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Testimony on Aviation and the Environment: Emissions

Sat, 22 Jan 2011 08:34:00 GMT

Testimony on Aviation and the Environment: Emissions

May 6, 2008

What's at Issue

Statement
of the
National Air Transportation Association

before the
Subcommittee on Aviation,
Committee on Transportation and Infrastructure,
U.S. House of Representatives:

Hearing on
Aviation and the Environment: Emissions

May 6, 2008
2167 Rayburn House Office Building
Washington, DC

Appearing for NATA:

James K. Coyne, President
National Air Transportation Association
4226 King Street
Alexandria, Virginia 22302
(703) 845-9000

Chairman Costello, Ranking Member Petri, and Members of the Subcommittee:

Thank you for this opportunity to appear before you to discuss our members' efforts to minimize the impact our industry has on the environment.

My name is James K. Coyne, and I am president of the National Air Transportation Association (NATA). NATA, the voice of aviation business, is the public policy group representing the interests of aviation businesses before the Congress, federal agencies and state governments. NATA's over 2,000 member companies own, operate and service aircraft and provide for the needs of the traveling public by offering services and products to aircraft operators and others such as fuel sales, aircraft maintenance, parts sales, storage, rental, airline servicing, flight training, Part 135 on-demand air charter, fractional aircraft program management and scheduled commuter operations in smaller aircraft. NATA members are a vital link in the aviation industry providing services to the general public, airlines, general aviation and the military.

Background

Climate change is an important topic and one that includes all of U.S. industry. The aviation industry is one of the fastest growing sectors of the economy, and attention has been focused on carbon dioxide emissions from aircraft. The industry has adopted an environmental agenda that also supports aviation's continued growth. This agenda includes testing alternative fuels to be used in aircraft, participation in carbon offset programs, and encouraging "green airports." It is important to highlight the facts on emissions concerning aviation:

Aviation accounts for only 3% of greenhouse gas emissions worldwide, according to data from the Intergovernmental Panel on Climate Change (IPCC).

Aviation gasoline and jet fuel account for 12% of all petroleum products. According to data from the U.S. Department of Energy, aviation gasoline and jet fuel supply account for 1,624,000 barrels per day compared to 20,588,000 barrels of all petroleum products used per day.

Alternative fuels programs exist within aviation. Virgin fuels, Boeing, and GE Aviation have joined forces to develop an alternative fuel that includes a biofuel blend composed of babassu oil and a mixture of jet fuel and coconut oil. Additionally, the University of North Dakota received a $5 million grant to develop a cold weather sustainable biofuel to be used by the military.

New aviation technology is producing cleaner and more efficient aircraft. Advances in aerodynamics offer more efficient wings and designs with less drag. The Cirrus and Columbia aircraft are examples of more efficient general aviation aircraft. New composite materials are making aircraft lighter in weight, which results in increased fuel efficiency.

NATA Climate Initiative

NATA's members have been very active in addressing ongoing concerns with the general aviation industry's impact on the environment. Late last year, NATA established its Environmental Committee to develop programs designed to assist member companies in minimizing their impact on the environment including the development of a new Climate Initiative that would provide NATA members with the opportunity to purchase carbon offsets for their aircraft operations. Below is a brief description of the new NATA Climate Initiative:

Carbon Offsets:

Carbon offsetting involves reducing emissions by investment in projects that save energy, such as investment in technology that allows industry to be more efficient and increasing the generation of renewable energy. NATA is establishing a program to make carbon offsets available to member companies. This includes a 3- to 4-cent per gallon carbon offset based on the Chicago Climate Exchange, the only voluntary, legally binding integrated trading system to reduce emissions of all six major greenhouse gases (GHGs), with offset projects worldwide.

Green Aviation Facilities:

NATA encourages its member companies to meet proper environmental compliance standards including a Spill Prevention Control and Countermeasure (SPCC) plan, if fuel is stored above ground in tankers. The association is currently undertaking the development of best management practices that will allow aviation businesses to capitalize on becoming more energy efficient and minimizing their company's impact on the environment. To date, NATA has crafted best management practices for the following topics (note: each topic has a white paper that is attached at the back of this testimony):

Spill Prevention Control and Countermeasures (SPCC)
Hazardous Waste
Storm Water
Used Batteries
Used Oil
Used Fluorescent Lamps

Public Relations Campaign

NATA is currently developing a public relations campaign to provide the facts about aviation's impact on the environment and what the association's members are doing to ensure the protection of the world's environment.

