Aviation Policy News: Legacy Airlines Prevail on Slot Hogging, Next Steps for Drone Policy and More

Aviation Policy Newsletter

Aviation Policy News: Legacy Airlines Prevail on Slot Hogging, Next Steps for Drone Policy and More

Plus: Competition for trusted travelers, searching for solutions for very high-altitude airspace, and more.

In this issue:

Legacy Airlines Prevail on Slot Hogging

Earlier this month, the European Commission gave in to major airline demands that they be allowed to continue to hold onto slots that they will not use at major airports during the winter season. The means to this end is that the normal requirement to use a slot at least 80% of the time—or lose it—remains suspended (as it was for the summer season) until March 27, 2021. This change denies the use of many of these slots to low-cost carriers that are eager to enter new markets and bring passengers back to flying.

Following on the European Commission’s heels, the Federal Aviation Administration published a notice in the Federal Register (Sept. 15) proposing to do likewise for the three U.S. airports defined by International Air Transport Association (IATA) rules as Level 3—congested enough that some kind of allocation of runway capacity is warranted: Kennedy (JFK), LaGuardia (LGA), and Reagan National (DCA). Separately, FAA has also proposed to continue through the end of the calendar year its reviews of schedules at four somewhat-less-congested airports: Chicago O’Hare (ORD), Los Angeles International (LAX),  Newark Liberty (EWR), and San Francisco International (SFO). In doing these reviews, FAA will treat legacy carrier flights not operated (due to the pandemic) as if they had been operated.

While legacy airline organization Airlines for America (A4A) had of course lobbied hard for these protections, the opposition is stronger than what we’ve seen in Europe. While Airports Council International-Europe ended up siding with the legacy carriers there, ACI-North America has correctly argued that ignoring the 80% use-it-or-lose-it rule “would encourage underutilization of valuable public resources,” and would harm airports financially—both indubitably true. Also speaking up for competition is the National Air Carrier Association, representing smaller airlines and the ultra-low-cost carriers (ULCCs). The proposed FAA policy would enable legacy carriers to “control capacity and raise fares at a critical time when the traveling public needs lower fares”—and, I add, when all airlines need to encourage the traveling public to resume flying.

My article last month criticizing the likely outcome in Europe (now realized) brought a lengthy email from a senior executive at a major European airport that does not have a dominant legacy carrier. With that person’s permission, I am copying large portions of that message, which explains why ACI-Europe caved in.

“The principal players [in slot allocation battles] are large hub airports with a traditional legacy carrier as the dominant player. . . . These airports have swallowed the IATA line about needing to protect schedules— hook, line, and sinker. They are not interested in competition, as they do not see it as a source of growth, as most [non-hub and] private-sector airports do. This is also reflected in the conditions, which focus entirely on ‘notice’ for the purpose of scheduling resources (i.e., managing operating costs). We know some flying will be possible through ad-hoc slots; however, route investment can take one to two seasons to pay off, and most airlines will be reluctant to invest in opening new routes without the certainty they can continue the following season.

“Attempts for a more-targeted waiver were also rebuffed within ACI even before they reached IATA; i.e., why not 60/40 [instead of 80/20]? Or a market-by-market or long/short/domestic split? The hubs basically said: We are dependent on connecting traffic, so everything needs to be excluded—completely ignoring the impact of competition at every other European airport.

“We are landed in the bizarre situation that most airlines are reducing staffing and fleets significantly (many by 20%+), yet they can keep 100% of slots, and the system will prevent any market response to this until after the winter 2021 season (assuming no further waivers), as this would be the earliest point slots could come back to the pool. In the meantime, passengers will get a raw deal, as airlines can manage yield through capacity allocation.”

As this email illustrates, slot allocation in Europe (which is far more widespread there than in the USA) is a device to keep major carriers in the driver’s seat, preventing the emergence of more-vibrant competition that would be better for passengers as well as being beneficial for the majority of airports (those not dominated by a legacy carrier). As I’ve written many times before, the slot system attempts to deal with airport congestion via a crude kind of central planning. The market-based solution—dynamic runway pricing—would lead to far more airline competition. That would be a lot better for passengers than the status quo.

