1990 vs 2005 vs 2016 Operations: Exposing FAA’s Inaccurate Forecasts

While doing some online research and archiving of older FAA documents, I ran into a copy of FAA’s 1993 Aviation System Capacity Plan. (click here for an archived copy of the 389-page document). Within this document, Table A-3 offered a detailed assessment of the 100 busiest towered airports, including operations in 1990 and forecasts for 2005.

The table below was created using the 1990 operations levels and 2005 forecast data for those 100 airports. But, it goes much further. It includes the actual operations counts as they happened in 2005. AND, it includes data showing how the operations counts evolved between 2005-2016.

Take a close look. This data explains why people are suffering so much at a few key FAA airports: KSEA, KJFK, KDCA, KBOS, KSFO and others.

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

It is extremely revealing, showing how FAA consistently forecasts far beyond what would reasonably follow … almost as if the FAA forecasts are not intended to be accurate, but instead are created to sell excessive airport development while also enhancing Congressional funding support.

A more in-depth aiReform analysis follows on page two.

Is Trump ‘Reloading the Swamp’?

It is good to see Administrator Huerta move along, though it would have been much nicer to see the President fire him a year ago.

Now, as to who will be heading FAA(?)… …well, it looks like the AvGov Complex powers-that-be are not trying to change the current game plan. Here is a clip from a recent article, with a short bio of acting Administrator Dan Elwell:

“Elwell was FAA assistant administrator for policy, planning and environment from 2006 to 2008. He was Aerospace Industries Association (AIA) VP-civil aviation from 2008 to 2013 and Airlines for America (A4A) SVP-safety, security and operations from 2013 to 2015.”

For airlines and lobbyists, Elwell has all the right plumage; his record suggests he is a revolving door swamp monster, and an industry loyalist. Not likely to be focused on making FAA accountable to the thousands whose homes and health are being destroyed by NextGen.

Click here to view source article at ATWonline.com, or here to view an archived copy, with some analysis footnoted by aiREFORM.

See also:
  • 5/15/2014 – (the Federal Register revision to ATSAP that stops citizens from using FOIA to learn about aviation safety failures … signed by Mr. Huerta.)
  • 8/19/2013 – (detailed letter opposing FAA’s proposal to hide ATSAP data from the General Public (7-pages plus a 4-page attachment)
  • 4/3/2008 – (full-day congressional hearing about FAA whistleblowers, and FAA management that not only works to stop safety actions, but also works to punish the whistleblowers.)
  • 2/15/2015 – (‘What’s all the Noise about Airport Noise?’, a 7-page slideshow presentation by Mr. Burleson)
  • 1/11/2018 – (FAA’s online bio, Dan Elwell)
  • 1/11/2018 – (FAA’s online bio, Carl Burleson)

Reflections on FAA as a Faux-Regulator Serving Industry, Not the Public

At year end, we often take time to reflect. This year, let’s reflect on precisely what it means, when a U.S. federal agency is ‘captured’ by industry, so as to serve the industry instead of the larger Public. This Post will look more closely at FAA later, but for now, to help see how serious the regulatory capture problem is, let’s look at another failing U.S. federal agency: the Food and Drug Administration (FDA).

FDA, just like FAA, has many responsibilities. For example, they are charged by Congress to regulate pharmaceutical companies. Additionally, Congress has funded FDA with the intent that they will be effective, working to protect public health from dangerous new drugs. One of those drugs, released two decades ago, is the addictive opioid, OxyContin. An online search reveals a jaw-dropping epidemic of addictions – and fatalities; indeed, odds are very high that everyone reading this Post knows at least one person who has been impacted by opioid addiction. Also, and not insignificantly, a deeper online research shows the fact that representatives of both major political parties have aided and abetted this epidemic, while also obstructing reforms and failing to pass overdue corrective legislation.

So, how well has FDA done their job? If agency leaders actually view their job as ‘serving customers’ such as the pharmaceutical industry, well, they’ve done a fantastic job. But, if any of us objectively assesses FDA performance from the perspective of serving the larger Public and actually protecting health, well, FDA is a total failure.

