The Impacts Are Not Due to ‘Customer Demand’, They Are Due to ‘Industry Greed’

SeaTac [KSEA] has been the fastest growing U.S. commercial airport in recent years, largely due to a 2012 decision by Delta to build a hub there. Here’s a JPEG showing KSEA annual operations and trends for each year, from 1991 through 2017:

(click on image to view the source table, which includes FAA ATADS data for 533 U.S. airports)

The data clearly reflects the operational history of KSEA. This is an airport where there was a former near-monoploy by Alaska Airlines, which is now expanding into a duopoly, with TWO airlines using it for hub operations. Notice the growth in flight numbers after 2012, following the Delta business decision. But notice also how operations at this airport declined by nearly a third, from 2000-2012. Think a bit about these sizable ups and downs: do they reflect strong swings in the local economy and population, or do they merely represent airline business decisions?

Now, ponder this concept, too: does ‘consumer demand’ drive airline business actions, or do airline business actions drive consumer demand? Is it fair to say that the entire goal of airline marketing is to stimulate more consumer demand, and ever-higher passenger mileage consumption?

Ask yourself this: regarding the demand for flying in the Seattle area (…and this is an attractive area, which has drawn many new residents from around the world), did ‘consumer demand’ DECLINE that much during the 2000-2012 timeframe, and has ‘consumer demand’ for flying by Seattle-area residents grown as massively as airport operations after 2012? In other words, is it inappropriate and misinformational for airlines, the Port of Seattle, and FAA to declare that ‘passenger demand’ is driving the current impactful hub growth, when the true driver is ‘corporate/airline demand’? Check out this screencap from page 8 of a recent FAA document (FAA’s CATEX… more about that later in this Post). If you spend any time looking at press releases by airlines and the Port of Seattle, you will find the same misrepresentations consistently repeated, all aimed at tricking readers into believing ‘consumer demand’ is driving this growth. Wouldn’t it be more accurate and truthful for the industry players to precisely attribute these hub operational changes to airline corporate decisions? Shouldn’t they instead brag about their marketing savvy and their ability to manipulate consumers, to create higher (or lower) rates of consumption? Should the industry players be more transparent, noting how when assets are reallocated from a declining hub to their latest new hub, we end up with economic decline and stagnation in the former?

The bottom-line is this: some airports grow excessively, while other airports seemingly whither away. Further evidence and examples can be viewed at the full 1991-2017 data collection for all tower airports (533 different airports, in this table). Do your own analysis for your own region, but be sure to take a closer look at the airports within the rustbelt centered on Ohio … from Detroit to Buffalo to Pittsburgh to Memphis to St. Louis and back to Detroit. Within this large region, at even the busiest airports, operational declines have averaged well over 50% from peak traffic years. And, many airport hubs have been outright abandoned.

What gives here?

Under the hub-and-spoke business model, commercial passenger operators maximize profits if they theoretically fly an infinite number of passengers into a hub airport at the same moment, have the passengers instantly sort out gate-to-gate into all the parked airplanes, and then depart all at the same instant. Of course, airports cannot be this efficient, and safety rules restrict aircraft flow rates, as both arrival and departure streams typically require around one minute spacing between consecutive flights. So, the next best thing for the airport and airlines (but certainly NOT for sleep-deprived and lung-impacted residents in the airport community!) is to tweak the rules in a way that maximizes ‘runway throughput’.

An example of this rule-tweaking is the use of diverging departure headings. At SeaTac, FAA took this to an extreme when they imposed routine 90-degree left turns immediately after takeoff, for Horizon Q400 turboprops heading south during North Flows. These departures impacted residents in Burien, the community at the northwest corner of KSEA. After concerns were raised (including legal engagement), FAA backed down early last year, removing an automated turn coordination from the tower-TRACON letter of agreement (also known as the ‘SEA-S46 LOA’). That should have been the end of this, right? Well, it was not. Instead, under new Regional Administrator David Suomi, FAA spent more than a year internally discussing and drafting papers to reinstate automated turns over Burien. The culmination of all that FAA effort (and, yes, we all paid for it!) is a 51-page CATEX document titled “Categorical Exclusion for Letter of Agreement Update to Automate a 250° Westerly Turn for Southbound Turboprops When Seattle – Tacoma International Airport is Operating in North-Flow Between the Hours of 6 am and 10 pm.” Read that title to yourself again, slowly and carefully, and try to make sense of it. All of this is just to formalize a written agreement between the tower and the radar controllers, so that the turns are automated, instead of coordinated verbally (push a button down, state a few words, and get concurrence … typically takes 2-3 seconds total) on a case-by-case basis. And, the automation discards the safety element of a diligent analysis of the traffic picture for each coordination event. Anyway, here is a copy of FAA’s PDF:

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

Like its title, this document is a doozy. Spend a little time studying it and you will see the extremes FAA goes to so as to enable excessive airport expansion. Page after page, lacking in substance, heavy on repetitive ‘safety’ and ‘efficiency’ soundbites, none of which are substantiated. If a particular detail or two really grab you, and you have an insight or a question, please email the aiREFORM administrator so we can share that on (odds are high, if you read something as puzzling or shocking, others will read it the same way, too). And, by the way, don’t waste your time trying to search this FAA PDF, because FAA scanned it to be unsearchable. I.e., although this captured agency claims to be engaging the community on matters such as early turns over Burien, in truth they are knowingly reducing the value of tools (such as this 51-page CATEX document) that concerned citizens need to carefully study). This trend, away from searchable PDFs, has been observed in FAA’s FOIA responses; whereas in the past nearly all PDF FOIA response documents were searchable, in time nearly all have become non-searchable.

The Dark Side of So-Called ‘Collaboration’

When two parties conspire in a way that adversely impacts a third party, we have collusion. In an age of propaganda, when collusion happens between aviation parties such as FAA, airport authorities, and airlines, they just call it ‘collaboration’. The true and unspoken purpose of their so-called ‘collaboration’ is to achieve a consistency in their soundbites. The early turns over Burien are an example of this ‘collaboration’. Another example is how these same players routinely claim the excessive growth at SeaTac is to meet customer demand. The short answer to that claim is, well, ‘Bullshit!’. Frankly, ‘demand’ is just a lame and misrepresentative excuse; the real cause of extreme over-expansion at airports is greed by the aviation players. And let’s be clear: it is not just the airlines, but also the airport authorities and the FAA. There is plenty of collusion to go around.

Here’s some data that proves the above point. It offers data from three Delta hub airports that have been scaled down, and shines a light on the downsizing of aviation in Middle America:

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

Conclusion:

This data reflects the harsh reality that today, in the U.S., FAA serves the airlines with a propaganda line, trying to sucker taxpayers into believing passenger demand creates impact problems at places like Seattle, Boston, Long Island, Maryland, and Charlotte. This is blatantly false, and most people at FAA know this. Hub concentration is NOT driven by consumer demand; no, airline greed is driving hub concentration, at great cost to local communities.

Congress needs to demand FAA serve all of us, not just the airlines and airport authorities. FAA is out of control and needs to be reigned in, and must not be allowed to continue operating as the captured regulator it has become.

The Congressional Process to Reauthorize FAA: Is it Just a Show, and Will it Go Far Enough?

Lots is happening in DC right now, though it is not clear if more than a few of the well-paid elected officials care enough to press through long-overdue reforms. If they fail to alter FAA’s cozy protectionism of this industry, the problems will persist: more noise (along with less sleep), more air pollutants (along with higher morbidity rates), and more rapid expansion of the greenhouse gas emissions by an industry that is the fastest growing contributor to global climate change. In time, the latter will mean loss of the polar ice (which appears to be accelerating), as indicated in this chart:

selected years added and labeled by aiREFORM (click on image to view source at NSIDC)

Note how Arctic sea ice has steadily declined in the past three decades. Losing polar ice is not a trivial matter; it will result in much higher sea levels, higher atmospheric energy and water vapor levels (stronger winds and bigger rain/snow events), and intensified weather extremes (the kind that fool trees into blooming early, only to freeze off the pollinized blossoms, killing that year’s fruit crop).

The Ball is in Your Court, Congress!

This week, the details are being deliberated in the U.S. House, and it looks like the Senate is also pressing to ‘hurry up’ and reauthorize FAA. Congress has important work to do for us in the U.S., but the consequences are global, going far beyond just us. From a climate justice perspective, the consequences are horribly unjust. Air travel and air cargo are industries that serve the wealthiest nations, but the poorest nations tend to be the most vulnerable. A nation like the U.S. can spend enormous funds elevating runways in Florida, but what is a small nation in equatorial regions to do, except simply move away? And, as the most vulnerable nations are destroyed, the global scarcity of land will only compel more instability, more refugees, and more wars.
We need to understand this now: there are real and ugly consequences for our obsessive hyper-consumption, and aviation is a big part of that bad habit. Every benefit bears a cost; the aviation-related benefits we enjoy today are at a growing cost to others on the planet … not just airport neighbors near over-developed U.S. hubs, but also communities at or near sea-level, across the globe.

