Let’s replace the failed DNL metric; Submit Comments by March 15th

When it comes to mitigating (or even simply recognizing!) aviation noise, FAA has a proven track record of failure. This agency serves only industry, always working to enable more operations per hour at even the busiest airports. FAA consistently fails to properly assess noise impacts, and they persist in using the failed DNL noise metric designed to guarantees any and all expansion.

There is currently a solicitation for public comments. Please go to the Federal Register webpage and submit your comments, which might include:

  • Reject FAA’s use of the DNL noise metric, the 65 dB threshold, and continued use of the Schultz Curve.
  • Reject FAA’s desire to continue to research (and thus delay reforms).
  • Demand the use of noise metrics that already exist and actually work: a good choice might be simply quantifying the number of flights per hour in peak hours and the number of flights above (or audible) per day.
  • Demand widespread selective reversion of NextGen PBN procedures to reduce today’s impacts caused by repetition and route concentration; and,
  • Demand restored local controls (ability to limit traffic levels, impose curfews, etc.) and reassignment of federal ‘noise impact oversight’ from FAA to a restored ONAC-Aviation office at EPA.

Click here to view or download the packet of documents and analysis by aiREFORM. Click here to view the Federal Register webpage, and here to submit a public comment.

Happening this Week: the Aviation Noise & Emissions Symposium

This week, aiREFORM is attending a series of presentations about aviation impacts, at the 2021 Aviation Noise & Emissions Symposium. In recent years, the annual symposium sponsored by UC Davis has been held in southern California and Florida, in late winter. This year, due to the pandemic, it was transitioned into an online symposium, using the Pheedloop virtual event platform. Organizers did a great thing: they opened registration to activists everywhere, to participate at a reasonable $25 price. As a consequence, many of the U.S. aviation impact activists are participating.

In the first two days we’ve heard four presentations. While some presenters have seemed to lack an ability to see outside the culture that delivers their industry-sourced paycheck, a few have offered great comments. Steve Alterman and Nick Miller (retired principal from HMMH) come to mind.

Those activists who did not register can still benefit. Check out the ANES-UCD website and, under the ‘About’ menu bar, open up the webpages for the 2019 and 2020 Symposia; you can then view or even download numerous PDFs with material used in the earlier events. And, the same should be posted soon after this year’s event is finished.

Some Context on ‘Noise & Emissions’

It is not clear from a cursory online investigation precisely when and how UC Davis began this series of events (we hope to add those details in the near future). But, research does show that ‘Noise & Emissions’ are at the thematic heart of what FAA was working with, as NextGen evolved nearly twenty years ago.

It starts in December 2003. That’s when Congress passed Public Law 108-176, the Vision 100–Century of Aviation Reauthorization Act. At Section 321, FAA was directed to work with NASA and others to “…conduct a study of ways to reduce aircraft noise and emissions and to increase aircraft fuel efficiency.” Noise and Emissions.

The Reauthorization included language ordering a report back to Congress, for delivery within a year. That report, authored by Ian Waitz et al at MIT, was delivered in December 2004, and at three points (p.7, p.31, and p.42) it identifies the name for the new program: Next Generation Air Transportation System, aka NGATS. It was early 2006 when FAA Administrator Marion Blakey started using the ‘NextGen’ brandname, in FAA’s 2005 Annual Performance Report.

Hard to believe, nearly 18-years later, that FAA was supposed to do good, environmentally, with the NextGen implementation. Instead, we have a program serving only industry, destroying decades-old noise abatement procedures, and imposing hugely impactful concentrated computer-flown tracks over new noise-ghettos below. Bad for community, bad for health, but good for industry, so FAA ensures it flies.

In a nutshell, NextGen is not about ‘noise and emissions’ as Congress ordered, nor is it about ‘safety or efficiency’; it is about automation, replacing human controls (pilots and controllers) with computer controls, all to accommodate heavier hub scheduling (and slightly tweaked profit margins) by the few remaining U.S. airlines. Airlines that typically operate near-monopolies at most of the U.S. commercial service airports.

For a deeper dive into how NextGen evolved and why it is failing these environmental goals, download this 2017 aiREFORM presentation (42 slide PDF, 4Mb), delivered at a Quiet Skies Puget Sound forum.

