National Airport officially opened to jet aircraft on April 24, 1966 but within a few months it became clear to the FAA that airlines were not adhering to the spirit of the CAB agreement.  It was determined that carriers were in fact circumventing the 650 mile perimeter rule and flying long haul jet operations by scheduling interim stops at an airport within the existing perimeter in which originating National passengers remained on the aircraft during its very short time on the ground before the flight continued on its transcontinental journey.

The noise problem also did not improve as the ORI study had suggested instead residents called in greater numbers as the high pitched tone of the new jet aircraft was far different, and in fact more disturbing to a great number of residents than the usual piston and turboprop aircraft.  So many people complained that the FAA set up a noise complaint call center which recorded and plotted citizen noise complaints, a practice that continues to this day.

Further instead of reducing operations at National as the study had suggested, the introduction of jets only served to intensify the pressure on National, which by then was bursting at the seams having absorbed an additional 16,000 passengers while Dulles’s passenger total dropped off by 15,000 during the same time period in 1967.

The FAA, convinced the airline’s could not be counted on to live up to the previous agreement issued a Notice of Proposed Rule making (31 Fed. Reg. 9148) which established a hard perimeter of 500 miles and revoked the previous grandfathered routes under the existing CAB agreement this was later revised to allow the existing 650 mile perimeter rule and grandfathered routes to continue, but it was decided that the director of National Airport would hold final approval over aircraft scheduled on a given airline’s route.

Then in the summer of 1966 the FAA issued a Notice of Proposed Rule making:  “Limitations Governing Number of Air Carrier Operations Each Hour at Washington National Airport” (14 Code CFR, Part 159, Docket 7526;Notice 66-29) which established a cap of 60 hourly flight operations, reserving 40 of those operational slots for commercial airline operations.  Unfortunately the cap did not adequately reduce congestion at the airport and so the CAB began to explore additional avenues to resolve the overcrowding problem at National, including forcing the relocation of some existing flights to either Friendship or Dulles.

By this time the DOT was in the midst of developing the so called “High Density Rule,” that capped hour flight operations at five of the country’s most congested airports:  National, La Guardia, JFK, Newark and Chicago O’Hare.  The High Density Rule imposed the following specific restrictions on National operations:

    1.  Air Carriers operating under IFR conditions were limited to 40 scheduled flights per hour, with
         the exception of extra sections of the same flight, a concession demanded by Eastern Airlines to
         protect its lucrative New York-Washington shuttle operation.
    2.  General aviation operations would be limited to 12 operations per hour during IFR conditions
         and air taxi operations to 8 per hour (U.S. DOT 1971, 7).

In 1968 in an effort to expand and modernize National's piston era facilities the FAA announced that it had hired an architect to draw up plans to redesign the terminal to meet the demands of the jet age.  The plan met with stiff opposition from residents concerned about increased noise, as well as both Friendship and Dulles supporters who were convinced that an enhanced National would increase the popularity of the airport at the expense of the region’s other two airports.

There was also a debate in Congress over who exactly should own and manage Dulles and National, with some questioning whether the FAA/DOT should be in the airport business at all.  In the end the differences were just to great to overcome and no federal funding was approved and the FAA was forced to shelve its modernization plans for National.

Despite the setback the FAA was able to establish a clear vision for the future of National Airport built on voluntary agreements with the airlines and the DOT’s High Density Rule, which emphasized the following objectives:

    1.  To provide the optimum utilization of Washington national Airport
    2.  To emphasize its role as a short haul airport
    3.  To reduce undue congestion at the airport
    4.  To maintain efficient runway operations
    5.  To improve serve to the traveling public (Federal Register, 9148, 1966).

During the 1970’s the FAA continued to pursue an operating policy which adhered to these strict objectives and later added two additional criteria, to reduce the aircraft noise and congestion associated with the prevailing use of Washington National and to prescribe a role for both Washington National and Dulles International airport in order to permit the orderly planning for the future at both these facilities.  The need to promote better utilization of Dulles Airport and emphasize its role as the long haul domestic and international airport was seen as the key component to reducing congestion at National.