First, let's review the magnitude of carbon emissions for aviation as compared to other modes of transportation. The U.S. Department of Energy (DOE) has issued a publication titled Transportation Energy Data Book: Edition 26 (June 1, 2007). In this publication, the DOE provides an annual statistical compendium designed to characterize transportation activity and explore data on other factors that influence transportation energy use. Much of this publication is just the numbers, but an analysis of this data can provide some very interesting insights. In order to obtain a relative comparison of the magnitude of carbon emissions for different modes of transportation, an analysis of fuel consumption is used. Because different types of fuel (gasoline, diesel fuel, jet fuel to name a few) provide different energy values, the data is normalized by looking at the energy use in British Thermal Units (BTUs). This provides a better comparison than actual gallons of fuel consumed. The table below shows the energy use for aviation and several other modes of transportation.

Mode of Transportation	BTUs Used (Trillions) in 2005	Percent of Total

Aviation	2,477	9.0%
Cars	9,140	33.4%
Light Trucks	8,108	29.6%
Medium/Heavy Trucks	4,577	16.7%
Water	1,366	5.0%
Pipeline	842	3.1%
Rail	657	2.4%

The table shows that aviation accounts for only 9% of the total transportation energy use. Cars and light trucks each use more than three times the energy as the aviation industry, and medium/heavy trucks account for about twice that of aviation. Highway transportation (cars, light trucks, and medium/heavy trucks) combine for almost 80% of the transportation energy and thus contribute a similar level of greenhouse gases. Aviation, on the other hand is a much smaller contributor to energy use and greenhouse gas emissions.

Further analysis within the aviation group shows the relative contribution of commercial aviation versus general aviation. The table below shows this comparison.

Mode of Transportation	BTUs Used (Trillions) in 2005	Percent of Total Transportation

Aviation	2,477	9.0%
Domestic Carriers	1,861	6.8%
International Carriers	373	1.4%
General Aviation	242	0.9%

General aviation accounts for less than one percent of the total transportation energy use in the United States and its fuel use is about one seventh that of the domestic air carriers.

The analysis of the relative efficiency of fuel use for different modes of transportation includes several additional factors. This analysis includes normalizing the data using the BTU content as did the previous analysis, but also includes the average passengers per vehicle, and provides a conversion into an equivalent miles per gallon (MPGe) based on the BTU content of gasoline (115,000 BTU per gallon). For example, automobiles have an average passenger use of 1.57 passengers per car. Using the DOE data, we find that cars use on average 3,496 BTUs per passenger mile and this corresponds to approximately 33 MPGe. The table below shows several modes of transportation and their corresponding MPGe.

Mode of Transportation	Average Passengers per Vehicle	BTUs per Passenger Mile 2005	MPG Equivalent

Aviation	90.4	3,959	29 MPGe
Cars	1.57	3,496	33 MPGe
Light Trucks	1.72	4,329	27 MPGe
Rail (Commuter)	32.9	2,569	45 MPGe
Rail (Intercity- Amtrak)	17.9	2,760	42 MPGe
Bus (Transit)	8.7	4,318	27 MPGe

This table shows that aviation provides the greatest average passengers per vehicle and the resulting MPGe of 29 is roughly the same as cars and light trucks. With the vast advantage of moving large numbers of people quickly over many miles, the aviation industry is a very efficient mode of transportation.

In summary, this analysis of transportation modes shows that aviation provides a very efficient mode of transportation and compares similarly to typical highway transportation (cars and light trucks) in per passenger equivalent miles per gallon. Additionally, the aviation industry contributes a much smaller percentage (about 9%) of the total energy use and thus contributes a much smaller percentage of greenhouse gas emissions as compared to highway transportation (about 80% for cars, light trucks and medium/heavy trucks).

Industry Actions

Two prime examples of NATA members being proactive on the environmental front are NetJets Inc. and DayJet Corporation.

NetJets Inc.
On September 13, 2007, NetJets Inc. Chairman & CEO Richard Santulli announced the company's new multifaceted program to address the impact of its flight operations on the environment.

The initiative, which will be expanded in the coming months, includes a focus on offsetting carbon emissions from NetJets' flights, while at the same time it begins to reduce the carbon footprint of NetJets' operations worldwide. It also includes a substantial investment in leading-edge technology research with the goal of creating an ultra-low emission jet fuel.

