Airline Mergers: Issues Raised by the Proposed Merger of United and Continental Airlines
Published: 2010-05-27T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Earlier this month, United Air Lines (United) and Continental Airlines (Continental) announced plans to merge the two airlines and signed a merger agreement. This follows the acquisition of Northwest Airlines by Delta Air Lines (Delta) in 2008, which propelled Delta to become the largest airline in the United States. This latest merger, if not challenged by the Department of Justice (DOJ), would surpass Delta's merger in scope to create the largest passenger airline in terms of capacity in the United States. The passenger airline industry has struggled financially over the last decade, and these two airlines believe a merger will strengthen them. However, as with any proposed merger of this magnitude, this one will be carefully examined by DOJ to determine if its potential benefits for consumers outweigh the potential negative effects. At the Committee's request, GAO is providing a statement for the record that describes (1) an overview of the factors that are driving mergers in the industry, (2) the role of federal authorities in reviewing merger proposals, and (3) key issues associated with the proposed merger of United and Continental. To address these objectives, GAO drew from previous reports on the potential effects of the proposed merger between Delta and Northwest and the financial condition of the airline industry, and analyzed Department of Transportation (DOT) airline operating and financial data.
section_title: What GAO Found
paragraphs: As GAO has previously reported, airlines seek to merge with or acquire other airlines to increase their profitability and financial sustainability, but must weigh these potential benefits against operational costs and challenges. The principal benefits airlines consider are cost reductions--by combining complementary assets, eliminating duplicate activities, and reducing capacity--and increased revenues from higher fares in existing markets and increased demand for more seamless travel to more destinations. Balanced against these potential benefits are operational costs of integrating workforces, aircraft fleets, and systems. DOJ's antitrust review is a critical step in the airline merger and acquisition process. DOJ uses an integrated analytical framework set forth in the Horizontal Merger Guidelines to determine whether the merger poses any antitrust concerns. Under that process, DOJ assesses the extent of likely anticompetitive effects of reducing competition in the relevant markets--in this case, between cities or airports. DOJ further considers the likelihood that airlines entering these markets would counteract any anticompetitive effects. It also considers any efficiencies that a merger or acquisition could bring--for example, consumer benefits from an expanded route network. Finally, it examines whether one of the airlines proposing to merge would fail and its assets exit the market in the absence of a merger. One of the most important issues in this merger will be its effect on competition in the airline industry. For example, GAO's analysis of 2009 ticket data showed that combining these airlines would result in a loss of one effective competitor (defined as having at least 5 percent of total traffic between airports) in 1,135 markets (called airport pairs) affecting almost 35 million passengers while creating a new effective competitor in 173 airport pairs affecting almost 9.5 million passengers. However, in all but 10 of these airports pairs there is at least one other competitor.

section_title: Letter
paragraphs: We appreciate the opportunity to provide a statement for the record on the  potential implications of the merger proposal recently announced by  United Air Lines (United) and Continental Airlines (Continental). Earlier  this month, these two airlines announced plans for United to merge with  Continental through a stock swap the airlines valued at $8 billion. This  follows the acquisition of Northwest Airlines (Northwest) by Delta Air  Lines (Delta) in 2008, which propelled Delta to become the largest airline  in the United States. The United-Continental merger, if not challenged by  the Department of Justice (DOJ), would surpass Delta’s in scope to create  the largest passenger airline in terms of capacity in the United States.  However, as with any proposed merger of this magnitude, this one will be  carefully examined by DOJ to determine if its potential benefits for  consumers outweigh the potential negative effects.
Extensive research and the experience of millions of Americans  underscore the benefits that have flowed to most consumers from the 1978  deregulation of the airline industry, including dramatic reductions in fares  and expansion of service. These benefits are largely attributable to  increased competition from the entry of new airlines into the industry and  established airlines into new markets. At the same time, however, airline  deregulation has not benefited everyone; some communities—especially  smaller communities—have suffered from relatively high airfares and a  loss of service. We have been analyzing aviation competition issues since  the enactment of the Airline Deregulation Act of 1978. Our work over the  last decade has focused on the challenges to competition and industry  performance, including the financial health of the airline industry, the  growth of low-cost airlines, changing business models of airlines, and  prior mergers. In the airline context, DOJ has the primary responsibility  to evaluate most mergers in order to carry out its antitrust  responsibilities. In its review, DOJ considers a number of factors,  including increases in market concentration; potential adverse effect s on  competition; the likelihood of new entry in affected markets and possible  counteraction of anticompetitive effects that the merger may have posed;  verified “merger specific” efficiencies or other competitive benefits; and  whether, absent the merger, one of the airlines is likely to fail and its assets ex it the market.
