(Archived document, may contain errors)
717 June 30,1989 STATUS REPORR AIRLINE COMPETJIXON AND
CONCENTRATION SINCEDEREGULATION INTRODUCTION Airline dereguktion
once again is under attack. Pointing to the recent wave of mergers
between airlines, some observers now are saying that r dere Nation
hG I failed b Loosening federal I controls .ax over 1. airline
routing and pricing w& billedias the key tomore competition,
but instead, they say e U.S. is heading toward an airline
oligopoly.
The facts, however, tell quite a different story. Rathe r than a
trerid toward oligopoly, competition in the industry remains vastly
stronger than in the days of regulation. Freed from the old
regulatory limits on competition, todays typical air traveller
enjoys greater choice of carriers than before deregulat ion.
For instance while in 1977 almost half of all passengers flew on
airlines that had 70 percent more of the traffic on their route,
last year only about 20 percent did so flights handled by the one
or two largest carriers has grown considerably since de regulation.
This is largely a natural consequence of the market-driven hub and
spoke system of routing, in which passengers are routed through
central hub airports. But the result of this reorganization for
consuniers has been overwhelmingly positive, as a irlines have been
able to serve more consumers on more frequent flights at much lower
costs. And far from benefitting transitting passengers at the
expense of hostage residents of the hubcities, local residents have
been among the systems largest benefici a ries enjoying more
frequent senrice and more non-stop destinations the otherwise would
be possible Positive Results. To be sure, at certain major airports
the proportion of Andrew Laperriere and Michael McLaughlin assisted
with the research for this study .
Nevertheless, there is still much to be done to stimulate even
more competition. For one thing, legal barriers to service in the
United States by non-U.S. carriers should be reduced, thereby
expanding the number of airlines available to domestic passenge rs.
For another, action should be taken to expand the capacity of the
nations airport and airway system, to provide room for new
competitors to enter the market. Important steps for this include
improved management of airport slots and gates and the use o f
private-sector incentives to expand and build airports.
By these actions, the benefits of deregulation can be further
extended.
Reregulation on the other hand, would mean less competition and
higher prices for passengers THE GROWTH OF HUB AND SPOKE NETW ORKS
For most of its history, the U.S. airline industry was tightly
controlled and regulated by the federal government. The Civil
Aeronautics Act of 1938 gave the federal government final say over
the routes airlines served and the prices they charged. Wi th the
Airline Deregulation Act of 1978, however, airlines became free to
set their own routes and prices.
The next few years were a time of dramatic change, as numerous
new firms entered the airline industry. Typical of an industry in
which new competitio n is introduced, this turbulent period was
followed by an equally turbulent period of shake-out and
consolidation. In large part, this consolidation was driven by a
new and more efficient form of routing developed by the industry
the hub and spoke system E fficient Hub Networks. When airlines
were regulated, their routing systems looked very much like those
of railroads, with aircraft making several stops at various cities
during a flight. Under the hub and spoke system, by contrast,
passengers are flown to a central hub location, from which they
travel to their final destination. Through this system, airlines
can reduce the number of empty seats on aircraft, increase the
frequency of flights to less travelled destinations, and nearly
eliminate the need for passengers to change airlines in
mid-trip.
Although it was economically possible to develop these more
efficient hub and spoke networks ever since jets came into use,
they were not widely used before deregulation simply because the
regulatory system made r oute changes difficult. For hubs to work
best, a certain volume of traffic and number of destinations is
needed to fill airplanes and make frequent flights possible. This
incentive for a larger scope of operations helped trigger a series
of airline merger s in recent years. From 1985 through 1987,
nineteen airline mergers took place.The industry has since
stabilized, with few airline mergers since 1987 2 HOW CONCENTRATION
IN THE AIRLINE INDUSTRY HAS DECREASED Looking at these mergers,
some journalists and l a wmakers have assumed that the airline
industry is becoming an oligopoly. Yet the facts do not support
this conclusion the market enjoyed by major firms. Despite the
airline merger trend, the shares of the national market held by
major U.S. carriers today a re very similar to those before
deregulation.The largest airline in 1977, United Airlines, carried
about 14.5 percent of passengers. Texas Air was the largest firm by
1988, carrying about 16 percent of passengers. But almost half of
these passengers flew o nTexas Air's now-bankrupt subsidiary,
Eastern Airlines. Discounting this traffic,Texas Air last year
handled only about 14 percent of passengers. Furthermore, the three
largest airlines accounted for about 43 percent of passenger
traffic in 1988 oqy margi n ally higher than the 40 percent share
for the three largest in 1977 Measuring Competition. Such overall
figures, however indicative they may be of the broad picture, say
little about the actual extent of choice enjoyed by passengers on a
particular route. Passengers travelling, say, from Detroit to
Cleveland are most concerned about their choices for that journey,
not national market shares for each airline. Thus, the best measure
of concentration in today's airline industry is the amount of
competition on each of the 70,000 or so routes across the
country.
