Aviation Policy News: Airport groups, the evolving U.S. airline market, and more
Photo 35224701 / Airport Planes © Brett Critchley | Dreamstime.com

Aviation Policy Newsletter

Aviation Policy News: Airport groups, the evolving U.S. airline market, and more

Plus: Ultra-low-cost carriers, air traffic control modernization, aviation emissions, and more.

In this issue:

Airport Groups Are Changing Commercial Aviation

Over the past 25 years, a new phenomenon has quietly evolved—the airport group. A study by ICF and Oxford Economics, commissioned by Airports Council International, documents the growth of this new entity and explains how and why it is adding value to large and medium airports worldwide. The study is “Value Creation by Airport Groups” and is online here.

An airport group is a set of airports with common management. Today, 425 airports are part of airport groups, handling 2.7 billion annual passengers (29% of the global total) and 27 million annual tons of cargo (23% of the total). As of 2019, airport groups handled 53% of Europe’s passengers, 28% of Asia-Pacific passengers, 14% of passengers in Latin America and the Caribbean, but only 3% of passengers in North America, 2% in the Middle East, and none in Africa.

If you recognize this distribution as similar to the figures for privatized airports, you’re right. Most airport groups consist of either privatized airports (London Heathrow, Frankfurt) or corporatized airports (Amsterdam Schiphol). The report identifies 27 airport groups, all but six of which provided data for the ICF-Oxford study. The five largest airport groups, ranked by the number of annual passengers, are:

RankGroupNumber of Airports2019 Passengers (M)HQ Country
2Capital Airports53266China
3Vinci Airports51235France
5Group ADP11163France

Two small airport groups are U.S.-based—Vantage Airport Group and AvPorts.

The study identifies two types of airport groups in terms of their underlying business. The large majority are airport operators, per se—i.e., that is their primary business. But five large groups are led by infrastructure and construction companies: Vinci Airports, Egis Group, Atlantia, Ferrovial, and GMR Airports. The report does not identify any major differences in how the two types operate.

Why should we care about this emerging phenomenon? The report identifies a number of ways in which the airport group model adds value. It provides economies of scale (e.g., in knowledge sharing with smaller airport members, lower costs via bulk purchases), resilience (e.g., a downturn in one country’s economy may not affect the airports in other countries or regions), and increased ability to finance capital investments. The airport group can also set management policies and performance targets for member airports and ensure that various standards are met. Airport groups can try out new technologies and procedures at one of their airports before deciding whether to adopt them group-wide.

As I noted above, there is a significant overlap between airport groups and airport privatization. And that means we should not be surprised that this model has not become very visible in the United States. We have, however, seen airport groups taking part in responding to requests from qualifications from the occasional U.S. airport that expresses potential interest in privatization (e.g., St. Louis in 2019). So when U.S. airport owners finally get serious about long-term public-private partnership leases of their airports, I expect there will be keen interest from global airport groups.

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Ultra-Low-Cost Carriers in a Changing U.S. Airline Market

On his third-quarter earnings call late last month, United Airlines CEO Scott Kirby declared that ultra-low-cost carriers (ULCCs) are “doomed” due to rising fuel costs and labor shortages, going so far as to describe the ULCCs’ business model as a Ponzi scheme. Aviation Daily then quoted airline consultant William Swelbar as not having quite as negative a view but suggesting that with the current U.S. pilot shortage, “legacy carriers are offering their regional pilots as much or more money than flight crews at ULCCs earn, in many cases.” Both Kirby and Swelbar are highly knowledgeable airline experts, but I’d like to offer a different assessment.

First, I doubt that it’s sustainable for legacy carriers to dramatically increase pilot compensation for flying regional jets that carry a small fraction of mainline airliners’ passengers. Second, the fact that regionals, many of them owned by or contracted by legacy carriers, have much lower cockpit crew salaries means that ULCCs can address their own growth needs by offering improved pay and benefits to regionals’ pilots and first officers.

Third, with one exception, I see no signs of ultra-low-cost carriers slacking off on growth. That exception is Spirit, which has agreed to be bought out by JetBlue. Earlier this month, Spirit announced that it is cutting 35 routes next year, as it anticipates being absorbed into JetBlue, which will reduce the seating capacity of Spirit’s planes and convert it to JetBlue’s model of being an intermediate between a legacy carrier and an ultra-low-cost carrier. That change, assuming regulators permit the merger to happen, will open up the market for the remaining ULCCs. And they intend to expand into that void.