This statement presents (1) an overview of the factors that are driving  mergers in the airline industry, (2) the role of federal authorities in  reviewing merger proposals, and (3) key issues associated with the  proposed merger of United and Continental. This statement is based on  two previously issued reports—our 2008 report for this Committee on  airline mergers and our 2009 report on the financial condition of the airline  industry and the various effects of the industry’s contraction on  passengers and communities—as well as our other past work on aviation  issues. In addition, we conducted some analysis of the proposed United  and Continental merger, including analysis of the airlines’ financial, labor,  fleet, and market conditions.
To identify the factors that help drive mergers in the airline industry, we  relied on information developed for our 2008 and 2009 reports on the  airline industry, updated as necessary. To describe the role of federal  authorities, in particular DOJ and the Department of Transportation  (DOT), in reviewing airline merger proposals we relied on information  developed for our 2008 report, also updated as necessary. To identify the  key issues associated with the proposed merger of United and Continental,  we reviewed airline merger documents and financial analyst reports and  analyzed data submitted by the airlines to DOT (Bureau of Transportation  Statistics financial Form 41, origin and destination ticket, and operations  data). We also analyzed airline schedule data. We assessed the reliability  of these data by (1) performing electronic testing of required data  elements, (2) reviewing existing information about the data and the system  that produced them, and (3) interviewing agency officials knowledgeable  about the data. We determined that the data were sufficiently reliable for  the purposes of this report. We conducted this audit work in May 2010 in  accordance with generally accepted government auditing standards. Those  standards require that we plan and perform the audit to obtain sufficient,  appropriate evidence to provide a reasonable basis for our findings and  conclusions based on our audit objectives. We believe that the evidence  obtained provides a reasonable basis for our findings and conclusions  based on our audit objectives.
subsections: section_title: Background
paragraphs: On May 3, 2010, United and Continental announced an agreement to merge  the two airlines. The new airline would retain the United name and  headquarters in Chicago while the current Continental Chief Executive  Officer would keep that title with the new airline. The proposed merger  will be financed exclusively through an all-stock transaction with a  combined equity value of $8 billion split roughly with 55 percent  ownership to United shareholders and 45 percent to Continental  shareholders. The airlines have not announced specific plans for changes  in their networks or operations that would occur if the proposed merger is  not challenged by DOJ.
The airline industry has experienced considerable merger and acquisition  activity since its early years, especially immediately following deregulation  in 1978 (fig. 1 provides a timeline of mergers and acquisitions for the seven  largest surviving airlines). A flurry of mergers and acquisitions during the  1980s, when Delta Air Lines and Western Airlines merged, United Airlines  acquired Pan Am’s Pacific routes, Northwest acquired Republic Airlines,  and American Airlines and Air California merged. In 1988, merger and  acquisition review authority was transferred from the Department of  Transportation (DOT) to DOJ. Since 1998, despite tumultuous financial  periods, fewer mergers and acquisitions have occurred. In 2001, American  Airlines acquired the bankrupt airline TWA, in 2005 America West acquired  US Airways while the latter was in bankruptcy, and, in October 2008, Delta  acquired Northwest. Certain other attempts at merging in the last decade  failed because of opposition from DOJ or from employees and creditors.  For example, in 2000, an agreement was reached that allowed Northwest  to acquire a 50 percent stake in Continental (with limited voting power) to  resolve the antitrust suit brought by DOJ against Northwest’s proposed  acquisition of a controlling interest in Continental. A proposed merger of  United Airlines and US Airways in 2000 also resulted in opposition from  DOJ, which found that, in its view, the merger would violate antitrust laws  by reducing competition, increasing air fares, and harming consumers on  airline routes throughout the United States. Although DOJ expressed its  intent to sue to block the transaction, the parties abandoned the  transaction before a suit was filed. More recently, the 2006 proposed  merger of US Airways and Delta fell apart because of opposition from  Delta’s pilots and some of its creditors, as well as its senior management.
