House Oversight Hearing: How Leaded Aviation Fuel Is Poisoning America’s Children

An important hearing was held today at the Environment Subcommittee of the House Oversight Committee, chaired by Representative Ro Khanna. Both FAA and EPA were asked to attend; they both refused to attend. No surprises there… failure hates to confront accountability.

The hearing is well worth a listen. It ran for 106-minutes, but your listening time is actually only 76-minutes, due to a full 30-minute recess (starts at minute-24, and you can skip ahead to minute-54) for a House Vote. A general timeline follows at the bottom of this post.

One interesting twist to ponder… so, as mentioned at the Hearing, FAA refused to show when invited. Where were they? Well, it so happens today is the middle of the week for the biggest General Aviation (GA) event of the year: AirVenture at Oshkosh, WI. Yes, FAA will have MANY officials rubbing elbows with the mostly recreational-flying community, as they celebrate their rights and freedoms at Oshkosh, but our national regulator cannot find even one FAA official to appear at this hearing. And, the interesting twist… well, as testimony to how FAA is deploying its ‘delay-delay-delay’ tactic, check out FAA’s PDF of their PAFI presentation at Oshkosh this same week 6-years ago, on July 26, 2016. Back then, FAA sent a team to present to pilots, letting them know how hard FAA was working (budget ~$6M per year, thank you Congress!) to safely and quickly achieve the end of leaded fuels. Within the PDF it declares goal was implementation by 2018. Um, that was how many years before how many pandemics and how many insurrections?

And, wouldn’t it be interesting to know just one short set of figures:

  1. how many gallons of leaded fuel were consumed for flying to and from (and at) this year’s AirVenture in Oshkosh?
  2. how many aircraft flew to and departed from the AirVenture event this year, and what is their composition, in terms of how many must burn leaded fuel versus how many can burn unleaded fuel or leaded, versus how many can burn ONLY unleaded fuel?
  3. can we have a short list of all aircraft types within each of the three categories listed above?
  4. similarly, can we have a short list of all aircraft engine models that are lead-only, versus lead or no-lead, versus unleaded only?
  5. and, lastly, can we include on the above two lists the year of introduction for each aircraft type and engine type?

The last item on this list would be fascinating to learn. Is it possible, in the roughly thirty years FAA has had to ‘fail’ to phase out lead, that nonetheless FAA has successfully certified numerous NEW aircraft types and NEW engine types that must burn leaded fuel, only perpetuating the problem … and just how messed up is that, from an environmental justice and health perspective?

What was my read?

As an ‘overall view’, I found it interesting AND VERY CLEAR that (R)’s tended to be on the side of aviation and commerce, while (D)’s were pushing to clean this up. No surprise there, given recent history. Just as interesting, clearly, D’Acosta was the mouthpiece (sort of the Giuliani?) for the (R)’s to bounce questions off, all aimed at legitimizing this ongoing failure… or, at least, aimed at suckering regular people into believing the lie that FAA and industry are actually making progress. It’s all smoke and mirrors and lots of delay.

Other Activist Views:

During the preparation of this Post, other activists shared a few good thoughts:

  • Cindy Chavez deserves a National award!
  • Does anyone know how to obtain a copy of the AOPA letter Herrell entered into the record? Her opening statements regarding GA had more to do with fire-fighting and life flight whereas the complaints filed by the public are much more focused on flight training and private pilots. As far as the economic benefits of GA, it’s a heavily subsidized industry. If it was a good business investment then why the chronic dependence on public handouts? I’d rather see my taxpayer dollars spent on jobs focused on environment safeguards, reducing global  warming, education, health care, parks and the arts as well as high speed rail.
  • Democrats and Republicans have very different reasons for wanting to issue subpoenas. A lot of politics involved. That being said, both parties seem to be frustrated by the FAA and EPA foot-dragging. Flood’s comment on EPA top down decision-making regarding an endangerment finding or leaded fuel ban is preposterous. If any sector engages in a top down approach its the FAA and the aviation industry.
  • Both Khanna and Lofgren called the avgas issue a national health crisis. There was a declaration of this nature made during the Flint water crisis and a lot of bottled water was shipped in as a result, but how replace lead polluted air?
  • Dr. Lanphear referred to it as an urgent public health problem. Tlaib also emphasized the need for a greater sense of urgency as children are being poisoned now. Lofgren described the RHV lead study findings as “terrifying.” Both she and Khanna spoke of being outraged by the ongoing inaction. Like Lofgren, I’m appalled that the FAA would tell communities they have to continue poisoning children due to grant assurances.