COVID’s Impact on U.S. Airports, Through December 2020

The COVID pandemic has deeply impacted the passenger aviation industry. Despite enormous (and repeated) payroll subsidies from the federal government, many people remain highly resistant to the pay-to-fly experience, most likely due to the crowding, shared air, and other dangerous conditions. This Post uses FAA’s latest ATADS data to show how the ASPM77 airports have been impacted since March 2020. The analysis goes a step further to look at the FAA’s 35 biggest commercial airports (OEP35), showing how far they had declined BEFORE the pandemic, as well as how they further declined due to COVID.

Click here to view or download the analysis.

These days, there IS such a thing as ‘a Free Lunch’

Congress has done it again, proving their bipartisan support for monied individuals and corporate wealth. Here we are, deep in a pandemic with millions facing an imminent eviction wave as well as growing food insecurity. So, why not add language to a temporary aid package, that allows 3-martini lunches (and other business meal expenses) to be paid fully (as in 100%!) by the taxpayers?! The outgoing President wants it (some of those meals will be procured at his businesses); so, WHY NOT? (see article at Boston Globe, or PDF copy here)

This has been a grueling year. It seems that not a minute passes without yet one more surreal news item or troubling tweet. Somehow, a more hopeful core within makes me ‘hope’ this is a fake news story. But, it likely is not. It is just like the pattern of corporate-welfare and capital-welfare we have so long seen within aviation. Two examples:

  1. federal tax rules for accelerated depreciation and bonus depreciation coddle concentrated wealth, enticing those with larger income tax bills to instead spend those taxes buying jets and helicopters AT PUBLIC EXPENSE.
  2. lobbyists have pushed legislation, passed in so many states, that waives sales taxes for aviation-related expenses such as maintenance, creating the absurd reality that a minimum-wage parent with a beater car pays sales tax for an oil change, but the owner of a small plane (mostly older, mostly white, mostly male, and flown mostly recreationally) pays ZERO sales tax as a privilege.

As Bob Dylan would sing, The Times They Are A-Changin’. Conditions are getting worse in the U.S., economically, for those who do not have money reserves. Yet, the same duopoly that panders to aviation and the White House holds the majority hostage while serving out more for the most elite wealth. Will our electeds at any level come around to taking care of people first, before money? Reforming aviation is a great place to start.

Learn More? ..see ‘SubsidizedAviation’

[aiRchive] A Bicameral Letter to FAA Administrator Steve Dickson

The end of 2019 is looking far better than the start of this very long year.

A few days before Christmas, eighteen elected representatives, from both the Senate and the House, sent the following letter to FAA Adminsitrator Stephen Dickson:

Click on the image below for a scrollable view of the international Press Release; the PDF file may be downloaded.

The letter makes reference to the 41-page Audit Report done by the DoT Inspector General and published last August (click here for a PDF copy, archived at page two of this Post).

An aiREFORM Analysis

Here are a few quick observations:

  • The Bicameral letter is excellent, but has one incorrect point in paragraph #2, where it repeats the oft-declared propaganda by FAA that Metroplex was introduced “…in order to make airspace more efficient.” FAA’s true reason for Metroplex was to achieve a giveaway for the airlines; they used Metroplex to do a wholesale removal of all previously existing noise mitigation procedures, so the airlines would no longer be encumbered with the ‘nuisance’ of having to reduce impacts below.
  • Again, Metroplex is NOT about efficiency. If Metroplex was about improving efficiency, would we not expect FAA to be deeply concerned about the gross inefficiencies of flying more and more passengers on longer overall trips, via major airline hubs? Would we not see FAA advocating for ticket prices (and fees) proportional to total direct-miles flown, and advocating for a steep aviation carbon tax?
  • True efficiency would be accomplished by ensuring the passengers are able to fly direct, one-hop flights from trip origin to trip destination. But, it behooves FAA and industry players to fly more passengers indirectly, via hub airports, as doing so artificially inflates enplanements, falsely suggesting a booming industry. And, more enplanements translates to more airport passenger fees, an attractive revenue generator for airport authorities like Port of Seattle and MassPort. This is a system rigged toward concentration, imposing a noise/health cost on local communities, and also undermining the viability of other airports within a few hundred miles of the emerging super-Hubs.
  • The Senators and Representatives are hopeful that FAA will start serving ‘We The People’, not just industry players. But FAA has a long history of arrogance, indifference, and aversion to accountability. This is the same ‘regulator’ that essentially let Boeing self-regulate the 737 MAX design that killed 346 in two horrific crashes, and was the last national regulator to ground this dangerous design.