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A New Flap Over TSA Registered Traveler Alternatives

The Transportation Security Administration’s (TSA’s) PreCheck program reached a new high of 10 million members in February 2020, the agency announced in March before air travel began shutting down. While impressive, that number is woefully short of the agency’s long-time goal of 25 million by 2019. Much larger numbers would be a boon for airports and air travelers, as well as for TSA itself, since PreCheck members take far less time to pass through security checkpoints, consume less TSA resources, and take up less airport space.

That’s why ever since 2013 various proponents of registered traveler programs, both within TSA itself and in business organizations like the U.S. Chamber and the U.S. Travel Association, have called for enabling multiple companies to recruit and process the applications of potential PreCheck members. Several times TSA got as far as holding bidders’ conferences and at least once actually testing vetting algorithms submitted by big-data companies that were interested in providing such services. But most TSA administrators were leery of such efforts, and the lone TSA contractor for recruiting PreCheck members—Morpho Trust (recently renamed IDEMIA)—lobbied hard to retain its monopoly.

In response to the lack of progress on this subject, a bill sponsored by Sen. Dan Sullivan (R, AK) was introduced earlier this year — S. 3730, the Registered Traveler Act of 2020. If enacted, it would allow private sector companies to apply to TSA to be designated as Registered Traveler Service Providers (RTSP), which would have to meet various TSA requirements in order to be so designated. Each RTSP would recruit and vet members using TSA-approved procedures, and—at the airport when a member arrives at security screening—would verify the traveler’s identity and his/her security status, and then direct the traveler to the actual screening lane (as PreCheck currently does). TSA would have to define the rules each RTSP would follow, and it would do periodic audits of each company.

The proposal has the support of the Chamber and U.S. Travel Association, which supported previous efforts to expand PreCheck and other registered traveler programs. But it is also encountering a lot of opposition. TSA Administrator David Pekoske opposed the bill, but, earlier this month, a senior official of parent agency DHS overruled that opposition. A Bloomberg Government article on this decision made the cheap-shot comment that “the 9/11 terrorist attacks were partly blamed on loose security by private companies.” That is factually the case, but the flaw was not in the companies being private but in the complete lack of regulatory oversight or performance standards and also that this was an unfunded mandate imposed on competing airlines, which sought to minimize the cost of paying for this mandate. European airports before 9/11 used, and continue today to use, registered aviation security companies for screening, under tough national government performance requirements.

Another argument is that because the identity-verifying company CLEAR has lobbied for the bill, its passage would create a monopoly. Nothing in the bill limits the service to a single company, and the many years of effort (and previous legislative proposals) have all been about getting multiple companies into the business, so as to significantly expand trusted traveler programs, in a safe and secure manner.

And of course, the union that represents TSA screeners—the American Federation of Government Employees—is opposing the legislation, just as they typically try to defeat efforts of airport management (such as in Orlando and Sacramento in recent years) to opt-out of TSA screening in favor of using TSA-certified screening companies, as part of TSA’s Screening Partnership Program.

I think the bill, S. 3730, may need some tweaks to provide greater accountability (such as annual audits, rather than once every five years). But the basic concept is sound.

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What’s Next for U.S. Drone Policy?
By Marc Scribner

In October, the FAA’s Unmanned Aircraft System (UAS) Integration Pilot Program (IPP) will come to a close. Despite the looming termination of the IPP, many integration issues remain unresolved. However, there are indications that IPP yielded enough information for FAA to begin making key policy changes necessary for UAS airspace integration and to enable future UAS services over the coming years.

The IPP was a three-year effort by FAA to investigate the safety and operational policy changes necessary to integrate UAS into the national airspace system. Key airspace integration issues examined during the IPP include nighttime operations, flights over people, flights beyond the operator’s visual line of sight, package delivery, data communications security, detect-and-avoid automation technologies, and remote identification.

These are all important, but most important is remote ID, which is viewed by FAA and other stakeholders as necessary to provide a foundation of safety and security before advanced UAS operations could be authorized as part of a conventional regulatory framework. Unfortunately, that regulation is still not complete, and the proposal received harsh criticism from some in the UAS industry as unworkable. The proposed remote ID rule was initially projected to be published in May 2019 but did not appear in the Federal Register until New Year’s Eve 2019. Based on the most recent data published by the Office of Management and Budget, the final remote ID rule will not be published until 2021 at the earliest.