Patrick Radden Keefe recently wrote an article in The New Yorker, The Family That Built an Empire of Pain (click here to view the source article online; click here to view an archived and annotated version of the same article). Below is an excerpt that summarizes how Oxycontin legal actions are evolving; this particular excerpt primarily quotes Mike Moore, a former Mississippi State Attorney General:

… Ten states have filed suits, and private attorneys are working in partnership with dozens of cities and counties to bring others. Many public officials are furious at the makers of powerful painkillers. Prescriptions are expensive, and taxpayers often foot the bill, through programs like Medicaid. Then, as the ruinous consequences of opioid addiction take hold, the public must pay again—this time for emergency services, addiction treatment, and the like. Moore feels that the Sackler family, as the initial author and a prime beneficiary of the epidemic, should be publicly shamed. “I don’t call it Purdue. I call it the Sackler Company,” he said. “They are the main culprit. They duped the F.D.A., saying it lasted twelve hours. They lied about the addictive properties. And they did all this to grow the opioid market, to make it O.K. to jump in the water. Then some of these other companies, they saw that the water was warm, and they said, ‘O.K., we can jump in, too.’ ” There may be significant legal distinctions between a tobacco company and an opioid producer, but to Moore the ethical parallel is unmistakable: “They’re both profiting by killing people.” …

FAA as Faux-Regulator

So, how does studying this opioid epidemic, and Mr. Keefe’s article, help us to better understand FAA’s failure? Simply by showing a near-perfect analogy for the many signs of regulatory capture. Here is a short list of discernible failure patterns, the ‘symptoms’ of regulatory capture:

  • Industry becomes the primary customer. For FAA, nothing shows this failure as starkly as the whistleblower hearings held on 4/3/2008.
  • Money trumps health and environment; the faux-regulator enables industry to advance corporate profits, by assisting in expansions and system redesigns that invariably bear an enormous cost on environment, health, and local (usually residential) quality of life.
  • Consequences of failures are eventually lethal. FDA failures fuel a rise in addictions and overdoses; FAA failures sustain sleep-deprivation that cause most of today’s multi-fatal commercial accidents, such as Colgan-Buffalo, Comair-Lexington, and UPS-Birmingham.
  • Consequences of FAA failures also extend to the corruption of a culture that we are repeatedly and fraudulently told is ‘all about safety’, when the full record shows it is anything but. For example, the agency’s use of ATSAP to hide ATC safety data from the general public; the agency’s inability to see the enormous impacts imposed by NextGen changes and hub expansions; the agency’s wanton denial of obvious performance failures (such as the controller error at Santa Monica, or the rash of near-collisions at San Francisco); and of course the war against whistleblowers (those rare few inside FAA, who choose to speak up to correct the cultural failures, only to suffer retaliation).
  • Key personnel within the faux-regulator end up serving only industry, often via a revolving door. In the Oxycontin story, the key FDA regulator was earning his federal pay and building his eventual federal pension when he signed off on the fraudulent Oxycontin marketing plan; just two years later, he worked for Purdue! The same pattern happens repeatedly at FAA, all the way to the FAA Administrator position (e.g., when Marion Blakey retired, she immediately became head of a major aviation lobby firm).
  • The legal system becomes a third-party tool, used to maximize corporate advantage, an additional ‘enabler’. Both industry players and faux-regulator officials posture around threats of legal actions by industry, using this pattern as a hammer to force changes that accommodate industry, at the expense of the larger Public.
  • To protect industry greed, and to ensure the legal system will enable these failures to persist, a heavy budget is allocated to lawyers who self-enrich with what is effectively a ‘license to lie and deceive’. Not just industry-paid lawyers, but also agency lawyers, paid for by the people.
  • If and when manipulation of the legal system appears likely to fail, especially if the case is headed for trial, a ‘settlement’ suddenly appears. ALWAYS, this last-ditch legal maneuver protects both industry and faux-regulator from any accountability, by sealing records that were about to become a part of the public record, records that would among other things reveal how badly agency officials have failed. And, routinely, the so-called ‘settlement’ will include language that shuts out third parties (such as actual communities, or victim families) from future legal action.

Can This be Fixed?

