Amazon Air Policy Brieffinal
Amazon Air Policy Brieffinal
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        Putting more emphasis on cargo-only airports than most other package-shipment providers
        More oriented toward daytime flights and point-to-point routes than FedEx and UPS
        Expanding its fleet to 70 airplanes by 2021 and could grow to 200 planes in 7-8 years
        Making Cincinnati (CVG), Chicago Rockford, Ontario, Tampa, and Wilmington (OH) focal points
        Creating a CVG megahub that greatly boosts its potential to be a multi-purpose delivery provider
                                                     1
Observation 1. The growth of Amazon Air is a cornerstone of the retailer’s push
to expand its presence in the overnight and two-day home delivery market, a
segment that has long been dominated by FedEx, UPS, and the United States
Postal Service. Amazon Air’s orientation, however, differs from these more
established carriers in several notable ways.
Since making its maiden flight in 2016, Amazon Air has been on a rapid growth trajectory, having grown
to 42 airplanes by May 2020 and announcing plans to have at least 70 airplanes by 2021. In just three
years, it has become a major component of Amazon’s overnight and two-day delivery business. Amazon
Air complements the retailer’s massive ground-
based shipping network, which by one estimate
now surpasses 20,000 trucks. 2 The carrier’s
growth is being spurred by the expansion of
Amazon Prime, which heavily promotes
overnight and second-day delivery, and there
has been speculation that the COVID crisis has
accelerated the carrier’s expansion.
Amazon Air, being largely designed to support purchases on the Amazon platform, has many of the
qualities of a private carrier, much like the private trucking lines that serve Costco, Target, and Walmart.
Data on the amount of cargo it ships is not publicly disclosed. Its flight network appears designed largely
to augment the services of DHL International, FedEx, and UPS, such as by filling critical links between its
fulfillment and sorting centers, rather than being designed to replace them outright (DHL primarily
serves the international market).
Amazon Air has built large sorting facilities at numerous airports, including Chicago Rockford, Ontario,
CA, Tampa, FL, and Wilmington, OH. In some cases, these facilities are adjacent to FedEx and UPS
sorting centers, creating logistical synergy. If Amazon can’t ship you a product by the promised deadline
using its own trucks and planes, the package can be turned over to one of the integrators or USPS.
The massive investment being made in a large hub at Cincinnati/Northern Kentucky International
Airport, however, could change everything. This hub appears to be the lynchpin to Amazon’s efforts to
                                                         2
develop a comprehensive array of domestic delivery services across the United States. This hub, when
complete, will likely have a role similar to the FedEx “megahub” in Memphis.
Amazon Air flights constitute a large share of cargo operations by four of these carriers, accounting for
more than half the fleet of Air Transportation International (ATI) and more than a third of the fleets of
Atlas Air and Southern Air (Southern Air is a subsidiary of Atlas Air). ATI, in which Amazon is reportedly
acquiring a minority equity stake, is part of Air Transport Services Group, a company based at
Wilmington Air Park, OH. 4 Amazon Air accounts for all four of Sun Country’s freighters, although that
carrier’s operations were launched only in late April. This Twin Cities-based carrier is predominantly a
passenger airline, giving it a less cargo-centric orientation than the other contractors. The fifth carrier,
ABX, is another subsidiary of Air Transport Service Groups. None of ABX’s planes, however, were
identified in our analysis as being operated for Amazon Air, making its role unclear. 5 (The legal
relationship of the above entities is complex and evolving.)
70
60 19
50
40
                        30
                                      50
                        20                               16
                                                                              5
                        10
                                                         12                   13
                                                                                                 4
                          0                                                                                         0
                                   Atlas Air     Air Transport Int'l   Southern Air        Sun Country             ABX
Caption: All four of Amazon Air’s contract carriers devote a significant share of their freighter fleet to serve the retailer. Sun
Country is alone among the four to operate scheduled passenger service.