Since the proposed remote ID rule was heavily criticized on a number of fronts by UAS developers and operators, this delay may not be the worst thing in the world. But if remote ID is indeed a prerequisite for full UAS airspace integration, it means that UAS operators will continue to need temporary exemptions for their advanced UAS flight operations. This regulatory environment makes it exceedingly difficult to commercialize any meaningful UAS service.

The good news is that FAA appears to be making progress on meeting another important milestone: UAS aircraft certification (i.e., spelling out how FAA will formally approve the design of UAS vehicles, as it does for commercial and general aviation aircraft). In August 2020, when the agency granted Amazon Prime Air’s 2019 drone delivery exemption petition through Fiscal Year 2022, it noted that “issuance of this exemption is predicated on Amazon’s continued participation in the FAA type certification process for the MK27 UAS.” Earlier this month, FAA published a notice spelling out the basics of its approach toward UAS type certification, which it says will allow many UAS to be type certified as a special class of aircraft.

FAA Administrator Steve Dickson said FAA envisions a streamlined type certification process for UAS in order to allow these technologies and services to be more rapidly brought to market. FAA’s posture suggests a soup-to-nuts type certification process may be pared down from years to months. This is very good news. A traditional multiyear FAA aircraft type certification process is ill-suited for the nascent stage of UAS development when design iteration is extremely rapid. However, Administrator Dickson also highlighted detect-and-avoid technologies as an unresolved issue that must be addressed prior to the broader proliferation of UAS.

So, what’s next for drone policy? The conclusion of FAA’s IPP and recent announcements suggest the agency may not be proceeding at as glacial a pace as some had feared during the last few years. That said, a recent letter to congressional overseers from the Government Accountability Office highlighted additional UAS airspace integration issues that may be beyond the scope of the FAA’s authority. These include property rights, privacy, liability, and even the extent to which the FAA may claim low-altitude airspace as its exclusive domain.

Congress could likely put to bed many of these issues by passing clearly worded legislation, but given the partisan rancor on Capitol Hill, and that the current FAA authorization has three years left to go before expiration, we may be waiting until at least the second half of this decade for key UAS airspace integration issues to finally be resolved.

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Searching for Solutions for Very High-Altitude Airspace

Last month’s issue briefly discussed the high-altitude communications balloons being operated by Loon, an Alphabet company, in high-altitude airspace over Kenya. But many other players are expected to be operating in this airspace in the coming decades—including long-endurance (weeks or months) high-altitude gliders, suborbital launchers, supersonic transports, other long-endurance balloon operations, and various military aircraft. In addition, these air vehicles will have to pass through conventional air traffic control-managed airspace on their way to and from the 60,000-ft. altitude now being defined by FAA as the beginning of Upper Class-E airspace. So will a growing volume of orbital space launch vehicles.

Currently, there is no air traffic control in this airspace, and FAA is not interested in extending its ATC operations to it (or to the below-400-foot airspace where small drones operate). But as David Hughes reported in the cover story of Air Traffic Technology International 2021, pp. 24-30, NASA and FAA have been working on a concept of operations (conops) for the upper airspace, now designated E Traffic Management (ETM). As Hughes describes it, the Version 1 conops envisions industry providing separation services under FAA regulatory supervision—a throwback (my view) to the origins of U.S. air traffic control by the fledgling airlines in 1929, via a nonprofit user cooperative called Aeronautical Radio, Inc. (ARINC).

Hughes quotes the ETM conops vision as follows:

“It is largely a community-based, cooperative traffic management system where the operators are responsible for the coordination, execution, and management of operations with rules of the road established by FAA. Operators share awareness of proximate operations and deconflict when necessary. ATC accesses cooperative and National Airspace Systems data to safely separate operations under their control.”

That is indeed visionary, but lots of specifics about who would do what (and how) remain to be worked out. FAA and NASA are launching research on how various tasks could be carried out, with input from participating stakeholders including supersonic bizjet company Aerion, Virgin Galactic’s SpaceshipCompany, AeroVironment, Loon, Aurora Flight Sciences (owned by Boeing), and aerospace heavyweights Leidos, Lockheed Martin, and Northrop Grumman.

As Hughes points out, at this point only Canada and the USA have defined 60,000 and above as a separate class of airspace. ICAO has not launched a project on this subject, but it is following the FAA/NASA effort. One key difference between super-low (below 400 ft.) and the ETM airspace is that the latter is inherently global. Loon’s balloons for Keyna are launched from Nevada and Puerto Rico and navigate their way to Kenya. SSTs will likely operate mostly internationally. And space launches and returns will pass through the ETM airspace of more than one country in most situations.

