Hideki Fukui

My comments on the proposed rules for New York area airports are confined to the function of secondary slot market. The U.S. slot buy/sell system has received much attention, and has caused debate on the question of whether it has facilitated competitive entry and effective use of slots at the four HDR airports (National, Kennedy, LaGuardia, and O'Hare). Although there have been not a few scholars and stakeholders (including the FAA) who acknowledge, "the best way to maximize competition is with the development of a robust secondary market" (73 FR 20856, 73 FR 29634-5), the empirical effects of secondary slot markets have not been investigated systematically. Attached is a paper on the secondary slot trading in the United States. This paper examines whether slot markets have resulted in new entry and service expansion by other carriers, especially rival carriers. Slot transfer data from four HDR airports between 1994 and 1999 were examined using regression analysis. Results of the analysis were mixed: although at Kennedy and O'Hare, rival carriers have been suffered from less desirable opportunities for slot lease than related carriers (i.e., carriers that were related to the lessor of the slots), this has not been the case at National and LaGuardia. These results suggest that the necessity and appropriateness of pro-competitive interventions depends on market conditions and circumstances unique to each airport, and that subsequent interventions should reflect those conditions and circumstances.