In this issue:
- What problem is ATC reform trying to solve?
- Separating ATC from safety regulation
- Government corporation or nonprofit corporation?
- What about service to rural and small-city airports?
- Are overseas ANSP models scalable to the USA?
- Why not a for-profit ATC corporation?
- GPS backup back on the agenda
- News Notes
- Quotable Quotes
Since last month’s issue, both the House and Senate aviation subcommittees have held hearings on reform of the funding, governance, and structure of the air traffic control system. The prospect of sweeping reform, such as corporatizing the Air Traffic Organization, has raised a number of questions for debate and discussion. Accordingly, the majority of this issue is devoted to addressing some of the most important ones.
In his April 14th testimony before the Senate’s aviation subcommittee, FAA Administrator Michael Huerta acknowledged that “there is talk about restructuring the FAA as part of this reauthorization. I am all for having that discussion, but . . . we need to be sure that any governance changes would work to solve the challenges faced by the FAA.” When Commerce Committee chair Sen. John Thune (R, SD) asked him to clarify, Huerta replied that “it is important to ask what exactly is the problem we are trying to solve.”
In my testimony before the House aviation subcommittee several weeks before, I stressed that there are three interlinked problems that need to be solved. First is funding. Recent years of sequester and partial government shut-downs have led almost everyone to agree that uncertain, unstable funding is unacceptable for a vital service such as air traffic control. And by not facilitating revenue-bond financing of large capital programs (like airports use), it makes large-scale modernizations like NextGen and facility consolidation all the more difficult.
The second problem is governance. When I have talked with senior FAA people off the record, and former ATO officials more openly, they have been very candid that having to respond to the combined oversight of the DOT Secretary, the Office of Management & Budget, the Government Accountability Office, the DOT Inspector General, and ultimately 535 members of Congress consumes an enormous amount of top management time. And that ends up focusing management attention on satisfying those “customers,” rather than where it should be focused-on the customers using the services of the ATC system.
The third problem-much less discussed-is the ATO’s dysfunctional organizational culture. Compared with the innovation that keeps bubbling up in the Boeings and Honeywells of the world, the ATO is highly status-quo oriented, and has an organizational/management structure that, as one veteran observer told me, empowers 10 people to say “no” for every one that can say “yes.” This status-quo culture is part of the reason the U.S. ATC system lags behind its corporatized counterparts overseas in actually implementing the systems and procedures envisioned in NextGen, such as controller-pilot data link, replacing ILS with GPS-based landing systems, implementing RNP curved approaches, signing up for global space-based ADS-B, etc. (It also does not help that with civil service pay scales, the ATO has difficulty attracting and keeping high-performing engineers, software experts, and program managers.) My detailed assessment of this problem, commissioned by the Hudson Institute, is a 54-page report, “Organization and Innovation in Air Traffic Control.” (/wp-content/uploads/2014/01/air_traffic_control_organization_innovation.pdf)
The three problems are interlinked in a number of ways. Funding reform is needed not just to provide a more reliable basis for the ATO’s capital and operating costs. If this is done by switching from aviation taxes to ATC fees paid directly to a self-supporting ATO, that changes the funds from taxpayers’ money to the ATO customers’ money. And that means the oversight of how those funds are spent can shift from myriad governmental entities to a governing board made up of stakeholders. This kind of funding reform directly enables governance reform.
My conclusion about the primary reason for the ATO’s risk-averse, status-quo culture is that the agency is embedded within a safety regulatory agency, which has shaped its culture. Therefore, a precondition for changing that culture is removing the ATO from the FAA, putting it at arm’s length from the safety regulator, just as innovative Boeing and Honeywell (and every airline, and every FAA service contractor) are regulated at arm’s length by the FAA. I discuss the safety consequences of this kind of separation of ANSP from air safety regulator in the article below.
Overall, three serious problems would be solved by converting the ATO into a self-supporting corporate entity, funded directly by its aviation customers, governed by a board representing those customers and other key stakeholders, and regulated at arm’s length by the FAA. (My March 24th testimony is available at: /wp-content/uploads/2015/03/robert_poole_testimony_air_traffic_control.pdf>.