Some Resources

Here are a few current documents and articles for readers to ponder:

  • HR.4, FAA Re-Authorization draft, Section-by-Section Summary – offers summaries of the many proposals, before most were either withdrawn or voted out by committee. One wonders: is there a better process for compelling a captured agency to serve THE PEOPLE, not just their industry? Is this current process rigged to empower lobbyists and opportunistic politicians? (27p, click here for archived copy)
  • HR.4, Draft Rule – take a look at the rules set up to ‘manage’ the amendment proposals and ensure the final draft serves industry. (click here for archived copy; click here for source)
  • UPDATE: The Dirtiest of Washington Politics? — ATC Privatization By Deception? – it was suspicious when Shuster suddenly announced abandonment of ATC privatization and his decision to not run again. Now it is back on the plate again, which begs the question: did Shuster et al decide to quit wasting effort deliberating and instead just impose their industry-serving plans? (click here for archived copy; click here for source)
  • Climate Change Could Increase ‘Whiplash’ Between Wet and Dry Years in California, Leading to More Disasters (click here to view source, a 4/24/2018 article at EcoWatch)

Debunked: FAA’s Latest 20-Year Forecast

It is that time of year, when FAA again parades out a 20-year forecast to prop up agency spending. These forecasts are notorious for being routinely exaggerated, i.e., robustly unrealistic, but the pro-spending bias keeps happening, since the exaggerations work well to dupe the public.

The opening line is revealing; compare this statement (“…All indicators show that air travel in the United States is strong…”) with FAA’s own data, which has been compiled into the table below.

This table shows combined total tower operations for all of the 500+ FAA and contract control towers, as documented in ATADS. Note that total operations peaked in 1999, and have fallen 26% since. The decline has gone on for decades, and has been steady; there is no concrete sign of a reversal.

Note also a paragraph deep in the FAA news release, justifying further expansion of infrastructural spending, on the weak FAA assumption that total airport operations will rise 19% in the next 20 years (from 51.0 million in 2018 to 60.5 million in 2038). Think about it; airport operations cannot even keep up with the positive growth rate of our national population. The data is clear: this industry has been declining. And, yes, the new forecast truly is based on FAA’s ‘assumption’, that a downward-flat trend for two decades will suddenly inflect upward.

While you critically study FAA’s news release, 24-page Forecast, and Fact Sheet (archived copies at the three links), ponder these notes:

  • The RPM metric is not a valid metric for industry growth. As the few remaining airlines continue to adjust schedules with increased hub concentration, passengers end up flying LONGER flights with added legs (origin-to-hub-to-destination, and even origin-hub1-hub2-destination, instead of origin-direct-destination). This increases RPM totals. If a routing via the Atlanta hub adds 24% to the total flight distance, RPMs also increase by 24%. The fastest growing hub right now is Seattle; when Delta sells tickets for passengers between California and the Midwest or East Coast, more and more itineraries end up flying via KSEA. Likewise, as FAA continues to over-accommodate airline excessive hubbing on the East Coast, we will see RPM increases on trips to the West Coast out of Boston, the NYC airports, Charlotte, Atlanta, and Reagan National.
  • Here’s another piece of spin, from the fifth paragraph of the News Release: “Air Traffic Modernization is rapidly moving towards satellite navigation technologies and procedures which will continue to allow enhanced navigation for more aircraft….” The truth is, there has been no rapid modernization because most of the GPS system was implemented in the mid-1990s! Also, the so-called ‘enhanced navigation’ is potentially a valuable improvement, but it is consistently rendered worthless by FAA’s failure to manage capacity, such as by imposing hourly flow limits. In other words, so long as FAA continues to allow airlines to over-schedule at a handful of airline-chosen hubs, ATC will have to continue to issue delays … as we routinely see at KBOS, KJFK, KLGA, KDCA, KSEA, and elsewhere. Using online flight tracking programs, we see thousands of delays everyday, in the form of gate holds, long taxi-out times due to congestion, turns and loops during the enroute/cruise segment, extended patterns to sequence arrivals via radar vectors, and long taxi-in times due to congestion. If FAA does not change their strategy, these delays will only grow.
  • The news release notes that there were 840.8 million domestic enplanements in 2017. If we fly a nonstop ticket from our origin to an airport destination, it will count as one enplanement, but ONLY if it is a direct nonstop flight. If we fly via a hub, or a series of stops, the number of enplanements increases (one enplanement per takeoff segment). Thus, a figure of 840.8 million enplanements in 2017 sounds like a big number, but actually means no more than 420.4 out-and-back ‘trips’. With more data, we could establish an estimate that is likely even fewer than 300 million actual full ‘trips’ per year, once we factor out extra trip legs (such as via hubs).
  • The news release also cites a 1.7% annual growth rate estimate for domestic enplanements, but how much of this will be due to increased hubbing? Even the simplest hub-related flights (e.g., outbound routed origin-HUB-destination, and return trip routed destination-HUB-origin) tallies four enplanements, which is roughly double the national annual average. If Delta, JetBlue, and others intensify hubbing, we can end up with an annual growth rate far exceeding the national population growth rate. But, with more hubbing, this would actually be less energy-efficient; lengthened flight distances and more stops would INCREASE fossil fuel consumption, having an even higher impact on climate and communities.
  • On average, U.S. citizens fly less than one commercial passenger air trip per year. And, importantly, some of us travel a whole bunch, many times per week. So, in this annual forecast, we really need FAA to go deeper with the data and attempt to accurately define just how elite air travel is. What percentage of our national population did not fly at all in 2017? And what is the trend year to year; are more people responding to climate change concerns by electing to travel less, or not at all? It could actually be that airlines serve an elite few U.S. citizens, more so than the larger ‘general public’. Considering the intensive fuel consumption (and impacts, upon climate change as well as health and neighborhood quality of life), it would be an appropriate national policy to stop subsidizing this industry and shift costs away from communities and onto the airlines and passengers; it would also be an appropriate national policy to impose a fee structure that discourages excessive flying by one passenger (e.g., no tax on the first two roundtrips per year, a steep tax for the third thru fifth roundtrip each year, and a very steep tax for subsequent roundtrips).
  • Aviation is the most intensive fuel-consumption activity in our modern lifestyle. It has enormous negative impacts, not only upon climate change, but also upon public health and neighborhood quality of life. Efforts to increase airport capacity do not reduce these impacts; they INCREASE these impacts.
  • Near the bottom of the news release, a paragraph glows about how this annual forecast is the ‘industry-wide standard’. More accurately, this annual forecast is a propaganda tool issued by a captured regulator, in collaboration with industry players and their lobbyists. It is disinformational, an improper use of public monies.

A Call For Action by OUR Elected Officials

Activists in the Boston area are gaining support from elected officials, toward a health study that needs to be done OUTSIDE FAA. Here is a graphic; please enlist the support of YOUR elected officials, too.

(click on image to view the FairSkiesNation FaceBook page)

Speaking of needed Congressional actions, below is the current aiREFORM wishlist. Every one of these proposals is doable. We just need elected officials who believe in empowered citizens, and who are driven to clean up the bureaucratic waste and abusive authority found in over-matured (and captured) federal regulators, like FAA.

Eleven FAA Reforms Our U.S. Congress Needs to Demand:

For starters, Congress needs to pass legislation that will achieve the following:

  1. arrange with the National Academies Division of Health and Medicine for a consensus report of existing study findings on the harmful health impacts of the NextGen technology.
  2. remove from FAA the authority to evaluate, manage, and reduce noise and air pollution impacts by aviation, and place those authorities under EPA or another non-FAA agency.

Further, Congress needs to pass legislation that will direct FAA to:

  1. fully implement all noise and air pollution impact recommendations, from the non-FAA authority, unless FAA can clearly document that implementation would create a hazard (in other words, prioritize aviation commerce BELOW aviation impacts).
  2. remove incentives to over-expand hub airports, by phasing out passenger facility charges and allowing (even encouraging) divestiture of excess airport lands for local non-aviation use. PFC’s need to be capped at $3.00, then phased out; AIP regulations need to be reformulated to end the current coddling of industry. The current regulations create perverse incentives to grow excessively and operate inefficiently, while also making it that much harder for other communities to have viable commercial airports.
  3. draft revisions to airport funding regulations and other FAA documents, that empower local officials with the right and duty to engage local citizens in democratically deciding how their local airport may be used (to include allowing night-time curfews, reduced flow rates, banning some aircraft types for safety reasons, etc.).
  4. advocate for LOCAL authority and LOCAL problem-solving (thus, support all locally designed solutions, even if they reduce total air commerce at that location, so long as the solutions are non-discriminatory and do not create a valid safety hazard).
  5. create clear regulations – and aggressively enforce them! – to end helicopter thrill rides sold as ‘air tours’ (neither the recent NYC tour crash, nor the earlier Grand Canyon crash, should have happened … and they would NOT have happened, if FAA was truly regulating this industry).
  6. create a program that makes flight data easily accessible online, so as to maximize operator transparency for repetitive flight operations; the goal should be to protect citizens against abuse by rogue operators, and to empower citizens in achieving real local control.