The data on individual routes show a large and unmistakable
decrease in concentration since the airlines were deregulated. In
1977, for instance almost half of all passengers travelled on
airlines that c arried 70 percent or more of the traffic on the
route. In 1987, only 19.5 percent did so. Even more striking: in
1977, more than one in ten passengers flew on carriers with 100
percent of the traffic on their route. In 1987, only 1.8 percent
did so.
Overall, in 1977, the average passenger flew on a carrier with
over 60 percent of the market on the route. By 1987, this figure
was down by about a third to approximately 40 percent.
Virtually Unchanged Concentration. The recent airline merger
wave seems to have had only a minor effect on route concentration.
From 1986 to 1987 the portion of travellers on airlines with 70
percent or more of the traffic on their route rose only four
percentage points to 19.7 percent still much less than the levels
of the 1 970s. Since then, based on third quarter 1988 data, it has
remained virtually unchanged.
Such a decrease in concentration on routes may at first seem
strange given the fact that overall market shares in the industry
are now about the same as they were befo re deregulation.The
explanation lies in the nature of the old The simplest measure of
competition in an industry is the overall share of 1 Calculated
from Civil Aeronautics Board and Department of Transportation Ak
Carrier Traffic Statistics 1977 and 1988 3 regulatory system. The
Civil Aeronautics Board often gave airlines protected by route
positions on the routes they Passengers Traveling on Carriers with
High Market Shares p 0 I flew, with few or no competitors on each
route.
With the removal of that pr otection, airlines were able to
elbow into one anothers routes Thus, even with similar overall
market shares, concentration could decrease significantly I n t 60
7 40 Pa0 00 Pereon1 of Market Held by Carrier 20 0 n 10 a Year
Heri(.oe InloOhul Source: Civi l Aeronautics Board and Department
of Transportation Origin and Destination Surveys 1975-i988 (third
qu-irter only for 1988.
CONCENTRATION AT HUB CITIES Despite the substantial general
decrease in concentration in the industry there has been serious
concer n over concentration in particular areas especially at hub
airports. As airlines established hubs, and directed more of their
traffic toward their hub airports, each handled an increasing
percentage of the traffic at those airports. For instance, in 1987,
Trans World Airlines WA) handled over 80 percent of the traffic at
St. Loui; and Northwest Airlines handled over 80 percent of that in
Minneapolis.
Such statistics might seem to imply that passengers in major
cities confront near monopolies. But traffic s hare statistics can
exaggerate the real level of concentration. There are several
reasons why the data are misleading. Among them 1) Airport
concentration is not a universal trend Many major airports, such as
Los Angeles, New York, Buffalo and Cleveland, h ave seen decreased
concentration since deregulation. Overall according to a study by
the investment banking firm of Salomon Brothers Inc 21 of the 50
Largest U.S. airports saw decreased concentration between 1977 and
1987.3 2) Measurements of the gross am o unt of traffic handled by
airlines at hubs inflate the extent of their dominance The figures
compiled by Salomon Brothers, like most similar studies, are based
on the total number of passengers boarding-or leaving an airplane
at the hub, without regard to their ultimate destination. However,
half or more of a airline passengers using a typical hub are merely
connecting from one 2 Julius Maldutis, Airline Competition at the
50 Largest U.S. Airports Since Deregulation, Salomon Bros Inc
August 1987, pp. 22,28 3 Bid 4 flight to the next. Thus, although
Northwest, for instance, handles almost 80 percent of the traffic
at the Memphis airport, only about 55 percent of the passengers
actually going to or from the city of Memphis travel by
Northwest.