Hearing Timeline: (…times PDT)

~1106: Rep. Ro Khanna (D, CA Dist.17) chair, opening statement.

1111: Rep. James Comer (R, KY Dist.1), brief statement handing off to Rep Herrell.

1113: Rep. Yvette Herrell (R, NM Dist.2) member. Opening statement; she read off the debatable pro-aviation points so often pushed by FAA and industry, while ignoring the impacts. But, on a positive note, she did say the committee needs to issue subpoenas for FAA and EPA.

1117: Rep. Zoe Lofgren (D, CA Dist.19) her district includes KRHV.

1119: witnesses sworn in

1119: Cindy Chavez (Santa Clara County supervisor): discussed KRHV scope, lead history, efforts eliminate lead, role of industry lobbyists to block health initiatives, etc.

1124: Maricela Lechuga: lives 5-blocks from KRHV. Family history, historical context of Mexicans having East San Jose available for housing. Impacts of proximity to airport, to the point of not even being allowed to grow trees to offer shade for children.

1129: recess for voting at Congress. Reconvened at 11:59 PDT. (recess was for a vote related to semiconductor chips)

1200: Bruce Lanphear presented short video about impacts of lead on growing children, loss of IQ score even for very lead pollution levels. Also, increased ADHD incidence, increased risk of heart disease. Airborne lead: aviation produces ~70% of total pollution; particles are much smaller than lead particles associated with old-paint lead.

1206: George Braly, chief engineer at GAMI. Link to an AOPA article dated 7/21/21. “It’s just amazing, the bureaucratic mumbo-jumbo that has gone on….” He believes FAA is in defiance of Congress, in its failure to act, failure to even communicate.

1212: Chris D’Acosta, CEO of swift Fuels. Link to an AOPA article dated 11/11/13 when FAA approved use of Swift’s unleaded fuel.

1218: Rep. Khanna recognized self for 5-minutes of questions:

  • Supervisor Chavez, would you say lead is an environmental justice issue?
  • Lechunga, Do you feel your comment has received the concern and action it deserves?
  • further questions to Mr. Braly, Supervisor Chavez,…

1224: Rep. Herrell recognized. Offered AOPA written statement into the record. Series of Q&A to Mr. D’Acosta. Herrell: “It’s obviously a very robust process.”

1229: Rep. Rashida Tlaib (D, MI Dist.13) member. Concerns about what she has learned about impacts in Detroit area airports. Question to Mr. Lanphear, about the ‘cost’ of lead on IQ and health. Question to Supervisor Chavez.

1235: Rep. Pat Fallon (R, TX Dist.4) recognized. Asked Mr. D’Acosta to detail history on PAFI and EAGLE fuel programs. Video cut out before end. Links to background info…

  • PAFI White Paper (FAA, no date, 4p) at link. (download saved)
  • FAA’s webpage about Eagle Initiative at link. (PDF printed)

1241: Re. Lofgren recognized. Thank you to Supervisor Chavez. One question to Professor Lanphear, regarding blood level study. Expressed outrage over DoT Secretary not replying to letter from Congressional reps; “Hopefully we will get some action from this administration that is sorely lacking.”

1246: Rep. Mike Flood (R, NE Dist.1) Concerns about impact on agriculture (spray planes) if leaded fuel was disallowed. Questions to D’Acosta. At 12:50, at end of Rep. Flood’s time, Mr. D’Acosta asked to clarify on aircraft types.

1251: Closing comments by Rep. Khanna, noting that House Reps have 5-days to submit written materials. Adjourned at 1252.


REFERENCE MATERIALS: (more to be added as found later)

 

Our Unsustainable Secret: Leaded Fuel and City-Owned Fuel Tanks at Santa Monica

UPDATE, 30 MAR 2022:Elected officials in Santa Monica continue to be paralyzed and unable to do the right thing: discontinue leasing out their old tanks for leaded avgas and jet fuel sales, tanks that are decaying and well past their prime. They fear a lawsuit, and the City Attorney is only adding to their fears, by failing to identify who might file, at what venue, and citing what laws or regulations. Lacking any legitimate basis for a lawsuit, the Council is effectively being bullied into paralysis.
Here are two recent items: a letter to the editor by Joseph Schmitz, and a Facebook Post by Charles Blum.