The following core elements of the initiative are the results of a detailed environmental review process undertaken by NetJets beginning in early 2006:

1. Improving Energy Efficiency and Reducing Greenhouse Gas Emissions - NetJets U.S. has established a goal of improving its energy efficiency, cutting waste, and reducing carbon emissions from its internal operations by 10% over the next two years. It has established Director of Environmental Management positions, reporting to the Office of the Chairman, in both the United States and Europe. These senior executives will manage, monitor, and report regularly on NetJets' progress and any ongoing challenges, as well as helping to identify new opportunities to do more in the coming months and years.

2. Driving Technological Transformation - NetJets is investing in cutting-edge research to identify more environmentally friendly aviation technologies through sponsoring The Next Generation Jet Fuel Project at Princeton University with the University of California, Davis to develop an ultra-low emission jet fuel.

3. Offsetting Unavoidable Impacts - NetJets is investing in a set of carefully reviewed and closely monitored carbon offset projects that will provide verified greenhouse gas reductions. These projects will allow the company to offset fully the carbon footprint of its internal operations. The offset portfolio will also be available to NetJets Owners so they can offset their flights. Additionally, Marquis Jet Partners will make the NetJets carbon offset portfolio available to Marquis Jet Card Owners.

4. Leveraging World Class Expertise - To ensure that NetJets remains a leader on climate issues, the company has established both U.S. and European advisory boards - each consisting of environmental experts who can help NetJets apply best-in-class practices and provide guidance to the company at every step along the way. The U.S. Advisory Board consists of Fred Dryer, Professor of Mechanical and Aerospace Engineering at Princeton University; Ashok Gupta, Director of the Air and Energy Program at the Natural Resources Defense Council; Terry Tamminen, former Secretary of the California Environmental Protection Agency; Bonnie Reiss, Operating Advisor to Pegasus Capital and founder of the Earth Communications Office; and George Favaloro, Managing Partner at Esty Environmental Partners.

NetJets realizes that its responsibilities also extend to the communities in which it operates. With this in mind, it will build on these four areas of immediate commitment by launching a community-based Solar Schools Project. Beginning in California and drawing on Governor Arnold Schwarzenegger's environmental leadership, this innovative public-private partnership will fund the placement of photovoltaic cells on school roofs - while in the process educating school children about environmental issues.

DayJet Corporation
Dayjet Corporation has produced a Very Light Jet Footprint Analysis Concept Paper to ensure that it maximizes its operations by using state-of-the art technology while minimizing its impact on the environment. A description of this concept paper can be reviewed below:

Introduction
DayJet Corporation is a technology-driven company, pioneering the creation of the on-demand, per-seat air, regional transportation market. In spearheading the use of the new generation of very light jets (VLJs) in air carrier service, DayJet is committed to building on the inherent efficiencies and favorable footprint of the Eclipse 500 aircraft, toward the long range goal of sustainable air transportation. DayJet's strategies are informed and motivated by the emerging understandings of the epochal challenges of managing carbon dioxide and other greenhouse gas effects on climate dynamics. DayJet strives to translate the understanding from the climate science community to applications on how the company manages the effects of its aviation activities. DayJet works to apply these understandings to its company strategies for technology, for operations, and for business practices.

DayJet's strategic framework for moving toward a sustainable business in on-demand air transportation includes three major phases of technology implementation over the near term (two to four years), mid-term (four to six years), and longer term (more than six years).

Near Term: This phase of the strategy focuses on reducing carbon emissions through airspace efficiencies. With the Federal Aviation Administration, DayJet plans the early implementation of certain of the operating capabilities envisioned in the U.S. Joint Planning and Development Office (JPDO) vision for the Next Generation air transportation system (NextGen). This vision underpins transformation of the national airspace toward a performance-based air traffic management system. This system incorporates performance-based navigation, surveillance and communications technologies. The technologies associated with this transformation include Required Navigation Performance (RNP), Area Navigation (RNAV), and Automatic Dependent Surveillance-Broadcast (ADS-B). These technologies let DayJet optimize its flight routes for savings in energy, carbon and noise. When implemented, these optimized routes will reduce fuel consumption for the company's networked fleet operation by an estimated 15 percent and more. These fuel savings translate directly into emissions reductions. DayJet's business model operates effectively using the second- and third-tier airports serving the nation's smaller suburban, rural and remote communities. These airports are largely underutilized national assets, with virtually none of the congestion and delays issues that would add unacceptable costs to DayJet's operations. At these smaller airports, as a consequence, DayJet is able to operate with greatly reduced ground times from engine start to takeoff and from landing to engine shutdown. The effect is to reduce emissions that would affect local air quality around airports.