Passengers thus exercise a much wider degree of choice that the
raw data would at first suggest 3) The share of airport traffic
does not directly indicate the degree of choice enjoyed by
passengers The markets in which airlines compete are the routes
between airports, n ot the airports themselves. Thus it is
competition on each route which is important, rather than the
proportion of passengers using a particular airline at an
airport.
Analyzed from a route perspective, concentration at hub airports
is lower today than bef ore deregulation. In St. Louis, for
example, airline concentration measured by airport traffic share
has more than tripled since 1977.5 Yet, concentration on routes to
and from St. Louis today is lower than it was a decade earlier. In
1977, almost 35 perc ent of passengers going to or from St. Louis
were on routes in which one carrier handled 90 percent or more of
the traffic. Yet in 1988, only about 17 percent were on such
routes.
Similarly, the portion of such travellers on routes where one
carrier held 70 percent or more of the traffic fell from about 60
percent to just under half!
For all hub airports, the share of passengers carried by
airlines with 70 percent or more of the traffic on a route fell
from 42 percent to 31.8 percent between 1980 and 19887 PRICING AT
HUBS Another way to gauge competition at hub airports is to examine
the fares charged there. The General Accounting Office calculates
that, on average fares at airports it defines as concentrated are
27 percent higher than those at other airpo r ts! Yet a closer
examination reveals that this pricing difference generally is not
attributable to less competition at airports. In fact, fares at
airports seem to show little correlation to the percentage of
flights handled by the leading carriers. For e x ample, in
Pittsburgh, USAir handles over 80 percent of the traffic, but
charges fares that are less than the industry average for similar
distances On the other hand, at the less concentrated San Francisco
airport, United offers fares 27 percent above ave rage. 9 4
Northwest Airlines statistic 5 Maldutis, op. cit p.
28. Based on Herfmdahl-Huschman Index of concentration 6
Calculated from Civil Aeronautics Board and Department of
Transportation Origin and Destination Surveys 1977 and 1988 (third
quarter onl y for 1988 7 Shat, Heilensen & Eichner, Hub
Operations: An Analysis of Airline Hub and Spoke Systems Since
Deregulation May 1989 table 4-11 Using third quarter figures 8
Kenneth M. Mead, Air Fams and Service at ConcentmtedAirports,
Statement before the Su b committee on Aviation, Senate Commerce,
Science and Transportation Committee, p. 5 June 7,1989 9 Kurth Co
Inc Salt Lake City Airline Fares' Sfudy, February 1989, chart 4 5
Differences in the fares charged to and from particular airports
reflect many facto r s. Fares are generally lower, for instance on
more densely travelled routes. Many of the most densely travelled
routes in the country are between non-hubs, such as between NewYork
and Washington, D.C while many less densely travelled routes are
between sm a ll city hubs, such as Charlotte and Raleigh/Durham.
Other factors, such as capacity limits at airports, also affect
fare levels Consistently Better Service. The most important factor
explaining fare differences, however, appears to be the service
quality p rovided to passengers using the airport. Service from hub
airports generally is consistently better than elsewhere. For
instance, passengers embarking at hub cities typically fly
non-stop. At Memphis and Detroit, for example, the number of
non-stop destin a tions went up 20 percent after they were
designated as hubs. At non-hubs, by contrast, non-stop flights are
the exception. Since non-stop flights are more attractive to
passengers, airlines can charge a higher price for them on average
about 14 to 24 perc ent more than other flights." This factor alone
explains a large portion of the fare differential.
Designation as a hub also dramatically increases the quantity of
service available to residents of that city. For instance: in the
four years after Northwest designated Detroit and Memphis as hub
airports, the number of flights and available seats at those
airports rose by about 40 percent. As a result, residents of these
cities enjoy more frequent service than these cities could
otherwise have supported.
On the other hand, cities that are not hubs generally have fewer
flights than comparable hub cities. Cleveland, until 1987 the
largest American city that was not a hub, had a lower frequency of
service than hub cities its size. In one typical 1987 quarter, f o
r instances, Cleveland had about 13,000 departures, with about 1.5
million available seats. During that same quarter Minneapolis-St.
Paul, a similar-sized metropolitan area that serves as a hub had
26,000 departures with 3.6 million available seats Even D ayton, a
ci only half the size of Cleveland, had as many daily departures as
Cleveland.