The passage of the National Environmental Policy Act (NEPA) of 1970 helped push the FAA to establish separate operating plans and policies for both National and Dulles.  But the road to establishing these procedures would be a long and winding one over the course of the next decade, necessitating countless environmental impact statements and proposals which were all submitted for public review and comment, before a final compromised solution could be reached.


In April of 1970, the FAA under the direction of Administrator Jack Shaffer lifted the ban on the stretched 200 series of the popular Boeing 727 at National, approving its use on an interim basis until a complete evaluation of the aircraft’s effect on airport capacity and air traffic congestion could be completed.  The FAA sponsored study concluded that the 727-200 had no adverse effect on either air traffic or airport congestion and permanent approval was given to airline operators to deploy the aircraft on routes in and out of National.

However supporters of Dulles and Baltimore’s Friendship airport did not agree stating that by allowing the stretched 727 to operate at National, Dulles had lost 20,000 and Friendship 200,000 passengers in the first full year of 727-200 operations at the airport.  During that same time period National’s passenger count had grown by 550,000.

In response a coalition of citizen groups filed suit against the FAA in an effort to preserve air traffic at Dulles and reduce noise and air pollution from jets operating at National Airport.  The suit stated that the FAA was in violation of NEPA for failing to file an environmental impact statement in relation to its decision to allow the stretched 727-200 to operate at National and its operating plans for each airport.  The plaintiff’s intended outcome was to force the FAA to redirect a portion of the jet traffic to either Dulles or Friendship airports.

The case was heard by the U.S. Court of Appeals Fourth Circuit, which ruled that the FAA was indeed required under NEPA to submit an EIS in relation to its operations plan for the two Washington Airports under its direct control, but the court further stipulated that the decision to lift the restriction on the 727-200 did not require an EIS or public review.  On August 15, 1980 the FAA issued its Final EIS and Operating Policy for National Airport  which emphasized the need to cap operations at National and continued enforcement of the perimeter rule to further limit access to the airport to short haul jet aircraft.

The 1977 extension of the Metro rail system to National Airport only exacerbated the inconvenience of Dulles and led to a further decline in passengers, as the METRO extension meant that National Airport was only a short 15 minute train ride away which further enhanced its appeal to passengers and helped to reduce land side congestion in and around the airport.

The following year Congress passed the Airline Deregulation Act of 1978, which had an almost immediate negative effect on traffic levels at Dulles, so pronounced was the decline in operations and passengers in the five years preceding deregulation that by 1983 the long term viability of the airport was being questioned.  In the face of increased competition from the flurry of start-up airlines as the result of deregulation, established carriers quickly abandoned less profitable flights into Dulles in order to consolidate their position at National.


    1.  An annual ceiling of 16 million passenger enplanements
    2.  A nonstop perimeter of 1,000 miles with no exceptions
    3.  An allocation of takeoff and landing slots up to 37 scheduled operations per hour for air
         carriers utilizing aircraft with 56 or more passenger seats (except for extra sections which need
         not obtain a slot), 11 per hour for commuter air carriers using aircraft with less than 56
         passenger seats and 12 per hour for general aviation.
    4.  Wide-body aircraft are banned from operating at National unless otherwise directed by the    
         administrator of the FAA and director of the airport on a case-by-case basis.
    5.  A night time noise limitation on aircraft operated after 9:59 PM and before 7:00 AM, such that
         no aircraft generating more than 72 dBA on takeoff may depart and no aircraft generating more
         than 85 dBA on approach may land during these hours except for aircraft scheduled to arrive
         before 10:00 PM that have received an approach clearance before 10:30 PM.

The proposed 1,000 mile perimeter at DCA did not set well with elements of the Texas Congressional delegation and on September 22, 1980 the City of Houston and American Airlines filed a petition asking for the FAA to extend the nonstop perimeter to 1,250 miles which would allow nonstop flights to National from Houston Intercontinental Airport which was just a few hundred miles beyond the existing 1,000 mile limit.  In July of that year the Federal Appeals Court upheld the FAA’s decision and denied the petition to extend the perimeter.

