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Monday, March 31, 2008
DOT Using Flawed Assumptions in Anti-Congestion Initiatives
Calling it demand management in disguise, Regional Aviation Partners, citing a study done by Regional Airline Association, said that the $25 user fee that has stalled FAA’s reauthorization since last September, would devastate small community air service. More importantly, is the RAA assertion that congestion airports such as JFK have already lost much of their small community air service and cutting them further would serve no purpose since it is the narrow-bodies and over-saturation in such leisure markets as Florida that is the cause of the problem.
DOT’s proposal is based on flawed assumptions, especially regarding the operating characteristics of regional aircraft, said RAA. Government initiatives since the mid-1990s have already cost small and medium-sized communities a host of air service options. Related Story RAA called the proposal to ban small aircraft from certain airports anti-consumer, anti-competitive and said it will have dire consequences for small communities, the national air transportation system, and the U.S. economy
“Twenty one percent of domestic passengers travel in markets that produce fewer than 50 passengers per day,” said RAA. “While total air service at JFK increased, JFK small and non-hub air service has lost 14 percent of daily operations, 21 percent of operations during the busiest hours, 11 percent of daily seats and 17 percent of seats during the busiest hours. JFK’s average aircraft size increased from 98 to 102 seats. The current debate over access to increasingly constrained airspace and the urge to place blame on a single industry sector risks losing sight of a more important question: How can America’s Air Traffic Control system expand in a way that keeps pace with passenger demand?”
DOT’s proposed rule permits airport operators to use a two-part landing fee structure – a per-operation charge and a weight-based charge which the organization called short-sighted since it ignores the need to modernize and expand the system rather than constrain it. In addition, the user fee has been shown to bring in less revenue to pay for that modernization.
“DOT’s proposal relies on incorrect data about regional jet performance,” said RAA in its statement which urged DOT to withdraw the proposal and focus on improving capacity through modernization. “It is a DOT myth that operations of smaller aircraft during periods of airport congestion reduce the efficiency of the airport. In fact, turnaround time for regional jet departures is typically 20-25 minutes. Larger aircraft require additional ground time to board and de-plane passengers, unload cargo, and refuel. Regional aircraft also require less airport parking space than larger jets.
“It is also a DOT myth these aircraft may have slower speeds on approach to and departure from the airport than larger jets,” RAA continued. “In fact, regional jets climb at speeds of 330 to 365 miles per hour and at initial climb rates exceeding 3,000 vertical feet per minute, comparable to the larger, narrow-body passenger jet performance. Approach and landing speeds are also comparable. It is a DOT myth that regional jets may require larger separation distances from large jet aircraft than other large jets. In fact, regional jets and narrow-body aircraft require the same airspace separation. Turboprop aircraft fly at altitudes lower than jet aircraft, utilize different runways where available, and therefore do not impact congestion.”
Operators have complained for over two decades that FAA procedures compromising the improved operating specs of regional aircraft. Even with the advent of new-generation turboprops in the late 1980s and the regional jets in the 1990s, air traffic control procedures failed to keep pace with improvements in regional aircraft. Recently, on a flight out of Newark, Regional Aviation News learned that the Q400 was not being vectored to use of a cross-wind runway there which could alleviate congestion. Pinnacle Airlines indicated that its presentations have convinced the Port Authority of New York and New Jersey of the aircraft capabilities, but, apparently, the FAA has yet to catch up.
“Medium-sized airports would see reduced competition and passengers could face a twofold fare increase – one from new congestion fees and another as base fares climb due to fewer connecting passengers,” said RAA, adding 450 of those airports (70 percent) are served exclusively by airlines operating aircraft with fewer than 90 seats. It also pointed out 100 airports connect only to airports that meet DOT’s congestion criteria with 69 connecting to only one other airport which also meet the congestion criteria.
“Aviation Policy determinations have a ‘trickle down’ effect and as all of you know by now, small communities are at bottom of the food chain and without strong advocacy, it is a certainty that we will feel the brunt of any uncontested decision/rule making long after it has been decided,” said RAP in its latest member alert.