Mid Term: This phase of the strategy focuses on alternative fuels that reduce carbon and other emissions. DayJet supports fuel strategies that enable movement toward carbon neutral practices across the company's industrial sector. Because DayJet's business model calls for approximately a five-year life cycle for its aircraft, the company will be in a position to provide aircraft and engines coming out of its fleet for testing of new fuels.

Longer Term: This phase of the strategy focuses on being early adopters of advancing aircraft and propulsion systems that do not add carbon and other greenhouse gases to the environment.

Based on this framework, DayJet is undertaking action in five arenas:

Engines- DayJet works with the aircraft and engine manufacturers toward continual improvement in the efficiencies and emissions from flight operations, for the current and future generations of equipment.

Fuel- DayJet collaborates with the university research community on modeling, analysis, and strategies for continual improvement of the footprint for on-demand air transport operations using VLJs and other technologically advanced aircraft. DayJet is engaged in planning dialogue with Embry Riddle Aeronautical University (ERAU), Florida Institute of Technology (FIT), Florida Atlantic University, and the University of Central Florida (UCF) to establish relationship strategies leading to creation and adoption of new technologies.

NextGen Airspace Efficiencies- DayJet partners with other on-demand air transportation service providers to accelerate the early adoption of the operating capabilities envisioned in the U.S. Joint Planning and Development Office (JPDO) Next Generation Air Transportation System (NextGen). NextGen technologies reduce the footprint of DayJet's fleet operations.

Neutralizing Carbons- The DayJet service model is conceived to offer regional business travelers an alternative to highway travel. This means that the aggregation of travelers on a DayJet trip can be carbon-competitive with highway transport alternatives in certain specific cases. In the nearest term, DayJet will implement strategies for airspace efficiencies with the goal of advancing toward carbon-competitive effects of on-demand air travel, relative to highway alternatives.

Sustainable Business Practices- DayJet manages unavoidable carbon emissions through careful assessment of total company operations with the aim of achieving verified greenhouse gas reductions. The goal is to reduce where possible and to otherwise offset the carbon footprint of the company's internal operations.

Tropospheric Flight
The questions regarding potential fuel efficiencies (and therefore carbon sourcing) of on-demand, networked fleet operations of VLJs include the effects of flight in the troposphere versus the stratosphere. The initial assessments by the International Panel on Climate Change (IPCC) regarding the effects of aviation on the environment focused on flight in the stratosphere. These past studies published first in 1999i. and then reviewed in 2006ii. summarize the three most important ways that aviation affects the climate:

Direct emissions of greenhouse gases specifically CO2 and water vapor
Nitrogen oxide emissions interacting with ozone and methane
Contrail-induced cirrus cloud formation

A new generation of aircraft referred to as very light jets (VLJs), and a new generation of on-demand air transportation service business models are now emerging in regions of the United States, as well as in Europe and other continents. These new business models influence the characteristics of fleet operations using these new VLJs. These operations will share common characteristics in flying relatively shorter segments and in making effective use of mid-altitudes that are not extensively used by larger air carrier transports. In particular, because the average flight segment length in these regional transportation services is approximately 300 miles, and because of airspace utilization and traffic flow considerations, the typical flight levels for these fleet operations are below 26,000 feet, well below the stratosphere, and within the troposphere.

Based on these operational realities, we plan to support research focused on the following four topics:

Comparative greenhouse effect of water vapor emitted by VLJs between 18,000 and 26,000 feet, versus in the stratosphere
Comparative effect of nitrogen oxide emitted by VLJs between 18,000 and 26,000 feet on atmospheric ozone versus emissions in the stratosphere
Implications of the effect of NOx-induced depletion of methane for NOx emissions in the troposphere
Reduced effect of cloud formation due to absence of contrails by VLJs flown in the troposphere
Effect of lowered propulsive efficiency in the troposphere versus higher propulsive efficiency in the stratosphere on overall carbon dioxide emissions, for VLJs. The results of this analysis will lead to engine design requirements for operating turbofans such as the Geared Turbofaniii. in the mid altitudes.