                                                                  3
Among these four contractors, only Atlas Air operates a larger fleet of freighters unrelated to its Amazon
business. Amazon made headlines this month when it announced it would begin using its own
employees to load and unload some Amazon Air planes, which reportedly could cut substantially into
contractor revenues. 6
The 42 airplanes presently operated for Amazon Air make it a mid-size cargo carrier—and one much
smaller than the three dominant “integrators”, FedEx (463 planes), UPS (275), and DHL (77). 7 These air-
freight integrators, however, operate worldwide networks, so their planes are spread throughout a half-
dozen continents, whereas Amazon flights are largely confined to North America. Even so, Amazon Air
already has a fleet that is larger than some prominent global cargo airlines, including CargoLux (27) and
Lufthansa Air Cargo (a subsidiary of Lufthansa Airlines having 13 planes). Note, however, that there is
much uncertainty about the actual fleets of some airlines, due to different reporting practices across the
globe and the pervasiveness of outsourcing, which can result in fleet totals being understated. 8
          500
          450    431
          400
          350
          300           257
          250
                               200
          200
          150                         104     89    77
          100                                              71       70   69     60
                                                                                       42     28     27
           50                                                                                               18    18     13
            0
Caption: For consistency, all estimates of fleet sizes are estimates of planes in service by the planespotters.net website. These
estimates understate the fleet sizes of certain airlines due to the fact they exclude certain planes operated by contractors.
Amazon’s fleet is projected by Morgan Stanley to grow to around 100 in 2025 and to 200 by 2028 by our study team.
 * See Appendix (page 13) for a discussion of this Chaddick Institute estimate.
                                                                4
If Amazon Air achieves its stated goal of having 70 planes by 2021, the carrier’s fleet size will be similar
to the present size of DHL (77) and China Airlines Cargo (71), potentially putting it in the top seven in
the world (while reiterating there is considerable uncertainty in the above fleet-size estimates, and
certain carriers may be missing from Figure 2). Other cargo airlines may grow as well, but, due to the
pandemic, some appear poised to downsize or grow only cautiously.
When measured on the basis of the available lift (cargo carrying capacity) of its planes, Amazon Air has
a lower ranking among cargo airlines. At present, Boeing 767s account for about 90% of its flights, with
the remainder being Boeing 737s, both of which have less cargo-carrying capacity than the B747s,
MD11s, A300s, and other large jets commonly used by other cargo airlines.
Our research team prepared the following map that shows the juxtaposition of airports served by
Amazon Air with its warehouses. The 170 warehouses identified are clustered by geographic region
using GIS software (Figure 3).
                                                             5
   Figure 3. Juxtaposition of Airports Served and Fulfillment Centers for Amazon Air
Caption: This maps shows the proximity of Amazon Air’s airports on the U.S. mainland to its fulfillment centers. The red circles
designate airports with Amazon flights, based on a sample encompassing flights on a randomly selected day. Some airports
with only periodic service are not shown.
Airports on Map. Lehigh Valley, Allentown-Bethlehem, (ABE), Baltimore/Washington (BWI), Charlotte (CLT), Chicago/Rockford
(RFD), Cincinnati (CVG), Dallas/Fort Worth (DFW), Denver (DEN), Fort Worth Alliance (AFW), Hartford, CT (BDL),
Hartsfield/Atlanta (ATL), Houston (IAH), John F. Kennedy (JFK), Lakeland Linder (LAL) Miami (MIA), Minneapolis (MSP), Ontario
(ONT), Phoenix (PHX), Portland (PDX), Providence (PVD), Riverside, March Air Reserve Base (RIV), Sacramento (SMF), St. Louis
(STL), San Antonio Kelly (SKF), San Bernardino (SBN), San Francisco (SFO), Seattle (SEA), Stockton (SCK), Tampa (TPA),
Wilmington (ILN).
Amazon Air’s network emphasizes proximity to its fulfillment centers, many of which are a considerable
distance from dense urban centers. The company has a network in which flights do not necessary arrive
or depart at locations close to the customer but instead are integrated with Amazon’s vast network of
trucking routes to close the spatial gaps. Several major cities, such as Detroit, MI, Kansas City, MO,
Indianapolis, IN, and Salt Lake City, UT, for example, are not served by the airline but are within an eight-
hour drive (and in most cases only a few hours) from one of its airports. Service to Charlotte, NC,
Providence, RI, and San Bernardino, CA is expected to commence soon.