At the Routes World 2022 conference in Las Vegas last month, Frontier CEO Barry Biffle told attendees that JetBlue taking Spirit out of the market was as if “Nordstrom purchased a discount store like Walmart and then closed it down.” On Oct. 25, Biffle told Aviation Daily that with 18 Airbus A321XLR (extra long-range) aircraft in the pipeline, Frontier is looking to expand its existing international routes, with the new planes capable of trans-Atlantic and South American service. With the XLR version, “From Miami, you can reach pretty much anywhere in South America,” he said. Frontier already serves 20 non-U.S destinations in the Caribbean and Central America, in addition to its 92 domestic destinations, which include major airports such as ATL, BNA, BOS, BWI, CLT, DFW, FLL, LGA, MIA, MCO, MSP, ORD, PHL, SAN, SEA, and SFO, in addition to numerous smaller airports that are more-typical of ultra-low-cost carriers.

How about the other ULCCs? Allegiant now serves 91 airports, mostly in the United States. Newcomer Avelo, now in its second year, already serves 21 destinations, including Burbank, Ft. Lauderdale, Las Vegas, Orlando, and Tampa, plus smaller cities like Eugene, OR, New Haven, CT, Ogden, UT, and Sonoma, CA. And fellow newcomer Breeze has 30 destinations thus far, including large airports BNA, LAS, LAX, MCO, PIT, SFO, and TPA, plus smaller points like Ft. Myers, Hartford, Huntsville, Islip, Norfolk, Provo, and Syracuse.

Ultra-low-cost carriers appear to have found solid market niches aimed primarily at price-sensitive leisure travelers. The decline and then disappearance of Spirit will open additional opportunities, and if they can recruit enough pilots in the next five years, ULCCs’ planned growth seems probable, Scott Kirby’s skepticism notwithstanding.

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Next Congress Unlikely to Shake Up Air Traffic Control Status Quo
By Marc Scribner

At the beginning of November, I attended the Air Traffic Control Association’s ATCA Global conference in Washington, D.C. While many fascinating discussions on a variety of topics took place, perhaps the most urgent related to the forthcoming Federal Aviation Administration (FAA) reauthorization, which is due by the end of Sept. 2023.

Unlike the debate leading up to the previous reauthorization, much of which was focused on a failed effort to spin off FAA’s Air Traffic Organization into an independent, nonprofit user co-op, the debate this time around is likely to be centered on workforce problems plaguing the aviation sector. These include shortages of airline pilots and air traffic controllers needed to meet surging air travel demand in the recovery from the COVID-19 pandemic, which have led to a large number of flight delays and cancellations. As Congress prepares for FAA reauthorization with a special focus on labor shortages, it should consider technology solutions and governance reforms that could improve workforce productivity and enhance aviation system resilience.

During a panel of industry stakeholders, former longtime House Transportation and Infrastructure Committee aviation staffer Holly Woodruff Lyons said that aviation workforce shortages and their impacts on air service are likely going to be the most important issue motivating members of Congress going into reauthorization. Brad Van Dam, senior vice president for government affairs at the American Association of Airport Executives, noted that dozens of airports have seen commercial service cuts due to workforce issues, and members of Congress are experiencing the resulting flight delays and cancellations firsthand.

At another panel, aviation industry veterans weighed in on what the priorities should be for the next confirmed FAA administrator. Will Ris, the former longtime senior vice president for government affairs at American Airlines and currently a member of FAA’s Management Advisory Council, argued that Data Comm and space-based ADS-B should be the top technology priorities for the new Administrator. Ris said FAA needs to be more open to new ideas from outside the agency and must develop a better process for introducing new technologies and practices, but acknowledged this will be difficult to accomplish in a constrained and uncertain budget environment.

Sharon Pinkerton, the senior vice president for legislative and regulatory policy at Airlines for America, agreed with Ris but argued that FAA process is badly broken. Concerns about staffing at FAA are legitimate, but FAA “can’t do human infrastructure without adequate technology infrastructure,” concluded Pinkerton.