By 1983 quieter Stage III aircraft such as the Boeing 757-200 and MD-80, which met the 1981-82 noise thresholds established for night time jet operations began to be deployed on routes into National, which further exacerbated the noise issue for residents living near the airport who were not expecting these operations.  In that same year the FAA also attempted to pass more rules which further restricted access to DCA, by reducing the yearly passenger enplanement cap and revising the 1981 slot allocations at the airport.  Congress intervened passing legislation which prevented the FAA from implementing the new rules until September of 1985.

In June of 1984, then Secretary of Transportation, Elizabeth Dole announced that she would seek to introduce legislation in the 99th Congress to transfer ownership of Washington National and Dulles Airports to a regional authority or private sector entity.  The Holton Commission, a 15 member advisory panel was established to study how best to reorganize the Metropolitan Washington Airports and outline the process to facilitate transfer of ownership to the new controlling party.

The Holton Commission, comprised of representatives from the District of Columbia, the states of Virginia and Maryland, Congress, the Air Transport Association, National Business Aviation Association and the Regional Airline Association issued its final recommendation in December of 1984, concluding that:

    1.  The airports should be transferred to an independent authority created jointly by the
         Commonwealth of Virginia, and the District of Columbia, and that the authority have the ability
         to issue tax-exempt revenue bonds to finance improvements at the airports
    2.  The transfer of ownership should be accomplished through a long-term lease whereby the
         authority would make payments over a period of not more than 35 years
    3.  The authority would be governed by a board of 11 members with five appointed by the
         Governor of Virginia, three by the Mayor of the District of Columbia, and two by the Governor
         of Maryland and one by the President of the United States.

On October 16, 1986 Congress approved leasing the airports to a regional authority, passing the Metropolitan Washington Airports Act which effectively ended federal ownership and control of both Washington Airports by the FAA, a position the agency had maintained for 45 years. 

The compromised bill included many concessions which essentially revoked the 1980 and 1981 regulations adopted by the FAA concerning capacity at National Airport.  It also froze the number of hourly slots to levels established in the 1981 FAA Notice of Proposed Rule making.  The major concessions of the Metropolitan Washington Airports Act regarding National Airport included:

    1.  Passenger Ceiling  (CAP):  The bill eliminated the yearly passenger enplanement cap
    2.  Perimeter Rule:  The existing perimeter at DCA was extended from 1,000 to 1,250 miles to
         allow nonstop flights from Houston, TX
    3.  Widebody Aircraft:  The Act repealed the 1981 regulation prohibiting the operation of such
         aircraft at National
    4.  Nighttime noise:  The Authority was given authority to change the 1981-82 restrictions
    5.  High Density Rule:  The Act froze the number of slots and provided that the rule may not be
         changed except for reasons of safety.

PART 2

In just under 10 years from its opening in 1941 congestion at National had increased to the point that both the landside roadways and airside pavement were often overwhelmed by the sheer volume of traffic.  In addition the airspace over the District of Columbia was becoming increasingly crowded as traffic from National Airport mixed with military aircraft from surrounding airfields.  As a result Congress grew increasingly concerned about the potential for a major air disaster over Washington D.C. and eventually in September of 1950 they were moved to action, passing the Second Washington Airport Act.  The act appropriated funds for the construction of a second larger international airport to reduce the congestion and overcrowding at National. 

However as like the previous debate over the location of National Airport, Congress could not immediately agree on a suitable location for the new airport.  It would take seven years of political wrangling before the final site selection was made by the President and approved by Congress.  Construction of the new airport named "Dulles International" on 10,000 acres of land in rural Chantilly, Virginia some 26 miles from the Capitol finally began in 1957.

Dulles International Airport officially opened for business on November 20, 1962 with six airline tenants:  American, Braniff, Delta, Eastern, TWA and Northwest Orient.  The airport was the first airport to be built in the United States specifically to handle jet airplanes.  However the airport proved a tough sell to passengers, who preferred the convenience of congested National Airport to the modern and spacious but inconvenient Dulles.  In response to weak demand and the airport’s remote location air service options at Dulles would remain limited for the next several decades.

