Docket No. OST-2001-9849
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:
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:
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.
Andrew V. Cebula
Senior Vice President, Government and Technical Affairs
Aircraft Owners and Pilots Association
July 17, 2002