‘Rush to Reauthorize’, or should we bear down and ‘Get it Right This Time’?

The two houses of our national Congress have reportedly hashed out some details that may enable them to quickly reauthorize FAA. Is this good, or is this not so good? Should we ‘Rush to Reauthorize’, or should we bear down and ‘Get it Right This Time’?

I am for the latter, for three reasons. First, we are stuck in a rut (aviation over-expansion at all costs, with no accountability) that will not change, so long as we apply bandaids onto dirty wounds. Second, when we rushed to reauthorize the last time, it gave us horrible new laws like expanded CatEx; simply, rushed reauthorizations NEVER turn out well. And, third, the key lobbyist for the airlines (A4A) announced today, they ‘applaud’ this Congressional progress … which, frankly, coming from A4A, is like the smell near a run-over skunk; i.e., if A4A is for it, then whatever ‘progress’ Congress has made is almost certainly filled with industry privileges and community damages.

Some activists will be excited to see a glimpse of ‘progress’, too. But, be careful to not feel so beaten down that ANYTHING even slightly positive becomes something to thrill over. It is much like how people dying of hypothermia feel oddly warm just before their end. Stay focused; stay strong; know what industry and FAA are aiming to pull off; and, demand real reforms.

Reclaiming FAA for ‘WE THE PEOPLE’

Here is a PDF with a short analysis of the current situation, by aiREFORM:

Click on the image below for a scrollable view; the PDF file may be downloaded.

It is worth repeating…

…We can have a federal agency that serves WE THE PEOPLE, not just industry. We can benefit from aviation, while also ensuring aviation does not diminish our lives. And, this industry is strong enough to prosper without playing FAA and too many elected officials like puppets. But, nothing can happen, nothing will happen, until Congress steps up to the plate and reclaims FAA.

Demand real reforms at FAA. If this agency is too arrogant and too power-obsessed to heel, take away their power. Give that power back to the people, where it belongs.

Now is the time, Congress; you need to step up and serve the People, not the corporations.

‘We The People’ refuse to continue to be FAA’s Collateral Damage

The previous aiREFORM Post discussed two recent industry letters, sent to key U.S. Senators. The logo-saturated letters were sent by dozens of aviation industry coalition members. They pushed for a quick passage of FAA’s Reauthorization bill, and they also pushed Senators to ignore the many noise and pollution impact-related amendment proposals. The centerpiece of the aiREFORM Post was a ‘possible’ letter by the same coalition, suggesting what they would have written if they were temporarily honest, somewhat apologetic, and freed from their aviation greed. Check it out here.

At last week’s Sky Justice National Network teleconference, an activist from the New York City area made a great suggestion: we need to band together and present key Senators with OUR LETTER – a letter from all of us, pressing for no reauthorization passage until needed FAA reforms are added. Well, after some discussion by a handful of activists across the nation, the letter is finished. The plan is to gather as many signatories as possible – activist groups, individuals, even municipalities and local officials – and then send the letter to Majority Leader Mitch McConnell and Minority Leader Chuck Schumer.

What’s In The Letter?

The letter is fairly short. It presents the NextGen impacts in the context of failures by both FAA and our elected officials. The letter lays out key facts about disinformation in the coalition letters, as well as FAA’s NextGen history. The letter directly requests that the U.S. Senate do their job by debating the NextGen impacts and compelling FAA to repair the damages they have done. Here are two excerpts from the letter:

“Congress authorized FAA’s NextGen program in 2003. Sadly, the NextGen implementation has proven to be a full-frontal attack on citizens and communities, solely to benefit airline profit-margins. Routes have been concentrated and lowered, forcing citizens to lose sleep and forget peace under nearly nonstop noise assaults. The noise diminishes mental health and civility, while the air pollutants destroy our cardiovascular health, especially for children and the elderly. This is oppressive and unjust.”
“FAA is using NextGen as a hammer to disempower people. Local communities need Congress to restore meaningful local control, so that airlines and airport authorities can no longer metastasize their hubs into airports that are ‘Too Big to Fly’, airports that are brutalizing the people below.”

When Will The Letter Be Published?