And lastly, in relation to climate change, Congress needs to direct FAA to:

  1. impose a federal aviation carbon tax (make it a steep tax, with half the revenues going to non-aviation spending, overall tax reduction, etc.).
  2. impose an environmental impact tax on leaded GA fuels (again, make it very steep, and direct all revenues to environmental programs, such as the non-FAA office charged with evaluating, managing, and reducing aviation noise and air pollution impacts).
  3. replace most of the current aviation ticket taxes and other fees with:
    1. a passenger ticket fee proportional to flight distance (itinerary miles, NOT direct miles).
    2. a stepped ticket tax for commercial passenger seats (free, first two one-way trips or first roundtrip; single fee next few trips (e.g., roundtrips #2 and #3 in a year); double fee trips beyond that (e.g., roundtrips #4 and higher in a year).

UPDATE, 3/18/2018: — A discussion of item #1 of this Post was held at QSPS, and includes valuable insight by Cindy Christiansen; she explains the need for ‘independence’ and the nature of the proposed ‘study’, and also provides a link to a NAS Mission statement. Click here for the QSPS FaceBook discussion.

A Victory for the People: Shuster is Scrapping A4A’s ATC Privatization Scheme

Yesterday, Congressman Bill Shuster, chairman of the U.S. House Transportation and Infrastructure Committee, announced he is abandoning his multi-year push (going back to at least 2015) aimed at privatizing the U.S. ATC system. The idea was sold as a way to remove roughly 35,000 employees from federal service, but many saw that in fact, the idea was just a way to give more leverage to the airlines and other corporate interests.

This is a big victory for all of us who want FAA to stop being a captured agency, a faux-regulator that fails to serve people while serving only aviation commerce.

Below is an archived compilation of various news articles with the announcement. The actual Press Release has not yet been posted at Congressman Shuster’s website.

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


See also this earlier aiReform content:

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

A recent news article out of Phoenix [KPHX] shows that both FAA and local officials are again ‘collaborating’ to screw over residents impacted by NextGen routes. Click here to view an archived copy with aiReform comments.

What I find most distressing about this article is it shows the real intent of the so-called settlement between FAA and local officials. FAA plainly lost when their case was finally heard at the U.S. Court of Appeals for the DC Circuit (USCADC). A responsible federal agency, actually serving the public (instead of just industry), would have accepted the court decision and promptly acted to correct their errors. Instead, FAA lawyers pressed local officials to compromise, to effectively defang the court decision … thus rendering the court meaningless. They crafted a deal that only perpetuates and expands the root problem: real people impacted by aviation have been shut out from having any voice, any local control, to protect their homes and communities.

An Analysis

When neighborhoods (and health) are being ruined by excessive airport scheduling, who is to blame? And, who can fix the problems?

With or without legal action,[1] there is always a small collection of ‘parties’ involved, including:

  • Elected officials (local, and federal)
  • FAA – the federal ‘regulator’ created to serve the public, funded by the public, but inordinately serving industry
  • Local/state administrative officials
  • Airlines (and other industry players)
  • Real people: impacted neighbors/residents, as well as locals who use aviation services

What role does each party play, and how are these parties interconnected? At the federal level, our elected officials have been lobbied by industry to create laws – including fee/tax systems – that shift the balance of power amongst parties. FAA, a captured regulator serving industry, then processes these laws into regulations, always with a bias that benefits the airlines. At the heart of these laws and regulations, Congress and FAA are stealing away local control. The effect is that the airlines, along with FAA, have evolved into a sovereign alien, occupying not just the sprawling airport lands but also the air above our homes. Real people – in homes, in city halls, and even in the governor’s mansion – have no meaningful powers to mitigate these absentee landlords who are indifferent about how their decisions trend their status toward ‘slumlord’.