In view of these lower service levels, it would be surprising if
non-hub fares were not lower than hub fares Pi I 10 Simat,
Helliesen and Eichner, o p. cit table 6.8 11 Northwest Airlines
statistic 12 For a discussion of the problems faced by cities that
do not enjoy hub status, seeTeri Agins Off the Beaten Path
Cleveland Suffers As Largest City Without Major Air Hub Wall Street
Journal, August 19,198 7 6 POTENTIAL IMPEDIMENTS TO COMPETITION
Competition at many hub and even non-hub airports may be
constricted if entry by new competitors is limited in some way.
Many factors have been cited as potential barriers to new entry by
firms. Among them 1) Freque n t flyer programs. Most airlines offer
special benefits, ranging from service upgrades to free flights to
passengers who travel extensively on their planes. These programs
develop brand loyalty: passengers stick with that airline to earn
frequent flyer ben e fits.These frequent flyer programs are said to
inhibit competition by preventing passengers from responding to
better prices and services from a rival airline, and are among the
most likely targets of congressional action intended to strengthen
competitio n.
Congress, however, would be wrong to do so. In practice,
airlines cannot lock out competitors with these programs. New
passengers, with few accumulated credits, can easily be won away by
a rival airline, as can those who have recently converted their cr
edits into rewards. Those with the greatest incentive not to switch
are those passengers about to gain awards who impose costs on an
airline. Because of this, argues former U.S. Circuit Court of
Appeals Judge Robert Bork, in his book The Antitrust Paradox
programs such as this constitute a poor way to achieve monopoly
profits.13 Passenger Incentives. Frequent flyer programs in fact
may benefit passengers. Firms with large fixed costs need to ensure
a stable base of revenue. It is thus common in many indust r ies
for firms to act to encourage customers to provide a certain amount
of business. Thus, a steel producer may provide lower prices to
certain customers in exchange for the customers guarantee that some
or all of their steel purchases will be from that p r oducer As a
result, the producer is better able to make long-term plans and can
operate more efficiently. The basic purpose of frequent flyer
programs appears to be the same. Although passengers do not
guarantee business to the airline, they are given an i ncentive to
fly the airline again. While competitors are not locked out, the
effect is a more stable base of revenue call the principal-agent
problem. Simply put, this means a business traveller may choose to
fly an unduly expensive airline simply to obta i n a frequent flyer
benefit, while his employer pays the tab. Thus he is not sensitive
to cost. But this problem occurs whenever an employee can benefit
from services he purchases at employer expense such as taking a
client to a restaurant. Rather than new regulation, the solution
appears to lie in increased employer monitoring of travel expenses,
a common cost-control procedure in prudent companies. The federal
government should also consider equalizing the tax treatment of
frequent flyer benefits and othe r employee fringe benefits
Admittedly discount frequent flyer programs can result in what
economists 13 Robert H. Bork, 77ae Antihust Pamdar New York Basic
Books, 1978 p. 326-8 7 2) Travel agent bias. Another supposed
barrier to competition is the system o f bonuses provided to travel
agents by most airlines for selling tickets on their flights. This
is said to prompt travel agents to steer passengers toward favored
airlines. Yet, competing airlines can counter any effect by
offering similar incentives. Perh a ps more important, since the
travel agency industry is one of the most competitive in the world,
any such bias by an agent is quickly corrected in the marketplace.
Customers can and do routinely switch travel agents if they feel
they are not getting the b e st deals from them 3) Computer
Reservations Systems (CRSs Some major airlines own computer
reservation systems, through which flight information is given to
travel agents and reservations booked. These airline-owned systems
have been accused of displaying their own flights more prominently
on computer listings, thus giving their flights an advantage over
those of others.
Such a display of information does have real advertising value,
much like eye-level placement of goods on a supermarket shelf helps
sell products. Yet just as a supermarket cannot drive out
competitors to its own house brands by giving those products better
shelf position, an airline can hardly expect to drive out
competition through CRS preferences. In fact, if it were to do so,
it would d ecrease the value of its system to travel agents, by
encouraging the growth of other systems. Pressure on travel a ents
by consumers for the best flights ensures that any system bias is
limited. q4 4) Limited airport capacity. As airline travel
continues to grow, and airports become more congested, airlines are
finding it more.difficult to acquire the gates and landing slots
necessary to enter into new markets.This may be the biggest threat
to continued strong competition in the airline industry.