The actual letter will be fully publicized after it is mailed, which is planned to happen before the end of August. For now, it is important that we get the largest possible number of signatories. Those wanting to sign or learn more about the letter can contact Jana Goldenberg or Elaine Miller at Plane Sense 4 LI, using this email address:

Ps4longisland@gmail.com

A Letter They Would Never Send

There is a recent big push by industry players to get the U.S. Senate to hurriedly pass reauthorization legislation without needed environmental impact amendments. This push is reflected in two ‘coalition letters’, sent on July 26th and August 15th (click on the dates to view aiRchived copies).

Both letters are disingenuous and packed with disinformation. This is incredibly insulting to the thousands across this nation whose homes and health are being destroyed by NextGen, Wake Recat, OAPM, and other FAA programs. We are seeing our Democracy hijacked by slick collaborated propaganda. And, we are seeing our elected officials corrupted by their obsession with reelection funding; they express concerns to the little people, but their actions and their histories expose their true bipartisan loyalty is to corporate power. These elected officials are owned.

What if this ‘coalition’, these groups, dipped their cups in a koolaid bowl filled with temporary truth serum? Might their letter look like this?

Click on the image below for a scrollable view; the PDF file may be downloaded.

Obviously, this is NOT the letter sent by A4A, NBAA, and other groups. No, this letter is what these groups should be writing, what they would now send to Senators McConnell and Schumer, if they cared to clean up their mess. But they don’t care about anything beyond industry profits to fatten their own annual benefits and bonuses.

Some are suggesting that we activists need to work together, send OUR LETTER to these Senators, and get them to serve OUR INTERESTS. Time to get to work.

The Impacts Are Not Due to ‘Customer Demand’, They Are Due to ‘Industry Greed’

SeaTac [KSEA] has been the fastest growing U.S. commercial airport in recent years, largely due to a 2012 decision by Delta to build a hub there. Here’s a JPEG showing KSEA annual operations and trends for each year, from 1991 through 2017:

(click on image to view the source table, which includes FAA ATADS data for 533 U.S. airports)

The data clearly reflects the operational history of KSEA. This is an airport where there was a former near-monoploy by Alaska Airlines, which is now expanding into a duopoly, with TWO airlines using it for hub operations. Notice the growth in flight numbers after 2012, following the Delta business decision. But notice also how operations at this airport declined by nearly a third, from 2000-2012. Think a bit about these sizable ups and downs: do they reflect strong swings in the local economy and population, or do they merely represent airline business decisions?

Now, ponder this concept, too: does ‘consumer demand’ drive airline business actions, or do airline business actions drive consumer demand? Is it fair to say that the entire goal of airline marketing is to stimulate more consumer demand, and ever-higher passenger mileage consumption?

Ask yourself this: regarding the demand for flying in the Seattle area (…and this is an attractive area, which has drawn many new residents from around the world), did ‘consumer demand’ DECLINE that much during the 2000-2012 timeframe, and has ‘consumer demand’ for flying by Seattle-area residents grown as massively as airport operations after 2012? In other words, is it inappropriate and misinformational for airlines, the Port of Seattle, and FAA to declare that ‘passenger demand’ is driving the current impactful hub growth, when the true driver is ‘corporate/airline demand’? Check out this screencap from page 8 of a recent FAA document (FAA’s CATEX… more about that later in this Post). If you spend any time looking at press releases by airlines and the Port of Seattle, you will find the same misrepresentations consistently repeated, all aimed at tricking readers into believing ‘consumer demand’ is driving this growth. Wouldn’t it be more accurate and truthful for the industry players to precisely attribute these hub operational changes to airline corporate decisions? Shouldn’t they instead brag about their marketing savvy and their ability to manipulate consumers, to create higher (or lower) rates of consumption? Should the industry players be more transparent, noting how when assets are reallocated from a declining hub to their latest new hub, we end up with economic decline and stagnation in the former?

The bottom-line is this: some airports grow excessively, while other airports seemingly whither away. Further evidence and examples can be viewed at the full 1991-2017 data collection for all tower airports (533 different airports, in this table). Do your own analysis for your own region, but be sure to take a closer look at the airports within the rustbelt centered on Ohio … from Detroit to Buffalo to Pittsburgh to Memphis to St. Louis and back to Detroit. Within this large region, at even the busiest airports, operational declines have averaged well over 50% from peak traffic years. And, many airport hubs have been outright abandoned.

What gives here?