Yes, it’s all fixable. And really not that difficult to do, so long as people demand performance from both agency and elected officials. The first step, though, is obvious: we have to accept that FAA, FDA and other agencies are broken, serving as faux-regulators, enabling industry players to evolve in ways that are truly destroying homes and people. Perhaps with a new year, we can get to work?

FAA’s ‘Noise Portal’: A good idea, or a way to shut down Noise Complaints?

Last November, FAA filed a statement in the Federal Register, seeking comments from the general public about a proposal for FAA to create a new ‘Noise Portal’. on the surface, it seems like a good idea, though only a good idea if FAA actually intends to collect complaints and take action to address them. But, it also seems like a TERRIBLE IDEA, if FAA’s actual intent is to force the general public to use only FAA’s ‘Noise Portal’ to pigeon-hole their growing concerns.

Here is one of the public comments, submitted by a citizen impacted near Sea-Tac:

“15 minutes per complaint????
FAA is not a regulatory agency, its a shill for the airline industry. By making it so long to file a complaint, it is just further stifling the public interest. This is ridiculous, clearly a blatant attempt to silence dissent.”

Here is a letter by the interim Executive Director at Port of Seattle. He makes some fairly good points, though those of us who know how unresponsive POS has been to area noise concerns will shake our heads, knowing there is plenty of POS hypocrisy at play here. Anyway, here is a copy of the letter, followed by a copy of a short point-by-point analysis by aiREFORM…:

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

…and, here’s the point-by-point analysis of Mr. Soike’s letter to FAA:

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

Click here for an archived copy of the Federal Register filing, or click here to view the source at Federal Register, which includes a link to view comments. Try and make sense of this, if you can; it appears that FAA employee Barbara Hall has a job filing multiple items with Federal Register, to solicit public comments. Oddly, though, the public comments appear to be batched together into one folder at web location, thus combining an unmanageable diversity of public comments.

FAA/Industry’s Own Data Exposes ‘Greener Skies’ as an Environmental Fraud

This Post looks at data in two online documents, presenting further evidence of the ‘Greener Skies’ fraud that FAA, Port of Seattle, and industry players are foisting on the Public. For all intents and purposes, this is the same fraud being pushed throughout the U.S., and by industry and Congress as well, under the NextGen label.

The data are at:

  1. Projected average day fuel burn on approaches, with no change: 2.64M lbs
  2. Projected average day fuel burn WITH RNAV/RNP changes: 2.61M lbs.

These figures were presented in units (pounds) that make the numbers impressively ‘bigger’, but also make it harder to intuitively comprehend. To correct this, the figures are converted in this table (to gallons, then to annual consumption):

Fuel burn (lbs) Converted to gallons Gallons per year
No Change 2,640,000 388,200 141.7M
‘Greener Skies’ 2,610,000 383,800 140.1M
Difference: 30,000 4,400 gal/day 1.6M gal/year

So, the proposal is expected to achieve a savings of 1.6 million gallons annually … at an airport that sold 487.1 million gallons that year. In other words, this proposed savings is less than one third of one percent of total fuel sold at Sea-Tac. Now, to the airlines, this (~0.3%) translates to more profits; indeed, the two dominant players at KSEA, Delta and Alaska, might each save around $1,000,000 per year in fuel. But, the costs shifted onto neighborhoods and health far exceed these added corporate profits.

A little deeper research reveals another interesting fact: the alleged fuel savings of Greener Skies are massively dwarfed by annual increases at an airport scheduling more arrivals than the gates can handle. Here’s the data, from page 18 of the 2016 Annual Report for ‘Sea-Tac Fuel Facilities LLC’, showing year-to-year changes far greater than the comparatively measly 1.6 million gallons saved:

  Gallons Consumed Year-to-year Change 1.6M as a percentage…
2014 487.1M
2015 544.8M 57.7 (a 12% increase) 2.8% of increased consumption
2016 586.3M 41.5 (an 8% increase) 3.9% of increased consumption

The improvements are nothing when compared to the consumption growth trend. Here’s a chart showing the trends, in both annual fuel consumption and annual operations: And, here’s an analogy: imagine the public view if we were funding a drug-treatment program that was successfully helping 3% of addicts while the number of addicts was growing at such a huge rate. Would we smile if, for every three treatment successes, there were 97 new addicts? Of course, we would not. Only an idiot (or a con-artist) crows ‘success!’ about a failure.