In 1959 the newly established Federal Aviation Agency enacted a ban on all pure jet operations at Washington National Airport.  It was the agency’s belief that National's runways were too short and structurally unable to support repetitive operations by four engine intercontinental jets like the DC-8 and 707.  Secondly the FAA which owned and operated National and the then uncompleted Dulles airport wished to prohibit jet use at National to force airlines to move those operations to Dulles to help spur growth at the new airport once it opened.  The state of Maryland also objected to the use of jet aircraft at National as they felt that action would inhibit growth at Baltimore's Friendship Airport.  Last the residents living around National were becoming increasingly vocal about the noise generated by piston engine aircraft landing and departing the airport, and there was much public outcry against allowing even louder jet airplanes to use the facility.

By 1960 the noise problem at National had become such a large concern, that then FAA administrator Elwood Quesada, tired of the continuous calls from residents moved to establish specific noise abatement procedures for arriving and departing aircraft.  As a result National Airport became the third airport in the country to have prescribed noise abatement procedures, the first of which went into effect in the fall of 1960.


But even with the prohibition on jet aircraft, National was still the fourth busiest airport in the country in 1962 averaging a takeoff or landing every minute.  The new Dulles Airport simply was not having the desired effect of reducing congestion at National as the FAA had hoped, which was reflected by the fact that by 1965 the three year old airport was averaging less than 90 flights a day compared to National’s 600 daily flights.   While Dulles was losing money National was generating over $100 million a year in revenues for the federal government.  In short the situation at National had become untenable and the FAA realized that Dulles at least in the short term was not the solution to reducing congestion at DCA and they would have to explore other options to curb the growth at National Airport.

By 1965 the prohibition on jet aircraft at National was making life increasingly difficult for airlines, and presenting serious challenges to aircraft scheduling.  The proliferation of small to medium sized commercial jets led by the Boeing 727 and Douglas DC-9, was wide spread by this point with more than 70 U.S. airports having regularly scheduled jet service.

Advancements in jet engine technology in the 1960’s created an entirely new class of short haul narrow body jets beginning with the French built Caravelle which made its American debut with United Airlines in 1961.  These new lighter short haul jets were more than capable of operating from National’s short runways and produced noise levels equivalent to those of existing piston engined and turboprop aircraft currently servicing the field.

The airlines were shedding expensive and unreliable piston engine aircraft in great numbers by this time and began to turn up the heat on the FAA to try to force the agency to repeal the ban on pure jet aircraft at National.  The outcries from the airlines were soon joined by voices from Congress and the media, both of which detested the long arduous drive to Dulles just to fly on a jet.
 

In response the FAA commissioned Operations Research Inc. (ORI) in 1966 to conduct a study to explore the Economic Feasibility of Alternative Programs for Washington National Airport.  The study was focused primarily on the feasibility of opening National to jet operations and investigating the effects the jet aircraft would have on the growth of the airport, subsequent effect on both Dulles and Baltimore Friendship airports and the noise impact on residents living around National.  The conclusions of the ORI study are summarized below.

1.  Dulles and Friendship’s growth would not be hampered by allowing jet aircraft into national.
2.  1.5 million hours of travel time would be saved over the course of the next 15 years, resulting in
     a savings of approximately $15 million a year for the next 15 years.
3.  The potential monetary benefit of allowing jets into National should be supported by an
     investment by the federal government of up to $150 million to enhance and expand the airport to
     accommodate these aircraft.
4.  The introduction of higher capacity jet aircraft would likely cause an overall reduction in noise
     for residents, as aircraft operations would decline with the added capacity until 1970 when the
     study forecasted that the noise influence zone would begin to grow.
5.  The noise level of short and medium haul jets was predicted to be similar in level to existing piston
     and turboprop aircraft using the airport and due to their higher performance and speed the jet
     aircraft would be able to climb higher and faster which would reduce the noise impact to residents
     around National.