Amazon Air serves the enormous New York City market primarily from its hub at the relatively small
Lehigh Valley International Airport, in Allentown-Bethlehem, PA, which is about 90 miles from
                                                               6
Manhattan and handles only about 2% of the passenger traffic as Newark Liberty International.
Customers between Philadelphia and central Virginia are primarily served from its
Baltimore/Washington International Airport hub. Both are endpoints for an expansive system of trucks
and vans.
Our analysis also suggests that there could be a need for additional airports on the Amazon Air system in
the Northeast and Mid-Atlantic regions, as well as in metropolitan Chicago. This analysis will be
available in mid-summer 2020.
             Figure 4. Amazon Air Flight Network on a Typical Day, April 23, 2020
                Flights departing 6 a.m. – 10:59 p.m. in orange; overnight flights in blue
This map shows roughly 90% of Amazon Air’s flights on a typical day, based on itineraries from flightradar24.com on April 23,
2030. One transoceanic flight, linking Anchorage to Inchon, South Korea, is not shown. Our analysis indicates the Amazon Air
planes make an average of 2.1 flights daily.
                                                              7
Observation 5. Amazon Air’s network of flights gives it a highly decentralized
orientation, although this is poised to change.
Our research team has tracked the origins and destinations of Amazon Air flights on several occasions.
Most recently, it recorded the itineraries of about three-quarters of Amazon Air flights on April 23, 2020
(Some flights could not be tracked due to missing information on airplane registration numbers). The
airports with the most Amazon Air flights over the course of this day (Figure 5) showed that
Cincinnati/Northern Kentucky International Airport is the busiest station (24 flights), followed by Tampa,
FL (16), Chicago Rockford, IL (15), Wilmington, OH, and Ontario, CA (both 13). These totals may
moderately understate flight activity due to airplanes we were unable to track. Please refer to the
Appendix for a complete list.
                                               Total
                Airport                                                                    Notes
                                              Flights
 Cincinnati (CVG)                                24        Emerging megahub; also DHL's primary hub
 Tampa (TPA)                                     16        Traffic could diminish with opening of Lakeland-Linder
 Chicago/Rockford (RFD)                          15        Also a major hub for UPS
 Wilmington (ILN)                                13        Headquarters of contractor ATI
 Ontario (ONT)                                   13        Also a major hub for UPS
 Seattle (SEA)                                    9        Used for international flights to Asia
 Houston (IAH)                                    9        One of four airports in Texas Triangle
 Fort Worth Alliance (AFW)                        8        Also a mini-hub for FedEx
 Allentown/Bethlehem (ABE)                        6        Serves New York City and Philadelphia regions
Note: These estimates may modestly understate flight activity due to lack of information on certain flight itineraries.
The above analysis illustrates the point made earlier that Amazon Air’s network does not yet have the
breadth to allow Amazon to provide the same range of service as FedEx and UPS. It is designed partially
to compete with—and partially complement—the services of these other companies. Such
complementarity is reflected in the fact that three of the five airports having the most Amazon Air
flights—CVG, Chicago Rockford, and Ontario—are major hubs for air-freight integrators.
Other schedule-related differences between Amazon and air-freight integrators are also noteworthy.
Whereas FedEx and UPS flights are scheduled to support next-day shipments, much of Amazon Air’s
design appears still oriented partially for second-day delivery, which makes having flights in the middle
of the night less critical. About three-quarters of Amazon Air flights, our evaluation suggests, depart 6
a.m. – 10:59 p.m., local airport time, a virtual mirror image of the integrators, which are largely
nocturnal creatures. Amazon Air schedules are also more dynamic. Although FedEx and UPS schedules
are highly predictable, Amazon’s vary considerably from day to day.
