Statement of Dennis E. Roberts
Vice President and Executive Director
Government and Technical Affairs
Aircraft Owners and Pilots Association
before the
Federal Aviation Administration
Joint Resource Council (JRC)
Mr. Steve Zaidman, ARA-1
Mr. Tom McSweeney, AVR-1
concerning
SatNav Investment Analysis Decision
September 2, 1999
Good Afternoon. My name is Dennis Roberts. I am vice president and executive director of Government and Technical Affairs for the Aircraft Owners and Pilots Association. I also co-chair of the Satellite Navigation Users Group, which Jack (Ryan) and Dr. Rovinsky referred to as the SNUG. I serve in this capacity with my co-chair, Bob Frenzel of ATA. This user group has come together to develop a transition plan that will take us from the current system of ground-based navigation aids to a future system involving satellites. AOPA and ATA are joined on the SNUG by representatives from the CAA, HAI, NBAA, RAA, and the DoD.
Speaking on behalf of both AOPA and the SNUG, we want to thank the FAA for this opportunity to again provide input on a very critical element of the FAA’s NAS modernization program. Previously, we provided input to the JRC on Nexcom. We feel user input and comments should be the standard at all JRC meetings, especially where policy actions involving users are involved.
As you know, AOPA supports the implementation of satellite navigation and the goal to move away from the traditional ground-based navigation system. To this end, we have worked with ATA and other user organizations to help the FAA define a transition strategy that can be supported by both the users and service providers alike.
Throughout the development of the SatNav Investment Analysis, AOPA and the user community participated in Dr. Rovinsky’s team’s activities. We thank you and he for this opportunity. After carefully analysis of the document before you today, we believe the final benefits/cost ratio to be valid; however, extremely conservative. As was noted previously, the original 1998 GPS I/A baselining effort produced very bullish results—denoting an extremely high rate of return on the federal investment. Consequently, those results were received both by industry and on Capitol Hill with a great deal of skepticism. However, this study depicts a much different story.
According to Dr. Rovinsky, many safety, economic, and environmental benefits derived from the implementation of a GPS WAAS/LAAS system could not be quantified under existing federal I/A rules. However, these benefits are significant and should be considered in your deliberations prior to making a final decision on this program. Despite the conservative evaluation criteria, this study indicates a 2.4/1 C/B ratio, a number well exceeding the minimum criteria for a major federal investment.
I don’t need to tell any of you that satellite navigation is a critical element of the NAS modernization program and serves as the foundation on which most ATC system improvements will be built. In reality, it is the enabling, crucial technology necessary to maintain the industry consensus for NAS modernization and more specifically, the Free Flight Phase I program as well as future phases. Without it, there is no consensus.
Given the cost and complexity of the WAAS program and the scrutiny to which it’s been subjected, we fully understand the FAA’s cautiousness to move forward at a rapid pace. However, we believe any further scrutiny that fails to add to the program or answer critical path questions will only delay the delivery of operational benefits—thus increasing both FAA and user costs. Bottom line—it’s time for the FAA to eliminate the “paralysis of analysis” and get on with the program.
However, before you do that, there are several points of clarification and concern we need the FAA to address.
The first involves the 2002 checkpoint Dr. Rovinsky and Mr. Ryan referred to. We, like ATA and members of the SNUG, want the FAA’s assurance this checkpoint is only an evaluation of the implementation plan’s progress. At this point, decisions on the timing of the additional GEOs can be made. In no uncertain terms should the FAA consider this a “bail-out” point because users’ equipage rates. As Mr. Ryan noted, two years is far too short a time to determine equipage rates and cancel the program should the rates fall below some arbitrary level established by the FAA.
Speaking of equipage, we have always said that any equipage, particularly by the general aviation fleet, must be tied to added benefits for the users. However, in order to achieve these benefits, the FAA must do a number of items as well. It’s really a “cause and effect” issue here. FAA action is required in order for us to receive the promised benefits that justify the financial investments asked of our members.
Specifically, the FAA must (1) develop new instrument approach procedures to airports. In the investment analysis, some 3,000 new runway ends are identified. Secondly, the FAA must work on expanding satellite navigation capabilities. Items such as enhanced surveillance (ADS-B), CFIT avoidance, and curved approaches to reduce environmental and operational impact are but a few areas where SatNav can improve system safety and efficiency. Lastly, and probably most importantly for general aviation, is the development and accessibility of an affordable GPS database. Without these items, general aviation will be hard pressed to find any advantages or operational benefits from this system.
In summary, again I note despite the analysis being very conservative, the 2.4/1 C/B ratio is positive and justifies the JRC’s adoption. Now is the time to make a decision, set the future course for SatNav, develop and implement a transition strategy, and move on.
Failure on the part of the FAA and you as members of the JRC to positively act on this matter will result in continued confusion over the program’s direction—not only within FAA offices but also by the aviation user community, the manufacturers’ R&D planning efforts, on Capitol Hill, and with international consortiums who seem to have their own opinions on how SatNav should be implemented.
AOPA fully supports the recommendations included in the investment analysis and strongly urges the JRC to adopt them as their own. Speaking on behalf of both AOPA and the entire Satellite User Group, if the JRC favorably endorses this plan, we pledge to work with the FAA to gain support both with the users and on Capitol Hill to see these recommendations are carried out. We also look forward to our continued work with the FAA on developing a logical plan for transitioning to a satellite-based navigation system and the decommissioning of the existing navigational system’s infrastructure.
Thank you again for the opportunity to provide user input to the very critical program.
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