Under the hub-and-spoke business model, commercial passenger operators maximize profits if they theoretically fly an infinite number of passengers into a hub airport at the same moment, have the passengers instantly sort out gate-to-gate into all the parked airplanes, and then depart all at the same instant. Of course, airports cannot be this efficient, and safety rules restrict aircraft flow rates, as both arrival and departure streams typically require around one minute spacing between consecutive flights. So, the next best thing for the airport and airlines (but certainly NOT for sleep-deprived and lung-impacted residents in the airport community!) is to tweak the rules in a way that maximizes ‘runway throughput’.

An example of this rule-tweaking is the use of diverging departure headings. At SeaTac, FAA took this to an extreme when they imposed routine 90-degree left turns immediately after takeoff, for Horizon Q400 turboprops heading south during North Flows. These departures impacted residents in Burien, the community at the northwest corner of KSEA. After concerns were raised (including legal engagement), FAA backed down early last year, removing an automated turn coordination from the tower-TRACON letter of agreement (also known as the ‘SEA-S46 LOA’). That should have been the end of this, right? Well, it was not. Instead, under new Regional Administrator David Suomi, FAA spent more than a year internally discussing and drafting papers to reinstate automated turns over Burien. The culmination of all that FAA effort (and, yes, we all paid for it!) is a 51-page CATEX document titled “Categorical Exclusion for Letter of Agreement Update to Automate a 250° Westerly Turn for Southbound Turboprops When Seattle – Tacoma International Airport is Operating in North-Flow Between the Hours of 6 am and 10 pm.” Read that title to yourself again, slowly and carefully, and try to make sense of it. All of this is just to formalize a written agreement between the tower and the radar controllers, so that the turns are automated, instead of coordinated verbally (push a button down, state a few words, and get concurrence … typically takes 2-3 seconds total) on a case-by-case basis. And, the automation discards the safety element of a diligent analysis of the traffic picture for each coordination event. Anyway, here is a copy of FAA’s PDF:

Click on the image below for a scrollable view; the PDF file may be downloaded.

Like its title, this document is a doozy. Spend a little time studying it and you will see the extremes FAA goes to so as to enable excessive airport expansion. Page after page, lacking in substance, heavy on repetitive ‘safety’ and ‘efficiency’ soundbites, none of which are substantiated. If a particular detail or two really grab you, and you have an insight or a question, please email the aiREFORM administrator so we can share that on (odds are high, if you read something as puzzling or shocking, others will read it the same way, too). And, by the way, don’t waste your time trying to search this FAA PDF, because FAA scanned it to be unsearchable. I.e., although this captured agency claims to be engaging the community on matters such as early turns over Burien, in truth they are knowingly reducing the value of tools (such as this 51-page CATEX document) that concerned citizens need to carefully study). This trend, away from searchable PDFs, has been observed in FAA’s FOIA responses; whereas in the past nearly all PDF FOIA response documents were searchable, in time nearly all have become non-searchable.

The Dark Side of So-Called ‘Collaboration’

When two parties conspire in a way that adversely impacts a third party, we have collusion. In an age of propaganda, when collusion happens between aviation parties such as FAA, airport authorities, and airlines, they just call it ‘collaboration’. The true and unspoken purpose of their so-called ‘collaboration’ is to achieve a consistency in their soundbites. The early turns over Burien are an example of this ‘collaboration’. Another example is how these same players routinely claim the excessive growth at SeaTac is to meet customer demand. The short answer to that claim is, well, ‘Bullshit!’. Frankly, ‘demand’ is just a lame and misrepresentative excuse; the real cause of extreme over-expansion at airports is greed by the aviation players. And let’s be clear: it is not just the airlines, but also the airport authorities and the FAA. There is plenty of collusion to go around.

Here’s some data that proves the above point. It offers data from three Delta hub airports that have been scaled down, and shines a light on the downsizing of aviation in Middle America:

Click on the image below for a scrollable view; the PDF file may be downloaded.

Conclusion:

This data reflects the harsh reality that today, in the U.S., FAA serves the airlines with a propaganda line, trying to sucker taxpayers into believing passenger demand creates impact problems at places like Seattle, Boston, Long Island, Maryland, and Charlotte. This is blatantly false, and most people at FAA know this. Hub concentration is NOT driven by consumer demand; no, airline greed is driving hub concentration, at great cost to local communities.

Congress needs to demand FAA serve all of us, not just the airlines and airport authorities. FAA is out of control and needs to be reigned in, and must not be allowed to continue operating as the captured regulator it has become.