The state of the art in climate modeling is limited in terms of providing reliable estimates for the specific aviation-induced radiative forcing effects. Even so, perhaps the relative effects of stratospheric and tropospheric flight can be considered. A rule of thumb in climate science estimates that each unit of fuel burned by stratospheric air transport flights has the greenhouse effect of three times that of ground transport iv. Further, it is estimated that the radiative forcing from persistent contrails and contrail-induced cirrus clouds (PCC) exceeds the contributions from all other aviation-induced RF combined v. However, quantitative analysis is absent regarding the effect of flying in the troposphere specifically by VLJs. We plan to support analysis to provide quantitative information regarding this distinction.

Legislative Actions

Clearly Congress will have a vital role in outlining the next steps necessary to mitigate aviation's footprint on the environment. The U.S. House of Representatives' FAA Reauthorization bill, H.R. 2881, provides an outstanding blueprint for the aviation industry to utilize new technologies through the legislation's support of the Next Generation Air Transportation System.

Since last year, NATA members have been strongly encouraged to support H.R. 2881, a bill approved by the U.S. House of Representatives that would provide historic funding levels, nearly $13 billion, for the FAA's Facilities and Equipment (F&E) account that will accelerate implementation of the Next Generation Air Transportation System (NextGen). NextGen is the FAA's national plan to transform the air traffic control system from a ground-based navigation system using radar to a satellite-based system. This legislation will enable the FAA to make needed repairs and upgrades to existing facilities and equipment, and provide for high-priority safety-related systems.

By utilizing new technologies, airspace routes can be better defined, allowing more aircraft and more routes to be determined within the airspace. And most importantly, utilizing new technologies to improve airspace usage, aircraft will be able to fly routes more directly, thereby minimizing noise and the impact on the environment.

The demand for air travel is increasing steadily. The FAA projects that by 2025 the number of domestic enplanements will have doubled to 1,482 million per year. The environmental impact of air travel is increasingly important to consumers, which is why the aviation industry is collaborating to address this important issue.

Thank you for the opportunity to testify, and I will be happy to answer your questions.

___________________________________
i. International Panel on Climate Change Special Report: Aviation and the Global Atmosphere - Summary for Policy Makers, 1999.
ii. Workshop on the Impacts of Aviation on Climate Change: A Report of Findings and Recommendations. June 7-9, 2006 Cambridge, MA, August 2006.
iii. Pratt & Whitney reference TBD
iv. Noppel, F.; and Singh, R.: Overview of Contrail and Cirrus Cloud Avoidance Technology. Journal of Aircraft, Vol. 44, No. 5, Sept-Oct 2007, pp. 1721-1726.
v. Sausen, R., Isaksen, I., Grewe, V., Hauglustaine, D., Lee, D., Gunnar, M., Kohler, M. O., Pitari, G., Schumann, U., Stordal, F., and Zerefos, C.: "Aviation Radiative Forcing in 2000: An Update on IPCC (1999)," Meteorologische Zeitschrift; Acta Scientiarium Naturalium Universtatis Normalis Hunanensis, Vol. 14, No. 4, Aug. 2005, pp. 555-561.

Staff Contact:

Eric Byer
Vice President, Government & Industry Affairs
NATA
ebyer@nata.aero

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NATA Testimony on the FAA Reauthorization Act of 2009

Sat, 22 Jan 2011 08:32:00 GMT

Statement for the Record
of the
National Air Transportation Association

before the
Subcommittee on Aviation
Committee on Transportation and Infrastructure
U.S. House of Representatives

Hearing on
Federal Aviation Administration Reauthorization Act of 2009

February 11, 2009
2167 Rayburn House Office Building
Washington, DC

Chairman Costello and Ranking Member Petri, the National Air Transportation Association (NATA) appreciates the opportunity to submit the following statement to be included in the record for the Subcommittee’s February 11, 2009 hearing regarding the Federal Aviation Administration Reauthorization Act of 2009.

NATA, the voice of aviation business, is the public policy group representing the interests of aviation businesses before Congress, federal agencies and state governments. NATA's 2,000 member companies own, operate and service aircraft. These companies provide for the needs of the traveling public by offering services and products to aircraft operators and others such as fuel sales, aircraft maintenance, parts sales, storage, rental, airline servicing, flight training, Part 135 on-demand air taxi, fractional aircraft program management and scheduled commuter operations in smaller aircraft. NATA members are a vital link in the aviation industry providing services to the general public, airlines, general aviation, and the military.

