LGA Measures Imposed On RJs

The new restrictions on hourly flights at New York's LaGuardia Airport (LGA) are based on "unfounded and ill-informed bias against the small jet airliner," according to the RJ Defense Coalition (RJDC) that charged the Federal Aviation Administration (FAA) with using the regional jet as a scapegoat...

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The new restrictions on hourly flights at New York's LaGuardia Airport (LGA) are based on "unfounded and ill-informed bias against the small jet airliner," according to the RJ Defense Coalition (RJDC) that charged the Federal Aviation Administration (FAA) with using the regional jet as a scapegoat for the airport's systematic problems. (RAN, September 11, p.1)

"The NPRM erroneously attributes the majority of LGA's air traffic problems on the small jet," it said. "This ignores the fact that air traffic problems and challenges in the New York metropolitan area pre-date the small jet. The point is that the air traffic control system and airport facilities have always been challenged by changes in aircraft technology and the airline marketplace. Fortunately, the FAA did not restrict the use of 'fast' jet airliners on the basis of ATC concerns in the 1960s, nor did it exclude the 'enormous' Boeing 747 on the basis of the existing airport infrastructure wouldn't accommodate it. Instead we found ways to accommodate change and the flying public is the beneficiary of the government's ability to adapt. The introduction and use of small jet airliners should receive no less consideration." The organization further stated the NPRM's lack of objective economic analysis will result in an "ill-conceived plan that will fail to reduce traffic delays at LGA."

RJDC is not the only one angry over the proposal. The Air Transport Association called the rule "governmental micromanagement and interference ... not seen since the airline industry was deregulated in 1978." The Port Authority of New York and New Jersey (PANYNJ) also objects to what it sees as the FAA's interference in the ground operations of the airport, and has proposed its own set of reforms which would include forcing airlines to use their gates at 80% capacity for the year.

Effective New Years Day, the FAA imposed temporary measures to control congestion at New York's LaGuardia Airport, a move that targets regional jets, in limiting the number of hourly flights at the airport. The measures permit 75 scheduled and six unscheduled arrivals and departures per hour from 6:00 am through 9:59 pm during weekdays and reverts back to the restrictions at noon on Sunday. The agency is working on a final rule for the airport but has already imposed a final rule at O'Hare citing similar reasons. (RAN, August 28, p.1) RJDC indicated a reduction in the number of RJs at LaGuardia would have a negative impact on the New York economy as well as those communities with service to LGA. "In 2001, RJDC commissioned an economic impact study of the small jet on the Cincinnati economy," it said. "The report concluded that 10 50-seat jets had an annualized economic impact of over $8.3 million and created over 80 jobs. While some factors were unique to the Cincinnati area, the principle applies to all cities and must be accounted for in any proposal to restrict the small jet airliner."

The organization also attacked the NPRM's assumptions. "The single greatest error in the NPRM is it overlooks the economic reality that aircraft capacity must always match passenger demand," said RJ Defense. "Instead the NPRM merely assumes that passenger can be 'funneled' onto fewer, larger jets or that 'minimal' flexibility is required. This fundamental error demonstrates a total lack of consideration for real world airline economics and the needs of the traveling public and renders many of the NPRM's conclusions and purported 'benefits' erroneous."

RJDC said that the air traffic simulations and other studies conducted as part of the rulemaking were also flawed because they assumed that larger jets can replace small jets. In addition, the studies provided no mechanism for financing new, larger jets.

The organization noted that larger aircraft, while having lower seat-mile costs, have higher per-departure and hourly costs which unbalances the match between costs and passenger demand. Because of this, a 130-seat MD80 cannot be forced into a market that averages 70 passengers. "Conversely, placing two 70-seat CR7s in a 130-seat market is far more costly than using a single MD-80," it said. "Accordingly, the laws of economics don't recognize an arbitrary 70-seat limit and the artificial imposition of such a limit envisioned in the NPRM would have adverse economic consequences for all who depend upon an efficient and economical air transportation system."

RJDC indicated the NPRM also underestimated the role of frequency. "For business travelers who are often under tight time constraints, the availability of flights that fit their schedules may determine whether to travel, or what mode to use."

It pointed to the Northeast shuttle flights, saying the FAA would not propose upguaging those flights "because it is understood that the frequency of service in critically important to the business traveler. The same principle applies to the ability of a carrier to use small jets to provide needed frequency" a point overlooked in the NPRM.

The organization also attacked the presumption that an equal number of passengers can be "funneled" into fewer, but larger, aircraft. "If passengers are forced to accept a circuitous route or a flight departing hours from when they need to travel, they just don't travel at all or opt for another mode of transportation," it said, pointing out diminishing frequency will make many hub and spoke operations uneconomic. In addition, the higher per-departure costs of larger aircraft in thinner markets, requires more time between flights, reducing the number of passenger options with the consequent reduction in the number of passengers.

While the NPRM said that the restrictions only require a minimal flexibility, RJDC said that an adverse change may require that a 70-seat airliner be placed on a flight that was previously served by a 100-seater, or conversely, an improvement in a market may require the replacement of a 70-seat with a 100-seater. The contraints imposed would eliminate the flexibility needed to quickly meet changes in market conditions and may even result in loss of service.

RJDC also noted that the economic impact of applying similar restrictions at other airports around the country would be devastating and would not result in changes in congestion. The real issue is addressing air traffic congestion in a systematic way since it is a systemic problem throughout the country.

The group also cited the fact there were relatively few 71- to 100-seat airliners to replace existing 50-seat RJ service. Until such quantities of these aircraft are available, it said, a carrier would have to place a much larger, perhaps older, less fuel-efficient aircraft into the market with consequent impacts on air transportation efficiency, noise and other emissions at LGA. It indicated an A319 with only 70 passengers would consume 10.6 gallons of fuel per passenger, per hour, a 60 percent increase in fuel consumption over a small jet airliner. A DC9-30 would incur a 76 percent increase in fuel consumption.

Finally, RJDC said Air Canada noted that the new restrictions violate international aviation agreements which will only be satisfied by either withdrawing the rulemaking or exempting Canadian carriers. An exemption, however, then places U.S. carriers at a competitive disadvantage on transborder routes.