Since deregulation in 1978, the financial stability of the airline industry has  become a considerable concern for the federal government owing, in part,  to the level of financial assistance it has provided to the industry by  assuming terminated pension plans and other forms of assistance.  Between 1978 and 2008, there have been over 160 airline bankruptcies.  While most of these bankruptcies affected small airlines that were  eventually liquidated, 4 of the more recent bankruptcies (Delta, Northwest,  United, and US Airways) are among the largest corporate bankruptcies  ever, excluding financial services firms. During these bankruptcies, United  and US Airways terminated their pension plans and $9.7 billion in claims  was shifted to the Pension Benefit Guarantee Corporation (PGBC).  Furthermore, to respond to the shock to the industry from the September  11, 2001, terrorist attacks, the federal government provided airlines with  $7.4 billion in direct assistance and authorized $1.6 billion (of $10 billion  available) in loan guarantees to six airlines.
Although the airline industry has experienced numerous mergers and  bankruptcies since deregulation, growth of existing airlines and the entry  of new airlines have contributed to a steady increase in capacity, as  measured by available seat miles. Previously, we reported that although  one airline may reduce capacity or leave the market, capacity returns  relatively quickly. Likewise, while past mergers and acquisitions have, at  least in part, sought to reduce capacity, any resulting declines in industry  capacity have been short-lived, as existing airlines have expanded or new  airlines have expanded. Capacity growth has slowed or declined just  before and during recessions, but not as a result of large airline  liquidations.
section_title: Airline Mergers Are Driven by Financial and Competitive Pressures, but Challenges Exist
paragraphs: Volatile earnings and structural changes in the industry have spurred some  airlines to explore mergers as a way to increase their profitability and  financial viability. Over the last decade, the U.S. passenger airline industry  has incurred more than $15 billion in operating losses. Several major  airlines went through bankruptcy to reduce their costs and restructure  their operations, while others ceased to operate or were acquired. Most  recently, U.S. airlines responded to volatile fuel prices and then a  weakening economy by cutting their capacity, reducing their fleets and  workforces, and instituting new fees, but even with these actions, the  airlines experienced over $5 billion in operating losses in 2008 before  posting an operating profit of about $1 billion in 2009. Furthermore, over  the last decade, airfares have generally declined (in real terms), owing  largely to the increased presence of low-cost airlines, such as Southwest  Airlines, in more markets and the shrinking dominance of a single airline  in many markets.
One of the primary financial benefits that airlines consider when merging  with another airline is the cost reduction that may result from combining  complementary assets, eliminating duplicative activities, and reducing  capacity. A merger or acquisition could enable the combined airline to  reduce or eliminate duplicative operating costs, such as duplicative  service, labor, and operations costs—including inefficient (or redundant)  hubs or routes—or to achieve operational efficiencies by integrating  computer systems and similar airline fleets. Other cost savings may stem  from facility consolidation, procurement savings, and working capital and  balance sheet restructuring, such as renegotiating aircraft leases. Airlines  may also pursue mergers or acquisitions to more efficiently manage  capacity—both to reduce operating costs and to generate revenue—in  their networks. Given recent economic pressures, particularly increased  fuel costs, the opportunity to lower costs by reducing redundant capacity  may be especially appealing to airlines seeking to merge. Experts have  said that industry mergers and acquisitions could lay the foundation for  more rational capacity reductions in highly competitive domestic markets  and could help mitigate the significant impact that economic cycles have  historically had on airline cash flow.
The other primary financial benefit that airlines consider with mergers and  acquisitions is the potential for increased revenues through additional  demand, which may be achieved by more seamless travel to more  destinations and increased market share and higher fares on some routes.
Increased demand from an expanded network: An airline may seek to  merge with or acquire an airline as a way to generate greater revenues  from an expanded network, which serves more city-pair markets and  better serves passengers. Mergers and acquisitions may generate  additional demand by providing consumers more domestic and  international city-pair destinations. Airlines with expansive domestic and  international networks and frequent flier benefits particularly appeal to  business traffic, especially corporate accounts. Results from a recent  Business Traveler Coalition (BTC) survey indicate that about 53 percent of  the respondents were likely to choose a particular airline based on the  extent of its route network. Therefore, airlines may use a merger or  acquisition to enhance their networks and gain complementary routes,  potentially giving the combined airline a stronger platform from which to  compete in highly profitable markets.