Three realities stand out from this:

  1. The enormous sums spent pitching Greener Skies and eventually signing off on the proposal were all framed around being pro-environment. It was a massive marketing/propaganda campaign to get out into the communities, present alleged benefits, pretend to engage people to ‘help’ identify and resolve problems, all while parading the idea that FAA, POS and industry care deeply about the environment, air quality, climate change, etc. And yet, these numbers show clearly: there were to be no meaningful environmental improvements. FAA, POS and industry players all knew this fact, even before the Greener Skies briefings and publications that wrapped up in 2012. They also knew (and still know!) that this was all just a big dog-and-pony show, funded by the people and served onto the people.
  2. A full five years after the FONSI signoff, FAA’s controllers at Seattle TRACON are not even using the RNP procedure down the center of Elliott Bay that was the key component of Greener Skies, the one element supposed to enable the bulk of the environmental benefits. It is as if the entire Greener Skies public engagement process was just an exercise in propaganda.
  3. The figures presented in the 2012 Greener Skies EA may not even reflect reality. Look closely. The data source documents used in this Post, when combined, show FAA/POS claimed that 487.1 million gallons of jetfuel were pumped in 2014, while also claiming 141.7 million gallons were consumed by west side arrivals on the short descending flight portions between the arrival gates (HAWKZ to the southwest, and MARNR to the northwest). Carefully note, these estimates were ONLY for west side arrivals, and did not look at fuel consumption for east side arrivals. Now, here’s the problem: these portions of these flights are the most fuel-efficient phases for each flight, and are allegedly flown at or close to engine-idle; these portions also represent a small fraction of total flight distance. And yet, the numbers used to calculate potential fuel savings declare the fuel consumption on these relatively short descending flight segments represent nearly a third of the fuel pumped at Sea-Tac? And, bear in mind, Sea-Tac is a major international hub, serving flights across the Pacific Ocean and to Europe. It defies logic; there is no plausible explanatio. FAA and POS need to confirm the numbers, and they need to explain: how is it that the airlines operating in and out of Sea-Tac can allegedly burn so much fuel on these arrivals yet so little fuel on climbouts and enroute to and from all other airports around the world?


Greener Skies was (and still is) both a fraud and a side-show ‘act’, using erroneous estimates while pretending to create benefits that STILL do not exist! And the impacts, using the questionable numbers provided by PoS/FAA, are astounding: they are saying, in 2014, arrivals to Sea-Tac consumed 2.6 million pounds of jetfuel PER DAY while on approach, creating noise and air pollution that we are all supposed to ignore.

See also:
  • 2/25/2011 – ‘Greener Skies Project’ presentation by Doug Marek (FAA, 11-pages)
  • 11/01/2012 – GreenerSkies, Final Environmental Assessment Documents, archived at aiREFORM

Another Area Impacted by FAA Indifference: the Beaches of Destin, Florida

Whether they are locals or vacationers, people have a hard time enjoying the beaches of Northwest Florida, when overrun by helicopters. They also wish FAA would serve THE PEOPLE, not just the aviation interests.

Below, Jack Simpson notes that this is probably the most boring column he has yet written, but his annoyance with FAA is crystal clear. This meeting could have been held anywhere, and about so many similar situations involving FAA. The federal agency with all the power to manage U.S. aviation is instead in the business of enabling abuse by aviators, who profit while diminishing local quality of life. Through it all, FAA employees pretend they can do nothing about it. And notice, too, FAA using the same old trick: put the burden on the citizens to comply with onerous requirements, reporting details that often are impossible to compile.

This article was about helicopters, but the same framing could also represent a community impacted by NextGen, skydiving, air tours, etc.

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

ATC Is Not the Real Cause of Airline Delays…

…and the airlines have long had all the tools they need to solve the problems caused by their own corporate greed and mismanagement. If NextGen impacts are out of control where you live, you need to read the article below.