So, what a year, right? So much has been revealed. So many individuals have persisted in their activism. Maybe, just maybe, in the coming New Year, we can see more growth in the support needed from those we elected to serve?

To serve ‘We the People’, not to serve the aviation corporatocracy.

[ai-RCHIVE] Four Versions of FAA Advisory Circular 91-36

Here’s an example of abusive pilots, that also shows how FAA is a captured federal regulator actually enabling this type of abuse.

Fort Devens is a historic U.S. Army facility in the towns of Ayer and Shirley, roughly 25-miles west of Boston. Years ago, the Moore Army Air Field was closed. According to Wikipedia, part of the land then became a hospital facility, aimed primarily at serving specialized and mental health needs for prisoners.

Back in the early 1970’s, coincident with ‘Earth Day’ and the wave of citizen empowerment toward improving and protecting the environment, FAA was nudged into creating an ‘Advisory Circular’ about small airplane noise. The advisory circulars are not binding or regulatory, but they do spell out what FAA asks the pilot community to do, toward achieving certain objectives. This is how FAA treats pilots: ‘pardon me, would you please try this?’, like royalty. If pilots do not conform to the ‘advice’ contained within an advisory circular, eventually FAA can become compelled to issue actual regulations. Now, if FAA also chose to enforce those regulations, we might achieve a nice balance, between the right of the pilot community to use their aircraft, and the rights of the non-pilot community (aka, all of us residents) to enjoy our homes and yards without excessive noise and aviation air pollution.

Roughly a decade ago, residents around Ayer prevailed in a nuisance lawsuit filed against a group of pilots. Ever since, there has been an extraordinary concentration of low-level small-plane flight activity over the homes of the residents who won that legal action. When these residents complain to FAA, to MassPort (the airport authority), or anyone, they get nothing but deadends.

Check out this disturbing example, posted on Facebook.

Now, about that ‘Advisory Circular’. In the 46-years since it was first posted in 1972, it has been updated three times. The updates are generally unsubstantial, as you can see for yourself. Here are links to archived copies of all four versions of FAA’s Advisory Circular 91-36, ‘VFR Flight Near Noise-Sensitive Areas’. Each version is 2-pages, with minor changes as the Advisory Circular evolved. Version ‘91-36B‘ was signed off in 1982, version ‘91-36C‘ appeared in 1984, and version ‘91-36D‘ (the current version) was signed off in 2004.

Frankly, these four versions of Advisory Circular 91-36 show FAA’s ‘milquetoaste approach’ to NOT managing aviation impacts. FAA has made it clear to rogue operators like this one near Boston: they may bully with impunity, knowing FAA will not impair this perceived ‘right’. The impacts that FAA recognized in 1972 have persisted because FAA refuses to serve and fails to evolve. And so, across the nation, for two generations now, residents have complained and been ignored by an agency that serves only the industry it is supposed to be regulating.

Pine Island Glacier: the latest example of rapidly melting polar ice that will eventually flood major airports

Ecowatch published an informative article about a huge iceberg, roughly 115 square miles, that has calved off of the Pine Island Glacier. The article cites an interesting series of posts by Stef Lhermitte discussing a large new iceberg, designated B-46, which is rapidly disintegrating as it drifts toward the Pacific Ocean.

The series of posts includes a GIF slideshow showing annual sea-ice extent at the Pine Island Glacier. Here is a scrollable PDF showing a series of screencaps taken from the GIF slideshow, with images at roughly a 5-year interval from 1975 to 2018 (depending on what years had available images). The sea ice extent for each year is indicated by a color-coded thick line; over time, this line progresses upward, exposing more of the seawater below. In the background of all images, the satellite image appears to be current, as taken on 10/30/2018.

Click on the image below for a scrollable view; the PDF file may be downloaded.

Overall, this series of images shows a pronounced decline in sea-ice coverage. Within the images, you will also notice that there were a few years, ending in 2013, where sea-ice cover was expanding. Since 2013, the melting/calving has been precipitous. Bear in mind, the polar regions are in total darkness for months each year, and it may take years for new meltwater to mix with the seawater below. Thus, massive ice melting may cause an easily frozen freshwater lens to sit atop the seawater. This will create an illusion of expanding sea-ice extent for a few winters. But, eventually, once the excessive freshwater becomes mixed, or as ambient air temperatures continue to increase, the expanded ice that peaked in 2013 will become just a distant memory.