Generally , there are two factors limiting the ability of a
carrier to begin operations at a particular airport: the
availability of landing slots and gates.f5 Landing slots are
restricted by the Federal Aviation Administration(FAA) at four
major U.S. airports whic h experience particularly heavy traffic
Washingtons National, New Yorks LaGuardia and Kennedy, and Chicagos
OHare. Under current rules, each carrier at these four airports is
allotted a certain number of slots, which can then be bought and
sold to other ai rlines.
While an improvement over earlier, bureaucratic, methods of slot
allocation it is still often difficult for new entrants to gain
slots because incumbent airlines typically refuse to sell slots to
new challengers.
At other U.S. airports, slots are more freely available, and so
are not limited in this way. Occasionally, excessive traffic still
may be a problem at these other airports, but this usually results
in delays, rather than any lack of 14 It should also be noted that
the incentives to provid e such preferences may be lessening due to
an emerging trendof ownership of each system by several airlines.
See Carole A. Shifrin, American, Delta Computer Reservations Deal
May Intensify Global Competition,Aviation Week and Space
Technology, February 13, 1 989 15 A generic term which includes
take-off slots 8 access for new carriers. Nevertheless, with the
volume of air traffic expected to rise 72 percent by the end of the
cptury, capacity is expected to become more troublesome at more
airports Capacity Pro b lem. The second factor limiting entry is
the availability of boarding gates. Even with a landing slot, an
airline still cannot use an airport if it lacks a gate at which its
passengers can board or disembark. Gate availability is a limiting
factor on comp e tition at some airports, although estimates of the
extent of the problem vary.The General Accounting Office recently
concluded, for instance, that there is little chance of a new
entrant seriously challenging TWA for business at St. Louis. Yet,
the GAOs c o nclusion was based not on a physical lack of capacity,
but the assumption that St Louis probably could not economically
support full-size hubs by two airlines. Competition can exist,
however, without the existenceof a second hubbing airline In
addition, a m ple physical capacity for new entrants does exist. It
has been estimated a new airline in St. Louis could probably gain
enough gates to begin limited service in 60 days -and an entirely
new terminal, with temporary gates, could be ready in about six
month s.
Thus, capacity exists at St. Louis. Nevertheless, there may be
problems elsewhere. Airports with more limited physical space, for
instance, may have more limited options And with the growth of air
traffic, capacity doubtless will become more of a proble m HOW TO
INCREASE COMPETITION Airline competition in the U.S. today is very
healthy. It could be even healthier. Policy makers thus should
continue to search for ways to increase competition, and to promote
economic efficiency in the industry by improving choice to the
consumer.
This requires no new regulation. It has been proposed by some
analysts that the federal government control prices charged by
airlines at certain hub airports, or restrict airline marketing
practices. Such controls, however would ca use widespread
misallocation of airline resources. The victim would be the
American air traveller Instead of flirting with regulation, what
policy makers could do to foster competition is 1) Allow greater
freedom for non-U.S. airlines to compete in the U. S Under what are
called cabotage laws, only American carriers are allowed to carry
passengers travelling between UiS. cities. As a result, many
non-U.S carriers who would be able to serve U.S. markets are
prohibited by law from offering their services. Man y of these
carriers already serve U.S. routes 16 Federal Aviation
Administration, AipH Capacity Enhancement Plan (1988 p. 1-12 17
Department of Transportation, A Contpatison of Air Fares and
Services Before and Afrer Tmns World Airlines Acquired OzarJcAirl i
nes (January 1989 p. 34 9 British Airways, for example, has a
flight from London to Detroit via New York. However, because of
cabotage restrictions, it can only take on passengers in London; it
cannot carry passengers travelling only between New York and D
etroit Thus, it must fly with many empty seats from New York to
Detroit even though it could increase the choices available to a
New Yorker wishing to fly to Detroit passengers on the second leg
of international flights or even to introduce flights comple t ely
within the U.S. This process could begin by negotiating with other
governments for them to relax restrictions on U.S. carriers
operating in those countries. Such an initiative could gain the su
port of many U.S. airlines operating abroad, as well as f o reign
carriers: But given the possible benefits for U.S. consumers, even
unilateral action: opening up U.S. routes to non-U.S. carriers
should not be ruled out Congress should relax these restrictions,
to allow foreign carriers to carry 2) Improve the all o cation of
capacity at airports To increase the ability of firms to begin new
operations at airports, policy makers should act to improve the
allocation.of airport capacity. At the four airports at which
landing slots are controlled, for example, the Feder a l Aviation
Administration should consider allocating at least some slots
through direct auctions, at which both new and existing entrants
would have equal access. At all other airports where congestion is
a problem, landing fees should be set according to demand so that
all aircraft pay the full economic value of the landing rights they
use.Thus, for instance, fees could be raised during the most
congested times to encourage users who can to land or take off when
the airport is less congested. In this way, airports could make the
fullest use of valuable capacity.
