STATEMENT OF

THE AIR TRANSPORT ASSOCIATION OF AMERICA, INC.

BEFORE THE

AVIATION SUBCOMMITTEE OF THE

SENATE COMMITTEE ON COMMERCE, SCIENCE & TECHNOLOGY

CONCERNING THE IMPACT OF

NEW JET AIRCRAFT ON THE NATIONAL AIRSPACE SYSTEM

September 28, 2006

I. INTRODUCTION

A. ATA Introduction and Purpose
The airspace system in the United States is fast approaching a critical point. Several very decisive factors are in plain view; they will profoundly affect the system and its future ability to serve users. First, the system must be modernized. Existing and anticipated satellite-based navigation and communications technologies must be leveraged to improve the efficiency of the system and its ability to accommodate substantial new demand for air traffic services. Second, an equitable way to fund those system improvements must be developed. Third, the impact on the system of the much-anticipated introduction of great numbers of very light jets (VLJs) must be evaluated and dealt with. It is this last matter – the airspace implications of this new category of system user – that is the subject of our statement.

The Air Transport Association of America, Inc. (ATA) is the principal trade and service organization of the U.S. airline industry, and its members¹ transport over ninety percent of U.S. airline passenger and cargo traffic. As of June 30, 2006, ATA member airlines were operating a fleet of 4,316 airplanes.

As a key stakeholder in our nation’s aviation system, ATA respectfully submits these comments to the Aviation Subcommittee of the Senate Committee on Commerce, Science and Technology.

B. ATA Member Airlines Enable our Nation’s Economic Engine
The U.S. civil aviation sector (including air transportation, related manufacturing and air-based travel and tourism) was collectively responsible for $1.37 trillion of national output (i.e., economic activity) in 2004, supporting 12.3 million U.S. employees and $418 billion in personal earnings. Commercial aviation accounts for the majority of this impact with $1.2 trillion in output, $380 billion in earnings and 11.4 million jobs.

The national economy is highly dependent on commercial aviation, which, in 2004, was directly or indirectly responsible for 5.8 percent of gross output, 5.0 percent of personal earnings and 8.8 percent of national employment.²

These extraordinary economic benefits could not have been generated without an aviation infrastructure that enables air carriers to provide the services that passengers and shippers demand. Any changes to our nation’s aviation system, such as the introduction and proliferation of a new and different aircraft type, must be carefully assessed to ensure that the public continues to benefit from a safe, healthy aviation system.

C. The Introduction of VLJs Will Affect All National Airspace System Stakeholders
The introduction of VLJs into the National Airspace System (NAS) constitutes a significant change and will have far reaching and – at this point – not entirely known consequences. What we do know is that their impact will eventually be felt by all stakeholders, including airlines, FAA, manufacturers, Fixed Base Operators (FBOs) and many others. However this plays out, stakeholders share an obligation to ensure that their introduction does not jeopardize the unparalleled efficiency and safety of our NAS.

II. OVERVIEW OF VERY LIGHT JETS

A. What is a Very Light Jet?
A VLJ, also called a microjet or personal jet, is generally defined as a technologically advanced, high-performance turbine-engine-powered aircraft weighing 10,000 pounds or less (maximum certificated takeoff weight) and certificated for single pilot operations. These aircraft will feature advanced cockpit automation, such as moving map GPS and multi-function displays, automated engine and systems management, and integrated autoflight, autopilot and flight-guidance systems.

The cost of VLJs, somewhere in the range of $1.0M to $3.0M, places them well within the reach of many businesses and individuals.

B. Manufacturers and Models
FAA estimates that there are presently some 20 models of VLJs in various stages of design, certification and production. Exhibit 1 highlights a sampling of VLJs.