Here’s an excellent OpEd by Alan Levenson, a resident of Sunset Park, printed in the Santa Monica Lookout. His concerns are about toxic lead, still in the aviation fuel used by recreational pilots in small planes, a situation that persists in no small part because FAA resists changes, and because local elected officials are often too intimidated by FAA to lead and serve. This is a national problem, too; there are dozens of posts under the category ‘LeadedAvGas‘. Read on…

We are all aware of the controversial airport that sits behind a fenced area in the southeast corner of Santa Monica. We have heard of the noise problems, the safety problems and the pollution. We know we were promised a great park.

What most have not heard much, if anything, about is the lead. The same lead that has been banned in auto gasoline, paint and toys is used in aviation fuel.

The leaded fuel is burned by most of the small planes that take off and buzz around over neighborhoods. The lead comes out in the exhaust and falls on people, homes, and schools below; it drops like lead at the rate of two grams per gallon. The City need not sell aviation fuel. Storing and supplying fuel is not our responsibility, and it is definitely not a sustainable business.

What most do not know is the City owns six underground tanks, three of which are 36 years old. That’s old for an underground tank; old even when not in earthquake county. The tanks sit above our aquifer; the same aquifer that has already been fouled in the past by Douglas Aircraft and leaking tanks from gas stations in years gone by. The same aquifer that supplies drinking water. Sure, the tanks are periodically checked, but accidents and failures happen.

The City is voluntarily storing and selling a known toxin. Lead has been proven to be unsafe at any level. It has been found in the blood of children around a similar airport, Reid Hillview, in San Jose, CA, at the same levels found in the children of Flint Michigan. A recent air quality study found elevated lead levels in the air around our airport and declared the airport to be the only source of airborne lead in the area.

Last November 2021 Councilmembers Brock and de la Torre proposed the City staff divest from the storage and sale of leaded fuel and the council unanimously agreed (“Santa Monica Could Join in Call for Ban on Leaded Aviation Fuel,” November 5, 2021).

Our Airport Commission also agreed. Even though we are not required to do so, the City staff has recently undertaken a project to sell unleaded fuel from one of our tanks, but our staff has not charted a known course of action to stop the sale or storage of lead in the second and older 12,000-gallon tank.

The City Attorney claims shutting out of the second tank might cause a problem in the future with the FAA or the aviators. Yet we know that in the real and now present that lead is coming out of Santa Monica Airport, exposure to lead reduces the IQ in children, and its effects are permanent.

Lead is a clear and present danger. We know the tanks sit above our aquifer. Lead is the elephant in the room and in our tanks, and that elephant must be shown the door. Santa Monica does not have to participate in this dirty business that should have ended decades ago as it was with cars, paints and toys.

Pilots and aviation businesses alike claim they too would like to get the lead out of aviation fuel. Yet while leaded fuel is available, they continue to use it. We know lead is bad. Even a little lead is bad. No lead is good. Not in our water, our air, our soil or our bodies.

No one is putting a gun to anyone’s head to sell and store leaded fuel at Santa Monica Airport.

It’s not green, it’s not sustainable, and it’s not defensible. In fact, after being asked for a clear explanation as to why we cannot get out of the fuel business we were not shown a convincing answer. We are talking lead, not bacon wrapped hot dogs on the pier. You cannot refuse or hide from airborne lead. Aviation fuel is the serious stuff of industry. Toxic to living things.

Our FAA obligations do not allow the City to ban the total use or sale of leaded fuel at the airport, but in no place do they clearly state the City must provide tanks or the City must sell fuel. It is time to retire our old tanks and get out of the leaded fuel business. It makes sense to get out of the aviation fuel business altogether.

If an aviation business wants to bring in their own newer safe and up-to-code tanks, then let them bear the costs, as well as the responsibility for the harm they are causing to those on the ground.

There comes a time to stand up for what is clearly right and reject what is not. It is wrong for a responsible and sustainable city to support and participate in the sale and storage of lead and any toxic fuels. There is no safe level of lead in our water or our air. 

We have an obligation to keep the airport open until 2029. We have no obligation to store and sell fuel until then. 

Please get out of the fuel business. Do it for the kids.