In his Senate testimony, Administrator Huerta several times said that although all reform options are on the table, there “must be a tight linkage” between safety and modernized technology and procedures. In recounting recent modest progress in implementing some NextGen features, he attributed the progress to the “tight nexus” between ATO operations, NextGen developers, and safety regulators. And he said he is “fearful” of any structure that “puts a wall” between those functions. That would clearly rule out separating the ATO from FAA, it seems to me.
The idea that ATC reform should keep safety regulation and the ATC provider together received an unexpected endorsement in the House testimony of Craig Fuller, speaking in his capacity as vice chairman of the new FAA Management Advisory Council that took office in January 2014. He presented a concept-not yet approved by the MAC (as eight general aviation stakeholder groups noted in a March 23rd letter to Fuller)-that would convert the entire FAA into a Federal Corporation governed by a stakeholder board. According to his testimony, this would avoid a “disruptive” separation of safety regulation from ATC and a long transition period.
This is not a new idea. Its roots date back to periodic calls for taking the FAA out of DOT, making it a free-standing agency directly answerable to Congress, rather than to the DOT Secretary. And back in 1986 the National Academy of Public Administration, reviewing an ATC corporation proposal from the Air Transport Association, recommended instead converting the entire FAA into a corporation.
But by the time of Vice President Gore’s reinventing government effort in 1993-94, several self-supporting air navigation service providers (ANSPs) had been created by pulling the ATC function out of the government transport ministry. Their example provided the basis for what became DOT Secretary Pena’s 1994 U.S. Air Traffic Services Corporation (USATS) legislative proposal. The existing ATC system would be separated from the FAA and set up as a largely self-funded government corporation, with revenue-bond financing authority, governed by a stakeholder board. One of the key virtues cited by both Gore’s team and the two-volume USATS report was the separation of safety regulation from operations. Arm’s-length safety regulation was viewed as a far wiser approach than the self-regulation inherent in the traditional FAA structure.
The main USATS report addressed the “FAA Corporation” idea as follows:
“This model was perceived as less than optimal for several reasons. While there would have been benefits in keeping the FAA together as an organization, there was concern about establishing the safety regulatory and oversight functions outside the traditional government organization. There was also a concern that users, through Board membership, would have had some authority to oversee safety regulation. It was likely that a new safety oversight function would be required in DOT to oversee the corporation. There was also concern that the corporation’s independence and flexibility, especially with regard to the ATC function, would have been greatly diminished by the fact that the CEO and Board would have been directly accountable to the Executive Branch and Congress for major portions of the organization’s funding.”
The world has moved on since then. In 2001, the International Civil Aviation Organization (ICAO) revised its Safety Oversight Manual (Doc. 9734, Part A, Paragraph 2.4.9) to call for organizational separation of ANSPs from aviation safety regulators. And all 60 of the self-supporting ANSPs in operation today are regulated at arm’s length by their government safety regulators. As Steve Van Beek, member of the FAA MAC (2011-2013) put it in has April 16th piece in Aviation Week, “Other nations and ICAO recognize that national regulatory agencies should focus on the provision of public goods such as regulation and safety, not delivering user services. These systems typically separate the air traffic provider from the regulator, protecting the interests of the public while enabling the efficiencies and access to capital of a commercialized provider.”
But the ultimate answer regarding the impact of arm’s-length separation on safety is empirical data. The first large-scale study of before/after performance by commercialized ANSPs came out in January 2006. Overall, it found that safety performance was either unchanged or (in most cases) improved in the years after corporatization. (http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1317450)
More recent data on three of the most relevant ANSPs finds the following:
- Nav Canada: the rate of losses of IFR separation per 100,000 aircraft movements declined by 58% between 1997 and 2012.
- NATS (U.K.): “airproxes” per 100,000 movements declined 77% between 2002 and 2012.
- DFS (Germany): “risk-bearing airproxes” per 100,000 movements declined 85% between 1996 and 2012.
Those are long enough periods of time that if there were some kind of inherent defect in arm’s- length safety regulation, it would have shown up by now.
It is looking increasingly like the main alternatives for ATC restructuring will boil down to a government corporation versus a federally chartered non-profit corporation. Prototypical examples from overseas would be government corporations like DFS (Germany) and Airways New Zealand, on one hand, and not-for-profit, non-share capital corporation Nav Canada.
