Sunday, March 25, 2012

The History Behind Washington Reagan National's Perimeter Rule - Part 3

 Boeing 727-100 at Washington National Airport, photo copy write Steve Williams

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.

 Boeing 727-200 "Whisperjet," copy write Kenny Ganz

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.

The FAA tried in vain to stem the tide of airline defections at Dulles through a series of actions in 1980, including the waiver of all landing fees and cessation of charges to airlines for use of the mobile lounges.  But these measures proved ineffective and so the FAA proposed even stricter regulations which were encapsulated in the final August 15, 1980 plan for National which was later superseded in November of 1981 by the Metropolitan Washington Airports Policy of 1981.   The plan included the following regulations regarding operation of National Airport:

    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.

Boeing 757-200, first new narrow body Stage III airplane, copy write Bob Garrard

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.



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The author is an independent aviaion consultant with 7 years of industry experience and holds a Masters Degree in Aviation Safety from Embry-Riddle Aeronautical University

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