Testimony of James C. Miller III: Department of Transportation: Load Factor Standards

by James C. Miller on December 1, 1975
by James C. Miller

In this testimony I shall present the theoretical basis for load factor standards and shall make some assessment of their optimal level and structure … In the first section I outline the non-price competing model of the airlines to which several witnesses have testified in previous proceedings, and to which the Board apparently adheres… In subsequent sections I discuss the questions of a “market defect” which allegedly renders the load factor standard methodology imperative… I also present a brief analysis of the impact that a sudden increase in the load factor standard would have on total capacity, industry profits, total employment and the environment …

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