VLJs will be certificated to operate at maximum altitudes of roughly 41,000 feet, enabling them to join commercial airliners and business jets in competing for finite en route airspace. Unfortunately, VLJs will have maximum cruise speeds at those altitudes that are significantly slower than other aircraft (380 knots versus 550 knots). This difference in cruising speed will pose a potentially significant airspace management issue. They will have a range of roughly 1,200 nautical miles and carry up to four passengers.

D. Expected Uses
Current and projected aircraft orders illustrate two primary categories of VLJ buyer. The first is an individual who plans to use the aircraft for recreational transportation. The second, and much larger segment of buyer, is that which involves transporting passengers conducting business between major metropolitan areas. It is important to note that while VLJs will frequently utilize secondary airports, those airports are typically near – and share the airspace above – major metropolitan areas.

E. Projected Deliveries
Predictions regarding the number of VLJ deliveries vary from source to source. FAA predicts roughly 4,000 aircraft deliveries over the next 10 years, while others put the number at twice that. NASA translated their projections into flight activity and estimates that VLJs could account for 20,000 flights daily by the end of the 10-year period.

While aviation industry experts may debate the actual number of aircraft eventually ordered, most agree that VLJs will appear in sufficient numbers to significantly increase demand on an already strained air traffic control system.

III. ECONOMIC IMPLICATIONS

The early interest in VLJs clearly illustrates the demand in the marketplace for an aircraft with its capabilities. It appears to fill the void between conventional piston aircraft and high-end business jets at a price considered reasonable by its buyers.
Clearly the VLJ manufacturers and their suppliers stand to benefit from the sale of these new aircraft. Furthermore, the downstream activities linked to the operation and support of these aircraft will increase access and revenue to smaller airports. VLJs will drive new business for FBOs due to demand for storage, fuel, maintenance and related services.
Using VLJs, air taxi operators could open access to new business centers that previously were beyond the reach of available aircraft. This new access could generate new markets and opportunities resulting in further economic benefit.

At the same time, any incremental economic benefits would be quickly erased if the introduction of VLJs leads to an increase in airspace congestion. The airspace above major metropolitan areas is already or rapidly becoming congested, and any further increase in demand would cause an increase in delays for all users.

Delays are especially expensive to airlines and their customers. The Department of Transportation has estimated that delays cost U.S. airline passengers $9.4 billion in 2005. In addition to those direct costs to passengers, delays cost airlines an estimated $62 per minute in direct (i.e. aircraft) operating costs. Applied to the 94.1 million cumulative delay minutes recorded in 2005 reveals $5.9 billion in industry costs. Combining the passenger and airline costs produces a U.S. economic cost of $15.3 billion or $484 every second.

IV. IMPLICATIONS FOR OUR NATIONAL AIRSPACE SYSTEM

A. VLJs Will Place Additional Demands on an Already Constrained ATC System
The existing U.S. ATC system is based on vintage 1950s design concepts that can no longer be efficiently expanded to meet future demand. As the number of aircraft using the system increases, congestion will worsen resulting in artificial limits on demand – access to our nation’s airspace will be restricted to prevent total gridlock. Industry experts³ have expressed concern over the ability of the ATC system to accommodate growing demands:

“The non-airline turbine powered fleet is much larger than the air carrier turbine-powered fleet. And the total turbine-powered fleet is projected by FAA to increase by 49 percent over the next 11 years, putting considerable stress on the ATC system.”

It isn’t hard to imagine a system where access to airspace is rationed. That is precisely what exists today at New York’s LaGuardia and Chicago’s O’Hare airports. Congested airspace above New York and South Florida threatens to force further restrictions. It is critical to note that capacity limitations are not necessarily tied to a lack of runway or terminal capacity. More and more, airport accessibility is driven by the ability of the airspace above to accommodate the traffic. For example, VLJs attempting to access Fort Lauderdale Executive Airport may be blocked by saturated airways even though the airport itself could handle the traffic.