Of the aviation stakeholders testifying at the March 24th House hearing, Airlines for America (A4A) clearly favored the latter. As Douglas Parker said in his testimony, “Our work to date leads us to believe that a commercialized, non-profit type governance model would deliver the greatest benefits for a reformed ATC entity because such a structure would continue to put safety first, while driving value for all stakeholders.” That was also the recommendation of former Air Traffic Organization Chief Operating Officer David Grizzle, speaking on behalf of the ATC reform project of the Business Roundtable. Controllers union president Paul Rinaldi, while stressing that funding reform is NATCA’s top priority, said that they are willing to consider any organizational alternative except a for-profit corporation.
Dorothy Robyn, who worked on the USATS proposal in the Clinton White House, told the House subcommittee that although she favored a government corporation at the time, she has subsequently concluded that a better alternative for this country is a non-profit corporation, chartered by Congress but outside the federal government altogether. She compared the two alternatives in a recent piece for the Brookings Institution. She points out that “Government corporations in the United States do not have the same degree of political insulation as those in other countries,” citing the U.S. Postal Service, which despite being a nominally independent, self-supporting government corporation, has repeatedly had its business decisions (such as shutting down little-used post offices) thwarted by Congress. She concluded that the one ANSP that is outperforming all the others is non-profit Nav Canada.Why? “The reason is incentives: Nav Canada’s basic organizational design-management by a stakeholder board that is dominated by the users themselves-creates an incentive for efficiency in the absence of competition and eliminates the incentive for monopoly abuse.” (www.brookings.edu/blogs/fixgov/posts/2015/04/06-faa-user-cooperative-government-corporation-robyn)
I agree with that conclusion. There are also many impediments to businesslike operation created by federal law and practice regarding government corporations. For example, the Treasury Department generally insists on control of their bond issuance. Their fees and charges must be based on costs, not value (which makes it impossible to charge low fees to users with limited ability to pay). Government corporation boards are made up of political appointees. And many must still contend with oversight by congressional committees, the GAO, and even OMB.
A nonprofit, non-governmental corporation does raise questions that would probably not arise in converting the ATO to a government corporation, such as liability, insurance, and valuing the assets so that the company can obtain full title (and thereby use them as collateral and/or dispose of those no longer needed). Those are not trivial issues, but they were all resolved in the case of Nav Canada, and they can likewise be resolved here, if the consensus is that a government corporation is unlikely to fully solve the ATO’s underlying problems.
A genuine concern of people and businesses in small cities and rural America is access to the national airspace system. If the inherently public governmental provider-the current ATO directly overseen by Congress-is transformed into a 24/7 high-tech service business, would small towers be shut down, and growing communities without towers be prevented from obtaining them?
Those who favor a nonprofit corporation approach, especially of the user co-op variety (i.e., with a broadly based stakeholder board), argue that while that might happen in a for-profit ATC corporation, it would not be likely in the non-profit corporation, especially if the enabling legislation made it clear that continuing such access is part of the company’s mission.
Earlier this year it was alleged that after it started up, non-profit Nav Canada had reduced service to remote areas. I queried Nav Canada directly about this, and received a detailed listing of its facilities for the start-up years, 1996 through 1999. Over that four-year period, just one of its 44 control towers was closed (a part-time tower at North Bay) and replaced with a 16 hours/day flight service station (FSS). Four FSS’s were closed over those four years, replaced by either a 24-hour Contract Weather Office (CWO) or a Community Aerodrome Radio Station (CARS) providing weather and airport conditions. Each also was provided with FISE RCO-Flight Information Service Enroute and Remote Communications Outlet. They permit IFR arrivals and departures at very low-volume airports. Thus, none of these previously served remote locations was left without access to airspace services, tailored to their actual volume.
Overall, Nav Canada tells me that there is more service today to more places than was provided by their predecessor, Transport Canada.
Probably the most common concern I’ve heard expressed in discussions of an ATC corporation is along the following lines. Sure, some of the overseas ANSPs have been very successful, but none of them has anywhere near the level or complexity of air traffic handled by our ATO. As Paul Rinaldi of NATCA observed in his House testimony, in 2012 there were 12 million flights in Canada compared with 132 million in the United States. There are 21 centers here, but just 7 there, and 315 towers here versus 42 there. And this country has 8 of the 10 busiest airports in the world, and 16 of the top 30. Canada has only one, Toronto, ranked 15th busiest.
