21st Century Aviation - A Commitment to Technology, Energy and Climate Solutions

OBJECTIVES

Our objectives are to:

• Aggressively reduce commercial aircraft fuel consumption and greenhouse gas emissions;
• Provide for stable jet fuel supplies and prices; and
• Avoid further burdening an already overtaxed industry (including ensuring appropriate federal funding of air traffic control modernization).

To achieve these objectives, the U.S. airline industry should operate:

• Along optimum flight paths by a network-centric, satellite-based air traffic
  control system;
• In a market with commercially viable, environmentally friendly alternative jet fuels; and
• With a fleet of more energy-efficient aircraft than today.

It is time for the United States to once again take a leading role in aviation. Future domestic economic and job growth is critically dependent upon a viable air transportation system. More air transportation capacity will be necessary, not less.

U.S. airlines are fully supportive of the research, development and deployment of state-of-the-art technology and fuels that will reduce congestion and delays, reduce fuel consumption, reduce U.S. dependence on foreign oil and reduce greenhouse gas (GHG) emissions. This will enhance safety, improve travel for consumers, lower costs, support local economies and bolster competitiveness for all U.S. industries. However, U.S. airlines are completely dependent upon the U.S. government, aerospace manufacturers and energy companies to research, develop and deliver these vital new technologies. We must have appropriate government policies, leadership and legislation to achieve these objectives.

TO DATE

For the past several decades, commercial airlines have dramatically improved fuel and GHG efficiency by investing billions in fuel-saving aircraft and engines, innovative technologies like winglets and cutting-edge route optimization software. For example, between 1978 and 2007, the U.S. airline industry improved its fuel efficiency by 110 percent, resulting in 2.5 billion metric tons of GHG savings – roughly equivalent to taking more than 18.7 million cars off the road in each of those years.[1] Further, data from the Bureau of Transportation Statistics confirms that U.S. airlines burned almost 3 percent less fuel in 2007 than they did in 2000, resulting in absolute reductions in GHG emissions, even though they carried 20 percent more passengers and cargo on a revenue ton mile basis. Recent data suggests further gains in fuel and GHG efficiencies in 2008.

Airlines have an inherent economic incentive to reduce fuel consumption and the resulting GHG emissions because fuel accounts for a significant and volatile part of an airline operating budget. Stable energy prices are critical for a stable and viable airline industry, which begs for a committed energy policy of independence and alternative fuels. However, enormous amounts of capital and committed research and development are required to advance science and technology, all of which are essential to new sources of energy, further fuel efficiency gains and GHG reductions.

NEXT STEPS

It is critical to pursue initiatives that will enable airlines to significantly reduce fuel consumption and GHG emissions. This can only be accomplished if government, aviation manufacturers, energy companies, airlines and other stakeholders work together.

• First, it is critical that the FAA fund, develop and deliver a Next Generation Air Traffic Control System (NextGen).
• Second, it is vital that an energy policy is adopted by government that provides for stable supplies, stable prices, independence from foreign oil and is more climate-friendly. In particular, alternatives to crude oil-based jet fuels are imperative.
• Third, it is critical that new airframe and engine technologies be researched, developed and delivered.

Without these three initiatives, air transportation will be less fuel efficient, more expensive, less viable and, therefore, less able to support domestic economic and job growth.

In summary, these three initiatives are critical to the airline industry’s ability to further address climate change. It is vital to link any and all government aviation climate change policies to these three initiatives.

1.  NextGen Capabilities

“NextGen’s going to make a world of difference. Less noise. Less pollutants. Less carbon. That’s a green ticket….” – The Honorable J. Randolph Babbitt, FAA Administrator, before the RTCA, June 10, 2009.

“NextGen” is the FAA generalized concept for modernizing the air traffic control (ATC) system by 2025 at an estimated cost of $40 billion. NextGen would include transforming today’s antiquated ground-based air traffic navigation and surveillance system to a state-of-the-art satellite-based system. The cornerstone of NextGen is the FAA’s En Route Automation Modernization (ERAM) initiative to modernize and completely transform the nation’s en route ATM automation system.

