September 14, 2007
The Honorable Mary Peters
Secretary
U.S. Department of Transportation
1200 New Jersey Ave, SE
Washington, DC 20590
Dear Madam Secretary:
The Air Transport Association and its member airlines commend the Department of Transportation (DOT) and Federal Aviation Administration (FAA) on the recently announced redesign of the New York, New Jersey and Philadelphia metropolitan area airspace. Without question, this meaningful step in alleviating airspace congestion in the Northeast Corridor would not have occurred without the administration’s dedication and tenacity over the past decade.
As noted in my August 7, 2007 letter, the airlines are committed to addressing customer service concerns and growing system inefficiencies in the NY/NJ/PHL metropolitan area. We firmly believe that much of the public’s frustration over increasing flight delays could be addressed if delays in this area were reduced, thereby reducing delays throughout the country. We again urge DOT and FAA to accelerate the implementation of the redesign plan to realize its benefits, including reduced delays, as quickly as possible.
We also continue to support the appointment of a “czar” to lead a multi-faceted northeast congestion initiative. While the airspace redesign and Airspace Flow Program referenced in Administrator Blakey’s August 20, 2007 letter offer some relief, meaningful, near-term solutions to system inefficiencies are simply not possible without involving all operator groups. To ensure accountability, an individual empowered to make substantive adjustments to the management of the airspace should lead a multifaceted, focused initiative. Our members have committed to participate fully in this integrated effort and provide the necessary resources to implement measures to leverage existing technologies to produce incremental but important capacity increases. The procedural and operational measures contained in my earlier letter would provide incremental relief, and we again urge you to take steps to facilitate their implementation.
I would like to address Administrator Blakey’s recent suggestion that airline “over scheduling” is somehow causing congestion and that Congress will intervene if the airlines do not “voluntarily” address the situation. To the point, holding this threat over the airlines to solve a problem they did not cause is an odd incentive to encourage cooperation. Nonetheless, as we have stated repeatedly, the airlines are willing to work with others to address congestion in the New York/New Jersey/Philadelphia airspace. To ensure a fair and balanced effort and avoid potential antitrust concerns for the airlines, we urge the DOT to:
- appoint a “czar” by October 1, 2007, to assert a leadership role, encouraging other ongoing delay-reduction initiatives, including the Port Authority’s effort, to work under the direction of the DOT;
- prior to any discussions with the airlines, ensure all antitrust concerns for participating airlines are fully addressed, including preapproval by the requisite federal agencies and parameters for permissible discussion topics and procedures; and
- convene a meeting by October 15, 2007, to discuss short-term, viable operational and procedural measures to address system inefficiencies. Representatives of operator groups using the New York Tracon and Center services, including commercial airlines (U.S. and foreign flags) and corporate/general aviation operators should be included; “solutions” that advantage so-called “new entrants” or non-U.S. airlines, or that constrain demand, should not be considered.
To advance this process, we must acknowledge that historically the best way to maximize existing airspace capacity has been to implement measures to use all available capacity and produce the level of operations capable at the three major New York metropolitan airports. Recent FAA data suggests that New York area airports are not delivering the throughput they are capable of delivering. No real, lasting solution to reducing congestion is possible unless these fundamental issues are addressed very clearly. Artificial constraints on demand and so-called demand-management measures are not necessary. Congestion pricing, in particular, is counterintuitive and will result in considerably higher fares and contrived scheduling, with no benefit to passengers or the nation’s ATC system.
ATA and its member airlines are committed to working with the DOT to address this challenge. I look forward to hearing from you.