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ACTIVE MEMBER LIST: September 30, 2002
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ACTIVE MEMBER LIST: September 30, 2002
U.S. Territory: 1. Puerto Rico City of Ponce Puerto Rico (Port of Ponce Industrial & Commercial Devo), Ponce Canada: 1. Quebec Bombardier Aeropsace Regional Aircraft 2. Manitoba Standard Aero, Winnipeg U.S. States: 1. Arizona Mesa Air, Inc., Phoenix Kingman Airport Authority, Inc., Kingman Page Municipal Airport, Page Show Low Municipal Airport, Show Low Independent Airport Consultants International, Mesa Air, Inc. Yuma Chamber of Commerce, Yuma Marilyn Young, Mayor, City of Yuma Kachina Technical Services and Processes, Inc., Phoenix Melanie Grinstead-Hanak, Mayor, Lake Havasu City 2. Arkansas Hot Springs Municipal Airport, Hot Springs 3. California Elite Services Group, Walnut Creek 4. Colorado Pueblo Memorial Airport, Pueblo Walker Field Airport Authority, Grand Junction Grand Junction Area Chamber of Commerce, Grand Junction Durango Mountain Resort/Destination Durango, Durango
AIMS of America Inc. City of Naples Airport Authority, Naples 6. Georgia North-South Airways, Inc., Atlanta International Airline Support Group, Atlanta 7. Iowa Dubuque Regional Airport, Dubuque 8. Kansas Air Midwest, Wichita Raytheon Systems, Wichita Salina Airport Authority, Salina Garden City Regional Airport, Garden City Metropolitan Topeka Airport, Topeka Manhattan (KS) Area Chamber of Commerce, Manhattan Manhattan Regional Airport, Manhattan 9. Kentucky Owensboro-Daviess County Airport, Owensboro 10. Massachusetts Cape Air Nantucket Airlines, Hyannis 11. Nebraska Nebraska Department of Aeronautics, Lincoln 12. Nevada Heli USA Airways, Las Vegas 13. New Hampshire Lebanon Municipal Airport, West Lebanon 14. New Mexico Alamogordo-White Sands Regional Airport, Alamogordo Hobbs Chamber of Commerce, Hobbs Lea County Regional Airport, Hobbs Rio Grande Air, El Prado 15. New York Watertown International Airport, Watertown
CCAir, Charlotte CM Associates, LLC, Charlotte
Youngstown-Warren Regional Airport/Western Reserve Port Authority, Vienna 18. Pennsylvania Aviation Council of Pennsylvania, Allentown, PA Bradford Regional Airport, Lewis Run Clearfield-Jefferson County Airport Authority, Falls Creek Lancaster Airport Authority, Lancaster Venago County Airport, Franklin Venango County Commissioners, Franklin 19. South Dakota Pierre Regional Airport, Pierre
Jackson-Madison County Airport Authority, Jackson 21. Texas Durango Pro Focus, Midland Pagosa Management Corporation, Lubbock Revenue Technology Services Corporation, Irving 22. Utah The Perry Company, LLC, Park City 23. Virginia Lynchburg Regional Airport, Lynchburg Shenandoah Valley Regional Airport, Weyers Cave Greater Augusta Regional Chamber of Commerce, Fisherville Virginia Department of Aviation, Richmond 24. West Virginia Hart Field Coalition, Inc., Morgantown
Diversified Business Enterprises, Milwaukee 26. Wyoming Great Lakes Aviation, Cheyenne Cheyenne Airport, Cheyenne Fly Cheyenne, Inc., Cheyenne 1 Exhibit A lists current members. 2 60 FR 16230, 16274. 3 49 U.S.C.A. § 44701(A). 4 Sam Kazman , “Comments of the Competitive Enterprise Institute to the Federal Aviation Administration on its Proposed Rule to Increase Regulations on Certain Commuter Airlines Now Flying Under Part 135: 60 FR 16,230 (Mar. 29, 1995) Docket No. 28,154”, Competitive Enterprise Institute, Speeches & Presentations, June 27, 1995 "As FAA’s notice makes clear, the safety of part 135 airlines has not fallen; to the contrary, it has increased. " See attached document. 5 See Figure 1, page 4, supra. 6 60 FR 16230, 16231. 7 See Figure 1, page 4, supra. 8 Kazman. 9 Kazman. 10 60 FR 16230, at 16230. “The differences between parts 121 and 135 reflect differences in the size of aircraft and the scope of the operations. Part 135 is considered to provide a level of safety comparable to part 121… ”. And see, Sam Kazman , “Comments of the Competitive Enterprise Institute to the Federal Aviation Administration on its Proposed Rule to Increase Regulations on Certain Commuter Airlines Now Flying Under Part 135: 60 FR 16,230 (Mar. 29, 1995) Docket No. 28,154”, Competitive Enterprise Institute, Speeches & Presentations, June 27, 1995 11 60 FR 16230, at 16232. And see, id, Kazman. 