Today’s antiquated ground-based systems add flight time because they do not route aircraft in a direct, linear fashion. Further, because today’s technology does not precisely pinpoint an aircraft’s position in space, a greater amount of time and separation must be factored in spacing flights apart. Utilizing satellite-based systems, the FAA and airlines will be able to route flights more efficiently, precisely, and directly. This reduces flight miles, flight times, congestion, and delays. Less aircraft time in the air and on the ground means significantly lower fuel consumption and GHG emissions.

Projections of fuel consumption and GHG emissions reductions from full NextGen implementation are significant and range from 6 percent to 15 percent.

A. Elements of NextGen that are currently being deployed or undergoing testing and refinement by commercial airlines include, but are not limited to:

• Automatic Dependent Surveillance-Broadcast (ADS-B) – provides surveillance using GPS (space-based) signals to fix aircraft location in a fashion similar to today’s ground-based radar. ADS-B will provide radar-like coverage in areas where no coverage exists today (e.g., oceanic and mountainous areas). Ideally, ADS-B will permit reduced separation between aircraft due to improved accuracy by enabling FAA ATC to utilize shared precision information between controllers and pilots;
• Required Area Navigation (RNAV) – enables aircraft to fly on any path within coverage of ground- or space-based navigation aids, permitting more access and flexibility for point-to-point operations;
• Required Navigation Performance (RNP) procedures (RNAV with onboard technology) – monitors aircraft performance and enables closer en route spacing without intervention by ATC and permits more precise and consistent departures/arrivals;
• Continuous Descent Arrivals (CDA) – allow aircraft to fly continuous descent airport approaches rather than traditional “step downs,” which conserves fuel, though efforts should be made to ensure their use does not negatively impact efficiency gains made elsewhere;
• Tailored Arrivals – allow aircraft to fly an approach that is optimized for the conditions; guidance is developed by ATC based on all known constraints and up-linked to aircraft before top-of-descent;
• Ground-Based Augmentation System (GBAS) – technology used to support precision landings in low visibility, poor weather conditions; replaces outmoded instrument landing systems (ILS) and has the ability to serve multiple runways at a lower cost and with higher reliability;
• Precision Runway Monitor-Alternate (PRM-A) – leverages Airport Surface Detection Equipment (ASDE-X) to provide Closely Spaced Parallel Approach capabilities at airports, which allows aircraft to land more safely and efficiently, increasing runway capacity.

B.  Accelerating NextGen – “NowGen”

“NextGen is just flat out not moving fast enough. We must accelerate NextGen.
I want more, and I want more faster.” – The Honorable J. Randolph Babbitt, FAA Administrator, before the RTCA, June 10, 2009.

NextGen is a vital component to the future success of the airline industry and an important means to reducing flight delays and the industry’s carbon footprint. The swift implementation of NextGen must be a national priority. Fortunately, many of the technological and procedural advancements listed above are already available and a sizable portion of today’s commercial aircraft are equipped to fly more safe and efficient routes and procedures.

FAA is an essential NextGen leader. FAA leadership is the difference between success and failure in realizing the benefits of NexGen for all stakeholders. Accelerating the deployment of NextGen technologies; designing new routes; and implementing new airspace and procedures will produce material improvements in the operational performance and fuel efficiency of aircraft flying those procedures.

C. NextGen Challenges

While the foregoing technological and procedural advancements are essential for achieving future efficiencies, the FAA, in coordination with the aviation community,[2] should quickly and clearly design the future ATC system by identifying achievable near-term, mid-term and long-term:

• Milestones for NextGen implementation;
• Efficiencies for the industry;
• Performance metrics for NextGen technologies and procedures, including an energy-efficiency standard for designing new airspace and airport procedures;
• Revised separation standards;
• Investment goals premised on accelerated federal investment; and
• Concrete plans for achieving the above.