As a follow-up to yesterday’s Post, here is an outstanding article written by Michael Baiada, a retired United 747 pilot, who sees past the NextGen promotional frauds. Even better, Mr. Baiada gets into the details of how easily the U.S. air travel system could be made more efficient and less impactful, while also improving the flying experience for us consumers. Turns out, the root of the problem today is too many people abdicating their duties: airlines refusing to run their business, regulators who enable this management failure while also serving as cover, lobbyists too focused on perpetuating the lobbying revenue stream, and so forth.

The article is a bit technical but very well written, and Mr. Baiada does an outstanding job explaining system details that FAA/industry work so hard to make muddy and complex. I heartily recommend sitting down and carefully studying this article; you will learn a lot, to help fight for rational airports, serving the local communities ahead of the airlines.

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

A copy of the article by Michael Boyd, as referenced in Baiada’s article, is archived here.

Thanksgiving, 2017: Three Graphics That Say a Lot

Here are three graphics: the first posted by airline lobbyist A4A, the second posted by FAA, and the last shared online at the Facebook site, Plane Sense 4 Long Island. Note the conflicting data from FAA and the lobby; note also the noise and air pollutant impacts on communities, such as under the JFK Arc of Doom, or under the narrow NextGen flightpaths in and out of KBOS, KCLT, KLAX, KPHX, KSEA, and other airports.

The airline lobby says 28.5 Million ‘passengers’ are forecast… (click on image to view source)

…but FAA says 3.95 Million will fly for Thanksgiving. That’s a lot less than the 28.5 Million claimed by A4A. (click on image to view source)

I have to wonder: why such a huge discrepancy, 3.95 Million vs 28.5 Million? Well, the 28.5 Million figure was produced by the airline lobby, and released in a press package on November 1st. It looked suspicious then. And, as is to be expected for a lobbyist (or a captured regulator!), the spin felt aimed at helping us all believe air travel is incredibly popular. But, it is just spin, and quite deceptive. For example, what is a ‘passenger’, and how do they measure ‘passengers’? Is it each person counted only once, whatever their full travel itinerary flown, or is a person who flies 4 legs to get to dinner listed as ‘4 passengers’? Are flights via airline hubs subject to double- or even triple-counting, toward the 28.5 Million figure? Such accounting methods would rapidly inflate towards an absurd 28.5 Million figure. Most likely, FAA’s figure is reasonably correct, and represents the number of outbound and return seats, related solely to Thanksgiving trips; thus, a more accurate A4A infographic would have declared that 7.9 million seats will be filled in 2017 for Thanksgiving travel (the math: 2x 3.95M).

So, assuming that FAA’s figure is fairly accurate, what does this figure mean? I.e., why is air travel so elite, even in the United States? Think about it. This is the biggest family holiday of the year. The national population is now 326.3 Million (per the Census Bureau population clock). Here, FAA, the U.S. federal authority on aviation, claims only 1.2% of our citizens use aviation to travel for Thanksgiving? Seems mighty small … but it is probably fairly accurate (and FAA has the data, so they should know). Plus, notice the figures for automobile travel: 45.5 Million (i.e., 13.9% of us will travel by car, 11.5-times as many as who will air-travel this holiday).

Regarding the third graphic… how about those residents losing their minds (and sleep) under the nonstop aircraft streams? This problem is much worse in 2017 than it was in, say 2007. What changed? The two key changes are implementation of NextGen, and packing flights in closer using the reduced separation standards of Wake Recategorization (aka ‘wake recat’). Oddly, FAA/industry are always pitching NextGen, but they both cautiously stay quiet about wake recat; this is odder, still, because the NextGen pitch is far more fraudulent, thus should be the angle they stay quiet on. Anyway, these two changes together reflect an unspoken mission shift at FAA: this agency not only does not understand the dire need to allow a local voice to moderate air commerce in and out of their local airport, but now, FAA is fully in service to the airline industry, enabling these excessive and growing impacts.

The Bottom Line: What’s more important: rising airline profit margins, or families seated together, in the homes they worked to buy and build and maintain, so that they can relax for a day of shared gratitude?

What’s more important? Hell, this is a no-brainer; it sure is NOT airline profit margins.

…Jana Chamoff Goldenberg‎ posted the great graphic at Plane Sense 4LI (can we credit the artist, too?) … THANKS!