The Congressional Process to Reauthorize FAA: Is it Just a Show, and Will it Go Far Enough?

Lots is happening in DC right now, though it is not clear if more than a few of the well-paid elected officials care enough to press through long-overdue reforms. If they fail to alter FAA’s cozy protectionism of this industry, the problems will persist: more noise (along with less sleep), more air pollutants (along with higher morbidity rates), and more rapid expansion of the greenhouse gas emissions by an industry that is the fastest growing contributor to global climate change. In time, the latter will mean loss of the polar ice (which appears to be accelerating), as indicated in this chart:

selected years added and labeled by aiREFORM (click on image to view source at NSIDC)

Note how Arctic sea ice has steadily declined in the past three decades. Losing polar ice is not a trivial matter; it will result in much higher sea levels, higher atmospheric energy and water vapor levels (stronger winds and bigger rain/snow events), and intensified weather extremes (the kind that fool trees into blooming early, only to freeze off the pollinized blossoms, killing that year’s fruit crop).

The Ball is in Your Court, Congress!

This week, the details are being deliberated in the U.S. House, and it looks like the Senate is also pressing to ‘hurry up’ and reauthorize FAA. Congress has important work to do for us in the U.S., but the consequences are global, going far beyond just us. From a climate justice perspective, the consequences are horribly unjust. Air travel and air cargo are industries that serve the wealthiest nations, but the poorest nations tend to be the most vulnerable. A nation like the U.S. can spend enormous funds elevating runways in Florida, but what is a small nation in equatorial regions to do, except simply move away? And, as the most vulnerable nations are destroyed, the global scarcity of land will only compel more instability, more refugees, and more wars.
We need to understand this now: there are real and ugly consequences for our obsessive hyper-consumption, and aviation is a big part of that bad habit. Every benefit bears a cost; the aviation-related benefits we enjoy today are at a growing cost to others on the planet … not just airport neighbors near over-developed U.S. hubs, but also communities at or near sea-level, across the globe.

Some Resources

Here are a few current documents and articles for readers to ponder:

  • HR.4, FAA Re-Authorization draft, Section-by-Section Summary – offers summaries of the many proposals, before most were either withdrawn or voted out by committee. One wonders: is there a better process for compelling a captured agency to serve THE PEOPLE, not just their industry? Is this current process rigged to empower lobbyists and opportunistic politicians? (27p, click here for archived copy)
  • HR.4, Draft Rule – take a look at the rules set up to ‘manage’ the amendment proposals and ensure the final draft serves industry. (click here for archived copy; click here for source)
  • UPDATE: The Dirtiest of Washington Politics? — ATC Privatization By Deception? – it was suspicious when Shuster suddenly announced abandonment of ATC privatization and his decision to not run again. Now it is back on the plate again, which begs the question: did Shuster et al decide to quit wasting effort deliberating and instead just impose their industry-serving plans? (click here for archived copy; click here for source)
  • Climate Change Could Increase ‘Whiplash’ Between Wet and Dry Years in California, Leading to More Disasters (click here to view source, a 4/24/2018 article at EcoWatch)

A Victory for the People: Shuster is Scrapping A4A’s ATC Privatization Scheme

Yesterday, Congressman Bill Shuster, chairman of the U.S. House Transportation and Infrastructure Committee, announced he is abandoning his multi-year push (going back to at least 2015) aimed at privatizing the U.S. ATC system. The idea was sold as a way to remove roughly 35,000 employees from federal service, but many saw that in fact, the idea was just a way to give more leverage to the airlines and other corporate interests.

This is a big victory for all of us who want FAA to stop being a captured agency, a faux-regulator that fails to serve people while serving only aviation commerce.

Below is an archived compilation of various news articles with the announcement. The actual Press Release has not yet been posted at Congressman Shuster’s website.

Click on the image below for a scrollable view; the PDF file may be downloaded.


See also this earlier aiReform content:

KSEA: Beacon Hill’s Fight for Health & Quality of Life

Archived copy of a good article, shared at Facebook, with some footnoted analysis by aiReform. This may help define what we need from our elected officials, to reclaim long-needed local control, so our airports are in balance with our local communities.

Click on the image below for a scrollable view; the PDF file may be downloaded.

Is Trump ‘Reloading the Swamp’?

