Aviation Policy News #163
David Donald

Aviation Policy Newsletter

Aviation Policy News #163

Remote towers reaching new levels, French government to privatize Aeroports de Paris, and more.

In this issue:

Remote Towers Reaching New Levels

The cover story of the current issue of Air Traffic Management is “The Digital Tower.” Inside the issue is a 20-page feature that provides both a global overview and profiles of specific programs and accomplishments.

Since my last report on remote towers, in the January issue, a number of air navigation service providers have announced their country’s first digital/remote/virtual (the terms are synonymous) tower projects. These include:

  • Australia, with a trial operation for the Royal Australian Air Force, developed and managed by Indra Australia and Kongsberg Defense and Aerospace;
  • Brazil, where Frequentis is implementing the country’s first digital tower at Santa Cruz Air Force Base in Rio de Janeiro;
  • Canada, where Nav Canada and Searidge are considering remote towers to replace aging conventional towers, such as at Red Deer, Alberta;
  • Iceland, where ANSP Isavia and Frequentis are researching an extreme-weather remote tower; and,
  • New Zealand, where Frequentis is installing a virtual tower with Airways NZ, at Invercargill Airport at the southern end of South Island.

The growing experience with actual remote/virtual towers is rebutting a number of misconceptions about the potential of this new approach to managing local airspace. For example, only a year or two ago there were doubts that aviation safety regulators would approve the control of multiple airports from a single remote tower center (RTC). The most ambitious such project to date is Norwegian ANSP Avinor’s in-operation RTC in Bodo. Now under way is the roll-out of control from Bodo to 15 small airports between now and the end of 2021, with a possible future expansion to a total of 36.

Based on some very early tests, there were also concerns about the difficulty of obtaining a very high data rate to permit nearly real-time control of an airport from the RTC. But bandwidth keeps getting cheaper. Now certified and in operation, DFS’s RTC in Leipzig is controlling traffic at Saarbrücken, 280 miles away. Two additional airports will be added to that RTC’s responsibilities over the next two years.

The idea that a RTC could deliver better performance than a conventional tower had skeptics several years ago, but they are mostly being convinced by the ability of infrared cameras to see aircraft through fog and rain and to provide much better “out-the-window” views at night than controllers’ eyes can provide. Moreover, their cameras (visual and infrared) can monitor runways that cannot be seen from an existing physical tower, which will likely permit Heathrow to avoid building a new tower when its third runway is actually added. (Too bad this technology was not available for two-tower DFW or three-tower O’Hare.)

Conventional wisdom a few years ago maintained that while a remote tower may be fine for small, low-traffic airports, it could not handle a large hub. That is not the view of Katrin Scheidgen of DFS Aviation Services. She told Air Traffic Management’s David Hughes that, “Technically, it is less challenging to provide control through remote technology at a large hub airport. Hubs usually have better surveillance and a more homogeneous traffic mix of mostly IFR movements, which a remote tower system can handle more easily.” London Heathrow already has a contingency remote tower capability, and one is under development for Singapore Changi. And for medium hub Budapest, HungaroControl’s remote tower is now fully capable of handling all the airport’s traffic, but for the time being, the ANSP is using it for training and as a contingency facility—though it may well replace the physical tower in the future.

We are also starting to get a handle on cost savings. U.S. control tower developer Bill Payne told David Hughes that just building the road to reach the site of a physical tower can cost as much as the structure since it must handle heavy airport fire and rescue trucks. The tower must also have an elevator and water, sewer, and power lines—none of which is needed for an at-ground facility added to an existing airport building. Dieter Eier of Frequentis USA estimates that airports needing a new or replacement tower should be able to save 50 percent by using a remote tower instead.

The sad part of this story is that America’s ANSP—the FAA Air Traffic Organization—is still not engaged with remote towers. To be sure, there are two pilot projects under way with the agency’s blessing and monitoring (in Leesburg, VA, and Loveland, CO)—but no funding. Last year’s FAA reauthorization bill nominally created an FAA remote towers program, but Congress has still not appropriated any funding for it. The Defense Department, by contrast, has an RT program under way, with fixed sites at Homestead Air Force Reserve Base and Jacksonville Naval Air Station, both in Florida, plus two deployable RTs for use in the field.