Ihaven’t checked those numbers, but their order of magnitude is certainly correct. But also irrelevant. I asked former COO David Grizzle about this question, which he gets repeatedly. His answer was as follows:
“The U.S. air traffic control system is already scaled. It already has more than 500 facilities, more than 14,000 controllers, more than 6,000 technicians, and more than 5,000 managers. What is the scale component they are looking at? The boards and senior management cadres are the same for $500 million organizations as they are for a $50 billion organization. It would be one thing if we were starting with the Canadian system and building it to serve the needs of the U.S. system. But the fact is that the U.S. system already exists, fully scaled. It just needs to be managed with a different set of principles and values. That particular activity does not present a scale issue.”
I also asked the question of John Crichton, CEO of Nav Canada. While agreeing on the much larger overall size of the U.S. system, he asked, “Does it really matter? What if California became a separate country with its own ATC system and had 10% of the traffic of the current U.S.? Would that change the nature of ATC in California or the rest of the U.S.? It would not.”
On the question of airspace complexity, let me refer back to a series of reports produced jointly by Eurocontrol and the FAA, “Comparison of Air Traffic Management-Related Operational Performance: U.S./Europe.” These reports focus on air traffic to and from the largest airports in the two regions. While the average number of daily IFR departures is larger for the 34 main U.S. airports than the 34 main European airports, the larger dozen or so EU airports exceed the number of departures at about one-third of the 34 U.S. airports. And maps in these reports comparing the density of IFR flight hours by center show that traffic density is just as great in Europe’s core area (Benelux, northeast France, Germany, and Switzerland) as in the airspace of our Cleveland, Chicago, Indianapolis, and Atlanta centers.
Crichton puts it this way:
“The U.S. ATC system is complex. Does that change the nature of the operation? The execution of the ATC function is done in sectors. Sectors are designed so that one controller or small group can execute the function without being overloaded. An approach control center in Toronto, Canada or London, England or Langen, Germany is configured and operated in a remarkably similar fashion to an approach control center in Atlanta. Each individual sector handles about the same amount of traffic. There are more sectors in the U.S. than elsewhere, but each sector operates in a functionally similar way. There are five busy airports in the London area. NATS claims that it is the most complex airspace in the world, with good reason. The U.S. ATC system is large and complex in aggregate, but is not different in nature than other busy, complex airspaces.”
At the March 24th House hearing, former Aviation Subcommittee chair Rep. John Mica (R, FL) passed out copies of a draft bill to transfer the ATO to a corporation based on an employee stock ownership (ESOP) plan. Mica has long championed ESOPs as a way to motivate the employees of a government service provider to accept transitioning it to the private sector. Mica asked those of us testifying that day to submit our comments on the bill by April 15th. I did so, recommending against this approach, but on April 16th we all saw headlines about Mica introducing his ATC ESOP privatization bill.
In my written comments, I noted that for the foreseeable future, ATC everywhere is and will be a monopoly (except for contractor-operated control towers). When a function is a monopoly, there must be some way to protect its customers from monopoly pricing and other possible abuses. The three principal alternatives are a for-profit company with an external regulatory agency (as with investor-owned utilities), a government corporation (which is presumed to operate in the public interest, such as municipal utilities), and a non-profit user co-op.
In air traffic control today, we have examples of all three. The large majority of ANSPs are government corporations, operated on a not-for-profit basis, with no regulation. The one partially private, for-profit ANSP is NATS, the U.K. provider. Accordingly, it has an external economic regulator that controls the rates it charges on its monopoly services. And we have one example of what amounts to a user co-op: not-for-profit, stakeholder-governed Nav Canada. It has no economic regulator, but does have statutory charging principles it must follow, with a right of appeal to the government if a customer group considers a rate charged to be in violation of the charging principles.
Utility regulation has a host of well-studied drawbacks, including a tendency to over-invest in costly facilities (to have a larger “rate base” against which to earn the allowed rate of return), and asymmetry of information between the regulator and the regulated company. I see no particular reason, therefore, to go the for-profit route, if there is a simpler way to get the right incentives. And with a considerable history of user co-ops in aviation (including the first U.S. air traffic control, set up by airline user co-op ARINC), that has long seemed to me to be the best model.