Recently, RAA said the Department of Transportation recent proposal calling for congestion pricing at the nation’s busiest airports threatens service to over 100 communities. Related Story



DOT’s proposal is based on flawed assumptions, especially regarding the operating characteristics of regional aircraft, said RAA. Government initiatives since the mid-1990s have already cost small and medium-sized communities a host of air service options. Related Story RAA called the proposal to ban small aircraft from certain airports anti-consumer, anti-competitive and said it will have dire consequences for small communities, the national air transportation system, and the U.S. economy
“Twenty one percent of domestic passengers travel in markets that produce fewer than 50 passengers per day,” said RAA. “While total air service at JFK increased, JFK small and non-hub air service has lost 14 percent of daily operations, 21 percent of operations during the busiest hours, 11 percent of daily seats and 17 percent of seats during the busiest hours. JFK’s average aircraft size increased from 98 to 102 seats. The current debate over access to increasingly constrained airspace and the urge to place blame on a single industry sector risks losing sight of a more important question: How can America’s Air Traffic Control system expand in a way that keeps pace with passenger demand?”
DOT’s proposed rule permits airport operators to use a two-part landing fee structure – a per-operation charge and a weight-based charge which the organization called short-sighted since it ignores the need to modernize and expand the system rather than constrain it. In addition, the user fee has been shown to bring in less revenue to pay for that modernization.
“DOT’s proposal relies on incorrect data about regional jet performance,” said RAA in its statement which urged DOT to withdraw the proposal and focus on improving capacity through modernization. “It is a DOT myth that operations of smaller aircraft during periods of airport congestion reduce the efficiency of the airport. In fact, turnaround time for regional jet departures is typically 20-25 minutes. Larger aircraft require additional ground time to board and de-plane passengers, unload cargo, and refuel. Regional aircraft also require less airport parking space than larger jets.
“It is also a DOT myth these aircraft may have slower speeds on approach to and departure from the airport than larger jets,” RAA continued. “In fact, regional jets climb at speeds of 330 to 365 miles per hour and at initial climb rates exceeding 3,000 vertical feet per minute, comparable to the larger, narrow-body passenger jet performance. Approach and landing speeds are also comparable. It is a DOT myth that regional jets may require larger separation distances from large jet aircraft than other large jets. In fact, regional jets and narrow-body aircraft require the same airspace separation. Turboprop aircraft fly at altitudes lower than jet aircraft, utilize different runways where available, and therefore do not impact congestion.”
Operators have complained for over two decades that FAA procedures compromising the improved operating specs of regional aircraft. Even with the advent of new-generation turboprops in the late 1980s and the regional jets in the 1990s, air traffic control procedures failed to keep pace with improvements in regional aircraft. Recently, on a flight out of Newark, Regional Aviation News learned that the Q400 was not being vectored to use of a cross-wind runway there which could alleviate congestion. Pinnacle Airlines indicated that its presentations have convinced the Port Authority of New York and New Jersey of the aircraft capabilities, but, apparently, the FAA has yet to catch up.
“Medium-sized airports would see reduced competition and passengers could face a twofold fare increase – one from new congestion fees and another as base fares climb due to fewer connecting passengers,” said RAA, adding 450 of those airports (70 percent) are served exclusively by airlines operating aircraft with fewer than 90 seats. It also pointed out 100 airports connect only to airports that meet DOT’s congestion criteria with 69 connecting to only one other airport which also meet the congestion criteria.
“Aviation Policy determinations have a ‘trickle down’ effect and as all of you know by now, small communities are at bottom of the food chain and without strong advocacy, it is a certainty that we will feel the brunt of any uncontested decision/rule making long after it has been decided,” said RAP in its latest member alert.
Recently, RAA said the Department of Transportation recent proposal calling for congestion pricing at the nation’s busiest airports threatens service to over 100 communities. Related Story




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