In June, Airbus and Boeing made a presentation to the ICAO Air Navigation Commission, calling for the need to harmonize all proposed approaches to ETM airspace on a global basis—and that it should be fully integrated with existing air traffic management. In their recent joint white paper, reports Hughes, “The two giant airspace managers believe a single integrated airspace management system is needed for global implementation that will embrace all airspace users.” That is a very different vision from what FAA and NASA are focused on.

Also different is the fact that some ANSPs (unlike FAA) are interested in providing traffic management in ETM airspace—and charging users for this service, as Kenya’s is already doing. If Airbus and Boeing are correct is saying that “Aviation is at the dawn of a third major era” following the first begun by the Wright Brothers and the second by the jet age, then all of air traffic control may be in for a major rethink.

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WestJet Distorts Nav Canada Fee Increase

Canadian carrier WestJet, on Sept. 1, announced an increase in the amount it charges its passengers, allegedly to cover the cost of air traffic control services provided by Canada’s nonprofit, stakeholder-governed ANSP. Nav Canada had announced a rate increase effective Sept. 1st. In its notice, WestJet pretended it was being considerate of passengers by estimating that although the increase will cost it from $6 to $9 per passenger, it would only increase its ATC surcharge by $4 to $7 per passenger.

What is wrong with this picture? To begin with, despite having been part of the coalition backing ATC reform in the 1990s, and supporting the selection of the nonprofit corporation funded by ICAO-compliant ATC fees and charges, Canada’s airlines have ever since Nav Canada’s beginning added an “ATC surcharge” to the price of their tickets. This is analogous to adding a fuel charge, or a flight attendant service charge to the ticket price. The only rationalization I can think of for why they did it (unlike any other airlines which routinely pay ATC fees all over the world) is that Canada used to have an airline ticket tax, but that was abolished with the advent of a user-fee-financed ANSP. (The United States is the only remaining country with a passenger ticket tax to fund aviation.)

In its early years, Nav Canada received regulatory approval to set up a Rate Stabilization Fund, setting aside each year a portion of its revenue. The purpose was to be able to avoid increasing its rates during times of recession when airlines would be hurting. That policy has been a big success. In 2006 and 2007, Nav Canada’s rates went down, and they have remained flat ever since; there was no increase due to the Great Recession of 2008 and beyond. But the current aviation recession is far more serious than that recession, and its impact is far beyond what the Rate Stabilization Fund could manage.

Not only did WestJet ignore all of this, but it engaged in a more serious distortion. Nav Canada’s airline rate increase is not being added to its current bills. The portion covered by the increase will be shown separately on the invoice and will be payable in equal installments over the next five years. So WestJet is pretending that it must cope with the increase now, and upping its phony surcharge to passengers, even though it is not having to pay the Nav Canada increase while its revenues are in the tank. Needless to say, most of its passengers have no way to know any of this.

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Feedback on ERAM Article

Last month’s lead story on the Department of Transportation Inspector General audit of updates to the ERAM system at FAA’s en-route centers led to comments from three knowledgeable, people, two of whom I’ve known for many years.

Dres Zellweger, one of the architects of what became known as NextGen, wrote to correct an error regarding the computer software that preceded ERAM. He noted that in the 1980s, when the HOST computers were acquired to replace obsolete IBM 9020s, HOST itself was not programmed in ADA, but that language was selected for the Initial Sector Suite (ISS) system. After the original ISS was canceled, the contractor that eventually developed the display system replacement and ERAM “decided to re-use much of the ADA code that had been developed for ISS.”

A former controller with automation experience wrote a lengthy missive first pointing out that the 15-year service life for the ERAM computers is not short; for computers, it is quite long—and I stand corrected. He went on to write that although prior to ERAM each center’s HOST automation system was heavily customized by each center, “ERAM eliminated local software changes and implemented a single national baseline of system software that cannot be modified locally and that is tested at the national level.” He also wrote that adding capabilities to ERAM for such new functions as time-based flow management (TBFM), Datacom, and Performance-Based Navigation (PBM) has inter-facility implications that must be addressed and tested, while the system continues controlling traffic using existing capabilities.