Integrating VLJs into the current ATC system will present challenges for FAA and existing users. VLJs will be incompatible with existing aircraft using high-altitude airspace because they cruise at significantly slower speeds. Introducing VLJs into these routes is analogous to allowing tractors on a freeway. Air traffic controllers would be faced with an increased level of complexity. This increasingly complex environment translates into increased controller workload, leading to excessive and inefficient aircraft separation.

Clearly it is in the best interest of VLJ operators and all other users of our nation’s airspace system to collaborate in building a system that safely, efficiently and equitably accommodates all users. Vern Raburn, president and CEO of VLJ manufacturer Eclipse Aviation, clearly recognizes the importance of NAS transformation on the success of his business:

“In my opinion, we need to be asking and answering the hard questions that will lead to implementation of a next-generation distributed ATC system. And we should be doing it sooner, because later is already here.”⁴

Unfortunately, the revenue collected by FAA will not cover their costs to provide ATC services to VLJ operators and will fall far short of the amount needed to finance NAS modernization. FAA will be faced with significantly increasing demand for services without a corresponding increase in revenue. To illustrate the problem caused by today’s FAA funding mechanism, consider that a typical 737 commercial airliner flying from New York to Fort Lauderdale pays $1,506⁵ toward funding FAA, while an Eclipse 500 corporate VLJ on an identical route using the same ATC services pays only $53.⁶ Based on an analysis of FAA’s cost data, ATA estimates that it costs FAA approximately $781 to provide those services.

B. VLJs Could Introduce New Operational and Safety Risks
Historically, the cruise performance capabilities of the aircraft operated by the various segments of the aviation community naturally segregated them into distinct operating environments. Larger, faster aircraft (like business jets and commercial airliners) typically cruise above 28,000 feet, while piston-driven recreational and on-demand charter aircraft primarily operate at lower altitudes.

VLJ performance will blur the lines between the blocks of airspace conventionally used by the different types of operators. VLJ operators will be able to climb to and cruise at altitudes that previously were inaccessible due to the performance limitations of their previous aircraft.

While the impact of VLJs on the airport terminal airspace environment will be more a function of the number of operations rather than an issue of compatibility, the FAA must assess a broad array of integration considerations. Approach and departure patterns, wake turbulence interaction and ramp congestion are but a few.

In recognizing that the potential will exist for relatively inexperienced pilots to be operating high-tech aircraft in a complex and challenging environment, the FAA must ensure that current training, experience and medical standards are adequate to ensure the continued safety of the system.

C. VLJs Will Consume Limited FAA Resources

1. Initial Certification
With some 20 VLJ models in various phases of certification, FAA is applying significant resources in an effort to support manufacturers’ production and delivery schedules. While some certification work is handled indirectly by FAA through the designees, the direct burden on FAA is significant. FAA resources allocated to VLJ certification efforts delay other certification activity.

2. Ongoing Safety and Regulatory Oversight
After certification of the aircraft, FAA is responsible for ensuring that the users of VLJs comply with federal regulations applicable to their use of the aircraft. While oversight of individuals flying VLJs recreationally is relatively straightforward, oversight of large air taxi operators operating hundreds of aircraft is a complex and resource-intensive effort. In recent testimony before the House Aviation Subcommittee, the GAO observed that:

“Meeting the challenges posed by recent safety trends and program changes will be exacerbated by other changes in human capital management; the acquisition and operation of new safety enhancing technologies; and new types of vehicles, such as very light jets (VLJ), that may place additional workload strains on FAA inspectors and air traffic controllers.”⁷

3. Air Traffic Control
The performance of VLJs and their apparent incompatibility with existing traffic in the terminal and en route environment will make air traffic control more challenging. Mixing fast and slow traffic on high-altitude routes, as described previously, increases controller workload. Sequencing large and small aircraft in terminal areas to reduce the effect of wake turbulence adds complexity for controllers. In limited cases, FAA may be able to respond by adding additional controllers. The more common response will be to increase spacing to manage the difference in aircraft speeds and reduce workload. This results in wasted capacity and ultimately constraints on demand.

