September 16, 2009

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The National Business Aviation Association (NBAA) represents the interests of over 8,000 member companies who rely on the use of general aviation aircraft for a business purpose. General Aviation includes diverse operations, with business uses that range from agriculture, law enforcement, fire and medevac services, to varied government, educational, nonprofit and business organizations. NBAA’s members operate in every type of airspace and airport across the nation. We appreciate the opportunity to provide the Aviation Subcommittee with our views for the hearing today on the Hudson River Airspace.

Aviation remains the safest mode of transportation, bar none. The number of safely completed operations continues to rise each year. This impressive record is in large part due to the continued partnership between the aviation community and the government to pursue new technologies, enhanced procedures and implement new safety-based requirements that further improve aviation’s already impressive safety record.

As we all know—tragically–aviation accidents do happen. When they occur, the entire aviation community feels a sense of loss and pain. Every accident investigation provides insight and lessons as to how we can improve aviation safety. However, it is important to note that each incident involves a unique set of situations, causal elements and factors. In this area, the National Transportation Safety Board is tasked with analyzing accidents and determining the cause.

Long History of Safety Partnership

NBAA and its member companies have a long, demonstrated history of partnering with the FAA to address safety issues and mitigate risks. It has been shown repeatedly, and again following the recent tragic midair collision over the New York City-Hudson River, that engaging affected parties to assist with the development of safety solutions produces better results. We commend FAA Administrator Randy Babbitt for reaching out to the aviation community in the days immediately following this accident to identify cooperative steps that could be taken to enhance air safety in this busy and vital air corridor.

Specifically, the airspace and radio frequency changes proposed by the FAA will standardize existing procedures, provide greater knowledge of those local procedures to transient aircraft, and increase communication between FAA controllers overseeing those operations.

While we do not yet know all the facts relating to the causes of the August 8, accident, NBAA believes that the actions proposed by the FAA will further enhance aviation safety in the New York City-Hudson River airspace. These announced steps take advantage of established industry practices already in place and well known to pilots that regularly operate within that busy airspace. The new safety procedures in the low-level airspace over the Hudson River are reasonable and workable and our members are committed to these efforts.

In addition to the important analysis work done on aviation accidents and incidents, it is also vital that we continue to maximize the vast operational data collected by the FAA, NTSB, aviation manufacturers and operators to drive future safety enhancements and improve accident prevention. This analytical data often contains trends which are important in identifying risks and capturing behaviors which can contribute to aviation accidents. This knowledge is vital in assisting industry and government efforts to improve aviation safety.

Action Key to Improved Safety

The FAA will soon issue a detailed rulemaking proposal to incorporate these airspace safety proposals into regulation. We look forward to reviewing the proposed rulemaking and being an active and constructive stakeholder in the regulatory process.

NBAA would also like to take this opportunity to urge FAA to implement several pending proposals that we believe would further enhance aviation safety.

Nearly five years ago, an industry working group (The Part 135 and 125 Aviation Rulemaking Committee) chartered by the FAA–and which I chaired–submitted extensive recommendations for regulatory changes that would update and strengthen safety for FAR Part 135/125 industry. These recommendations covered a multitude of subjects including basic requirements for flying commercially, updates to pilot duty and rest requirements, enhanced training for commercial pilots, revised aircraft maintenance requirements and role of very light jets (VLJ’s) in on-demand charter operations–all of which that would significantly improve safety. Unfortunately, the Agency has not acted on those recommendations to date. A copy of those recommendations and the transmittal letter are attached to my testimony.

Over the years, NBAA has consistently welcomed the opportunity to support FAA efforts that seek to improve aviation safety. We have committed significant time, energy and resources to these projects only to have the products of our effort languish with no improvements in safety. While we understand that the FAA faces resource limitations like the rest of us, it is frustrating to continue to support these FAA projects without any clear understanding whether the agency will implement the final recommendations.

In the interest of continued improvement in aviation safety, NBAA and our members will always strive to lead, not follow. We look forward to working with this Subcommittee, and the other government and industry stakeholders to keep safety as our number one priority. NBAA appreciates the opportunity to provide our comments to the Subcommittee today. Thank you.