It is good to see Administrator Huerta move along, though it would have been much nicer to see the President fire him a year ago.

Now, as to who will be heading FAA(?)… …well, it looks like the AvGov Complex powers-that-be are not trying to change the current game plan. Here is a clip from a recent article, with a short bio of acting Administrator Dan Elwell:

“Elwell was FAA assistant administrator for policy, planning and environment from 2006 to 2008. He was Aerospace Industries Association (AIA) VP-civil aviation from 2008 to 2013 and Airlines for America (A4A) SVP-safety, security and operations from 2013 to 2015.”

For airlines and lobbyists, Elwell has all the right plumage; his record suggests he is a revolving door swamp monster, and an industry loyalist. Not likely to be focused on making FAA accountable to the thousands whose homes and health are being destroyed by NextGen.

Click here to view source article at ATWonline.com, or here to view an archived copy, with some analysis footnoted by aiREFORM.


See also:
  • 5/15/2014 – (the Federal Register revision to ATSAP that stops citizens from using FOIA to learn about aviation safety failures … signed by Mr. Huerta.)
  • 8/19/2013 – (detailed letter opposing FAA’s proposal to hide ATSAP data from the General Public (7-pages plus a 4-page attachment)
  • 4/3/2008 – (full-day congressional hearing about FAA whistleblowers, and FAA management that not only works to stop safety actions, but also works to punish the whistleblowers.)
  • 2/15/2015 – (‘What’s all the Noise about Airport Noise?’, a 7-page slideshow presentation by Mr. Burleson)
  • 1/11/2018 – (FAA’s online bio, Dan Elwell)
  • 1/11/2018 – (FAA’s online bio, Carl Burleson)

Reflections on FAA as a Faux-Regulator Serving Industry, Not the Public

At year end, we often take time to reflect. This year, let’s reflect on precisely what it means, when a U.S. federal agency is ‘captured’ by industry, so as to serve the industry instead of the larger Public. This Post will look more closely at FAA later, but for now, to help see how serious the regulatory capture problem is, let’s look at another failing U.S. federal agency: the Food and Drug Administration (FDA).

FDA, just like FAA, has many responsibilities. For example, they are charged by Congress to regulate pharmaceutical companies. Additionally, Congress has funded FDA with the intent that they will be effective, working to protect public health from dangerous new drugs. One of those drugs, released two decades ago, is the addictive opioid, OxyContin. An online search reveals a jaw-dropping epidemic of addictions – and fatalities; indeed, odds are very high that everyone reading this Post knows at least one person who has been impacted by opioid addiction. Also, and not insignificantly, a deeper online research shows the fact that representatives of both major political parties have aided and abetted this epidemic, while also obstructing reforms and failing to pass overdue corrective legislation.

So, how well has FDA done their job? If agency leaders actually view their job as ‘serving customers’ such as the pharmaceutical industry, well, they’ve done a fantastic job. But, if any of us objectively assesses FDA performance from the perspective of serving the larger Public and actually protecting health, well, FDA is a total failure.

Patrick Radden Keefe recently wrote an article in The New Yorker, The Family That Built an Empire of Pain (click here to view the source article online; click here to view an archived and annotated version of the same article). Below is an excerpt that summarizes how Oxycontin legal actions are evolving; this particular excerpt primarily quotes Mike Moore, a former Mississippi State Attorney General:

… Ten states have filed suits, and private attorneys are working in partnership with dozens of cities and counties to bring others. Many public officials are furious at the makers of powerful painkillers. Prescriptions are expensive, and taxpayers often foot the bill, through programs like Medicaid. Then, as the ruinous consequences of opioid addiction take hold, the public must pay again—this time for emergency services, addiction treatment, and the like. Moore feels that the Sackler family, as the initial author and a prime beneficiary of the epidemic, should be publicly shamed. “I don’t call it Purdue. I call it the Sackler Company,” he said. “They are the main culprit. They duped the F.D.A., saying it lasted twelve hours. They lied about the addictive properties. And they did all this to grow the opioid market, to make it O.K. to jump in the water. Then some of these other companies, they saw that the water was warm, and they said, ‘O.K., we can jump in, too.’ ” There may be significant legal distinctions between a tobacco company and an opioid producer, but to Moore the ethical parallel is unmistakable: “They’re both profiting by killing people.” …