At present, Amazon Air has a less hub-centric design than the integrators. Only about 20% of its
                                                                8
domestic flights use the Cincinnati hub, less than the share of FedEx and UPS flights using their
“superhubs” at Memphis and Louisville, respectively. As noted in Observation 6, however, this will likely
change.
    •    Amazon is investing $1.5 billion in a 3 million square foot building at the hub, with truck bays
         designed to support shipments across the country.
    •    The state of Kentucky is building a new interchange on I-275 to support this massive
         development, as well as widening several other highway routes.
    •    An estimated 200 flights per day are reportedly expected to use the hub.
    •    As many as 100 Amazon-branded planes could operate from CVG. The site being developed
         reportedly has capacity for 100 Amazon planes. 10
The development of CVG, however, remains in a relatively early phase. Much of these needed facilities
are not expected for completion until later in 2021. Expanding to 200 flights per day from these
facilities (up from only about two dozen today) also likely requires a much larger fleet than the 70 planes
anticipated to be on the Amazon Air roster by 2021.
Observation 7. Amazon Air’s aggressive growth plans bode well for advocates of
airports dedicated to handling freight traffic. The carrier is less focused on
operating from airports with a mix of passenger and cargo traffic than the air-
freight integrators.
Airports oriented primarily toward cargo have had mixed success in recent decades. Many have been
bypassed by the air-freight integrators, which have generally opted for creating hubs at airports with a mix of
cargo and passenger traffic (such as Louisville and Memphis, each of which handles more than 3 million
passengers annually). Six of Amazon’s roughly two dozen operational focal points, however, are airports
with little or no passenger traffic: Chicago Rockford (in Rockford, IL), Fort Worth Alliance, Ohio’s
Wilmington Air Park, San Antonio’s Kelly Airport, and California’s Stockton and Riverside airports.
Among these six, only Chicago Rockford and Stockton have any scheduled passenger service, and
neither handles more than 300,000 passenger per year.
Moreover, service is expected to begin soon to Lakeland Linder International, a general aviation airport
near Tampa, FL that has no scheduled passenger flights. Amazon Air will reportedly also start flights
                                                       9
soon to San Bernardino International Airport, a cargo-only facility. As a result, more than a quarter of
Amazon Air’s principal focus points could soon be cargo-oriented airports. This is a far greater share
than that of FedEx or UPS, which operate large hubs at only two cargo-focused airports, Chicago
Rockford (UPS) and Fort Worth Alliance (FedEx).
                                                                                      Allentown/Bethlehem
                                                       Chicago Rockford
                                                                                       Wilmington
         Stockton
             San Bernardino
              Riverside
Caption: Amazon Air has a far greater orientation toward airports that have minor roles in scheduled passenger travel (defined
as handling fewer than 300,000 passengers per year). Among the eight meeting this criterion, only Rockford and Stockton have
any regularly scheduled passenger service at all (Amazon Air service to Lakeland and San Bernardino is expected to begin soon).
Allentown/Bethlehem handles fewer than 1,000,000 passengers annually and thus also has a cargo orientation.
Observation 8. Amazon Air’s growth trajectory will make it difficult for the retailer
to maintain harmonious relationships with FedEx and UPS. Amazon’s decision to
stop delivering packages not generated through its platform temporarily eases
tensions, but the carrier is poised to eventually return to the broader business-to-
consumer market.
Amazon has an uneasy relationship with FedEx and UPS, which are taking steps to deal with its ever-
growing presence in the home-delivery business. Amazon Air’s apparent low costs and its synergy with
the retailer’s vast network of fulfillment centers suggest it is positioned to grow rapidly. FedEx decided
not to handle certain Amazon traffic late last year for financial reasons. 11 On the whole, UPS appears to
be more vulnerable to Amazon Air’s expansion than DHL or FedEx. 12
According to the Global Research unit of Bank of America, “Amazon is approaching a truly vertically
integrated logistics network on par with the largest delivery companies in the world.” However, as
previously noted, it has not achieved this yet: its network is still less well-developed than that of FedEx
                                                              10
and UPS. In 2019, Amazon delivered an estimated 2.3 billion packages in the United States, which were
largely comprised of goods purchased on its own platform. 13 That number, while impressive, is
considerably below the 3.1 billion and 4.7 billion total packages delivered (and generated from many
different buying platforms) on FedEx and UPS, respectively. The USPS delivered 6.2 billion.