I’m glad to have those clarifications and corrections. But another long-time source, a former FAA engineer and program manager, wrote to say “ERAM and Enroute have been a cash cow for the same two contractors for over 30 years,” and that the agency is so dependent on their specific knowledge that this duopoly continues indefinitely. That is probably too controversial a subject for the Inspector General to look into, but it suggests there may well be higher costs and slower progress than if FAA had more capable (and better-paid) program managers riding herd on contractors who have developed a lock on important business.

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News Notes

Atlanta Airport’s Undisclosed Security Problems
The City of Atlanta’s auditor submitted a report on Hartsfield-Jackson International Airport’s security, including access to secure areas, video surveillance, and employee security badges. The report was submitted to the city council, but all 15 recommendations were redacted, in accordance with federal law, which means the media and the public have no idea of the extent of the problems. The Atlanta Journal-Constitution reported on Sept. 10 that the unredacted report would be submitted to the city council’s transportation committee to be discussed in an executive session.

Hong Kong ANSP Signs On with Aireon
The government’s Civil Aviation Department will begin using Aireon’s space-based ADS-B surveillance in the first quarter of 2021. The system will bring increased precision to some 400,000 arrivals and departures to Hong Kong, as well as overflights in the Hong Kong flight information region (FIR). It will also be using the new ADS-B data to coordinate with other ANSPs in the region for air traffic flow management.

Negative Outlook for European Airports
Standard & Poor’s downgraded the debt of four major European airports in July, including Amsterdam Schiphol and Zurich, and placed London Gatwick and Rome on credit watch. S&P estimated that capital spending by European airports will be cut by $11.8 billion over the next three years. Both Gatwick and Schiphol are contemplating significant job cuts, after posting first-half losses. And The Wall Street Journal reports major negative impacts due to a near-collapse in airport retail at major hubs including London Heathrow.

Growing Focus on GPS Alternatives
Aviation Daily (Sept. 4) reported that the attention devoted to GPS vulnerability by the controversy over the FCC’s approval of Ligado Networks’ use of spectrum close to that used by GPS has led to tangible action. Field tests of 11 backup technologies, required by the 2018 National Timing Resilience and Security Act, were completed in spring 2020 and are now being analyzed by U.S. DOT. Two of the 11 demonstrations were by companies making use of eLoran. DOT plans to make a series of recommendations based on its analysis of the field tests.

St. Louis Airport Lease Removed from November Ballot
The St. Louis NAACP and the Carpenters Union on September 3rd withdrew their charter amendment that would have required the city government to resume the process of selecting a qualified team for a long-term public-private partnership (P3) lease of St. Louis Lambert International Airport. The only explanation given was that “the rising number of COVID-19 cases and the current political climate require that we focus our time and attention on other critical decisions on the November 3rd ballot.”

DOE Funding Electric Airliner Research
The U.S. Department of Energy’s Advanced Research Projects Agency-Energy program has awarded $33 million in grants for 17 projects dealing with electric propulsion for airliners. Of the total, $18.5 million is for eight projects focused on high-performance energy storage and power systems, while the balance goes for nine projects to develop all-electric powertrains. More details are in “U.S. Energy Department Funds Electric-Airliner Research Projects,” Aviation Daily, Sept. 3, 2020.

Adani Now Majority Owner of Mumbai International Airport (MIAL)
Adani Enterprises last month bought out the Mumbai Airport’s former majority owner, GVK, acquiring a 50.5% stake. It also plans to purchase the 23.5% owned by Airports Company of South Africa and Bidvest. The acquisition also includes MIAL’s 74% stake in Navi Mumbai International Airport (NMIAL), the planned second airport for this metro area. MIAL’s revenue has been seriously impacted by the pandemic, leading GVK to welcome the acquisition by a financially strong investor.

U.S. Airports Slow to Acquire Federal Relief Funding
While U.S. airports continue to call for additional federal funding, the Eno Center for Transportation in August reported that data from usaspending.gov show that airports lagged far behind Amtrak, airlines, and transit agencies in actually acquiring (let alone spending) the CARES Act bailout funds. The report showed that only 9% of the airport funds had been disbursed, compared with 100% of the Amtrak funds and 71% of the airline funds. Among the few airports that stood out, the highest three were DFW (58%), PHL (46%), and MIA (45%)—all American Airlines hubs.

