Air New England v. Civil Aeronautics Board

636 F.2d 825, 1981 U.S. App. LEXIS 20459
CourtCourt of Appeals for the First Circuit
DecidedFebruary 3, 1981
Docket80-1390
StatusPublished

This text of 636 F.2d 825 (Air New England v. Civil Aeronautics Board) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Air New England v. Civil Aeronautics Board, 636 F.2d 825, 1981 U.S. App. LEXIS 20459 (1st Cir. 1981).

Opinion

BOWNES, Circuit Judge.

Petitioner Air New England, Inc. seeks review of the decision of the Respondent Civil Aeronautics Board (CAB) that the Airline Deregulation Act of 1978 did not by operation of law open the existing subsidy rates of subsidized carriers. For the reasons stated below, we affirm the decision of the CAB.

To understand the issue presented, it is first necessary to understand the manner in which subsidies to airlines are granted. “Rate” in this context means the annual subsidy paid to the carrier. The rate is calculated on the basis of the compensation needed by the carrier to ensure the maintenance of its service and to develop air transportation. Theoretically, subsidized carriers operate on “final” (closed) rates. • If a carrier wishes to have its rate changed, it may petition to have its rate “opened” and a new one set. The Board may also on its own initiative open a carrier’s rate. Under a doctrine approved by the Supreme Court in Transcontinental & W. Air, Inc. v. CAB, 336 U.S. 601, 69 S.Ct. 756, 93 L.Ed. 911 (1949) (TWA), the Board may not give retroactive effect to a rate modification beyond the date on which the rate was opened for review. Between the time the carrier’s rate is opened and the time a new final rate is set, the Board generally establishes a “temporary” rate for the carrier. The amounts paid under the temporary rate will be supplemented to the extent that the final rate eventually set is higher than the temporary rate, but must be refunded to the extent that the final rate proves to be lower than the temporary rate granted.

Air New England receives a subsidy under § 406 of the Federal Aviation Act, 49 U.S.C. § 1376, for providing air service to certain New England areas whose traffic generally is too low to support profitable service by certificated air carriers. 1 On March 16, 1979, it filed a petition with' the Board to open its rate. The carrier requested a temporary annual subsidy of approximately $4.6 million, as well as an unspecified increase in its final rate. Ten days later Air New England filed an amendment to this petition requesting a final subsidy rate of $5.4 million annually. On April 20, Air New England filed an amendment in *827 creasing the amount of its request for both temporary and final subsidies because of a change in its calculations: the airline computed its need at $5 million annually on a temporary subsidy basis and $5.8 million annually for its final subsidy rate. On May 10, 1979, the Board awarded the carrier a temporary subsidy of $4.6 million from the date of Air New England’s original petition, March 16, 1979. This order was made final on May 23, 1979.

Air New England filed a third amendment to its petition on January 24, 1980. It requested an increase in its temporary rate and, for the first time, asked that its subsidy be extended to cover the period from October 24, 1978, the date of the enactment of the Airline Deregulation Act of 1978, to March 16, 1979, the date on which it had petitioned to have its rate opened. In its April 16, 1980 Order to Show Cause, the CAB agreed to a small increase in the carrier’s temporary subsidy rate, but found that the Deregulation Act did not require it to open Air New England’s subsidy rate back to October 24, 1978, adhering to its decision that the carrier’s rate was opened on March 16, 1979. It is this decision that is the subject of Air New England’s petition for review.

To prevail, Air New England must overcome the TWA rule that the Board may retroactively modify a § 406 subsidy rate only to the date on which the rate was opened. 2 In TWA the Court noted that § 406 “reads like a typical public utility rate-making authority.” Id. at 604, 69 S.Ct. at 757. Customarily such rates are never set retroactively to the commencement of the rate-making proceeding. The Court in TWA found that neither the language nor the legislative history of the Act suggested that Congress had intended to depart from these rate-making traditions. Id. at 605, 69 S.Ct. at 758. As a result, the Court felt that

a construction which would make it possible to revise rates retroactively to any point of time would be a real innovation which should have a more solid basis than our own predilections. We cannot but feel that if the rate-making power were to be put to such a novel use, the purpose would have been made clear. It is too unprecedented a departure from the conventions of rate-making to rest on mere inference.

Id. at 607, 69 S.Ct. at 759.

Air New England argues that by the passage of the Airline Deregulation Act, Congress has made such a purpose clear. First, it points to the changes made in § 406(b) by the 1978 amendments, 3 summarizing them as follows:

*828 1. For the period between October 24, 1978 and January 1, 1983, all other revenue of the air carrier is not to be considered in determining an air carrier’s need for compensation. Instead “all other revenue of the air carrier from the service for which the compensation is being paid” must be considered. 49 U.S.C. § 1376(b)(3)(A).

2. The subsidy must be sufficient to enable the carrier “to provide ... air transportation of at least the same extent, character, and quality as that provided during the year ending December 31, 1977.” 49 U.S.C. § 1376(b)(3).

3. “[Rjates of compensation paid to any carrier . . . for service performed between October 24, 1978 and January 1, 1983, shall be based on the subsidy need of such carrier with respect to service performed to points for which such carrier was entitled to receive compensation for serving during calendar year 1977.” Id.

4. For carriers, other than local service carriers, that received “compensation during the twelve months ended June 30, 1978, ... subsidy need shall be determined pursuant to the method in effect during the twelve months ended June 30, 1978.” Id.

*829 In Air New England’s view, these changes, and their .legislative history, demonstrate Congress’ desire to substitute competition for regulation in the air transport industry by moving gradually from regulation to deregulation. This, it argues, places upon the Board an affirmative duty to fix subsidy rates for the entire period between October 24, 1978 and January 1, 1983. According to Air New England, the amendments require the Board to make a de novo determination of whether, on or after October 24, 1978, the subsidy Air New England was receiving satisfied its need, based only upon a consideration of its revenues from the service for which the compensation was being paid.

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636 F.2d 825, 1981 U.S. App. LEXIS 20459, Counsel Stack Legal Research, https://law.counselstack.com/opinion/air-new-england-v-civil-aeronautics-board-ca1-1981.