This point was underscored by Paul Rinaldi, a former air traffic controller who retired last year as the longest-serving president of the National Air Traffic Controllers Association, who called for fundamental reform of the Federal Aviation Administration. Responding to Ris’s earlier point, Rinaldi said, “Data Comm is old technology that we should already have in our system.”

Rinaldi had been a strong supporter of spinning off FAA’s Air Traffic Organization into an independent, user-supported nonprofit modeled on world-leader Nav Canada in the lead-up to the 2018 reauthorization. Institutional reform, said Rinaldi, isn’t needed solely to speed procurement and deployment of new technologies but also to recruit, train, and retain top talent. “We still train controllers like in the 1970s,” he lamented.

The Federal Aviation Administration continues to fall behind peer countries in modernizing its air traffic control system. Earlier this month, FAA announced Cleveland Hopkins International Airport as the first U.S. commercial airport to see FAA’s Terminal Flight Data Manager (TFDM) system deployed (“New Surface Congestion Prevention System Debuts At Cleveland Hopkins,” Aviation Daily, Nov. 7, 2022). Both TFDM configurations include electronic flight strips, which would replace the paper flight strips used by controllers for generations. Electronic flight strips replaced paper strips years ago in Canada, the United Kingdom, and most of Europe, but FAA doesn’t anticipate finishing its planned 89-site deployment of TFDM until 2031.

ATCA Global featured many exciting new air traffic management technologies, especially those designed to manage new entrants, such as unmanned aircraft systems and advanced air mobility. However, FAA’s legacy institutional problems are likely to prevent the agency from keeping up with technology.

At the closing keynote panel, Kip Spurio, technical director of air traffic systems at Raytheon, predicted the National Airspace System of 2035 will be a lot like today. Changing FAA culture to be more innovative will require strong leadership that hasn’t yet materialized. “If the U.S. really wants to stake a claim to being the preeminent aviation and airspace system in the world, it will require concerted effort,” said Spurio.

The air traffic control governance reforms debated five years ago that ultimately were not included in the 2018 FAA reauthorization are not likely to be considered in the next Congress. This is unfortunate because modernizing the technical capabilities of U.S. air traffic control with technologies already widely deployed in peer countries could help address both the workforce shortages facing FAA by increasing controller productivity and help integrate new entrants into the National Airspace System, subjects that are likely to receive top billing in next year’s planned reauthorization. Unfortunately, Congress is most likely to reauthorize FAA and spend the next five years wondering why their words were not translated into meaningful action.

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Time to Rethink Airport Slots

Long-time readers of this newsletter know that I oppose systems that deal with airport demand that exceeds runway capacity by having the government allocate landing/takeoff slots to specific airlines. As practically every economist will tell you, the best way to deal with demand that exceeds supply is to raise the price. Of course, in most countries, the “price” to use the scarce good of runway space is based on the gross weight of the aircraft. Legacy airlines claim that they own slots they were allocated many years or decades ago, but in the United States, at least, the U.S. Department of Transportation (DOT) has never accepted that claim.

The slot system is a barrier to competition at popular hub airports. The U.S. DOT attempts to promote competition (increased entry by non-incumbent carriers) when airlines propose to merge (or form other agreements, like American and JetBlue in the northeast, currently) by imposing divestiture of some slots at congested airports. But this is a far cry from market-based allocation.

During the pandemic, as air traffic shrank dramatically in both Europe and the U.S., governments waived the usual rule that at slot-controlled airports, carriers must use at least 80% of their slots during a given time period or they would lose those they weren’t using—the so-called 80/20 rule. U.S. DOT, last month, finally restored the 80/20 rule for U.S. slot-controlled airports, while European officials only restored theirs to 75/25, under heavy pressure from legacy carriers, some of them partially state-owned.

Recently we’ve witnessed the disclosure, during litigation about the American/JetBlue “Northeast Alliance,” that American had forgotten that it owned some of its slots at LaGuardia Airport. While that was going on, United CEO Scott Kirby threatened to cease serving JFK unless DOT gave United more slots than the few it has, which enable only four daily round-trips between that airport and two each to Los Angeles and San Francisco. He argued that because JFK has one more runway than Newark, it must have extra capacity because Newark works well with one less. Yet United has repeatedly urged DOT—unsuccessfully—not to reallocate slots that Southwest gave up when it ended service at Newark due to congestion at that airport.