Airports also should review the way in which gates and terminal
capacity are 1eased.The long-term leases now generally used can
hinder entry by new competitors. When most of these leases were
signe d this was less of a problem since competition was restricted
by the federal government. Today, they can be more troublesome.
Thus, as current leases expire, local airport authorities should
consider replacing them with leases which can better foster comp
etition 3) Expand airport capacity.
In addition to improving the allocation of existing physical
capacity, the expansion of airports in many cities likely will be
necessary to reduce congestion and preserve competition. The
trouble is that airport capacity is increasing at a snails pace. No
new U.S. airport has been built, since Dallas Ft. Worth
International in 1974 18 Liberalization of cabotage laws has
recently been endorsed by the.heads of both American Airlines and
British Airways. See, Let the Market p lace Prevail, speech by
Robert Crandall, Chairman and CEO of American Airlines, at the
American Enterprise Institute, March 30,1989; and Airlines:
Globalization and Post-1992 Europe, speech by Sir Colin Marshall,
Chief Executive, British Airways, at the N o rthwestern University
Transportation Center, April 27,1989 10 While much of the problem
stems from local noise and environmental concerns, for which there
is no easy answer, there are some steps which can be taken. For
instance, expansion at many airports is constrained by
majority-in-interest clauses in many leases between airports and
airlines.
These clauses typically give carriers controlling a majority of
existing gates the ability to limit the use of fees to finance
expansion. Airport authorities shou ld re-examine these clauses
when they expire Private sector financing also should be used to
expand airport capacity.
Every major U.S. airport is now government owned, typically by a
local airport authority. But there is no need to confine airport
constru ction and ownership to government bodies. Private capital
can and should be used to fund new airport projects. Private
management or ownership of airports also would spur improvements
through private-sector incentives for efficiency While there are no
maj o r private airports in the U.S the major British airports,
including Londons Heathrow and Gatwick, have been privately owned
since 1987, and could serve as a model for the U.S.19 CONCLUSION
Despite mergers, the U.S. airline industry today is less concentra
ted than when the industry was regulated. Measured by route,
concentration has decreased substantially: today less than 20
percent of travellers fly on carriers with 70 percent or more of
the market, compared with almost half in 1977.
With the development of the hub and spoke routing system, the
share of flights handled by particular airlines at certain large
airports has increased.
But even at hub airports route-by-route concentration still is
less than before deregulation. Moreover, while average fares at hub
airports appear to by higher than that elsewhere, passengers at
these airports receive a better product than other flyers. P a
ssengers at hub airports in fact may be the greatest beneficiaries,
rather than the victims, of airline deregulation Expanding
Deregulations Benefits. Nevertheless, U.S. policy makers should
take steps to increase competition even more, and protect it fro m
erosion from a growing airport capacity problem.They should remove
barriers to entry by non-U.S. carriers, explore means to allocate
existing airport landing slots and gate capacity better than is now
done, and to expand capacity, possibly with privately owned
airports A decade after its enactment, the Airline Deregulation Act
of 1978 continues to be a boon to travellers, providing lower
prices and much wider access to the air travel system than would
otherwise have been possible.
Announcements of the dea th of competition in this industry are,
as Mark Twain might have said, greatly exaggerated. Policy makers,
therefore, must 19 See, James Gattuso, Privatization of Britains
Airports: A Model for the U.S Heritage Foundation International
Briefing No. 17, Ja nuary 23,19
89. See also, Robert W. Pqole, Jr Airport Privatization, Reason
Foundation Working Paper (undated 11 ignore ill-advised proposals
to limit the market freedoms that have provided enormous benefits
to consumers in the past decade. Instead, they s hould be
introducing even more market-oriented reforms to enhance and
protect competition, and thus extend further the benefits of
deregulation to travelling Americans.
James L. Gattuso McKenna Senior Policy Analyst in Regulatory
Affairs 12