Corporatized ANSPs are leading the way in this paradigm shift, with a number of them forming joint ventures with RT companies to market this new approach in other countries. NATS and Nav Canada jointly own RT developer Searidge. The ANSP of Sweden, LFV, has formed a joint venture with Saab to develop and market RTs. Germany’s DFS and Frequentis have launched DFS Aerosense for the same purpose, as has Norway’s Avinor launching Ninox with Kongsburg and Indra Navia. But as a government department, the FAA’s ATO cannot invest in a business venture of any sort.

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French Government Ready to Privatize Groupe ADP

On April 11, the French parliament gave what appears to be final approval for the government to sell its 50.6 percent stake in Groupe ADP, the company that owns the three Paris airports and operates a total of 34 airports on four continents. While President Emmanual Macron’s program calls for offering a 70-year public-private partnership (P3) lease of ADP, rather than outright sale (thereby retaining the ability to oversee aspects of airport governance, such as not allowing a controlling interest to go to foreign investors), from a financial and management standpoint the long-term concession is tantamount to a sale.

The 50.6 percent stake is estimated to be worth around $10 billion. Current shareholders, besides the government, are as follows:

Institutional investors 22.3%
Royal Schiphol Group   8.0%
Vinci   8.0%
Credit Agricole   5.1%
Individual investors   4.3%
Employees   1.7%

Source: Inspiratia Infrastructure, March 25, 2019

Although the ADP privatization is likely to be the largest in value, it is far from alone in the coming year, with others on tap in Bulgaria, Brazil, France, Greece, Japan, and several others, including possibly the United States, if the pending process for a long-term P3 lease of St. Louis Lambert International Airport proceeds to a financial close. Given ADP’s size, speculation is rife about potential bidders, with Vinci (as an existing, and French, shareholder) the most frequently mentioned.

An example of investor interest comes from AMP Capital’s Damian Stanley, who told Inspiratia Infrastructure, “ADP is clearly a very different opportunity from what we have witnessed in the market [recently]. It is a very large capital asset that will be highly appealing to investors who have large amounts of capital, but obviously not to everyone.” Adds Ardian’s Juan Angoitia, “Thirty years ago, people saw airports as riskier than toll roads or other types of assets. With the crisis we saw in Europe traffic in toll roads going down, the market realized traffic can drop. Now people are more comfortable with airports, and there are certain levers one can pull to create value. Therefore, we expect increasing interest for investment in airports.”

From a public policy standpoint, recent research confirms earlier findings that privatized airports are economically more-productive than government-run airports. A paper by researchers at the University of British Columbia and Hebrew University of Jerusalem found that airports with government majority ownership are significantly less efficient than airports with private majority ownership. Also, airports with majority private ownership derive a much higher percentage (56 percent) of their total revenue from non-aviation services than any other ownership categories, while offering significantly lower aeronautical charges. That should be good news for the airlines that use them.

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Will the U.K. Manage Airspace Redesign Better than the USA?

The FAA had high hopes for its Metroplex program, intended to redesign the airspace in about a dozen major metro areas to take full advantage of performance-based navigation (PBN). While some of those changes have been implemented, nearly all have encountered opposition from homeowners and others whose properties either have been or are projected to be impacted by increased aircraft noise. Even though the intended result of Metroplex is savings in time, fuel burn, and emissions—as well as reduced overall noise impact on airport neighbors—an inevitable result of PBN’s reducing the wide dispersal of aircraft departure and arrival tracks is more-concentrated noise for some. Yes, a large fraction of those formerly under flight tracks end up with less noise exposure, but a smaller number get significantly increased daily noise as more flights go directly over their properties.

As someone who grew up a few miles from Miami International Airport—in a non-air-conditioned house and attending non-air-conditioned schools—I remember the regular interruptions in classes and conversations when a plane on final roared overhead. These impacts are real, and people genuinely suffer from reduced quality of life.

Needless to say, aviation interests in the U.K. have observed these problems, which FAA largely failed to anticipate. The corporatized ANSP of the U.K., NATS, has developed an Airspace Modernization Plan (AMP), intended to cope with the projected 44 percent increase in flights in UK airspace by 2030. Prior to releasing the plan, leaders of NATS and safety regulator CAA (Civil Aeronautics Authority) have set about to explain the need for the revamp and to level with the public about the noise impacts.

