Dangerous Flight Expansion 

The Capital Access Alliance (CAA) led a full-court press with Congressional allies to add 28 flights at National Airport.  The report contained unsupported assertions, talking points, and BOGUS DATA in its report done by the Boston Consulting Group (BCG).  BCG has a history of bending analyes into "hit jobs" to support dubious objectives.  Their analyses as sloppy at best. 

• CAA efforts were funded by self-interest groups/corporations, such as Delta Airlines, and powerful Senators Ted Cruz and Mike Lee. 

• The FAA, MWAA, and GAO raised serious safety and operational concerns about adding flights from National.

• Read the CAA/Boston Consulting Group (BCG)  Full Report

My dissection of BSG report supporting CAA on adding flights 

As Benjamin Disraeli and Mark Twain expressed - there are " lies. damned lies. and statisics".  The Capital Access Alliance (CAA) engaged the Boston Consulting Group (BGS)  to conduct a study to support its objective to expand DCA's perimeter rule.  The report is biased and littered with errors and canards in support of expanding direct service to Texas and Utah.  So let's dissect this report a bit to understand what's lying inside, what "facts" are BOGUS, and instances of offuscation or chicanery!  I will not dwell on the glitz in the body of the report and focus more on section 9,  that describes the report's "rigorous" methodology (how the sausage was made).

1. I think BCG correctly identified the CAA as a bunch of rubes and easy marks and CAA got taken by BCG on the expense of its perimeter rule report/analysis.   The body of the report makes bold assertions about DCA passenger usage, ticket prices, and overall economic benefits from expanding the perimeter rule - which are not supported by facts or described methodologies.  In fact, the Appendix appears to be mostly unrelated boiler plate descriotion of elaborabe BCG metrics/formulas (likely used in other reports) that do not seem support its assertions and conclusions. The CAA got scammed!  Statisicians running amok? 

2. Page 7, the CAA report cites DCA and IAD passenger volumes from 1999-2019 to highligh less passengers at DCA, but neglects to note 2022 passenger volumes of 24M for DCA and 21.4 million moving through IAD (down from 24.8 million in 2019),  https://www.washingtonpost.com/transportation/2023/02/18/national-airport-passenger-traffic-2022/

3. On page 10, the CAA misleads the reader regarding the 3 runways at DCA - only 2 are actively used.  Runway 19/01 is the main runway at DCA and most used. It serves most of the traffic at the airport and is the longest runway at 7169 feet. It can handle anything from a Cessna Citation V to a Boeing 787-9. Runway 15/33 is secondary of the two main active runways and only services commuter jets. It is shorter at 5204 feet long and requires sharp inflight turns on departure and arrival. Runway 04/22 is only used a few times a year.  Source: https://community.infiniteflight.com/t/how-to-dca/470078#:~:text=19%2F01%20is%20the%20main%20runway%20at%20DCA.%20It,is%20the%20longest%20runway%20there%2C%20at%207169%20feet So any increase in DCA long haul  traffic will occur on the main runway and, contrary to the report, will lead to congestion and potential delays.

4. On page 12, the report states "Protecting in-perimeter communities’ access: As per findings of the GAO report [https://www.gao.gov/assets/gao-21-176.pdf]  stakeholders assert that the perimeter rule ensured that airlines continue to provide service to smaller in-perimeter communities from the nation’s capital. Flights to these communities generally tend to be less valuable than larger beyond-perimeter communities in revenue. Lower traffic volumes primarily drive this from these communities resulting in lower revenue per flight compared to a flight from a larger beyond- perimeter market"  This is blatantly false!  As noted in its report, the GAO considers several factors—existing slot control rules; capacity at Reagan National; and potential effects on noise, other area airports, passengers, and airline competition—should be considered in any decision to modify Reagan National’s perimeter rule, according to GAO’s prior work and stakeholder interviews. The report also noted "As has generally been the case with previous statutes, when exemptions were made for new beyond-perimeter flights, airlines have added flights without reducing the number of within-perimeter flights to small communities". The concern about expanding the perimeter rule is clearly articulated by the GAO on page 11 "While Other Effects Are Less Certain, Beyond-Perimeter Flights Increased Passenger Traffic at Reagan National Likely Reducing Available Capacity".  Who to believe BCG or GAO?

5. Moreover, the methodology described on page 53 of the Appendix supporting Section 5.1 - Effectiveness in protecting in-perimeter communities’ to expand access to Washington, DC is based on a faulty hypothesis as well as statistically manipulative and groundless analysis.  

6. Page 56, the report describes its Block time buffer analysis as a key performance indicator (KPI) to measure runway congestion to argue its point on expanding the perimeter rule.  According to CIRIUM Aviation Analytics, the total amount of time a flight takes — from pushing back from the departure gate (“off-blocks”), to arriving at the destination gate (“on-blocks”) — is called “block time”, and airline block times vary for the same routes. This KPI measures carrier service reliability (as correctly and surprisingly noted by BCG on page 17) and is not a KPI to measure of airport congestion   https://www.cirium.com/thoughtcloud/block-time-airline-schedules/ 

7. Let's examine the GREENWASHING methodology articulatedin Section 6.5 – Perimeter rule’s impact on CO2 footprint for Washington, D.C., metro to support the report's assertion that expanding the perimeter will reduce emissions. (hold your breath!).  The report states that it uses methodology from the ICAO website to calculate fuel emissions data: https://www.icao.int/environmental-protection/CarbonOffset/Documents/Methodology%20ICAO%20Carbon%20Calculator_v11-2018.pdf   The CAA methodology described in its report, however, does not align with the ICAO instructions, skips steps, and makes irresponsible extrapolations.   A key mystery is how the CAA derived its Pax load factor since it does not coorespond to the ICAO database based on number of passengers transported, the number of seats available in a given route group, and origin/desinations airports. It is pretty common to cook CO2  calculations to make more flights by larger planes look greener.

8. Lastly, on page 60, the CAA  describes its Airport preferences from a consumer survey.  The CAA report challenges the GAO assertion that consumers have an outsized preference for DCA. The CAA  survey results  show that less than 50% of passengers who traveled out of any of the three Washington, D.C considered another airport.  CAA explains their survey methodology stating: "A few qualifiers were set: The survey taker must have traveled by air within the past year and must be at least a 50% decision maker in the households’ travel purchases. Passengers who did not meet these two qualifications were removed from the survey results." This filter certainly favors a survey cohort toward single-headed/decision households and against multiplel-head (decision) households.  So the results tend to not reflect the general DC area "flying" population.

Other entities that argued against adding flights at National

• FAA disputes bogus statistics and assertions supporting this page's analytic criticism below.  FAA states that  Adding Flights Would Increase Delays 

• Letter from MWAA CWG on aircraft noise formally opposes Perimeter Rule change  Letter to Senators and followup article in Arlington local paper cites letter - ARLNow 

• Washington Post editorial against expanding the Perimeter Rule and exposing CAA backers (good read) Don't Ruin Reagan National 

• New group opposes longer flights out of Reagan National Airport 

• Visit home page of group against expansion of the DCA perimeter rule.  The PCA is a member of The Coalition to Protect America's Regional Airports (CPARA) 

• Great article from AXIOS - "Why Congress can add flights to D.C.'s busiest airport"