Additionally, a prompt resolution to labor/management issues at the FAA must be reached to enable all stakeholders to move forward uniformly to implement and utilize the new systems. Modernizing the aviation infrastructure overhead requires a broad-based team, training, technology and structure. This combination can produce solutions that integrate and address environmental, energy, business, labor and consumer needs required to move forward in the aviation sector.

D. Environmental

NextGen must comply with the National Environmental Policy Act (NEPA). The FAA has existing discretionary authority to determine “categorical exclusions”[3] from NEPA. Specifically, the FAA can determine that there is a categorical exclusion for procedural actions “involving establishment, modification, or application of airspace and air traffic procedures.”[4]

An action on the FAA’s categorically excluded list does not automatically exempt environmental review under NEPA. The FAA must also determine that no extraordinary circumstances are present that could require additional environmental analysis.

FAA must determine whether new procedures are required to undergo extended environmental review. However, environmental review should not be used to delay implementation and utilization of NextGen technologies and procedures. Instead, under its existing authority, FAA can and should carefully consider the broader environmental benefits that will accrue from NextGen and utilization of advanced avionics on appropriately equipped aircraft.

E. Cost of NextGen

According to the FAA, the total estimated cost of NextGen implementation could reach as high as $40 billion, including approximately:

• $20 billion for FAA program development, research, technology deployment, and training;
• $20 billion to equip aircraft and provide training.

Since this is an essential component of the nation’s infrastructure and achieving fuel efficiencies and reducing GHG, federal funds must be dedicated to funding NextGen, including both ground-based and aircraft equipage. Aviation taxes and fees, which already are disproportionately burdensome on the industry, must not be raised to accomplish these national infrastructure goals. The airlines simply do not have additional funds to contribute beyond their already exorbitant tax burden. The government must step up.

In any event, there are many actions the FAA could be taking today that are not tied to federal funding constraints. These actions include designing and implementing safe and efficient routes and procedures, including revised separation standards, which would produce material and immediate improvements in the operational performance and fuel efficiency of today’s advanced jet aircraft.

2.  Energy

Today, the aviation industry is dependent on crude oil as its source of jet fuel. Unlike other sectors of the economy airlines have no commercially available alternative to consuming fossil fuels. To address this reality, ATA supports a balanced and comprehensive national energy policy that increases U.S. energy independence, is climate-friendly, and results in more predictable and stable energy supply and costs. Core principles include:

• Supporting the development of alternative fuels as part of a comprehensive national energy policy that will encourage energy sources other than crude oil, freeing up crude oil for those solely dependent on it until technology evolves. This includes bio-fuel, clean coal, electricity, nuclear, hydro, wind and solar initiatives.
• Increasing domestic oil and gas supplies in an environmentally sensitive manner;
• Developing alternative jet fuels that are safe, economically viable, more environmentally friendly than today’s fuels and can be available in practicable and reliable quantities;
• Improving energy conservation and efficiency, primarily through NextGen initiatives; advancements in engine, airframe and avionics technologies to produce more fuel-efficient, cleaner burning engines and more aerodynamic aircraft; and the prompt certification, production and utilization of this equipment;
• Increasing oversight and transparency of the energy commodities market.

To execute these principles, Congress should consider legislative initiatives that:

• Provide for a balanced, comprehensive energy policy;
• Invest in and provide incentives for airlines to invest in NextGen aircraft, equipment and technologies;
• Accelerate development and implementation of satellite-based, NextGen technologies and high-tech procedures.

To assist in developing alternative, economical, and climate-friendly jet fuels, the federal government can assist the airline industry through the following actions:

• Research and development – While there has been significant progress over the past two years in the development and demonstration of alternative jet fuels, the federal government can further expedite the process in this critically important area by funding new research, development and demonstration programs, including the study of a new generation of “drop-in” synthetic fuels and new sources of biomass, as well as the feasibility of using pipelines to transport bio-jet fuel. Allowing private sector consortia as well as educational and research institutions to apply for funding to develop alternative jet fuels provides opportunities to the broadest field of applicants. This, in turn, increases the likelihood of success. Increased funding is also needed for ongoing U.S. military efforts to develop synthetic and bio-fuels for military jet fleets that will transition to commercial fleets.
• Certification assistance – A key step in alternative aviation fuel development is certification. Before the fuel can be approved for commercial use, it must meet rigorous safety and performance standards – much higher standards than fuel for ground-based transportation. Federal support is needed to accelerate the approval and deployment of several alternative aviation fuels that have already been developed and tested. Increased funding is also needed for ongoing U.S. military efforts to develop alternative and bio-fuels for military jet fleets that will transition to commercial fleets.
• Infrastructure investment – Considerable ground and flight testing has brought commercial aviation closer to the widespread use of alternative aviation fuels. However, the economic slowdown has dried up investment dollars for already conceived pilot plants and full-scale production plants. Direct federal support for such infrastructure investments, including the creation of new grant and loan guarantee programs will spur the long-term investment in alternative jet fuel refineries and related infrastructure projects. Moreover, the U.S. military – the largest consumer of jet fuel in the United States – should be granted the authority to enter into long-term contracts with alternative jet fuel producers. Such long-term contacts can advance commercialization and lead to the large-scale production of new sources of jet fuel.
• Environmental assurances – Alternative aviation fuels will only succeed if they are found to be more economically viable and more climate-friendly than today’s aviation fuels. Direct federal investment is needed to develop criteria in test programs and models that will accelerate the deployment of alternative aviation fuels.

3.  Airframe and Engine Technologies

With the airlines’ support, commercial aircraft and engine manufacturers have succeeded over the years in moving commercial aviation safety, reliability and performance forward. They have also made successive improvements in the areas of noise emissions and fuel efficiency, making today’s airplanes quieter and cleaner-burning than any type of aircraft ever produced.

By incorporating advanced wing systems and surfaces that reduce drag, modern commercial airplanes are significantly more aerodynamic than prior generations of aircraft. Modern aircraft weigh less, and the fuel efficiency of aircraft engines improves each year.

Based on recent technological advances in aircraft and engine manufacturing, further improvements in fuel efficiency are expected to continue only incrementally. Major advances in aircraft fuel efficiency to enable the airline industry to more aggressively reduce its GHG emissions are dependent on new engine and airframe technologies not yet available in the marketplace. Thus, to meet medium- to long-term emissions targets, radical new aircraft and engine designs are necessary. For instance, leading aircraft manufacturers have long studied a blended wing-body design that can burn 20-to-30 percent less fuel than conventional tube-and-wing aircraft. Unfortunately, in the near future, no major breakthrough in either aircraft or engine design is expected because of the enormous effort and cost of engineering research and development.

Over the past several years, the federal government has significantly reduced funding for FAA and NASA aeronautics research and development programs, which are critical in moving airframe and engine technologies forward. To counter that trend, the federal government should restore and increase funding for aeronautics research.

CLIMATE SOLUTIONS

Although commercial airlines account for less than two percent of CO₂ emissions in the United States and only two percent on a worldwide basis, the U.S. airlines continue to take additional steps to address this GHG emission from our operations. Accordingly, we join with the International Air Transport Association (IATA) in adopting an ambitious set of targets to mitigate GHG emissions from our industry under a global, sectoral approach, including collective industry commitments to:

• Continue the industry’s fuel (and, hence, CO₂) efficiency improvements, resulting in an average annual CO₂ efficiency improvement of 1.5 percent per year on a revenue ton mile basis from 2009 to 2020;
• Cap industry-wide CO₂ emissions from 2020 (carbon-neutral growth) subject to critical aviation infrastructure and technology advances achieved by the industry and government; and
• Contribute to an industry-wide goal of reducing CO₂ emissions by 50 percent by 2050, relative to 2005 levels.