But it’s also the case, as I pointed out in my brief, that nobody in the transportation research community or the aviation stakeholder community wants a for-profit ANSP. At the House hearing, NATCA’s Paul Rinaldi was quoted in several news reports saying, “NATCA absolutely opposes any model that derives profit from air traffic control services. A profit-driven system . . . might cut services to rural communities because of the lack of returns for shareholders. A profit-driven system might also be an impediment to our general aviation sector, which is very sensitive to changes in services or increased costs.”
Since you have to have a for-profit structure in order to have stock to use in an ESOP, but neither the employees nor other stakeholders want a for-profit structure, this appears to be a solution in search of a problem. But Mica is to be commended for being the first to actually offer a bill to corporatize the ATO.
It’s been eight years since the government’s Independent Assessment Team, at the request of DOD and DHS, recommended that the best overall backup approach for position, navigation, and timing (PNT) for all GPS users (not just aviation) would be to implement an enhanced version of the long-established Long Range Navigation system Loran, called eLoran. In February 2008 DHS announced that it had accepted the recommendation and that eLoran would be developed and implemented. But for reasons that have never been explained, the incoming Obama administration failed to implement this decision and the Coast Guard began shutting down the legacy Loran system.
Other countries have gone ahead with eLoran, including South Korea (which is vulnerable to North Korean jamming). There is a U.K./Ireland project to protect maritime navigation at northern European ports, including a high-precision pilotage version at Rotterdam Europort. And another European project is under way to use signals from the EU’s Galileo system over the Loran Data Channel to provide precise timing for telecommunications.
But the biggest news for U.S. readers is recent action in Congress to preserve the infrastructure of Loran-C for possible use as the platform for eLoran and its operation by a non-governmental commercial entity. And the bipartisan National Positioning, Navigation, and Timing Resiliance and Security Act of 2015, introduced by Rep. John Garamendi (D, CA), would require the Secretary of Defense to establish a reliable, land-based PNT system as a GPS backup. It calls for broadcasting eLoran signals from 19 towers across the country.
There is also a Federal Register notice, inviting public comment “regarding potential plans by the U.S. government to implement an enhanced Long Range Navigation (eLoran) system as a complementary positioning, navigation, and timing (PNT) capability.” Comments are due on or before May 22, 2015. The docket number you need is DOT-OST-2015-0053.
Searidge Scores Two Remote Tower Wins. Canada’s Searidge Technologies has announced contracts with two European ANSPs to set up remote tower centers. In a project funded by the SESAR Joint Undertaking, the ANSP of Italy-ENAV-will host a remote tower center at Milan Malpensa Airport that will provide night-time tower services for Milan Linate Airport, as well as a virtual airport. The system will include real-time video, target tracking and positioning, and real-time data on a common platform. The second contract is with HungaroControl, the ANSP of Hungary. It will create a remote tower at Budapest Airport, served by a customized video wall and interfaced with an Advanced Surface Movement Guidance and Control System from Indra Navia.
Australia Developing Fully Integrated Civil/Military ATC. ANSP Airservices Australia and the Royal Australian Air Force have selected Thales Australia to develop the country’s next-generation ATC system, which will integrate all civil and military airspace and management-reportedly the first such system in the world. The new system, called OneSky, is scheduled for full implementation by 2018.
FAA Awards Contracts for Contract Control Towers. On April 7th, the FAA announced new five-year contracts for all towers in the FAA contract tower (FCT) program. The three current contractors-Midwest ATC, RVA, and Serco-have retained most of the towers included in their previous contracts, with the only change being that Midwest will now manage Area 7 (Guam, four Hawaiian airports, and Saipan) instead of Serco.
GBAS Selected for St. Helena Island. The new airport on St. Helena, a British island territory in the South Atlantic, will be served by a Honeywell Smartpath Ground-Based Augmentation System (GBAS), which provides precision runway approaches by enhancing GPS satellite signals, instead of a traditional instrument landing system (ILS). The system is being installed this quarter, with navigation-aid calibration flights scheduled for July.
FAA Extends Flight Service Station Contract. Lockheed Martin has received a contract extension of up to 42 months to continue managing the existing Automated Flight Service Station (AFSS) program. With ever-larger numbers of private pilots using online access for flight-plan filing, weather briefings, and other AFSS services, the FAA Air Traffic Organization is still working on its Future Flight Service Program. FFSP will likely replace the two existing contracts for online services as well as the AFSS contract with a single new contract sometime between now and 2019.