Increased market share and higher fares on some routes: Capacity  reductions in certain markets after a merger could also serve to generate  additional revenue through increased fares on some routes. Some studies  of airline mergers and acquisitions during the 1980s showed that prices  were higher on some routes from the airline’s hubs soon after the  combination was completed. Several studies have also shown that  increased airline dominance at an airport results in increased fare  premiums, in part because of competitive barriers to entry. At the same  time, though, even if the combined airline is able to increase prices in  some markets, the increase may be transitory if other airlines enter the  markets with sufficient presence to counteract the price increase. In an  empirical study of airline mergers and acquisitions up to 1992, Winston  and Morrison suggest that being able to raise prices or stifle competition  does not play a large role in airlines’ merger and acquisition decisions.
Cost reductions and the opportunity to obtain increased revenue could  bolster a merged airline’s financial condition, enabling the airline to better  compete in a highly competitive international environment. Many industry  experts believe that the United States will need larger, more economically  stable airlines to be able to compete with the merging and larger foreign  airlines that are emerging in the global economy. The airline industry is  becoming increasingly global; for example, the Open Skies agreement  between the United States and the European Union became effective in  March 2008.
Despite these benefits, there are several potential barriers to successfully  consummating a merger. The most significant operational challenges  involve the integration of workforces, aircraft fleets, and information  technology systems and processes, which can be difficult, disruptive, and  costly as the airlines integrate.
Workforce integration: Workforce integration is often particularly  challenging and expensive and involves negotiation of new labor  contracts. Labor groups—including pilots, flight attendants, and  mechanics—may be able to demand concessions from the merging airlines  during these negotiations, several experts explained, because labor  support would likely be required for a merger or acquisition to be  successful. Some experts also note that labor has often opposed mergers,  fearing employment or salary reductions. Obtaining agreement from each  airline’s pilots’ union on an integrated pilot seniority list—which  determines pilots’ salaries, as well as what equipment they can fly—may  be particularly difficult. According to some experts, as a result of these  labor integration issues and the challenges of merging two work cultures,  airline mergers have generally been unsuccessful. For example, although  the 2005 America West–US Airways merger has been termed a successful  merger by many industry observers, labor disagreements over employee  seniority, and especially pilot seniority, are not fully resolved. More  recently, labor integration issues derailed merger talks—albeit  temporarily—between Northwest and Delta in early 2008, when the  airlines’ labor unions were unable to agree on pilot seniority list  integration. Furthermore, the existence of distinct corporate cultures can  influence whether two firms will be able to merge their operations  successfully. For example, merger discussions between United and US  Airways broke down in 1995 because the employee-owners of United  feared that the airlines’ corporate cultures would clash.
Fleet integration: The integration of two disparate aircraft fleets may also  be costly. Combining two fleets may increase costs associated with pilot  training, maintenance, and spare parts. These costs may, however, be  reduced after the merger by phasing out certain types of aircraft from the  fleet mix. Pioneered by Southwest Airlines and copied by other low-cost  airlines, simplified fleets have enabled airlines to lower costs by  streamlining maintenance operations and reducing training times. If an  airline can establish a simplified fleet, or “fleet commonality”—particularly  by achieving an efficient scale in a particular aircraft—then many of the  cost efficiencies of a merger or acquisition may be set in motion by  facilitating pilot training, crew scheduling, maintenance integration, and  inventory rationalization.
Information technology integration: Finally, integrating information  technology processes and systems can also be problematic and time- consuming after a merger. For example, officials at US Airways told us  that while some cost reductions were achieved within 3 to 6 months of its  merger with America West, the integration of information technology  processes took nearly 2 ½ years. Systems integration issues are  increasingly daunting as airlines attempt to integrate a complex mix of  modern in-house systems, dated mainframe systems, and outsourced  information technology. The US Airways-America West merger highlighted  the potential challenges associated with combining reservation systems, as  there were initial integration problems.
section_title: The Department of Justice’s Antitrust Review Is a Critical Step in the Airline Merger and Acquisition Process
paragraphs: DOJ’s review of airline mergers and acquisitions is a key step for airlines  hoping to consummate a merger. For airlines, as with other industries,  DOJ uses an analytical framework set forth in the Horizontal Merger  Guidelines (the Guidelines) to evaluate merger proposals. In addition,  DOT plays an advisory role for DOJ and, if the combination is  consummated, may conduct financial and safety reviews of the combined  entity under its regulatory authority.