Due to the global, interconnected nature of air transport, the global, sectoral approach should apply equally to both domestic and international aviation, without distinction. Policy measures must be developed at a global level to avoid the unilateral imposition of targets and measures and to avert creating a patchwork of conflicting and potentially overlapping national, regional and local policies. The global, sectoral approach and industry targets are discussed in greater detail in the ATA paper entitled “The Air Transport Association Climate Change Commitment: A Global, Sectoral Approach.”[5]

While our collective commitment to reducing fuel consumption and emissions is strong and constant, the tools that will enable the airlines to fulfill our commitment and achieve more dramatic reductions in GHG emissions are largely unavailable. This is because the airline industry is largely dependent on the pace of advancements in the following areas, which require strong government leadership and support:

• ATC modernization, including technical and operational improvements;
• Low-carbon, commercially-viable alternative jet fuel development and production; and
• Engine, airframe and related technologies and infrastructure.

Without major breakthroughs on the technology and energy fronts, including major government investments in new infrastructure and alternative fuel production, commercial aviation will be constrained to making incremental improvements in fuel efficiency performance. Another important element to reducing the industry’s carbon footprint is for the FAA to accelerate the pace of NextGen improvements, including the approval of performance-based navigation procedures, especially at our most congested airports.

Cap-and-trade is often discussed as the solution to climate change, but it is not a good solution for aviation. Under the major cap-and-trade proposals, which regulate transportation fuels “upstream” (i.e., at the fuel producer level), the airlines – and the transportation sector, in general – would be saddled with significant cost burdens through higher fuel prices. For an airline, higher fuel prices would negatively impact ticket prices, flight activity and economic development associated with commercial aviation (i.e., travel and leisure businesses, aircraft manufacturing, airport-related jobs, etc.), as well as the airlines’ ability to fund the purchase of new fuel efficient equipment and technologies.

CONCLUSION

1. Strong government leadership and support is essential to achieve our objectives. A “one size fits all” legislative approach to climate change that fails to recognize the uniqueness of industries, will fail to effectively reduce GHG and support economic and job growth. While the airlines are committed to doing their part, the industry’s contribution to further mitigating climate change depends on the effect of modernizing the ATC system, producing commercially viable alternative jet fuels, and the ability to acquire technologically-advanced aircraft because that will enable commercial airlines to fund initiatives and aggressively reduce our GHG emissions.

2. There will be several legislative opportunities to make funding available for DOT, FAA, NASA, the Department of Energy and other federal agencies to expedite:

A. the federal funding, development and deployment of satellite-based,  NextGen” technologies and high-tech procedures;

B. the production of commercially-viable, climate-friendly alternative jet fuels; and

C. the research, development, production and deployment of advanced, fuel efficient airframes, engines and other fuel-efficient equipment.

Such advancements are necessary for the commercial aviation industry to effectively address climate change. Without an upfront commitment to pursuing these initiatives, aggressive reductions in GHG emissions are technologically unattainable and, therefore, can only be achieved through punitive increases in energy costs that would cause the aviation industry (and, with it, the economy) to retract.

3. Revenue raised from the commercial aviation industry must be re-directed into aviation-related environmental and efficiency improvements.

4. Future government revenue-raising initiatives from aviation must take into account the already excessive burden imposed on the industry and the current use of such revenues.

5. A safety valve or price trigger mechanism should be included, to account for market forces, in any system contemplated to regulate carbon emissions.

6. U.S. airlines are part of an international aviation network. Measures addressing aviation and climate change should be focused on a global, sectoral solution, which includes:

A. International Harmonization – Airline emissions are currently subject to international standards established through the International Civil Aviation Organization (ICAO). Domestic legislation should be based on the principles contained herein and crafted to harmonize with ICAO standards.

B. Universal Standards – Because airlines operate within an international network, there should be one set of rules under which to operate. First, there needs to be safeguards to prevent the “double taxation” by two or more governmental bodies or the double-counting of GHG emissions. Additionally, the current federal preemption that prevents states and localities from establishing their own aircraft emissions standards should continue and extend to any future climate change legislation.

7. States should constructively engage with the federal government to develop a federal regulatory approach to climate change. Any federal regulatory approach should preempt state actions to impose limitations or other restrictions on GHG emissions from aviation. In the interim, the states should not act to impose limitations or other restrictions on GHG emissions from aviation.