The carrier’s growth will generate tensions with established operators—and surprises. Rival airlines and
logistics operators will make strategic moves to protect their business as the fast-growing startup
expands its fleet and grabs a bigger piece of the air-cargo pie. Long-established players may drive an
ever-harder bargain in negotiations—to the extent their market position allows it.
But it is noteworthy that, at a time when many other airlines are downsizing due to the pandemic,
Amazon’s push for faster and cheaper at-home delivery is moving ahead on an ambitious timetable.
Amazon Air’s robust expansion makes it one of the biggest stories in the air cargo industry in years.
                                                   11
          Authors and Study Team
                        12
                                                        Appendix
                                                                                             767          737
   Rank                                                                                    flights      flights       Total
 1              Cincinnati (CVG)                                                                  20            4           24
 2              Tampa (TPA)                                                                       10            6           16
 3              Chicago/Rockford (RFD)                                                             7            8           15
 4              Wilmington (ILN)                                                                  13            0           13
 4              Ontario (ONT)                                                                     13            0           13
 6              Seattle (SEA)                                                                      9            0            9
 6              Houston (IAH)                                                                      5            4            9
 7              Fort Worth Alliance (AFW)                                                          8            0            8
 8              Allentown/Bethlehem (ABE)                                                          6            0            6
 8              Portland (PDX)                                                                     4            2            6
 8              Miami (MIA)                                                                        6            0            6
 8              Baltimore/Washington (BWI)                                                         6            0            6
 12             Stockton (SCK)                                                                     4            0            4
 12             Sacramento (SMF)                                                                   4            0            4
 12             Riverside (RIV)                                                                    4            0            4
 12             Phoenix (PHX)                                                                      2            2            4
 16             Honolulu (HNL)                                                                     4            0            4
 16             Denver (DEN)                                                                       4            0            4
 16             Anchorage (ANC)                                                                    4            0            4
 19             Windsor Locks (BDL)                                                                2            0            2
 19             San Francisco (SFO)                                                                2            0            2
 19             San Antonio (SKF)                                                                  2            0            2
 19             Minneapolis (MSP)                                                                  2            0            2
 19             John F. Kennedy (JFK)                                                              2            0            2
 24             Incheon, South Korea(ICN)                                                          1            0            1
Note: these estimates are based on flights by 38 of the 42 planes reported as being part of the Amazon Air Fleet on April 23,
2020. Flight activity was monitored on flightradar24.com, a prominent flight-tracking website.
                                                              13
        Basis for projected fleet of 200 Amazon Air planes in 7 – 8 years
Amazon’s growth from 18 planes to 39 planes from 2017 to 2019 (Figure 8) resulted in a 47.2%
compound annual growth. Growth from 39 planes to 200 planes between 2019 and 2028 requires a
compound annual growth rate of 19.9%, less than half that previously observed. The completion of
facilities at Cincinnati (CVG) and expansion in international markets could result in growth for the next
several years well above 20%, allowing for more modest growth in the latter part of the period and still
achieving the 200-plane threshold (As noted earlier in the report, only one international flight was
among the 84 flight itineraries observed on April 23, 2020). Reports have indicated that the Cincinnati
hub alone will have room for 100 Amazon Air planes.13
The Morgan Stanley estimate, publicized in early 2019, that Amazon could have 100 planes by 2025
requires 17.0% compounding rate growth between 2019 and 2025.14 Although Chaddick’s projected
growth rate is marginally higher, it should also be noted that some of the expansion could be in the form
of smaller airplanes, similar to the those (including twin-engine turboprops or the Cessna 208B Super
Cargomaster equipment used by FedEx Express) used on many feeder routes operated by contract
carriers for FedEx, or through the acquisition of another cargo airline. It is unlikely that shortages of
equipment will be a deterrent to growing at this pace. It would require Amazon Air to add, on average,
about 1.5 planes per month through 2028.