In the July 2005 issue of Flight Safety Digest, the director of safety and technology for the National Air Traffic Controllers Association, and a former controller, identified the relatively low cruising speeds of VLJs as the biggest concern for controllers:

“The biggest impact most likely will be in the en route environment…In the upper flight levels, speed will be an issue”

He also expressed concern that VLJs will have an impact similar to other, relatively slow aircraft:

“The early (Cessna) Citations are already an issue for us. As a controller, you have to be aware of their slower speeds so that you don’t run them down. The very light jets are going to create the same issue if they’re put into the same flow with commercial aircraft…I don’t think the VLJs will mix in well with the flow that we have today.”

4. Use of Flight Service Stations
The introduction of VLJs, or any aircraft other than those used by large commercial air carriers, will drive a proportionate increase in the use of Flight Service Stations (FSS). FSS provide flight planning, weather and other related services to pilots free of charge. As the number of users increases, so will the demand on FSSs. Unlike general, corporate and business aviation users, commercial airlines typically do not use FSSs.

V. UNMANNED AERIAL VEHICLES MUST ALSO BE CONSIDERED
An issue closely related to the introduction of VLJs is that of Unmanned Aerial Vehicles (UAVs). While not the focus of this particular hearing, ATA is concerned about the aggressive pace of their introduction into the NAS. Although most are used in military applications today, UAVs are rapidly being deployed in a variety of non-military surveillance roles.

Unfortunately, the nature and capabilities of most UAVs today, combined with operators’ apparent limitations in handling UAVs, require that large blocks of valuable airspace be quarantined when UAVs are in use. Clearly this approach is not a viable, long-term solution.

The aviation industry will continue to work collaboratively to develop certification standards and operational procedures that will allow UAVs to be safely integrated into the NAS.

VI. SUMMARY
VLJs are an exciting innovation and a testament to the capabilities of the U.S. aircraft manufacturers. Their long-term viability, however, will be governed by the ability of our National Airspace System to safely and efficiently accommodate them.
ATA believes that the successful integration of VLJs hinges on the following:

• FAA must ensure that robust standards are in place for certification, operation and training
• FAA must segregate incompatible traffic to streamline flows
• FAA must employ a reliable and equitable funding mechanism that links revenues to costs
• FAA must use that revenue to create capacity through modernization of the ATC system.

ATA will continue to advocate a safer, smarter and fairer system that satisfies the current needs of all users while scaling to meet future demand.

¹Members are: ABX Air, Alaska Airlines, Aloha Airlines, American Airlines, ASTAR Air Cargo, ATA Airlines, Atlas Air, Continental Airlines, Delta Air Lines, Evergreen International Airlines, Federal Express Corporation., Hawaiian Airlines, JetBlue Airways, Midwest Airlines, Northwest Airlines, Southwest Airlines, United Airlines, UPS Airlines and US Airways. Associate members are: Aerovías de México, Air Canada, Air Jamaica and Mexicana de Aviación.

² The total impact of commercial aviation is compared to national aggregates of Gross Outputs and Personal Earnings (from the Bureau of Economic Accounts) and Total Covered Employment (from the Bureau of Labor Statistics) for the 50 states and the District of Columbia combined.

³ Vaughn Cordle and Robert W. Poole, Jr., “Resolving the Crisis in Air Traffic Control Funding,” 2005.

⁴ Vern Raburn, president and CEO, Eclipse Aviation, October 15, 2005.

⁵ Commercial airliner tax revenue based on passenger, cargo and fuel taxes, and assumes 70% load factor. Cargo and fuel taxes derived from DOT Form 41.

⁶ Corporate VLJ tax revenue based on Part 91 operation and assumes full fuel load at departure.

⁷ United States Government Accountability Office, Testimony before the Subcommittee on Aviation, Committee on Transportation and Infrastructure, House of Representatives, GAO-06-1091T

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