Back in 2008, one of the last actions of then-Transportation Secretary Mary Peters was to change federal airport policy to permit landing fees to be based on something other than gross weight—such as demand and supply. The airline trade association (then called ATA) litigated against this change but lost in court. So the policy remains. In principle, DOT could reassert its long-standing position that airlines have no property rights in “their” slots and encourage slot-controlled airports to shift to demand-based landing and takeoff fees instead of slots.

Incidentally, since the U.K. left the European Union, it is no longer part of the EU slot system and can decide how to deal with congestion at Heathrow and Gatwick. Both airports already vary their landing fees between peak and off-peak hours, but those fees are still based on gross weight. Both airports are owned and managed by commercial airport companies that might well be amenable to a shift to market-based landing and takeoff charges.

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Modest Improvements Coming for European Airspace

At a conference sponsored by Eurocontrol last month in Brussels, the agency’s director general, Eamonn Brennan, told Aviation Week’s Helen Massy-Beresford that the long-promised Single European Sky may not happen. “I don’t think it’ll ever happen in the way we all would like it to happen—a real Single European Sky. But we can make improvements.”

The near-term improvements he was referring to are two: Europe-wide free route airspace and Eurocontrol’s new network management system. Free route airspace will enable pilots to plan flights that avoid traditional zig-zag routes between mapped waypoints used by air traffic controllers. Simon Hocquard of CANSO, the Civil Air Navigation Services Organization, cited estimates of one billion fewer nautical miles flown per year, six million metric tons of fuel saved, 20 million metric tons of CO2 reduction, and $4.8 billion in fuel savings.” Those estimates assume that pilots opt to use the free route airspace rather than requesting deviations from their filed flight plans to avoid higher air traffic control charges in some countries’ airspaces. Free route airspace implementation has been slowed down by Russia’s war against Ukraine but is now expected to be in place Europe-wide by the end of 2025, one year later than planned. Maps in the Oct. 24/Nov. 6, 2022, edition of Aviation Week showed flight information regions with free route airspace by the end of 2022 and by end-2025, the latter still with a few small gaps.

The other impending change is Eurocontrol’s forthcoming integrated network management system. This technology upgrade will apply to all its network manager operational systems, with a new digital architecture in place by 2030. The first portion will go live in 2024. Legacy systems at individual air navigation service providers (ANSPs) are expected to evolve over the next five years to interface smoothly with the network management system. The new overall system is aiming to handle 13.8 million flights per year, up from the 9.5 million expected in 2022. It is intended to enable airline-chosen “ business trajectories” and 4D profiles under which controllers can manage flights in terms of time as well as distance.

These are all worthwhile improvements, but they will do little or nothing to reduce the high unit costs of European air traffic control (compared with Canada and the United States) due to far too many ATC facilities requiring far too many controllers. Those constraints are still not being tackled, which appears to be why Brennan thinks the Single European Sky will not accomplish its original objectives.

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Progress Being Made on Reducing High-Altitude Contrails

As I’ve reported previously, aviation’s non-CO2 emissions appear to constitute as much as two-thirds of its impact on global warming. Some of this is due to other tailpipe emissions, such as soot and nitrous oxides. Another contributor is contrails, which form at high altitudes under certain temperature and moisture conditions. It turns out that today’s much-improved weather forecasting can often identify areas where those conditions exist, which in principle should enable slightly altering flight paths to either go around that area or fly at a slightly different altitude.

A company called Satavia, which specializes in data analysis and aviation atmospheric science, has been working with two airlines, Etihad and KLM, to optimize their flight plans to avoid contrail formation. Its first test project, last year with Etihad, used a 787 flight from London Heathrow to Abu Dhabi. Satavia used its DecisionX:NetZero software to calculate small changes in altitude and routing to avoid contrail-forming conditions. NATS and Eurocontrol took part in those tests, reported in Aviation Week (Jan. 10-23, 2022). Last year Eurocontrol itself conducted live contrail trials in Europe, modifying the vertical flight profile of 209 flights over a 10-month period.

Aviation Daily presented an update on Satavia’s work in its Oct. 20, 2022 issue. This year it has adjusted the flight profiles of 49 Etihad and KLM flights. Each day’s flights are evaluated for potential contrail areas, with typically between 2% and 5% selected as most likely. Satavia gives each airline a daily briefing pack of proposed routing and altitude changes. After the flights, the company analyzes whether the predicted contrail conditions were avoided and, if so, the savings—computed as CO2-equivalent. Those 49 flight adjustments were reported as saving the equivalent of 6,309 tons of CO2. The company is aiming to auction off the climate savings at $10-20 per ton. Doing that will require validation that the contrails would have formed, except for the altered flight plans.