NATA strongly believes that modernizing the nation’s air traffic control system is an absolute necessity. With air traffic reaching record levels in both the commercial airline and general aviation sector, it is imperative that Congress and the Federal Aviation Administration (FAA) work together to create a vision that will accommodate all facets of the industry. Additionally, the economy is having a tremendous effect on the aviation industry and NATA is hopeful that the increase in funding for the Airport Improvement Program and FAA Facilities and Equipment provided in the bill will benefit aviation infrastructure while creating jobs.

Below are a number of key issue areas affecting NATA member companies that should be addressed in this important legislation.

Repeal the Fuel Fraud Provision
A provision to repeal the fuel fraud tax that was contained in the House and Senate versions of the FAA reauthorization bills from the 110th Congress should once again be included in the final bill in the 111th Congress. The purpose of the fuel fraud tax was to counter potential fuel fraud from highway truck drivers buying aviation jet fuel and mixing it with another substance to make it operable in highway trucks to avoid higher taxes. The tax resulted in an increase in funds to the Highway Trust Fund that would have otherwise been deposited into the Airport and Airways Trust Fund. The new fuel tax collection procedures posed a problem for aviation operators because they are required to submit additional paperwork for tax refunds. In the event that an operator or fuel provider does not apply for the refund, the aviation trust fund receives no revenue from the legitimate sale of the aviation jet fuel.

Removal of untaxed, undyed jet fuel from the terminal rack creates tax evasion incentives and opportunities that may result in the loss of not only federal aviation taxes but, more importantly, also federal and state diesel fuel excise taxes because jet fuel can be used in on-road diesel trucks. The repeal of this provision is justified because the large tax increases for aviation kerosene included in FAA reauthorization legislation remove the incentive for fraud.

No User Fees on General Aviation
A common misconception is that general aviation does not contribute to the Airport and Airway Trust Fund. Currently, general aviation operators pay into the Airport and Airway Trust Fund through a fuel tax of 21.9 cents per gallon for aviation jet fuel and 19.4 cents per gallon for aviation gasoline. Furthermore, on-demand air charter operators pay the same ticket and fuel taxes as scheduled airlines due to their classification as commercial operators. NATA has long argued that the fuel tax for non-commercial general aviation is the best method for paying into the Airport and Airway Trust Fund because it guarantees a consistent and efficient stream of funding by using a streamlined tax imposition and collection structure.

User fees would be detrimental to general aviation businesses in the United States for the following reasons:

Safety implications: If aircraft operators are assessed special fees for using air traffic control services or certain airports, general aviation pilots may attempt to lower costs and choose not to use all available resources for flying safely. User fees would have a negative impact on safety.
Increased cost to non-scheduled operators: Airline advocates have argued that all eligible operations should pay the same fee because air traffic control does not differentiate between types of aircraft and therefore each aircraft that uses air traffic control services should be classified the same. This argument fails to account for the fact that airline travel is what drives the cost of air traffic control services.
Less general aviation activity: User fees would undoubtedly result in many operators flying on a much less frequent basis due to the increased costs of using the aviation system. Less activity will have a large ripple effect throughout the industry, with many businesses suffering due to decreased fuel sales, maintenance projects, and other services.
A tremendous administrative burden and new bureaucracy: Virtually all countries that have implemented a user fee system have adopted a method of billing users of the system for the air traffic services used after their particular flight. None of these countries, however, have the significant level of general aviation activity found in the United States. A system of “after the fact” bills would result in a massive administrative burden for all general aviation pilots and the creation of a mammoth new bureaucracy to oversee a system for tracking fee-triggering activities, identification of the proper entity to bill, verifying that payments are received and resolving disputes. Meanwhile, users will have to dedicate significant resources for verifying the bills’ accuracy. The current fuel tax ensures that the Airport and Airway Trust Fund will receive the appropriate contribution as the fuel is purchased, without having to wait weeks and possibly even months for payment.