FAA Seeking Drone White Papers
On Aug. 21, the FAA released two requests for white papers from vendors interested in providing drone-related services. One is for companies that could help conduct tests of the impact on an operating jet engine of ingesting a small drone; the engine would be a turbofan of the size that powers a 737. The other notice seeks companies to take part in testing counter-drone systems to protect airports from drone incursions. The plan is to evaluate at least 10 such systems at the Atlantic City Airport (ACY), with possible testing at additional airports later on.

Montego Bay Airport Gets Health Accreditation
MBJ Airport, Jamaica’s largest airport and main tourist airport, is the first in the Caribbean to obtain the new Airport Health Accreditation. The measure has been promulgated by Airports Council International (ACI) as part of its pandemic recovery guidelines, consistent with ICAO’s Aviation Restart Task Force recommendations. MBJ Airport was modernized by and is operated by Grupo Aeroportuario del Pacifico (GAP) under a long-term public-private partnership (P3) concession. GAP is also the developer/operator of the San Juan International airport under a similar long-term concession. GAP’s Los Cabos Airport in Mexico was the first in Latin America to receive the Airport Health Accreditation.

Space Traffic Management by the Commerce Department
The National Academy of Public Administration (NAPA) last month released a report recommending that out of a number of possible organizational homes, the Department of Commerce’s Office of Space Commerce is best suited to handle civil space traffic management (STM). A number of industry organizations endorsed the NAPA recommendation. Its study was mandated by Congress in the FY 2020 omnibus spending bill. Commerce requested $15 million for the Office of Space Commerce in its FY 2021 budget proposal, with most of the funds going to STM.

UTM Systems Being Implemented in Estonia, Finland, and Norway
Aerospace company Frequentis is working to develop systems to manage UAS (drone) traffic in the airspace of three European countries. In Norway, it is working with the ANSP, Avinor, to implement its Flight Information Management System (FIMS) at 18 airport control towers. Frequentis has also partnered with Finnish drone specialist Robots Expert to develop UTM in Estonia and Finland. FIMS was demonstrated during a 2019 SESAR JU Gulf of Finland U-space research project.

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Quotable Quotes

“There are no new defense primes coming our way. We have to find models to blur the divides between military work and commercial work. Most of our opportunities are in commercial enterprise. Launch is a great example of us breaking down the barriers and learning to work in that space. . . . The Air Force and the Space Force have the audacity to try to create a launch market that could meet commercial launches and also national security ones. It’s been hugely successful. This is the beginning of what is going to be long-term competition in access to space.”
—William Roper (USAF Assistant Secretary), in Irene Klotz and Lee Hudson, “Incumbents ULA and SpaceX Retain Military Launch Business,” Aviation Week, August 17-30, 2020

“Imagine what might happen if all airlines were able to raise as much capital as their business model can support, rather than their national market can sustain. Imagine if airlines could consolidate as they see fit and create brands—OneWorld, SkyTeam, or Star, say—that actually mean what they say on the outside of the aircraft. Instead of national airlines that sometimes fly to other countries, we could have international airlines that could get rid of fig-leafs like alliances, could start to build true networks at airports that are keen to be as attractive as possible to an airline.”
—Andrew Charlton, “Being the Reform We Need to See,” Aviation International Reporter, September 2020

“Government support that has been given to airlines in some, but not all, countries has been crucial to keeping them afloat through extremely difficult times. But it cannot be a long-term, recurring prop. To better prepare themselves for an extended COVID-induced economic downturn, airlines must restructure, preferably outside of a bankruptcy court. And they must put a much higher priority on building strong cash reserves. Legacy and major airlines must also grasp that the pandemic has stripped them down to commodity level. The world’s ULCCs are now in a position to offer equal or better service than the ‘full-service’ carriers. The ULCCs’ ancillary revenue model means they continue to offer the same for-sale onboard snacks, beverages, and amenities they served before COVID struck. Many major carriers have suspended all onboard service. . . . Meanwhile, the more agile, innovative, and less union-controlled ULCCs are turning to digitalization and technology to push costs even lower while giving customers the instant information and automation they need more than ever. . . . All airlines are now in the new reality. Only those that adapt will survive.”
—Karen Walker, “Legacy Carriers Must Adapt to the New Reality,” Aviation Daily, Sept. 22, 2020

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