August 17, 2009
The Honorable Frank R. Lautenberg
United States Senate
324 Hart Senate Office Building
Washington, DC 20510
Dear Senator Lautenberg:
The National Air Transportation Association (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 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.
On behalf of NATA, I am writing in response to your request to hold a hearing on the safety of “on-demand” aircraft. NATA represents over 800 on-demand air charter operators that are licensed by the Federal Aviation Administration (FAA). We would be happy to meet with you and your staff to discuss the industry and how we might participate in an eventual hearing.
While the tragic collision of two small aircraft that recently occurred over the Hudson River was devastating, these occurrences are extremely rare. NATA remains concerned with the intense scrutiny being placed on the airspace in which general aviation aircraft operate in the New York City area and the characterizations being made about air tours specifically and on-demand operations in general.
As can often happen in such situations, there is excessive speculation and a natural desire to assign blame. We urge you not to fall into these traps but, instead, to take this opportunity to learn more about this unique industry that employs millions while the experts at the NTSB complete their investigative work.
Our industry is dedicated to safety and has demonstrated that resolve on multiple occasions. As an example, NATA and its members were part of the Part135/125 Aviation Rulemaking Committee (ARC) chartered in 2003 to overhaul Part 135 and Part 125 regulations. The ARC completed its work and submitted exhaustive final recommendations to the FAA in September 2005. Since that time, there have not been any significant regulatory changes. This rulemaking committee was cited extensively in the Department of Transportation’s (DOT) Inspector General’s (IG) report.
Further, we believe that the IG report failed to present a complete picture of the Part 135 regulatory environment. The report highlighted the differences between regulation and oversight of the airlines and on-demand operations, but did not acknowledge the necessity of differing regulations due to the fact that on-demand operations comprise a vast number of mission profiles and include nearly every size and type of airplane and helicopter. To make matters more confusing, the IG failed to give any details on the fact that for similar aircraft in Part 121 and Part 135 many of the same equipment and maintenance requirements already apply. Quite simply, apparently for the sake of brevity, the IG report doesn’t make the effort to give all the facts.
We would appreciate the opportunity to meet with you to discuss your concerns, and I hope that you will invite NATA to participate in the hearing you have requested by allowing myself or an NATA member company to participate.
Sincerely,
James K. Coyne
President