Time-Based Separation Now Operational at Heathrow. Traditional separation between flights in the landing queue uses a fixed distance, based on each plane’s wake vortex characteristics (mostly a function of size and weight). But when there are strong headwinds, planes move more slowly over the ground, which reduces the number that can land per hour. The alternative is to space flights by time, using real-time data on headwinds. A time-based separation system, developed by NATS (the U.K. ANSP) and Lockheed Martin, went live at London Heathrow Airport last month. It is expected to cut headwind landing delays in half.
North Atlantic ATC Streamlined by NATS and Nav Canada. The ANSPs of Canada and the UK have achieved two major milestones for the busy North Atlantic air routes, 90% of which are managed by these two providers. First, Nav Canada’s Gander Automated ATC System (GAATS+) went live at the NATS Oceanic Control Center in Prestwick on Nov. 24th . That provides seamless ADS-B surveillance for these routes, which will lead to reduced in-trail and lateral separation minima in coming years. And on Nov. 26th, the first digital messages were sent over the enhanced North Atlantic Common Coordination system. NACC now allows controllers in adjacent oceanic flight information regions (FIRs) to coordinate handoffs of flights from one FIR to the next digitally, rather than by voice.
“There is significant consensus about the basic problem: air traffic control is a massive, complex, technology-intensive service business operating within a conventional U.S. government bureaucracy. . . . It is a bit like putting a Ferrari engine into a dump truck body and still expecting it to win races.”
-David Osborne, The Reinventor’s Fieldbook, Jossey Bass, 2000, p. 106
“Support is emerging for using this year’s FAA reauthorization to address two pressing needs. First, where possible, remove the FAA’s services from the federal budget process, where they are vulnerable to interruption. Second, modernize the provision of air traffic control and other services by separating them from the FAA, allowing the agency to focus on its key regulatory mission. Passage of an FAA reform effort would be the most sweeping and significant aviation policy reforms since 1978-when the Airline Deregulation Act became law.”
-Stephen D. Van Beek, “Opinion: The Time Is Now for Aviation Policy Reform,” Aviation Week, April 16, 2015
“Our nation’s air traffic control system has served us well for many years, but it is still based on equipment, concepts, and procedures that date back decades. In recent years the FAA has tried to modernize the system by moving to satellite navigation and more automation. But these efforts have cost many billions of dollars with not as much progress as we all would like to see. The Government Accountability Office and DOT’s Inspector General have pointed out many shortcomings with respect to FAA’s efforts to modernize our air traffic control system. Some of the problems seem to be deep rooted and cultural in nature. Nearly eight years ago the IG noted that implementing NextGen would be an extraordinarily complex, high-risk effort. That looks like a gross understatement, as we are still many years away from full implementation, with many more billions yet to be spent. Some have suggested that the current governance model for air traffic control is ill-suited for NextGen. In that regard, I applaud Chairman Shuster, of the House Transportation and Infrastructure Committee, on his consideration of new approaches that may yield better results and deliver the promised benefits of NextGen.”
-Sen. John Thune, Chairman, Senate Commerce Committee, opening remarks at hearing on FAA Reauthorization, April 14, 2015
“Like it or not, it seems clear that the FAA-for a variety of reasons identified by numerous analysts including the DOT’s Inspector General and the GAO-cannot and will not effectively implement NextGen. Thus, to seize the benefits NextGen offers, we need to take the ATO out of the FAA and create a self-supporting corporate entity to perform the ATC function. As you all know, this is not a very radical proposal since many other countries-including Canada, the UK, Australia, and others-have already taken similar steps.”
-Robert Crandall, 2015 “Sight” Lecture, Wings Club, Washington, DC, March 26, 2015
“A4A has undertaken considerable research on various models of air traffic organization around the world. In particular, we have done a thorough analysis to benchmark and assess the governance, financial, and operational performance of the U.S., Canadian, and European ATC models in order to make an informed comparison between our current system and those systems engaging in best practices outside the United States. Our evaluation reviewed the safety, predictability, efficiency, cost/productivity, customer service, and NextGen implementation performance of each of these organizations. That research leads us to the conclusion that to bring our ATC system to where it should be today and must be for the future, transformation, not renovation, is required.”
-Douglas Parker, CEO, American Airlines, “Air Traffic Reform (ATC) Solutions,” Airlines for America testimony, House Aviation Subcommittee, March 24, 2015