People and Communities Would Benefit, if We Disincentivized Hubs

Interesting discussion about community impacts and port authority overdevelopment at Sea-Tac [KSEA], in this Quiet Skies Puget Sound Facebook Post.

(click on image to view source Facebook discussion)

Here, one of the area residents being victimized by Sea-Tac overexpansion suggests what really is the easiest solution: spread the flights out, so people are served locally, by their own local airport.

So, how do we make this change? The key to getting there includes changing the current system of fees/taxes to economically disincentivize hubs. For example, the U.S. Congress and FAA need to do three things:

  1. end ticket charges (especially the PFCs) that incentivize airport over-development. With airport PFCs, FAA/DoT collects billions of dollars each year, which are then reallocated into airport development projects. Much of this money goes to rural airports with nearly zero traffic (such as the recent debacle at Mora, MN), and the funds are generously doled out with near-zero local matches required. Airports like Sea-Tac are thus motivated to develop far beyond what the actual airport property and surrounding neighborhoods can stand.
  2. impose a steep carbon tax with at least half of revenues going away from aviation, such as to high speed rail. Indeed, the aviation sector provides an excellent opportunity to trial such a tax, while also funding new programs that are far more energy-efficient.
  3. establish a user fee system based on two key factors: direct-miles (between origin airport and destination airport), and aircraft seating capacity. Apply this fee system to all commercial flights (passenger and air cargo) as well as to all higher performance aircraft (e.g., bizjets, and flights by fractionally-owned aircraft). Thus:
      • for any origin-destination pair, a 200-passenger jet would pay twice the fee as a 100-passenger jet, and a 400-passenger jet would pay 4-times as much.
      • a 30-passenger bizjet would pay the same aviation user fee, whether it is chartering one elite passenger of 28, whether it is flying IFR (in the ATC system) or just out on a high-performance VFR hop.
      • passenger ticket fees/taxes would be proportional to itinerary distance. E.g., a passenger ticket from Seattle to Boston via Atlanta would pay 25% higher fees due to 25% higher distance (2,712 NM through ATL versus 2,161 NM direct SEA-BOS); likewise, a SEA-LAX-BOS itinerary would pay 43% higher fees than a direct SEA-BOS itinerary (hubbing via LAX, in this example, increases distance flown from 2,161 NM to 3,091 NM).
      • and, of course, this all would apply to commercial helicopters, too. A helicopter doing an urban air tour, or a helicopter charter hop from KSMO to Staples Center, would pay the fee, subject to a hefty minimum user fee per operation.
      • similarly, it would apply to commercial skydive operators, whose noisy aircraft would also be subject to a hefty minimum user fee per operation.

This simple set of proposed fees/taxes would not only reduce hub pressure at places like KSEA, KJFK, KCLT, KPHX, and KBOS; it would also all but eliminate system delays, and reduce environmental impacts. Plus, this system would strongly incentivize the airlines to offer more direct flights. This would mean less travel time for the consumers who fund this system, and would be a Win-Win for nearly everyone. The only losers would be the airlines and airport authorities who have gone too long, abusing too many, under the current flawed fee/tax system that maximizes consumption.

Just one thing is required: an elected Congress willing to work together, to order FAA reform: to totally revamp the fee/tax system, replacing it with only a carbon tax and a direct-miles fee.

Unfriendly Skies: Forty Years of Airline Deregulation Failure

An excellent analysis was sent to the aiReform administrator, along with this email comment:

“This is the best article I have seen in a VERY long time about the biggest hoax ever perpetrated on the traveling public, airline deregulation.”


He’s right. David Dayen did a fantastic job writing “Unfriendly Skies: It’s time to admit that airline deregulation has failed passengers, workers—and economic efficiency.”

A paragraph from the opening page of the article.

Mr. Dayen points out the role of all politicians, at both political extremes, in passing the Airline Deregulation Act in 1978; he debunks the myth of lower costs and higher efficiencies that actually did not happen, and shows evidence of FAA’s expanding regulatory capture; he also bears down on how the airline industry is a microcosmic example of the rise of oligopolies, that change processes and markets for their narrow benefit while imposing great costs onto many of us.

Click here to view Mr. Dayen’s source article at American Prospect, or click/scroll below to read a PDF archived copy with aiREFORM annotations.

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