FAA Standardization of Regulatory Interpretations
One of the biggest burdens confronting the general aviation industry is the varying interpretation of the FAA regulations by the agency’s Regional, Aircraft Certification (ACOs) and Flight Standards District Offices (FSDOs). Currently, there are 9 FAA regions, 10 ACOs and more than 80 FSDOs that each issue approvals on a wide range of maintenance and operational requests made by regulated entities such as Part 135 on-demand charter operators, Part 145 repair stations, and Part 141 and 61 flight training facilities. These regulated entities are constantly challenged by regulatory interpretations that vary from one inspector within one FSDO or ACO to another and are estimated to cost general aviation businesses hundreds of millions of dollars annually when previously approved actions are subject to “re-interpretation.” Inconsistent and varying interpretations of compliance also demonstrate a shortcoming in the FAA’s ability to coordinate its workforce and ensure that the decision-making abilities vested in inspectors are respected across all divisions of the agency, impairing efforts to achieve a uniform safety standard nationwide. NATA recently surveyed its members and found that eighty-nine percent felt that their businesses have suffered due to inconsistent interpretations of federal regulations within the FAA.

A General Accounting Office (GAO) report has been requested to review how inconsistent regulatory interpretations are costing the FAA and the aviation industry hundreds of millions of dollars in resources, while raising serious concerns about unified safety standards. NATA is hopeful that the results of the report will prove the significance of the issue and signify a need for change within the FAA. Congressional support for this GAO study to address this growing problem is critical.

Airports Providing Aviation Services:
In a growing trend, airport operators are seeking financial growth at their airport by competing with, or in some cases taking over the services of, fixed base operators (FBOs) by providing aeronautical services such as fueling or maintenance at their airport. Current conditions in the aviation industry, including the distressed financial condition of the airline industry, have left airport operators scrambling for alternate sources of revenue. Aviation businesses at the airport are among their first targets in the search for this increased revenue stream. While it is the airport sponsor’s right to venture into the business of providing aeronautical services, this practice can have detrimental effects for both the airport and its tenants. The practice of airport authorities seeking to compete with private business at the airport results in strained tenant/airport operator relations at the airport, is not cost effective, and usually has a negative impact on the airport’s attempts to achieve greater operating and financial targets. By entering into the ground support side of operations, an airport authority is distracted from its duties of managing the airport successfully. Anti-trust laws are also an issue, especially in cases when a local or state government runs the airport.

There is a high cost to be paid when government competes with private industry. Economic effectiveness is the largest problem, as government-run ventures are neither as responsive nor cost-effective as private industry. When a government entity, such as an airport authority, duplicates what is provided in the competitive market, government pre-empts competition, stifles entrepreneurial opportunity, destroys economic growth, and raises the price of doing business at the cost of the taxpayer. While airports may offer a less expensive product, they are able to do so because they are subsidized by the taxpayer. The government-run “business” is then able to eliminate market incentives that produce economic efficiency and greater wealth for both buyers and sellers.

Elimination of these businesses also impacts local, state and federal tax revenues. Private enterprises pay property taxes and annual income taxes from which government owned and operated businesses are typically exempt. A provision should be included that prohibits airports from providing aviation services.

NextGen
The existing U.S. air routes operate as narrow, pre-determined paths in the sky, thus airspace is crowded between airports with the most air traffic. Aircraft are separated from each other by defined vertical and horizontal distances. The architecture of the current ground-based navigation system does not allow for the use of the abundance of the entire airspace system. By utilizing new technologies, airspace routes can be better defined, allowing more aircraft and more routes to be determined within the airspace.

NextGen’s satellite-based system technologies include:

Automatic Dependent Surveillance – Broadcast (ADS-B)
Required Navigation Performance (RNP)
Satellite-based Area Navigation (RNAV)
Lateral Precision with Vertical Guidance (LPV) approach capabilities

NextGen’s innovation benefits to general aviation include:

Greater access to terminal airspace
Sustains small airports
Improved weather information

Provisions to Improve Environmental Impact
As climate change becomes a worldwide concern, all modes of transportation are adopting measures to reduce carbon emissions. While much has been written about the role aircraft play in generating emissions, it is important to highlight the scientific facts related to aviation emissions. It comes as a surprise to many that aviation accounts for less than 3% of greenhouse gas (GHG) emissions worldwide. Additionally, aviation gasoline and jet fuel account for 12% of total petroleum consumption, according to the Transportation Energy Data Book published by the U.S. Department of Energy.

Despite its small percentage of emissions, the aviation industry recognizes the importance of further minimizing its environmental impact and is being proactive in adopting an agenda that supports a sustainable environment. This is true across the industry, including general aviation, commercial airlines, airports, manufacturers and ground handlers.