In a separate project, Airbus is planning to test the impact of hydrogen-fueled aircraft engines on contrail formation, in a project called Blue Condor. It will equip two identical gliders each with a small jet engine—one powered by conventional kerosene fuel and the other by hydrogen. The planes will fly together in conditions conducive to contrail formation, with a chase plane carrying a suite of measurement instruments. The plan is to carry out these tests in early 2023 in the western United States. Hydrogen combustion produces 2.5 times more water vapor than conventional jet engines but no soot. So the tests should help to determine whether or how much contrail formation results from hydrogen fuel, compared with regular jet fuel.

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News Notes

MAC Calls for User Fees for New Airspace Users
The FAA Management Advisory Council (MAC) last month urged Congress to figure out how new users of the National Air Space (NAS) should pay for their growing usage of the airspace. New users include space launch and recovery, drones, and both urban air mobility (UAM) and regional air mobility (RAM). MAC member Donna McLean told Politico that new entrants are rapidly growing but are, in effect, being subsidized via the aviation user taxes paid by commercial and general aviation. “That is on everyone’s mind for [FAA] reauthorization,” McLean told an RTCA webinar audience on Oct. 26.

NATS Wins Contract to Operate Gatwick’s Tower
The UK is one of few countries where airports are responsible for local air traffic control. They can build and operate their own traditional or remote tower or hire an approved control tower company to manage tower operations. For the past six years, London Gatwick (LGW) has been served by Air Navigation Solutions Ltd, an affiliate of DFS, the German ANSP. But in this year’s competition for a new term, the tower division of NATS (the UK’s ANSP) won the bidding. According to Air Traffic Management, NATS is considering making use at LGW of some of the digital tower/artificial intelligence tools it has implemented at London Heathrow (LHR).

SpaceX and T-Mobile Plan Satellite Phone Service
T-Mobile and SpaceX announced an agreement under which the cellular phone company will use the SpaceX Starlink satellite network to provide voice and text-messaging services. The initial services will include not just the continental United States but also parts of Alaska, Hawaii, Puerto Rico, and U.S. territorial waters, with service beginning by late 2023. Competitors planning such services include AST SpaceMobile and Lynk, both of which have agreements with mobile phone networks in other countries.

Two U.S. Airports Pursuing Cargo Facility P3s
Los Angeles International (LAX) and Phoenix Sky Harbor International (PHX) are planning new air cargo facilities to be developed and operated as long-term public-private partnerships (P3s). LAX last month revised its request for proposals (RFP) to add more details on financing and to extend the deadline for submitting qualifications. The project will modernize and expand 27 cargo buildings totaling 2.6 million square feet. The Phoenix P3 project will finance, develop, and operate a new cargo complex on a 28-acre site on the airport‘s northwest corner. Responses to its RFP are due in mid-January, with a contract award as early as next May.

Nigeria Pursuing Airport P3s
Late month, the Federal Airports Authority of Nigeria (FAAN) announced winning bidders for three airport P3 concessions. A consortium led by TAV Airports was selected to develop international passenger and cargo terminals at the Murtala Mohammed International Airport in Lagos. TAV Airports, partly owned by Aeroports de Paris, operates 15 airports in Croatia, Georgia, Kazakhstan, Latvia, and other developing countries. A consortium headed by Corporacion America Airports is the preferred bidder for concessions to modernize the Abuja and Kano airports.

Can Starlink Satellites Provide GPS Backup?
The Radionavigation Laboratory at the University of Texas-Austin has announced the results of research commissioned by the Army Research Office. Their team reverse-engineered signals from Starlink satellites to show that they could be used for a positioning system in the event of GPS outages. Prof. Todd Humphrey from the Radionavigation Lab told MIT Technology Review that this research “could form the basis of a useful navigation system.” The Starlink constellation already includes over 3,000 satellites in low earth orbits, providing much higher signal strength than GPS satellites. A team at Ohio State University has also been researching this idea and says their algorithm generated an accuracy of about 7.7 meters.

