposed Domestic Airline Alliances Raise Serious Issues (GAO/T-RCED98-215, June 4, 1998).

Domestic Aviation: Service Problems and Limited Competition Continue in Some Markets

(GAO/T-RCED-98-176, Apr. 23, 1998).

Aviation Competition: International Aviation Alliances and the Influence of Airline Marketing

Practices (GAO/T-RCED-98-131, Mar. 19, 1998).

Airline Competition: Barriers to Entry Continue in Some Domestic Markets (GAO/T-RCED-98-

112, Mar. 5, 1998).

Domestic Aviation: Barriers Continue to Limit Competition (GAO/T-RCED-98-32, Oct. 28, 1997).

Airline Deregulation: Addressing the Air Service Problems of Some Communities (GAO/T-RCED97-187, June 25, 1997).

International Aviation: Competition Issues in the U.S.-U.K. Market (GAO/T-RCED-97-103, June 4,

1997).

Domestic Aviation: Barriers to Entry Continue to Limit Benefits of Airline Deregulation (GAO/TRCED-97-120, May 13, 1997).
47

Airline Deregulation: Barriers to Entry Continue to Limit Competition in Several Key Domestic

Markets (GAO/RCED-97-4, Oct. 18, 1996).

Domestic Aviation: Changes in Airfares, Service, and Safety Since Airline Deregulation (GAO/TRCED-96-126, Apr. 25, 1996).

Airline Deregulation: Changes in Airfares, Service, and Safety at Small, Medium-Sized, and Large

Communities (GAO/RCED-96-79, Apr. 19, 1996).

International Aviation: Airline Alliances Produce Benefits, but Effect on Competition Is

Uncertain (GAO/RCED-95-99, Apr. 6, 1995).

Airline Competition: Higher Fares and Less Competition Continue at Concentrated Airports

(GAO/RCED-93-171, July 15, 1993).

Computer Reservation Systems: Action Needed to Better Monitor the CRS Industry and

Eliminate CRS Biases (GAO/RCED-92-130, Mar. 20, 1992).

Airline Competition: Effects of Airline Market Concentration and Barriers to Entry on Airfares

(GAO/RCED-91-101, Apr. 26, 1991).

Airline Competition: Industry Operating and Marketing Practices Limit Market Entry

(GAO/RCED-90-147, Aug. 29, 1990).

Airline Competition: Higher Fares and Reduced Competition at Concentrated Airports

(GAO/RCED-90-102, July 11, 1990).

Airline Deregulation: Barriers to Competition in the Airline Industry (GAO/T-RCED-89-65, Sept.

20, 1989).

Airline Competition: Fare and Service Changes at St. Louis Since the TWA-Ozark Merger

(GAO/RCED-88-217BR, Sept. 21, 1988).
48

Competition in the Airline Computerized Reservation Systems (GAO/T-RCED-88-62, Sept. 14,

1988).

Airline Competition: Impact of Computerized Reservation Systems (GAO/RCED-86-74, May 9,

1986).

Airline Takeoff and Landing Slots: Department of Transportation's Slot Allocation Rule

(GAO/RCED-86-92, Jan. 31, 1986).

Deregulation: Increased Competition Is Making Airlines More Efficient and Responsive to

Consumers (GAO/RCED-86-26, Nov. 6, 1985).

(348246)