12 For example, the projected increase in training costs for only 10-19 seat aircraft (excluding 20-30 seat aircraft) is estimated to total $406,354,720, which is well above the FAA's estimate of $275M as the total cost originally projected to result from the rule change for 10-30 seat airplanes. 13 Id. 14 Mesa Air, Inc. (September 12, 2002). “Information from the four airlines that served 80 percent of the passengers flying on EAS subsidized service in 1999 revealed that [complying with FAA’s regulatory rules requiring commuter carriers to meet more rigorous safety standards increased their operating costs.] Officials from Mesa and Colgan emphasized that the Commuter Safety Initiative’s new training and personnel requirements were costly. For example, Colgan officials said that training costs increased by an additional $27,000 per month, in part due to having to hire full-time trainers. Mesa officials noted that because pilots who formerly required 8 hours of cockpit training now require 40 hours, the company had to hire additional pilots to ensure that it could fully staff its operations. According to its 1998 10-K report filed with the U.S. Securities and Exchange Commission, Mesa estimated that pilot training costs rose by $2.0 million due to stricter operating requirements under the rule. Officials with Great Lakes reported that commuter rule compliance drove up its wages for mechanics between 30 and 35%. According to its 1996 10-K report, Great Lakes reported that salaries, wages and benefits increased about 8 percent from 1995 to 1996, due in part to the Commuter Safety Initiative.” 15 60 FR 16230,at 16266. 16 Infra, at footnote 12. 17 U.S. GAO Report, Essential Air Service, dated August 30, 2002, page 6, "Program Costs Have Increased More Than Passenger Use." 18 60 FR 65832, at 65833. 19 U.S. GAO Report, Essential Air Service, dated August 30, 2002, page 2, “Results in Brief.” While the GAO lists smaller aircraft use as an option, carriers who cannot afford to operate under FAR Part 121 are limited to operating single engine, piston aircraft under FAR Part 135, representing 30 year old technology that is demonstrably less reliable than the twin engine, pressurized aircraft described in the CFR. We do not believe the FAA intended to promote a return to less reliable, piston engine aircraft in today’s environment. 20 60 FR 65832, at 65837. 21 U.S. Department of Transportation Draft Regulatory Evaluation, Initial Regulatory Flexibility Determination, and Trade Impact Assessment; Executive Summary, Integration of Part 135 Commuters into Part 121, dated February 1995. 22 U.S. GAO Report, Essential Air Service, see, pages 15-25. 23 49 U.S.C.A. §41732(B)(5),(6), "Service provided in aircraft with at least 2 engines and using 2 pilots, unless scheduled air transportation has not been provided to the place in aircraft with at least 2 engines and using 2 pilots for at least 60 consecutive operating days at any time since October 31, 1978." "…service provided by pressurized aircraft when the service is provided by aircraft that regularly fly above 8,000 feet in altitude." 24 Several air carriers, such as Lone Star Airlines, have gone bankrupt, and others such as CCAir, merged with or were bought by other carriers. 25 U.S. GAO Report, Essential Air Service, dated April 2000, page 23. 26 U.S. GAO Report, Essential Air Service, dated August 30, 2002, page 6, "Program Costs Have Increased More Than Passenger Use." "The average subsidy per community served in the continental United States rose from nearly $424,000 in 1995 to $828,000 in 2002," an increase of 95%. "For communities in Alaska, Hawaii, and Puerto Rico, the average subsidy per community served rose from just over $90,000 to an estimated $251,000 in 2002," an increase of 179%. 27 U.S. GAO Report, Essential Air Service Report, dated April 2000, page 24, "Changes in Subsidy Levels, Air Carrier Costs, and Passenger traffic." 