Santa Monica: The Quest for Local Control Continues

The last time the City of Santa Monica accepted FAA grant monies was in 1994. But, airport grants are not just for subsidizing the few who use the airport; they are also for imposing restrictions on the airport sponsor (in this case, the City of Santa Monica), so as to perpetuate the airport and also to compel airports to become dependent on more FAA grants. The list of restrictions, called ‘Grant Assurances’, is extensive. One of them, Grant Assurance 22, comes up time and again, used by FAA and aviation interests to confound airport sponsors and activists seeking balance or closure. 

By definition, Grant Assurances remain valid for 20 years; thus, 20-years after a grant is accepted, if an airport sponsor accepts no grants for those twenty years, they have finally earned their freedom from grant-slavery, come clean, and can theoretically regain local control of their local airport. This is what the people of Santa Monica aspired to do eight years ago, in 2014.

The Santa Monica Airport is jammed up against houses and, in fact, the spacing is so deficient residents have had lawn furniture overturned by the blast behind taxiing jets. The lead from leaded aviation fuel continues to be deposited on area homes, because FAA and the aviation industry have stonewalled the replacement of leaded aviation fuel. Indeed, in the 25-years since lead was removed from all U.S. automotive gas stations, there have been thousands of new engines built, put into new small recreational airplane designs, all centered on the consumption of leaded aviation fuel.

Activists have been fighting for health and quality of life for many decades, so it is not surprising that, when the City of Santa Monica finished their last grant obligations in 2014, a ballot measure was added to the November election seeking local control and conversion of the property to a park. The aviation lobbyists spent lots (estimates were 8-times the spending by Local Control proponents,) but they lost. The majority spoke and voter empowerment made it look like residents were going to see a park soon. It was headed that way until late January 2017, when a few City officials, fearful of dragged out legal challenges and an ongoing lack of FAA cooperation, caved to FAA’s pressure and ‘settled’ with a Consent Decree that made airport closure arguably a lot less likely.

The fight goes on. City Council met just last Tuesday, and was given a 94-page packet by City Manager David White, ‘Update on Dispensing Unleaded Fuel at SMO’. They also received 72-pages of citizen comments, all advocating for an end to leaded fuel sales, and preferring a full closure of the four underground fuel storage tanks the City owns. Included was this 3-page PDF investigating the integrity of the fuel tanks.

So, What’s With ‘Grant Assurance 22’?

Grant Assurance 22 is ten pounds of ambiguity under the headline, ‘Economic Nondiscrimination’. It has nine listed elements. Three of them are:

Grant Assurance 22a states: “It will make the airport available as an airport for public use on reasonable terms and without unjust discrimination to all types, kinds and classes of aeronautical activities, including commercial aeronautical activities offering services to the public at the airport.”

Grant Assurance 22h states: “The sponsor may establish such reasonable, and not unjustly discriminatory, conditions to be met by all users of the airport as may be necessary for the safe and efficient operation of the airport.”

Grant Assurance 22i states: “The sponsor may prohibit or limit any given type, kind or class of aeronautical use of the airport if such action is necessary for the safe operation of the airport or necessary to serve the civil aviation needs of the public.”

So, while 22a seems to imply ANY aviation activity has to be allowed without discrimination and on reasonable terms, both 22h and 22i offer exceptions, allowing specific conditions and even outright prohibitions, as needed for safety and efficiency.

Would it be a ‘reasonable term’ to NOT allow lease of an underground tank past its designed age limit? Should FAA’s view of safety include protecting area residents from lead toxin exposures? Is FAA our friend or our enemy (with us or against us)? What kind of a regulatory agency is it that leans hard with its sole authority but lacks the heart to cooperate with communities impacted by its activities?  Is this the same agency that handed off regulatory action to Boeing for the deadly 737MAX fiasco, and the same agency that grounds all tiny drones in yards to protect manned aircraft (yet is now slowly repealing rules so drones can fly low over crowds of people)? Yup, this is FAA: the U.S. aviation ‘faux-regulator’ captured to serve aviation, and working to protect industry from problematic people.