If Amazon reaches the 200-plane threshold, its fleet would likely remain well under a third as large as
FedEx’s, when equipment operated by contract carriers for this Memphis-based carrier is included. As
such, there are compelling reasons to believe that the 200-plane estimate is reasonable.
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                                Issues in Aviation Law & Policy
The Chaddick Institute is home to the widely circulated peer-reviewed journal Issues in Aviation Law and
Policy, featuring timely works from authors around the world. “IALP” covers both legal and policy issues
affecting civil aviation as well as matters related to commercial airports and other aspects of aviation.
Please email chaddick@depaul.edu for subscription information or a complimentary copy.
                                                   15
1
  The authors based all comments on publicly available data while acknowledging uncertainty that exists with regard
to the growth trajectory of Amazon Air.
2
  A widely circulated report that Amazon’s truck fleet has reached 20,000 is available at
https://www.thomasnet.com/insights/amazon-doubles-truck-fleet-to-20-000-in-one-year/.
3
  A summary of Amazon’s exit from the third-party delivery market for Amazon sellers who do not keep inventory
in its warehouses is provided in this CNN.com article from April 8, 2020, available at
https://www.cnn.com/2020/04/08/tech/amazon-third-party-shipping-suspended/index.html.
4
  The description provided of the legal relationships among Air Transport Services Group, ATI, ABX, and Amazon
Air is based on secondary sources. These relationships are complex and evolving, and beyond the scope of this
study. Readers may wish to consult Air Transport Services Group resources for details of its various holdings.
5
  None of the planes operated by Amazon Air are reported as being part of the ABX fleet on planespotters.net. It is
possible, however, that ABX is using parts of its regular fleet for this purpose.
6
  The announcement that Amazon will handle much of the loading and unloading is reported in this Business Insider
story, available at https://www.businessinsider.com/amazon-in-housing-air-cargo-prime-airlines-earnings-partners-
2020-5.
7
  These estimates are based on tallies in planespotters.net. Totals do not include planes operated under contract.
Estimates of the size of fleets differ between various sources.
8
  The practice of some cargo airlines to outsource makes definitive estimates of their sizes difficult. This article
illustrates some of the issues surrounding competitive contracting: https://www.aircargonews.net/airlines/freighter-
operator/unions-call-for-halt-to-cargolux-outsourcing-plan/. The practice of using contractors varies around the
world, but it is particularly problematic for estimating the size of Amazon Air, which is operated entirely by
contracted carriers that report only aggregate transportation statistics (both Amazon and non-Amazon traffic
combined) to the Bureau of Transportation Statistics.
9
  A summary of the Morgan Stanley projection is provided in this Business Insider article, available at
https://www.businessinsider.com/amazon-100-planes-by-2025-2019-1.
10
   A discussion of the proposed Cincinnati/Northern Kentucky International (CVG) hub is available at
https://www.bizjournals.com/cincinnati/news/2019/05/15/here-s-what-amazon-s-air-hub-at-cvg-will-look-like.html.
11
   FedEx’s decision to cease handling Amazon traffic (which was reported to have “minimal” impact on its
revenues), is reported in this U.S. News & World Report article from June 7, 2019, available at
https://www.usnews.com/news/business/articles/2019-06-07/fedex-will-stop-air-shipments-of-packages-for-amazon.
12
   For a more detailed discussion of the risks posed by Amazon Air’s expansion to FedEx and UPS, please refer to
this Barrons.com article, available at https://www.barrons.com/articles/amazon-is-a-delivery-powerhouse-look-out-
fedex-ups-usps-51587403739.
13
   A discussion of the proposed Cincinnati/Northern Kentucky International (CVG) hub is available at:
https://www.bizjournals.com/cincinnati/news/2019/05/15/here-s-what-amazon-s-air-hub-at-cvg-will-look-like.html.
14
   A summary of the Morgan Stanley projection is provided in this Business Insider article, available at
https://www.businessinsider.com/amazon-100-planes-by-2025-2019-1.
                                                        16
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