Putting this in a Geographic Context

Here is an excerpt from Wikipedia, describing this specific glacier:

Pine Island Glacier (PIG) is a large ice stream, and the fastest melting glacier in Antarctica, responsible for about 25% of Antarctica’s ice loss.[3] The glacier ice streams flow west-northwest along the south side of the Hudson Mountains into Pine Island Bay, Amundsen Sea, Antarctica. It was mapped by the United States Geological Survey (USGS) from surveys and United States Navy (USN) air photos, 1960–66, and named by the Advisory Committee on Antarctic Names (US-ACAN) in association with Pine Island Bay.[1][4]

The area drained by Pine Island Glacier comprises about 10% of the West Antarctic Ice Sheet.[5] Satellite measurements have shown that the Pine Island Glacier Basin has a greater net contribution of ice to the sea than any other ice drainage basin in the world and this has increased due to recent acceleration of the ice stream.

Here are a pair of images, showing Pine Island Glacier’s location on Antarctica, and showing the seas that surround Antarctica, connecting it to the extreme southern oceans.

What Does this Suggest for Our Global Future, and for Aviation?

The rate of calving in recent years is disturbing, and reflects a harsh reality: if our ever-expanding over-consumption of fossil fuels is not reined in, and we continue to see 2- or 3- ppm annual increases in average atmospheric CO2 concentrations (see Keeling Curve), we can expect collapse of these polar glaciers and large-scale sea-rise. Hundreds of the busiest airports across the globe will become underwater. Homes for more than a billion people will also become uninhabitable, under sea-rise. Displaced people will need to find new homes, and that situation will result in global conflict and likely massive human depopulation.

Would it not be a good idea to immediately impose policies that strongly disincentivize excessive and arbitrary use of aviation?

A Closing Image: Accelerated Melting is Likely

Below is a different perspective, rotated, but showing the recession of the glacier (roughly from left to right) and how it compares to actual shorelines beneath. The areas of ice over water are designated as the ‘northern ice shelf’ and ‘southern ice shelf’. Over land, colors appear to show ice flow rates using a spectrum, with red being fast, yellow being moderate, and blue being slow. A major concern among scientists who study polar ice loss and related sea-level rise is that loss of sea-ice eventually removes an important ‘plug’ that holds back glacial ice over land; kind of like eroding the footing out from under a bridge pier. In other words, in this example, the fear is that once the Pine Island Glacier recedes beyond the base of the SW tributary and the southern ice shelf is nearly gone, ice flow from the SW tributary will rapidly accelerate, which in turn will rapidly accelerate global sea-level rise.

It would seem to be very foolish, to continue to ignore this evidence.

The Fraudulent ‘Greener Skies’ Salespitch at Seattle

A recent pair of articles by Dominic Gates, at the Seattle Times, draws attention once again to the collaborated fraud known as ‘Greener Skies’.

Fraud is not too strong a word. Both FAA and Port of Seattle (POS) knew that the Elliott Bay arrival route would not be usable, and would not deliver any improvements on efficiency or impacts, so long as the airport had more operations than the runways can handle. They knew, but they coyly avoided discussing this fact. Nor have they addressed this problem. Instead, both FAA and POS have pretended they can do nothing to stop the massive growth that has beset KSEA since 2012. The net result is a community burdened with growing costs – declined health, diminished quality of life, and destroyed environments (for wildlife as well as for people), all solely to accommodate excessive hub growth by both Alaska and Delta.

Here are some randomly chosen insights into the history of this fraud, including screencaps of various documents.

(1) KSEA Annual Operations Data: Let’s start by looking at FAA’s ATADS data, showing the official operations count per year, from 1991 through 2017. Peak year was 2000, and operations bottomed out in 2012. Delta announced a new hub in 2012 and, after a short lag to shift their airline resources, KSEA saw huge growth in 2014, 2015, and 2016. Growth slowed in 2017 but is on target to be approximately 6% this calendar year. Notice the two columns on the left, marked ‘AC’ and ‘AT’; AC is air carrier (larger commercial planes), while AT is air taxi (which FAA has formerly used to identify Horizon Q400’s and other smaller commercial planes). There is a distinct shift away from AT to AC, as noted by Gates in his recent articles, but that shift is not as significant as the fact that airline hubbing is causing huge increases in operations per hour, for the two largest airlines at KSEA. Notice also that, from 1998 onward, KSEA is basically a commercial-only airport, with less than 1% of operations flown by military or general aviation.