That’s the core of it: No local control. Congress and FAA have created administrative sovereignty for an invasive and metastasizing aviation industry.

The situation is worsened today by the extent to which human greed is being played. Even our best officials are compromised by the lobbyists who now run the show.

Increasingly, it is an extremely rare official who, after winning an election or spending decades climbing to a high level administrative position, still maintains an ability to serve people, and not money. Corporations know what they want, and lobbyists (many of whom are also earning FAA retirement pensions!) know how to spin and maneuver to achieve what the corporations want. Money makes a great hearing aid; officials who seem tone deaf to constituent concerns ALWAYS come through to serve money. Some officials go totally rogue, accepting payouts, kickbacks, and jobs for the spouse. Most bought officials are careful to remain subtle. In all cases, though, nearly all officials find it easiest to bend to the lobbyist pressures; they drink their koolaid and trust their hype, without any critical assessment. Thinking and leadership are hard work; bending is far more convenient, especially if there is personal financial gain attached. In effect, and in time, many local/state officials become captured as industry servants.

Let’s be very clear on one other thing. When a new commercial airline impact appears and/or grows, it always does so because the one or two airlines who dominate that airport are tweaking the daily flight schedule, in pursuit of profits. Those profits do NOT come from adding more air travel for local residents; no, the profits come from more intense use of the local airport as a hub for more flights. The airline tallies more ‘through-passengers’ who pass through the airport as a passenger-sorting facility; the airport authority scores more PFC taxes, to pay off more accumulated airport capital improvement debt and fund more future airport growth projects. The airport sprawls larger and noise and pollutant impacts increase, yet the aviation service benefits to local residents show no meaningful gain.

Since the airlines are profit-seeking corporations, they do everything they can to minimize the costs (including labor) when implementing these changes. Thus, the fewest possible jobs are created; in other words, while noise/health impacts may soar, the real local economic benefits are held to a minimum. The marginal costs of growing a hub schedule typically always far exceed the marginal benefits to the local economy … which is why we see so much FAA/industry collaborated propaganda, spinning the illusion of airports as massive economic engines (while conveniently ignoring the massive subsidies involved).

A Short Data Example, from San Diego:

Here’s a table with enplanement data, extracted from the 2008 airport master plan for the crowded on-runway airport in San Diego [KSAN]. Operations data has been added, from FAA’s ATADS database. Also, the year-to-year change has been calculated.

  enplanements Yr-to-Yr change Operations (ATADS) Yr-to-Yr change
2002 7,471,644 206,605
2003 7,637,193 2.2% 204,713 -0.9%
2004 8,200,687 7.4% 215,211 5.1%
2005 8,692,694 6.0% 229,192 6.5%
2006 8,759,669 0.8% 230,798 0.7%
2007 9,172,966 4.7% 237,574 2.9%

Did local demand for aviation services grow 7.4% during 2004 and another 6.0% during 2005? No. If the local population had grown at such rates than, yes, it would be reasonable to expect such large annual increases. But, in fact, the enplanements grew far in excess of population growth. So, the enplanements grew due to shifts in airline scheduling. Those shifts massively increased the number of people from elsewhere, who became counted as enplanements when they changed planes or occupied a through-seat.

San Diego is a good example to study this because it is remotely located, in a corner of the nation, and close enough to the major hub at LAX. As such, it does not have the geographically central location needed to function well as an energy-efficient hub for through-passengers, at least not for domestic trips. In fact, if you study the airport’s Competition Plan,[2] you will see that all three legacy airlines (American, Delta, and United) offer very limited flights, primarily feeding only to their major U.S. hubs. The two airlines that use KSAN for hubbing are Southwest and Alaska. Southwest is the dominant airline and feeds many passengers through KSAN with origins or destinations along the West Coast. Alaska does the same thing, but Alaska’s hubbing is mostly to serve passengers vacationing at numerous Mexican destinations. If FAA wanted to minimize impacts on the local community at this very congested airport, they would remove the current incentives to use KSAN as a through-hub. If congressional officials wanted to help, they too would remove the current incentives, by pushing for changes in the laws that have defined the current problematic fee and tax system. If local officials wanted to serve impacted local residents, they would at least advocate, demanding FAA and Congress take these actions.