Satisfied that the introduction of jet aircraft would not negatively impact the two other regional airports and encouraged that these new aircraft might actually help reduce congestion at National the FAA announced on January 11, 1966 that it would open DCA to two and three-engined jets the following spring.

In order to help ensure the future growth of Dulles as a hub for international and long haul domestic air travel in the Washington D.C. market and to reduce the pressure on National the FAA worked out an agreement with the airlines that voluntarily limited nonstop flights to and from DCA to a radius of 650 miles. 

The subsequent agreement (CAB order E-23743) was filed with the Civil Aeronautics Board in May of 1966.  Seven existing routes to airports outside the 650 mile perimeter from National were given grandfather rights.  The agreement became known as the perimeter rule and was the first in a series of measures that served to restrict flight operations at DCA.  As part of the agreement commercial airlines also agreed to voluntarily refrain from scheduling jet flights between 10:00 PM and 07:00 AM at National in order to reduce the noise imposed on communities around National airport.

March 12th was the filing deadline for new entrant/limited incumbent carriers to submit applications to claim their share of the beyond perimeter slot exemptions created as a result of the FAA Modernization and Reform Act of 2012.  In total Congress authorized 16 slots or 8 total slot pairs for flights beyond the existing 1,250 mile perimeter.  The issuance of beyond perimeter slot exemptions at Washington Reagan National Airport (DCA) is rare with a total of only 24 previous slot exemptions having been issued in two separate proceedings since 2000. 

Washington Reagan is one of only two airports in the United States to have flight operations artificially restricted by a perimeter rule, New York LaGuardia is the other with a prohibition on nonstop flights beyond 1,500 miles.  But what is the history of the perimeter rule and why exactly was it established at National Airport?

Origins of National Airport
The Air Commerce Act of 1926 charged the Secretary of Commerce with fostering development of the nation's aviation system by centralizing oversight, control and enforcement of aviation regulations, including pilots licensing, aircraft certification, as well as establishment and maintenance of airways and their associated navigation aids.  To execute the duties outlined in the act, Congress directed that a new Aeronautical branch of the Department of Commerce be created.  This department was the forerunner to the Civil Aeronautics Authority which became the Federal Aviation Agency which was later renamed the Federal Aviation Administration.

One of the provisions of the Air Commerce Act expressly prohibited the federal government from owning and operating commercial airports.  This meant that construction and operation of an airport to serve the nation's capital fell under the jurisdiction of the District of Columbia.  However due to the circumstances surrounding the creation of the District of Columbia, Congress held final approval rights over the District's budget, therefore any money's allocated to the establishment of an airport within the district's jurisdiction would have to ultimately be approved by Congress.


The passage of the Civil Aeronautics Act in 1938 which President Roosevelt signed into law that June, effectively repealed the Air Commerce Act, including the provision which prohibited the federal government from owning and operating a commercial airport.  But the new law did little to spark action by Congress to finalize the site selection of the new airport.  Frustrated by the lack of progress during a Congressional recess Roosevelt instructed the newly established Civil Aeronautics Authority (CAA) to pick a site for the airport.

The CAA ultimately selected Gravelly Point, even though the majority of the land was comprised of mud flats which were underwater most of the time.  But of critical importance the site was less than four miles from Capitol Hill and the majority of the land was already owned by the federal government. Roosevelt appropriated funds from the Public Works Administration (PWA) and Works Project Administration (WPA) to pay for the new airport and in defending his decision the President stated that he was tired of waiting for Congress to act on the issue.

In order to build the airport the Army Corps of Engineers had to fill in 325 acres of marsh land with 19.5 million cubic yards of dredge material pumped from the bottom of the Potomac River.  Two years later in the fall of 1940 at the site dedication Roosevelt laid the cornerstone of what would become the main terminal building, referring to the airport as Washington National Airport.  The Airport officially opened for business the following summer and within a year traffic had grown to the point that National was the second busiest airport in the United States.

PART 2