(2) 2018 operations prediction: based on monthly operations counts, using FAA ATADS data, 2018 is on target to reach approximately 439,400 operations. This is a 6% increase year-over-year, and a 42% increase from the bottom year 2012. In other words, since Delta announced their hub development at KSEA, both Alaska and Delta have ramped up annual operations so that the total operations per day averages 42% more than it did in 2012, just six years ago. That is an average annual growth rate of 7%, far exceeding population growth or economic growth in the Puget Sound area.

(3) An Earlier Prediction, the Part 150 study: this was completed in October 2013, though oddly it uses old historical operations data, only through 2008. See image below; the blue line shows the chosen forecast for total operations; the red line, added by aiREFORM, shows actual growth trends, keyed to FAA’s ATADS figures for 2012 and 2018.
Now, think about this: between the peak in 2000 and the bottom in 2012, did the Seattle economy and population tank? No. Did Puget Sound area per capita demand for air travel drop by 30%? No, not at all. And, between 2012 and 2018, has Puget Sound area population and economy seen growth anywhere near 42%, averaging 7% growth per year? Again, of course not, nowhere near that strong.

So, what is going on here? Why are the annual ops at KSEA growing so fast? The answer is simple: since 2012, two airlines (Delta and Alaska) have been feverishly adding capacity to route more and more passengers – and flights – through Sea-Tac. Both FAA and POS have the data that will show this reality, how a higher percentage of passengers ‘enplaned’ at KSEA are actually just pass-through-passengers, who never even leave the airport terminal. Both FAA and POS are careful to avoid releasing this data, because industry does not want citizens empowered with hard data. Operations and impacts are expanding way beyond population and economic metrics. This is solely to serve airline profit margins. If FAA and POS would start serving the people, too, we’d be better empowered to bring this injustice back to a reasonable balance.

(4) FAA Spin, promoting ‘Greener Skies’ in June 2012: here is a recent screencap (made on September 22) of an FAA webpage crowing over ‘great success’ with Greener Skies… the plan that cost millions to develop and promote, yet it was never implemented (now 6 years later).Notice an important fact: FAA first posted this in June 2012, and they actually updated the content in late August 2018. FAA is ignoring the important reality, that Greener Skies was never implemented. No mention, in FAA’s recent update, of the fact that FAA is not even using Greener Skies. Will anyone at FAA be held accountable for this disinformation failure? Of course not.

(5) The Greener Skies EA: signed off by Elizabeth Ray, on 10/31/2012, here is a screencap noting FAA’s conclusion of ‘no significant impacts’. Notice how the EA predicted a 30.7% increase in annual ops by 2023. Well, we are now way past that. We are on target for a 42% increase by the end of 2018; five years earlier than 2023, and we are already a third higher than the original long-term prediction. Also, understand this: this EA was not about creating ‘efficiencies’; this EA was aimed at removing procedures that protected people and the environment, to increase CAPACITY.Wow. Just, wow. Do we need any further evidence of how tone-deaf FAA is to the impacts caused by excessive hub development? Is there a better piece of evidence showing FAA’s regulatory capture?

(6) FAA Spin, One Week After Signing off the EA: here’s a screencap of how FAA again claimed ‘great success’ on Greener Skies, published in FAA’s ‘FY2012 Performance and Accountability Report’, on 11/9/2012, a week after the EA was signed off:There is zero evidence that FAA has achieved ANY of the claimed benefits. Meanwhile, there is ample evidence (especially looking at enroute delays at cruise altitudes on arrival streams, and at departure delays, and even at arrivals stuck waiting for a gate to become available) that efficiency has plummeted. And, of course, there is enormous evidence that people on the ground below are impacted immensely, by both arrivals and departures.

‘Stay Grounded’: International Action has Begun, to Curtail Aviation Excesses

Click on the image below for a scrollable view of the international Press Release; the PDF file may be downloaded.

Over the past year, activists from around the world held a series of lengthy teleconferences to craft a position paper,’ 13 Steps for a Just Transport System and for Rapidly Reducing Aviation‘. This is a great group of people, concerned about aviation excesses in the face of unmitigated climate change.

Here are a few links:

  • Action weeks: the first two weeks of October 2018
  • Support: how you can support the Stay Grounded effort
  • Position Paper: download your own PDF copy of an excellent analysis (English version)

An example of recent activism was the protest by Stay Grounded leaders, at an EU aviation summit. Click here for a video, with a great protest speech. This is the kind of calm and factual activism we need across the planet, to rein in the damages and injustices being caused by excessive aviation growth.