FAA as Faux-Regulator

So, how does studying this opioid epidemic, and Mr. Keefe’s article, help us to better understand FAA’s failure? Simply by showing a near-perfect analogy for the many signs of regulatory capture. Here is a short list of discernible failure patterns, the ‘symptoms’ of regulatory capture:

  • Industry becomes the primary customer. For FAA, nothing shows this failure as starkly as the whistleblower hearings held on 4/3/2008.
  • Money trumps health and environment; the faux-regulator enables industry to advance corporate profits, by assisting in expansions and system redesigns that invariably bear an enormous cost on environment, health, and local (usually residential) quality of life.
  • Consequences of failures are eventually lethal. FDA failures fuel a rise in addictions and overdoses; FAA failures sustain sleep-deprivation that cause most of today’s multi-fatal commercial accidents, such as Colgan-Buffalo, Comair-Lexington, and UPS-Birmingham.
  • Consequences of FAA failures also extend to the corruption of a culture that we are repeatedly and fraudulently told is ‘all about safety’, when the full record shows it is anything but. For example, the agency’s use of ATSAP to hide ATC safety data from the general public; the agency’s inability to see the enormous impacts imposed by NextGen changes and hub expansions; the agency’s wanton denial of obvious performance failures (such as the controller error at Santa Monica, or the rash of near-collisions at San Francisco); and of course the war against whistleblowers (those rare few inside FAA, who choose to speak up to correct the cultural failures, only to suffer retaliation).
  • Key personnel within the faux-regulator end up serving only industry, often via a revolving door. In the Oxycontin story, the key FDA regulator was earning his federal pay and building his eventual federal pension when he signed off on the fraudulent Oxycontin marketing plan; just two years later, he worked for Purdue! The same pattern happens repeatedly at FAA, all the way to the FAA Administrator position (e.g., when Marion Blakey retired, she immediately became head of a major aviation lobby firm).
  • The legal system becomes a third-party tool, used to maximize corporate advantage, an additional ‘enabler’. Both industry players and faux-regulator officials posture around threats of legal actions by industry, using this pattern as a hammer to force changes that accommodate industry, at the expense of the larger Public.
  • To protect industry greed, and to ensure the legal system will enable these failures to persist, a heavy budget is allocated to lawyers who self-enrich with what is effectively a ‘license to lie and deceive’. Not just industry-paid lawyers, but also agency lawyers, paid for by the people.
  • If and when manipulation of the legal system appears likely to fail, especially if the case is headed for trial, a ‘settlement’ suddenly appears. ALWAYS, this last-ditch legal maneuver protects both industry and faux-regulator from any accountability, by sealing records that were about to become a part of the public record, records that would among other things reveal how badly agency officials have failed. And, routinely, the so-called ‘settlement’ will include language that shuts out third parties (such as actual communities, or victim families) from future legal action.

Can This be Fixed?

Yes, it’s all fixable. And really not that difficult to do, so long as people demand performance from both agency and elected officials. The first step, though, is obvious: we have to accept that FAA, FDA and other agencies are broken, serving as faux-regulators, enabling industry players to evolve in ways that are truly destroying homes and people. Perhaps with a new year, we can get to work?

ATC Is Not the Real Cause of Airline Delays…

…and the airlines have long had all the tools they need to solve the problems caused by their own corporate greed and mismanagement. If NextGen impacts are out of control where you live, you need to read the article below.

As a follow-up to yesterday’s Post, here is an outstanding article written by Michael Baiada, a retired United 747 pilot, who sees past the NextGen promotional frauds. Even better, Mr. Baiada gets into the details of how easily the U.S. air travel system could be made more efficient and less impactful, while also improving the flying experience for us consumers. Turns out, the root of the problem today is too many people abdicating their duties: airlines refusing to run their business, regulators who enable this management failure while also serving as cover, lobbyists too focused on perpetuating the lobbying revenue stream, and so forth.

The article is a bit technical but very well written, and Mr. Baiada does an outstanding job explaining system details that FAA/industry work so hard to make muddy and complex. I heartily recommend sitting down and carefully studying this article; you will learn a lot, to help fight for rational airports, serving the local communities ahead of the airlines.

Click on the image below for a scrollable view; the PDF file may be downloaded.

A copy of the article by Michael Boyd, as referenced in Baiada’s article, is archived here.