March 4, 2009
The Honorable James Oberstar The Honorable John Mica
Chairman, Ranking Member,
Committee on Transportation Committee on Transportation
and Infrastructure and Infrastructure
U.S. House of Representatives U.S. House of Representatives
2165 Rayburn House Office Building 2165 Rayburn House Office Building
Washington, DC 20515 Washington, DC 20515
Chairman Oberstar and Ranking Member Mica:
We write today to voice our concerns with the current version of H.R. 915, the FAA Reauthorization Act of 2009. Commercial aviation represents an indispensable element of America’s infrastructure and our nation’s economic well-being. Commercial aviation drives over $1.1 trillion in economic activity and 10.2 million domestic jobs. Aviation also enables the global economy, and the improvements we are seeking create opportunities for the United States to increase productivity and to effectively participate in future global economic development. By any measure, the U.S. airline industry is a valuable national asset and its continued economic health should be a matter of national concern. However, the current economic environment and an outdated air traffic control system represent a real threat to our ability to create jobs and produce environmental benefits for our country.
In this context, we want to express our concern that the current legislation does not make the needed changes to ensure acceleration of air traffic control (ATC) modernization, and hinders our ability to regain financial stability. As it is currently crafted, we respectfully oppose the bill.
Commercial aviation faces stark challenges given the decrease in demand resulting from the current economic insecurity. The industry suffered tremendously from last year’s skyrocketing fuel prices and carriers had to respond by reducing capacity, which means jobs lost and service to cities reduced or lost completely. Airline employment has dropped over 28 percent since 2001, marking a loss of one out of every four industry jobs. Last year alone, mostly as a result of skyrocketing fuel prices, over 28,000 airline employee lost jobs, and thousands more job losses are expected in 2009.
Given these perilous economic times, we are hopeful that the committee will modify provisions to do no harm and ensure our ability to continue our positive contribution to the economy and the jobs creation. In particular, we ask that you:
- Expedite investment in and deployment of NextGen. The United States is at a critical juncture right now. Either we can accelerate the transformation of the ATC to allow air transportation to grow in a safe and efficient manner while achieving environmental benefits, or we can risk bringing our economy and leadership in technology to a halt by failing to address our growing aviation capacity constraints. Leadership from the committee is needed to ensure that appropriate funding and program direction is in place to accelerate the deployment of this critical program.
- Reject increasing taxes and fees on passengers. An increase in the maximum passenger facility charge (PFC) from $4.50 per segment to $7.00 per segment would impose an additional and unwarranted $2 billion per year tax increase on commercial passengers. With airport revenue eclipsing record levels – over $12.7 billion in 2007 – and with $27 billion in unrestricted financial assets, the imposition of an increased PFC tax is not only unwarranted, but will also further reduce demand for travel.
- Protect our valued U.S. aviation repair facilities by ensuring that any requirements are applied in a manner consistent with U.S. obligations under international agreements. During recent conversations between U.S. trade associations and European officials, the Europeans have indicated that as a result of the current language in Section 303, many U.S. facilities would be subject to new, regulatory requirements by the European Aviation Safety Agency (EASA). Such duplicative, burdensome impositions are in no one’s interest.
- Preserve the integrity of valuable programs such as the Aviation Safety Action Program (ASAP). The ASAP program has worked well and has a strong historical track record. We recognize the importance of this program and would strongly urge the committee not to include any language that would impede the effective operation of this program.
- Ensure cooperative efforts in maintaining the highest occupational safety and health standards for all airline employees instead of prescriptively imposing standards on flight crews.
- Maintain safety without requiring overly strict fire-fighting standards. FAA regulations have safely dictated staffing and equipment requirements for airport fire stations for years based on the needs within the airport boundary. Increasing staffing and equipment based on surrounding populations will not enhance airport safety but will increase costs unnecessarily. These are not legitimate safety claims and should be rejected.
- Allow carriers to continue improving customer service without imposing unsafe or unreasonable deplaning requirements. In particular, we oppose a hard and fast rule requiring airlines to give passengers the option to deplane after three hours. Mandatory deplaning will have numerous unintended consequences that, ultimately, will create even more inconvenience for passengers and lead to even more flight cancellations.
The Air Transport Association stands ready to work with the committee in crafting an FAA reauthorization bill that addresses these concerns and provides for investment in ATC modernization. The environmental, capacity and efficiency benefits of NextGen are critical to meeting the needs of the flying and shipping public and to improving the financial condition of the U.S. airline industry.