Saudi eVTOL Network Planned
Saudi Arabian airline Saudia has signed a memorandum of understanding with electric vertical take-off and landing (eVTOL) developer Lilium for an eVTOL network in Saudi Arabia. The network would provide point-to-point services and feeder services to Saudia’s airport hubs. Service would be provided by Lilium’s seven-seat Jet eVTOL.

Azerbaijan Signs Up with Aireon for Space-Based ATC Surveillance
The ANSP of Azerbaijan (AZANS) has signed up with Aireon to provide space-based ADS-B surveillance of the country’s airspace. The Baku Flight Information Region (FIR) includes 86,600 square kilometers over land and 78,800 square kilometers over the Caspian Sea.

Mexican President Calls for Cabotage to Increase Airline Competition
President Andres Manual Lopez Obrador (AMLO) early this month said airfares in Mexico are too high and that allowing non-Mexican carriers to serve domestic routes would reduce average fares. In its Nov. 10 article, Aviation Daily notes that the European Union allows airlines from member states to operate domestic routes in other states, such as Ryanair’s domestic routes in Italy. Ultra-low-cost carriers (ULCCs) already have large domestic market shares in Mexico—Volaris at 40% market share and Viva Aerobus at 30%.

Inspector General Assesses FAA UAS Traffic Management Plans
In a Sept. 28 audit report, the DOT Office of Inspector General reviews FAA’s progress on the subject of managing traffic in the fast-growing field of unmanned aircraft systems (UAS). Called UAS Traffic Management, some such systems have been introduced in other countries. FAA has developed some concepts of operation but “has not established milestones for implementing the policies and processes necessary to allow for UTM deployment.” The report is AV2022041.

Drone Firm Links with Airways New Zealand UTM
New Zealand’s ANSP already has an operational UAS Traffic Management system called AirShare. It recently announced an agreement with startup company FlyFreely, which offers its own drone management platform for low-altitude operations. Airways New Zealand announced in late August an agreement that allows FlyFreely drone operators to access controlled airspace via AirShare.

October Was Big for Hydrogen News
Increasing interest in using hydrogen for future aircraft propulsion led to several developments last month. First, hydrogen pioneer ZeroAvia acquired HyPoint, a startup company developing hydrogen fuel cells for aviation. While ZeroAvia has focused on low-temperature fuel cells, HyPoint is a pioneer in high-temperature fuel cells. Several days later, American Airlines made a second strategic investment in Universal Hydrogen, which followed its August investment in ZeroAvia. Third, electric aircraft propulsion firm MagniX announced that it’s expanding into hydrogen fuel cells for 50-90-passenger aircraft.

Philippines Asks for Revised Bids for Provincial Airports
The Philippines’ government seeks to engage private companies to improve and operate 10 provincial airports throughout the island nation. Last month the government asked the companies that submitted proposals under the previous government to resubmit them to its Private Public Partnership Center before the end of the year. Inframation News also reported that the government will continue to operate the Ninoy Aquino International Airport in Manila until the two new airports being developed privately to serve Manila reach completion.

Tahiti Airport Award Thrown Out
The winning bid from Vinci Airports to redevelop and expand the Tahiti Airport was rejected by a court, leading to a new procurement. The other two bidders, Egis Projects and the local Chamber of Commerce had challenged the award of the 40-year P3 concession. A new competition is expected early in 2023.

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Quotable Quotes

“FAA has been supporting and trying to figure out how to incorporate these new users; inherently, the current aviation users are cross-subsidizing the new entrants, and it’s time for the new entrants to step up and pay. It’s very complicated, but we have got to make some decisions. . . . That’s on everyone’s mind for reauthorization.”
—Donna McLean, in Oriana Pawlyk, “New Airspace Entrants Should Pay Into the System, Advisor Says,” Politico Pro Transportation, Oct. 26, 2022

“[Airspace reform delays are] a disgrace. . . a scandal…. We have got to tackle these issues; it’s just too important; we can’t ignore it. Whether we call it the Single European Sky or whether we call it ‘get off your arse and sort [out] this inefficiency, it needs to be done.”
—Willie Walsh [IATA Director General], in Helen Massy-Beresford, “Eurocontrol Sees Free Route Airspace Delayed Until 2024,” Aviation Daily, Oct. 6, 2022

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