Oddly, the City Attorney is hung up on Grant Assurance 22, acting and speaking uncomfortably to question its applicability. And, unfortunately, the City Manager appears to be parroting the statements by the City Attorney. As a result, the City’s residents are being subjected to an unsafe, unhealthy perpetuation of aviation privilege that benefits a tiny elite. But these City officials are missing an important reality, so fearful they are of FAA. Both of them should ponder this: if they shut down all the tanks and an aviation lobbyist files a Part 16 complaint (against the City, claiming they are not compliant with grant assurances), their biggest penalty will be placement on the ‘Airport Noncompliance List’ and loss of grant eligibility… neither of which matter, for an airport set to close later this decade.

So, let’s close down the underground tanks. And, thank you, City of Santa Monica, for standing up to the FAA bully.

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.

[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.

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.

Airline Consolidation: Just Like the Banks?

A friend shared an article that included a variation of this diagram about bank consolidation.
Notice the pattern: banks consolidated from 37 in 1994, to 19 in 2001, to 11 in 2005, and to only 4 in 2009. Banks became less accountable and more inclined to gouge customers for absurdly high ‘fees’ (e.g., stuff like $31 for each ‘overdraft’ debit card usage, even for $1 or $5 purchases … they offered so many conveniences, but not the easy service of automatically alerting customers and rejecting the debit request at the point of sale). The greed-driven policies at the consolidated banks eventually created a financial meltdown. They were labeled ‘too big to fail’, so as to justify the enormous bailout by federal officials, using public funds. Our public funds, used to reward the overpaid bank greedsters.

It struck me that the diagram looks just like what has happened with U.S. airlines, where today the vast majority of passengers are ‘served’ by only six airlines and the so-called ‘regional’ feeders they contract with. Our final six are American, Delta, Southwest, United, Alaska and JetBlue.

If there is one big trend that we can all agree is happening in the U.S. and across the planet, it is industry consolidation and globalization. The gap between big and small, and the fraction controlled by big, just keeps growing. We now have fewer (but larger) banks, grocers, hospitals and immediate-care chains, gas stations, telecom providers, etc. It is also reflected in the widening wealth gap between the 1% and the 99% … and, again, not just in the U.S., but also in corrupt banana republics and across the globe.

We only hope that this trend is not driven by corruption even in nations like the U.S. We only hope that, if in fact this trend is as unsustainable as it appears to be, the ‘market correction’ will be peaceful and not too painful. Are we becoming the biggest Banana Republic in the history of the world? We only hope not.

Yesterday’s SkyJustice Phone Conference

The featured speaker at the 9/29/2018 Sky Justice National Network monthly phone conference was Jim Spensley. Airline and airport consolidation was front and center. A few of the many interesting points discussed included:

  1. The ‘final-6’ airlines are consolidating their schedules into fewer (but larger) hubs; i.e., while a few airports are seeing growth in annual operations counts, most airports have declined substantially for decades now. [for data, see the aiREFORM analysis at this 1/17/2018 Post (1990 vs 2005 vs 2016 Operations: Exposing FAA’s Inaccurate Forecasts), and see also this 10/23/2017 aiREFORM Post (NAS Annual Ops Have Declined for Decades Now, And NextGen Is Just Hype)]
  2. Most commercial service airports within the U.S. National Airspace System (NAS) offer monopoly or near-monopoly service; i.e., the predominant pattern is either only one airline offers direct service between two airports, or one airline has strong dominance on that airport-pair. This pattern appears to be an antitrust collusion between airlines; it also appears that federal regulators, including DoT, DoJ and FAA, are willingly not acting to end this antitrust collusion. [see this 2014 aiREFORM analysis (A Table Showing the ASPM-77 Airports – (Peak Years, Traffic Declines, and Trends Toward Airline Monopolies)]
  3. While the general public assumes there is an economy of scale that lowers unit costs and thus causes ticket prices to go down at larger hub airports, the opposite appears to be happening. Two key reasons are:
    1. the monopoly power held by the hub-dominant airline enables them to get away with setting much higher prices; this is especially true on those feeder routes to/from cities served by no other airlines.
    2. the airport authority accumulates an enormous debt burden for massive airport infrastructure expansion, all of which is predicated on continued unsustainable growth rates. In other words, a balloon is inflated, catalyzed by FAA grant funding and laws that incentivize hub concentration, and the balloon becomes primed to burst. The sudden popping of an airport hub balloon can be triggered by a general economic downturn, or it can happen if/when the hub-dominant airline arbitrarily decides to move to another airport; a prime example is the former Delta hub near Cincinnati [KCVG].
  4. There are other, environmental costs associated with these consolidated hubs, borne by residents and other ‘non-airport stakeholders’, but both FAA and airport authorities work hard to ignore and even deny these costs. The consolidation of flights into fewer but larger hubs causes more noise impacts (both persistent and repetitive noise patterns), more air pollution (thus more health costs), more destruction of residential neighborhoods and communities due to ‘land-grabbing’ by the airport authority, etc.
  5. One of Jim’s key points was that the airport authority has considerable power to set policies, to choose to NOT expand excessively … but the airport authorities tend to be beholden to the airlines, especially the hub-dominant airline. Why would someone like the Port of Seattle, PANYNJ, or Massport be so subservient to the hub-dominent airlines? It all comes down to money, needed to expand plans (and annual bonuses, in some cases), and also needed to pay off past and future development debt. The fear of an abrupt airline departure – like Delta did at KCVG, American did at KSTL, and United is now doing at KCLE – creates a peonage, rendered on a massive scale.