Most proposed airline mergers or acquisitions must be reviewed by DOJ as  required by the Hart-Scott-Rodino Act. In particular, under the act, an  acquisition of voting securities or assets above a set monetary amount  must be reported to DOJ (or the Federal Trade Commission (FTC) for  certain industries) so the department can determine whether the merger  or acquisition poses any antitrust concerns. To analyze whether a  proposed merger or acquisition raises antitrust concerns—whether the  proposal will create or enhance market power or facilitate its exercise— DOJ follows an integrated five-part analytical process set forth in the  Guidelines. First, DOJ defines the relevant product and geographic  markets in which the companies operate and determines whether the  merger is likely to significantly increase concentration in those markets.  Second, DOJ examines potential adverse competitive effects of the  merger, such as whether the merged entity will be able to charge higher  prices or restrict output for the product or service it sells. Third, DOJ  considers whether other competitors are likely to enter the affected  markets and whether they would counteract any potential anticompetitive  effects that the merger might have posed. Fourth, DOJ examines the  verified “merger specific” efficiencies or other competitive benefits that  may be generated by the merger and that cannot be obtained through any  other means. Fifth, DOJ considers whether, absent the merger or  acquisition, one of the firms is likely to fail, causing its assets to exit the  market. The commentary to the Guidelines makes clear that DOJ does not  apply the Guidelines as a step-by-step progression, but rather as an  integrated approach in deciding whether the proposed merger or  acquisition would create antitrust concerns.
In deciding whether the proposed merger is likely anticompetitive DOJ  considers the particular circumstances of the merger as it relates to the  Guidelines’ five-part inquiry. The greater the potential anticompetitive  effects, the greater must be the offsetting verifiable efficiencies for DOJ to  clear a merger. However, according to the Guidelines, efficiencies almost  never justify a merger if it would create a monopoly or near monopoly. If  DOJ concludes that a merged airline threatens to deprive consumers of the  benefits of competitive air service, then it will seek injunctive relief in a  court proceeding to block the merger from being consummated. In some  cases, the parties may agree to modify the proposal to address  anticompetitive concerns identified by DOJ—for example, selling airport  assets or giving up slots at congested airports—in which case DOJ  ordinarily files a complaint with the court along with a consent decree that  embodies the agreed-upon changes.
DOT conducts its own analyses of airline mergers and acquisitions. While  DOJ is responsible for upholding antitrust laws, DOT conducts its own  competitive analysis and provide it to DOJ in an advisory capacity. DOT  reviews the merits of any airline merger or acquisition and submits its  views and relevant information in its possession to DOJ. DOT also  provides some essential data that DOJ uses in its review.. In addition,  presuming the merger moves forward after DOJ review, DOT can  undertake several other reviews if the situation warrants. Before  commencing operations, any new, acquired, or merged airlines 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  deciding whether applicants are fit, willing, and able to perform the  service or provide transportation. To make this decision, the Secretary  assesses whether the applicants have the managerial competence,  disposition to comply with regulations, and financial resources necessary  to operate a new airline. FAA is responsible for certifying that the aircraft  and operations conform to the safety standards prescribed by the  Administrator—for instance, that the applicants’ manuals, aircraft,  facilities, and personnel meet federal safety standards. Also, if a merger or  other corporate transaction involves the transfer of international route  authority, DOT is responsible for assessing and approving all transfers to  ensure that they are consistent with the public interest.
section_title: In Creating the Largest U.S. Passenger Airline, a United-Continental Merger May Face Integration Challenges and Analysis of Some Overlapping Markets
paragraphs: If not challenged by DOJ, the merged United-Continental would surpass  Delta as the largest U.S. passenger airline. As table 1 indicates, combining  United and Continental Airlines would create the largest U.S. airline based  on 2009 capacity as measured by available seat miles, and a close second  based on total assets and operating revenue. The combined airline would  also have the largest workforce among U.S. airlines based on March 2010  employment statistics, with a combined 76,900 employees as measured by  full-time-equivalent employees (table 2). The airlines’ workforces are  represented by various unions, and in some cases the same union  represents similar employee groups, such as the union for the pilots (table  3). Finally, the combined airline would need to integrate 692 aircraft (table  4). The two airlines share some of the same aircraft types, which could  make integration easier.