Given the depressingly evident impotence and indifference of many U.S. elected officials, and the captured status of FAA as an industry-servant, we need this kind of activism here in the U.S. Can we return to our roots, as strong individuals who speak truth to power and demand meaningful civic involvement, or has this become a relic of our past American glory?

FAA Investigates: Police Helicopter ‘Crashing’ of a Football Tailgate Party

Who’s idea was it, anyway, to use a helicopter to fly over tailgating crowds ‘to make crowd announcements’?

Click on the image below for a scrollable view; the PDF file may be downloaded.

OK, let’s suppose a nearby nuclear reactor is melting down, say Three Mile Island (though I understand, yes, it is not actually near the stadium Lot 23 area for Penn State football games!). But, just to put this in perspective, would it be a good idea for a helicopter pilot with an announcement system to swoop down very low over a crowd to issue an urgent message aimed at triggering an immediate orderly evacuation? Well, yes and no. First, how likely is it the announcement will not be heard over the ‘whop whop’ roar of the helicopter? And, second, how smart is it to apply this level of intervention, this form of technology, to potentially trigger a stampede? If there is an urgent need for people to vacate an area, sending in a helicopter at tree-top level or even lower is like throwing gas onto a fire. Not a good idea.

Now, is it surprising that this pilot flew so low, endangering so many people? No, not at all. FAA’s regulations for Minimum Safe Altitude (officially known as FAR 91.119) are carefully worded so as to exempt helicopters from the ‘1,000-ft above’ requirement that all fixed wing aircraft have to comply with. Well, sort of. The ambiguity within FAR 91.119 creates a barn door wide enough to fly a helicopter through … or, at least, it creates opportunities for FAA to justify taking no enforcement actions. The key phrase within FAA 91.119 is this:

“(Except when necessary for takeoff or landing, no person may operate an aircraft below) … an altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.”

Check out the videos online, by tailgaters at this Penn State incident. How was this helicopter going to safely execute an emergency landing without actually crushing or chopping people and ‘property’ below in the congested, open air assembly of tailgaters? And, when the impact causes fuel to burst out and ignite, how does the PA State Police mitigate the ‘undue hazards’ of being burnt to death?

Let’s put this in FAA’s perspective: aviation is good, people are dumb, and we, as the federal ‘regulator’ with sovereign authority for all things U.S. aviation, do everything we can to grow aviation commerce and allow even stupid aviation activities.

  • From FAA’s perspective, why not allow the use of helicopters swooping low and back-and-forth to herd wild horses or cattle … or PEOPLE?
  • From FAA’s perspective, why not ignore the obvious hazard and imprudence of using helicopters for drying cherries, or suspending enormous brush-trimming devices? Why not also ignore the ‘candy drops’ and ‘turkey drops’? After all, candy drops help sell aviation to kids, the same way turkey drops and heli-hunting sell aviation to, well, redneck yahoos … so, both are best ignored, right? [Check out this Heli-hunting video. with two shooters on the left side of a low-flying Robinson R44. Try to estimate the altitude, but try not to ponder too hard the possibility that any human or animal (a dog or livestock?) might be within the aerial hunt zone.]

  • From FAA’s perspective, why not pretend to care about safety – better yet, make ‘safety’ our most over-used word – by creating rules such as FAR 91.119 but carefully including enough ambiguity to ensure every errant pilot can walk away from enforcement – that is, so long as they are not killed by their own stupidity? Did you know: the FAR 91.119 language protects persons and property ‘ON THE SURFACE’, but the pilot (a person) and aircraft (a form of property) are NOT ‘on the surface’, and are therefore disposable?
  • From FAA’s perspective, why not perpetuate a convenient privilege for those people who choose aviation as their hobby or profession? Why not continue FAA’s ongoing failure to meaningfully investigate and enforce violations of FAR 91.119 and other FARs? After all, we wouldn’t want to dampen demand for flying, would we?

It amazes me that FAR 91.119 is so riddled with ambiguity, almost as much as it amazes me that FAA does not really give a damn about enforcing safe practices … at least not when they interfere with the expansion of air commerce. In this context, I suspect FAA will do nothing to correct the excesses that happened with the state police helicopter, at the Penn State tailgate last Saturday.

FAA investigates? We all have our doubts.