Solutions?

So, who can solve the growing impact problems caused by airline consolidation and hub concentration? If both FAA and airport authorities are effectively captured, serving industry, we can expect they will continue to play a good-cop-bad-cop game, passing citizens back-and-forth to each other while offering no answers and no solutions. This is where we are today. It is why we depend even more on our elected officials. Especially in Congress, we need them to change the laws; take back what was taken from the people in the 1990 passage of ANCA [see this 6/9/2015 aiREFORM Post (Wendell Ford’s Edsel: Many of FAA’s NextGen Dirty Tricks were Also Used in the 1990 Passage of ANCA)]; restore local control, to include ensuring local residents have power over their airport authority; even, impose a steep carbon tax on aviation fuel, so that excessive airline hubbing is disincentivized.


See also:

Who is to Blame – and Who Can Fix – the Impacts Around U.S. Hub Airports?

A Short Video by Tyndall Centre

The Tyndall Centre for Climate Change Research created this short video:

The most important fact laid out in the video is that aviation technologies are already highly evolved and, as such, there are no great gains to be achieved with further technological improvements. Thus, impacts need to be addressed by reducing number of flights and total distances flown.

To take real actions to correct this situation, we need to tame the marketing that fools people into thinking aviation is cheap and good for the economy, while obscuring the environmental and social impacts. We also need to change tax laws and aviation fees, to remove incentives for excessive flying and hub concentration.

The smartest moves now are actually quite simple: change the fee and tax structure on aviation, so as to disincentivize aviation consumption. We need to impose a steep carbon tax on all aviation fuels; we need to impose passenger fees that are proportional to distance flown; and, most importantly, the fee and tax revenues need to be spent OUTSIDE of aviation, in other economic sectors.

Read this, to Start Understanding the ‘Greener Skies’ Fraud

Click here to read an interesting article about the ‘Greener Skies’ program fraudulently pushed by FAA, Port of Seattle (POS), and industry, and approved by FAA in late 2012.

‘Greener Skies’ was pitched, but it actually never really happened. David Suomi (now FAA Regional Administrator) admitted as much when doing his 4/25/2017 spiel for the Port of Seattle Commissioners. Conspicuously, ‘Greener Skies’ was focused ONLY on west-side arrivals. Why? Because if FAA had tried to create similar concentrated arrival streams over Bellevue, the entire proposal would have been killed by the residents below.

‘Greener Skies’ was supposed to bring enormous impact reductions. The key design element was to flow more than half of all Sea-Tac arrivals in over Elliott Bay, miles from homes, thus with almost no noise impact. Are they doing that, nearly six years later? No, not at all, not even in light traffic, and not even on clear Fall days perfect for flying. Why are the Elliott Bay arrivals so rare? Because the air traffic controllers have to fit all arrivals together, into the final landing flow; i.e., they need to merge both the west flow (especially the HAWKZ arrivals over Vashon Island) and the east flow (the CHINNS downwinds coming up from the southeast entry post near Mt. Rainier, as well as the GLASR feed from the northeast entry post near Leavenworth). The ‘Greener Skies’ design was fatally flawed, by the simple fact it intentionally DID NOT try to create RNP procedures for all the arrivals on the east side. The net result is kind of like having the tires aligned on your car… but not all tires, just the left side.

A half-assed design that cannot produce the desired results, and is simply doomed to fail. That is ‘Greener Skies’.