28 60 FR 16230, at 16274. 29 60 FR 16230, at 16274. 30 NTSB Government Aviation Accident Statistics Table 6 for FAR 121, and Table 8 for FAR 135. 31 The communities of Wichita and Salina, Kansas were particularly hurt by the loss of production of the BE-1900D resulting from the FAR Part 135 rule change. Both communities were economically disadvantaged through loss of jobs and tax revenue because of the premature shutdown by the manufacturer of the Beech 1900. Raytheon currently has 134 new and used BE-1900D’s parked due to a slow down in sales and leases to airline customers who cannot afford to acquire and operate these aircraft due to the increased operating expenses flowing directly from the rule change. 32 60 FR 16230, at 16276. "Alternatives to the proposed rule. According to the RFA, significant alternatives may include: the establishment of differing compliance or reporting requirements or timetables that take into account the resources available to small entities; the clarification, consolidation, or simplification of compliance and reporting requirements under the rule for such small entities; the use of performance rather than design standards; or an exemption from coverage of the rule, or any part thereof, for such small entities. " 33 60 FR 16230, at 16231. The FAA states that “while the safety level of part 135 operations has continued to improve, accident data, public perception, and recent government inquiries show a need for additional measures”. 34 60 FR 65832, at 65836. In regard to comments that higher fares resulting from this rulemaking will cause passengers to switch to less safe modes of transportation, it has been the FAA’s observation that passengers are usually willing to pay for safety.” 35 Insurance Institute for Highway Safety, Shopping for a Safer Car, p.1, (Oct. 2000). 36 “Airbag injury risk is lower in 1998 and later models because automakers have redesigned most of their airbags using less powerful inflators. Some automakers also have reduced inflation injury risk with dual deployment thresholds. Most airbag deaths and serious injuries have occurred in crashes at speeds close to the threshold at which airbags deploy -- crashes in which the bags provide relatively little additional protection to belted occupants. More new cars soon will have airbags with deployment thresholds that are higher when safety belts are used. Plus inflation forces will vary according to crash severity”. Id. 37 60 FR 16230, at 16274, “The American public demands a high degree of safety in air travel. This is manifested by the large amount of media attention given to rare accidents that do occur, by the short term reductions in revenues carriers have experienced following accidents or acts of terrorism, and by the pressure placed on the FAA as a regulator of air safety to further reduce accident rates”. 38 Sam Kazman , “Comments of the Competitive Enterprise Institute to the Federal Aviation Administration on its Proposed Rule to Increase Regulations on Certain Commuter Airlines Now Flying Under Part 135: 60 FR 16,230 (Mar. 29, 1995) Docket No. 28,154”, Competitive Enterprise Institute, Speeches & Presentations, June 27, 1995. 39 Bureau of Transportation Statistics, 2001 Pocket Guide to Transportation, (2000). 40 The costs associated with the recommended change are minor when compared to the net effect of the rule change. We estimate the cost of this safety enhancement to be less than $10K per airplane for the equipment. 41 As a practical matter, some operators may elect to continue operations under FAR Part 121, even if the exemption is granted. However, the granting of the exemption will provide viable alternatives for 10-30 operators to lower costs without compromising safety. Additionally, Category III and IV airports will benefit from lower costs associated with the hiring of additional personnel and lower expenses in acquiring fire equipment meeting FAA requirements. Download 138.8 Kb. Share with your friends:
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