Since 2000, aviation GHG emissions have been reduced by 13% as general aviation and commercial airlines have done a better job of transporting passengers on less fuel, including harmonizing schedules, increasing load factors, switching to more fuel efficient aircraft and engines, and decreasing idling times to reduce fuel consumption. More efficient general aviation aircraft such as the Cirrus and Columbia are being made of composite materials that are lighter and more fuel efficient. On the ground, airports and ground handlers are investing in infrastructure to reduce fuel use, such as fuel hydrant systems to reduce fuel truck usage and low-emission vehicles and ground support equipment.

Much like the automobile industry, the aviation industry is investing in research and development of new clean energy and alternative fuel technologies. Private companies are developing and testing hydrogen fuel cells and biofuel blends. The general aviation industry is concerned that Congress will impose stringent regulations, particularly on emissions, that will be detrimental to the aviation industry.

Conclusion
NATA looks forward to working with the Subcommittee during the reauthorization process and is eager to serve as a valuable resource for aviation businesses during this critical debate.

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Coyne Addresses Hudson River Corridor Concerns At Congressional Hearings

Sat, 22 Jan 2011 08:30:00 GMT

FOR IMMEDIATE RELEASE FOR MORE INFORMATION CONTACT

Eric R. Byer
Vice President, Government & Industry Affairs
800-808-6282
ebyer@nata.aero

COYNE ADDRESSES HUDSON RIVER CORRIDOR CONCERNS AT CONGRESSIONAL HEARINGS

Alexandria, VA, September 16, 2009 -- National Air Transportation Association (NATA) President James K. Coyne testified before the U.S. Senate Subcommittee on Aviation Operations, Safety and Security on Tuesday and the U.S. House of Representatives Subcommittee on Aviation today on the Hudson River midair collision that took place on August 8. The hearings were in response to recent recommendations made by the National Transportation Safety Board (NTSB) and the Federal Aviation Administration (FAA) to alter the Class B airspace in the New York/New Jersey area.

At the Senate hearing, titled “Aviation Safety: The Hudson River Midair Collision and the Safety of Air Operations in Congested Airspace,” Coyne discussed the contributions NATA has made to improving general aviation safety at Teterboro Airport while also highlighting the need to accelerate the modernization of our nation’s air traffic control system. Coyne noted that the Teterboro Airport Flight Crew Briefing produced by NATA in 2008 continues to train pilots and other crew members flying into and out of Teterboro Airport, enhancing safety on the ground at one of the busiest general aviation airports in the world.

“Since its implementation in June 2008, the Teterboro Airport Flight Crew Briefing Web site has had more than 220,000 visitors and, more importantly, there have been no runway incursions at Teterboro Airport in 2009,” Coyne stated. “As a result of the success of the Teterboro Airport Flight Crew Briefing, NATA is developing a similar tool for Newark Liberty International Airport that will be available by the end of the year.”

Today, testifying before the House Subcommittee on Aviation, Coyne also took the opportunity to detail the essential need for accelerating modernization within our national air transportation system. Coyne called on Congress to separate certain aspects of the Next Generation Air Traffic Control System including upgrading radios and other communication mechanisms in Air Traffic Control towers as well as allowing general aviation operators access to real-time air traffic activity.

Coyne praised the NSTB and the FAA for developing a task force and expeditiously releasing several recommendations to improve the safety of the Class B airspace near the Hudson River.

“One of the most significant changes is the division of airspace into altitude corridors that separate aircraft flying over the river from those operating to and from local helicopter bases, which NATA supports,” Coyne stated. “While the FAA claims that VFR is the best approach for such airspace as the Hudson River Corridor, every general aviation operator should have the ability to purchase and receive radar positioning via satellite. 21st century technology that is available in the U.S. should be made readily available for general aviation aircraft.

To view NATA’s Senate testimony, please click here.

To view NATA’s House testimony, please click here.

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NATA Comments on Air Carrier Maintenance Requirements

Mon, 01 Jan 0001 00:00:00 GMT

The Federal Aviation Administration (FAA) published this Notice of Proposed Rulemaking (NPRM), Air Carrier Contract Maintenance Requirements, in November 2012 in response to a mandate contained in section 319 of the FAA Modernization and Reform Act of 2012 as well as numerous Department of Transportation (DOT) Inspector General (IG) reports.
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