"Peak-hour pricing" won't reduce airport congestion, building more runways will, AOPA tells DOT

Docket Clerk
Docket No. OST-2001-9849
Room PL-401
400 Seventh Street, SW
Washington, DC 20590

Re: Notice of Market-based Actions to Relieve Airport Congestion and Delay, Federal Register, April 22, 2002, page 19614, FR doc 01-20980

The Aircraft Owners and Pilots Association (AOPA), representing the interests of over 380,000 aviation enthusiasts and professionals nationwide, respectfully submits the following comments to the cited notice put forth by the Department of Transportation (DOT). The government's endorsement and participation in the concept presented in this notice would establish far greater governmental control and regulation of air commerce and the national air transportation system than is necessary without first being able to justify a direct and immediate benefit.

Airports in their most basic form exist to provide a transportation service to the air traveling public. Airports have a profound impact on the economic and social health of the communities in which they are located. Airports, a public utility, do not exist for the economic well being of airport proprietors, scheduled airlines, or other aircraft operators. Every airport in the United States is a part of the national air transportation system for the public's use and benefit. Actions taken at any airport in the national air transportation system to address congestion will have an impact on the other airports within the system. Market-based demand management options in particular must be evaluated on the basis of their total impact, not only to the national air transportation system, but also the public.

The absence of sufficient study, industry participation, modeling, and discussion on the effect of market-based demand management options makes it difficult to consider it a logical or beneficial approach to airport congestion at the present time. It is AOPA's belief that market-based demand management options to address airport congestion should only be utilized as a last resort. In the meantime, there are several options to addressing airport congestion that need to be fully explored and implemented. These options include:

1. Additional airport development. The most effective way to meet capacity demand is to expand current airports or providing alternative facilities.
2. Environmental streamlining processes for airport construction projects that include evaluating the expansion of categorical exclusions.
3. Advances in airport design that more efficiently address surface movements, runway design, terminal design, and taxiway and gate congestion.
4. More efficient use of terminal airspace including further development and utilization of automatic dependent surveillance-broadcast/cockpit display of traffic information (ADS-B/CDTI), passive final approach spacing tool (pFAST), and integrated terminal weather system (ITWS).
5. Development and utilization of additional simultaneous instrument approaches at airports to increase capacity during adverse weather conditions.
6. FAA involvement in regional, state, and national transportation planning. Currently, a clear national aviation policy emphasizing the implementation of an airport expansion and utilization plan is lacking.
7. Governmental incentives to the airline industry to consolidate multiple flights to a particular market through the utilization of larger aircraft where applicable or flexible flight scheduling. To this end, the federal government could utilize tax or other financial incentives.
8. On the basis of the FAA's capacity benchmark study, in coordination with the FAA, those airports should develop decongestion plans exploring all possible alternatives available at that specific facility that can be taken to meet capacity demands.

Market-based options for airport congestion will have an impact on all aircraft operators. General aviation, with the exception of air taxi operations, account for 8.3 percent of the total operations at the 31 busiest airports identified in the FAA's benchmark study. General aviation access to all airports in the national air transportation system must be permitted without a significant cost increase to those operators.

Airport congestion is largely an air carrier issue. However, it is only an airline issue to the extent that the public, for which the airlines serve, are not being denied access to the national air transportation system because of overcrowding. Rather, the typical airline traveler is merely experiencing an inconvenience with flight delays and cancellations. In so far as airport congestion is largely a customer service issue, governmental intervention endorsing market-based controls is not necessary.

To this end, if market-based options for demand management at airports are to be considered, we offer the following suggestions:

1. Market-based demand management options will not be revenue neutral. Therefore, all revenue generated by airports in excess of that required for the airports self-sustainability (49 USC § 47107) should be deposited into a fund to be utilized by all airports in the national air transportation system. In lieu of depositing the additional revenue into a fund for use by all airports, the additional money should at least be utilized by the federal government to institute a federal plan for airport decongestion. In no circumstances should the additional money remain with the airport sponsor, be used to subsidize air carriers, or to advance air carrier development at airports.
2. General aviation access to all airports in the national air transportation system needs to be preserved in a fair and reasonable manner.
3. The capacity benchmarks established by the FAA should be used as the basis for determining location implementation and determination of off-peak hours and conditions for market-based options. As such, the FAA's capacity benchmarks should be expanded and the goals of the program included in the FAA's Operational Evolution Plan (OEP).
4. The impact of market-based options on regional airports and the essential air service act need to be fully evaluated. Undoubtedly, there will be an impact.
5. When determining the economics involved in market-based options, one must consider the ability of air carriers to pass along fees to passengers. This is a luxury the typical general aviation operator is not afforded. Given this, market-based options should not be considered an effective deterrent for the airline industry to cut operations during peak hours.
6. The coordination and flow of traffic during specific time periods and during a variety of conditions is an important aspect affecting the efficiency of demand-management options. As such, any policy on demand management options must be coordinated with FAA offices responsible for airspace.

AOPA is deeply concerned that market-based demand management options will be seen as the solution to airport congestion. That simply is not and cannot be the case. Demand-management options should only be considered after all alternative solutions have been fully explored. Discussion within DOT and throughout the entire aviation industry would be more effectively spent focused on capacity expansion, not options that would create constraint. AOPA suggests there be further discussion other airport capacity options. We look forward to participating in those discussions and maximizing the long-term benefit of the national air transportation system for the public.

Respectfully,

Andrew V. Cebula
Senior Vice President, Government and Technical Affairs
Aircraft Owners and Pilots Association

July 17, 2002