Some might suggest these growth figures do not reflect airline scheduling strategies, but instead reflect a recovery from 9/11. This is not the case. It is absolutely true that, across the U.S., enplanements and operations dropped after 9/11. But, two other truths also exist: (1) at all but the biggest hub airports, airline activity growth rates were already starting to decline in 2000;[3] and (2) the bulk of the recovery was completed in 2003. In other words, if FAA applied its resources to objectively study the data and report it to the public, FAA itself would prove that, by the end of 2003, the real people residing in and near San Diego had fully resumed their local consumption of aviation services. An uncaptured federal regulator writing such a report would confirm: the growth in impacts upon the local community are solely due to FAA’s accommodation of airline scheduling; more through-passengers means more profits … and more impacts.

What does this analysis mean, for resolving aviation impacts?

It all comes down to airline schedule changes for which marginal impacts increase far more than marginal benefits.[4] The impacts are increasing because the Av-Gov Complex is a machine that has airlines, FAA, and various local/state officials ‘collaborating’ to feed benefits to corporations … and this very same machine is screwing over the people. There is no local control. Instead, we have predictable choreography, with Av-Gov Complex players finger-pointing and claiming they are powerless, with zero accountability as impacts continue to worsen.

People want aviation services, but they also want (and need!) local control.

Since 2012, when Delta announced a new hub expansion at Sea-Tac [KSEA], all airport metrics have grown enormously (annual operations, enplanements, fuel consumption, air cargo tonnage). But so too have grown the many problems that both FAA and Port of Seattle take no action to fix: noise impacts, air pollutant impacts, arrival congestion forcing delays even at cruise altitude, road congestion for Seattle-area access to the airport terminal, even lengthy tarmac delays simply because the airlines are allowed to schedule in excess of existing gate capacity. The ongoing non-performance by FAA and Port of Seattle, and their bias toward accommodating airline greed, is shameful.

If O’Hare [KORD] scaled back to half its operations, would the Chicago area still be amply served with excellent service across the globe? Absolutely. And, at the same time, would impacts upon neighborhoods to the east and west be reduced? Yes, and to an astonishingly positive degree (as would national system delays).

Is the same true at other major hub airports? Yes. All of the communities where summer barbeques are destroyed (the food just doesn’t smell right, when the air smells like jet fuel), where incessant and repetitive noise patterns deny the restorative powers of nature or enjoying backyard play, where sleep is lost to accommodate loud early-morning cargo flights … all of these communities want their local airport to provide local services. But, these residents also want (and need!) local control, so that the scale of airport development and airline scheduling does not end up destroying health and quality of life.

The problems are not just at Phoenix, San Diego, Seattle and Chicago. While most U.S. airports continue to scale back (this is a shrinking industry), there is a small handful of other airports where one or two airlines want to grow more hubbing profits. To enable this, FAA’s NextGen implementation is plowing down residential quality of ([KBOS], [KJFK], [KLGA], [KBWI], [KDCA], [KCLT], and [KSFO] are all on that list).

Solutions will not happen, so long as the co-conspirators continue to conspire. The problems are local, and the best people to define and resolve the problems are the local residents. We are long overdue for the restoration of REAL LOCAL CONTROL, even (and especially!) at our largest hub airports.

— <> <[]> <> —


footnotes:

[1] It is also important to understand: the legal actions, such as the case heard when Phoenix sued FAA, are not full-fledged lawsuits where a plaintiff can force corrections and payment of damages; these are practically administrative hearings, as they are directed (by Congress) to be filed under a very short time limit, to the USCADC, which has a long history of bias favoring corporations, federal agencies, and other status quo powers. If Congress cared to protect citizen rights, we would be granted far more latitude, to pick more favorable court venues.

[2] One of the more interesting details within this Competition Plan is at pages 11-12; it is there noted that KSAN offers direct scheduled passenger flights to 56 destinations, but 47 of those are served by only ONE airline. Routes are thus 84% monopoly-flown.

[3] FAA ATADS data shows that KSAN commercial operations peaked in 1995 (219K), then dropped every year, bottoming out at 191K ops in 2000. In 2001, when airports were totally shut down for days, KSAN commercial ops actually INCREASED to 192K. Fifteen years later, the 2016 commercial ops had retreated 2.9%, to 186K; also, between 2001 and 2016, declines in TOTAL airport ops were even steeper, down 4.8%.

[4] Significantly, too, while the benefits accrue solely to the non-resident airline corporation, the costs accrue to the local residents. This cost-shift is a taking.

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.