If not challenged by DOJ, the airlines would attempt to combine two  distinct networks, United with major hubs, where the airline connects  traffic feeding from smaller airports, in San Francisco (SFO), Los Angeles  (LAX), Denver (DEN), Chicago O’Hare (ORD), and Washington DC Dulles  (IAD) and Continental with hubs in Houston Intercontinental (IAH),  Cleveland (CLE), Guam (GUM), and New York Newark (EWR), as shown  in figure 2.
The amount of overlap in airport-pair combinations between the two  airlines’ networks is considerable if considering all connecting traffic;  however, for most of the overlapping airport-pair markets there is at least  one other competitor. Based on 2009 ticket sample data, for 13,515 airport  pairs with at least 520 passengers per year, there would be a loss of one  effective competitor in 1,135 airport-pair markets affecting almost 35  million passengers by merging these airlines (see fig. 3). However, only  10 of these airport-pair markets would not have any other competitors in after a merger. In addition, any effect on fares would be dampened by the  presence of a low-cost airline in 431 of the 1,135 airport pairs losing a  competitor. The combination of the two airlines would also create a new  effective competitor in 173 airport-pair markets affecting almost 9.5  million passengers.
section_title: Contact and Acknowledgments
paragraphs: For further information on this testimony, please contact Susan Fleming at  (202) 512-2834.
Individuals making key contributions to this statement include Paul  Aussendorf (Assistant Director), Amy Abramowitz, Lauren Calhoun,  Elizabeth Eisenstadt, Delwen Jones, Mitch Karpman, Heather Krause, Sara  Ann Moessbauer, Dominic Nadarski, and Josh Ormond.
section_title: Related GAO Products
paragraphs: Airline Industry: Airline Industry Contraction Due to Volatile Fuel  Prices and Falling Demand Affects Airports, Passengers, and Federal  Government Revenues. GAO-09-393. Washington, D.C.: April 21, 2009.
Airline Industry: Potential Mergers and Acquisitions Driven by  Financial Competitive Pressures. GAO-08-845. Washington, D.C.: July 31,  2008.
Commercial Aviation: Bankruptcy and Pension Problems Are Symptoms  of Underlying Structural Issues. GAO-05-945. Washington, D.C.:  September 30, 2005.
Commercial Aviation: Preliminary Observations on Legacy Airlines’  Financial Condition, Bankruptcy, and Pension Issues. GAO-05-835T.  Washington, D.C.: June 22, 2005.
Airline Deregulation: Reregulating the Airline Industry Would Likely  Reverse Consumer Benefits and Not Save Airline Pensions. GAO-06-630.  Washington, D.C.: June 9, 2005.
Private Pensions: Airline Plans’ Underfunding Illustrates Broader  Problems with the Defined Benefit Pension System. GAO-05-108T.  Washington, D.C.: October 7, 2004.
Commercial Aviation: Legacy Airlines Must Further Reduce Costs to  Restore Profitability. GAO-04-836. Washington, D.C.: August 11, 2004.
Transatlantic Aviation: Effects of Easing Restrictions on U.S.-European  Markets. GAO-04-835. Washington, D.C.: July 21, 2004.
Commercial Aviation: Despite Industry Turmoil, Low-Cost Airlines Are  Growing and Profitable. GAO-04-837T. Washington, D.C.: June 3, 2004.
Commercial Aviation: Financial Condition and Industry Responses  Affect Competition. GAO-03-171T. Washington, D.C.: October 2, 2002.
Commercial Aviation: Air Service Trends at Small Communities since  October 2000. GAO-02-432. Washington, D.C.: March 29, 2002.
Proposed Alliance Between American Airlines and British Airways  Raises Competition Concerns and Public Interest Issues. GAO-02-293R.  Washington, D.C: December 21, 2001.
Aviation Competition: Issues Related to the Proposed United Airlines-US  Airways Merger. GAO-01-212. Washington, D.C: December 15, 2000.
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