Contact: Dan Hubbard, (202) 783-9360, firstname.lastname@example.org
Washington, DC, May 8, 2015 – The National Business Aviation Association (NBAA) today submitted comments to the FAA on the agency’s proposal to limit the number of unscheduled flight operations at three airports serving the New York metropolitan area: John F. Kennedy International Airport (JFK), Newark-Liberty Airport (EWR) and LaGuardia Airport (LGA). NBAA contends the notice of proposed rule making (NPRM), if finalized in its current form, will negatively impact a broad range of aviation operations that have not been shown to cause any delays or congestion at these airports.
“Incorporating in rule format operating limitations for a dynamically changing resource such as airport and runway capacity appears to suggest an outdated, prescriptive approach to rulemaking,” wrote NBAA Vice President for Regulatory and International Affairs Doug Carr in the Association’s response.
The proposed slot restrictions would limit unscheduled operations at EWR to one per hour. Unscheduled slots would be limited to two per hour at JFK. The FAA also proposes to maintain the current limitations on unscheduled operations to three per hour.
Under normal conditions, operators often choose to operate at Teterboro Airport (TEB) in Teterboro, NJ. When weather forces the reduction of runway capacity or prevailing winds favor non-standard operations, Teterboro often suffers inequitable delays (ground stops, miles-in-trail, etc.) in order to favor air carrier operations at EWR, LGA and JFK. Severely limiting slots at those three airports would be a de facto ban on business aviation operations into the area during such scenarios, said Carr.
The slot restrictions raise a safety concern as well, according to NBAA. Large airports with longer runways, such as JFK, EWR and LGA, remain attractive safety options for business aircraft operators facing deteriorating weather conditions. Aside from flights that have declared an emergency – which allows the pilot-in-command to deviate from any rule, including presumably FAA’s slot limitations, to the extent necessary to meet that emergency – it appears that operators facing a safety decision would no longer be able to plan on using EWR and JFK as alternatives when safety considerations would warrant their use.
NBAA has determined FAA did not perform an analysis on the safety impact of reducing unscheduled slots as part of formulating its NPRM.
The NBAA response also pointed out the adverse effects these slot restrictions would have on the two companies, Signature Flight Support and SheltAir, which have Fixed-Base Operations (FBOs) at the three major New York area airports. These businesses rely on non-scheduled traffic for their livelihoods. Each has invested millions of dollars to build, develop and maintain their facilities at these airports.
“It’s clear to NBAA that the FAA’s regulatory evaluation and cost-benefit analysis failed to include any review of the impact that the reduction of unscheduled slots would have on these FBOs and their ability to satisfy financial obligations to the airport,” NBAA wrote in the its response to FAA’s NPRM.
NBAA says the FAA’s NPRM “has not sufficiently justified any changes contained in this NPRM affecting unscheduled operations at EWR and JFK…. Based on the lack of information contained in this proposal, we believe that the FAA must not pursue any [new] unscheduled operating limitations.”
Along with the broad community of aviation operators that would be affected by the slot restrictions, NBAA welcomes the opportunity for dialog with FAA on how best to address the agency’s concerns about the use of these vital New York area airports.
Review NBAA’s full comments to the FAA. (PDF)
Founded in 1947 and based in Washington, DC, the National Business Aviation Association (NBAA) is the leading organization for companies that rely on general aviation aircraft to help make their businesses more efficient, productive and successful. The Association represents more than 10,000 companies and provides more than 100 products and services to the business aviation community, including the NBAA Business Aviation Convention & Exhibition, the world’s largest civil aviation trade show. Learn more about NBAA at www.nbaa.org.
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