NATS commissioned a survey research firm to find out what the public thinks about aviation in the U.K. Results released early last month showed that 82 percent of adults think aviation is important to the economy, and 59 percent favor “airspace modernization” as described briefly by the survey team. Not surprisingly, 80 percent knew nothing about the plan to do this prior to hearing about it via the survey.

Separately, the CAA has been disseminating information to explain to the public about the impact of airspace redesign on noise, noting that “For some, the increase in traffic may lead to an increase in noise, or the concentration of traffic can focus noise over a smaller area.” As former FAA Chief Counsel Sandy Murdock wrote in a recent issue of JDA Journal, “Being clear is always a preferable tactic for the government in communicating with the public. The above CAA statement makes it clear that the AMP implementation will likely lead to some zero-sum decisions between communities.” And he adds, “It will be interesting to see whether the honest pronouncement will lead to a less-contentious process or whether the advance warning will result in greater opposition by the neighborhoods which bear the impact.”

I have two thoughts on that question. First, in U.K. aviation, there is a clear separation of roles between the ANSP which has proposed the airspace redesign (NATS) and the regulatory agency (CAA) which must approve, modify, or reject the redesign plan. Things are more muddled in this country since the FAA plays both roles. It is not clear that citizens or legislators are able to see FAA/regulator as an objective judge of the plan that FAA/operator-of-ATC wants to implement. That problem would be reduced if FAA’s Air Traffic Organization were completely separate from FAA, regulated at arm’s length.

Second, since the increased noise impact on some properties can be objectively measured and is, indeed, an intrusion into the peaceful enjoyment of their properties, the CAA has an opportunity to explore some form of ongoing monetary compensation to those whose noise exposure is involuntarily increased. And since this problem is caused by more-intensive use of airports, primarily by commercial airlines, the money for this could be added to airport charges. Devising such a plan is not the job of NATS, but it would fit well with the public-interest role of the CAA.

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Why Has TSA Failed at Covert Testing of Airport Screening?

The aviation community and the general public were shocked in 2015 when the Department of Homeland Security (DHS) Inspector General disclosed that its covert testers were able to get prohibited items through airport checkpoints over 80 percent of the time. That was only the latest of a number of outside assessments reaching such a conclusion. And the next year (2016) the Government Accountability Office (GAO) reported that the results from TSA’s own covert testing were unreliable (GAO-16-704). That GAO report led TSA to redesign how it carried out its covert testing.

Alas, a just-released assessment by GAO, requested by members of Congress, found that the revised program is still seriously flawed. In anticipation of the report’s release (the classified version was released in January; I am reporting on the redacted version released in April, GAO-19-374), TSA has begun a further reform of its covert testing.

The redacted version is 70 pages long, and contains far more detail than I have space to discuss. But here are some key points. TSA’s 2016 redesign involved two separate covert testing programs. One was managed by its Inspection division, the other by Security Operations. The former, sensibly, tested all aspects of checkpoint and baggage screening for security flaws. The testing by Security Operations involved only seeing how well Transportation Security Officers (TSOs) followed standard procedures for checkpoint and checked-baggage screening. GAO reviewed the results of over 15,000 covert tests carried out by these two entities in 2017 and 2018. Among the general findings were the following:

  • The 2016 revisions did not make full use of the promised risk-based approach for selecting test scenarios to be used in covert testing;
  • The quality of results in the tests done by Security Operations was poor (see below); and
  • TSA has done little to use results from covert testing to fix problems identified or to disseminate best practices.

Those broad findings don’t begin to illustrate the extent of the problem. For example, prior to the 2016 changes, “some testers consistently ran tests at the same airports, increasing the likelihood that they might be recognized by TSOs and compromise the covertness of tests.” Under the revised system, testers from Inspection may not go back to the same airport within a pre-specified period. The 2016 revisions for Security Operations’ testing call for covert tests to be carried out at different times of day and days of the month, rather than on the same time and day of the month (duh!), and also that testers not be recruited from people employed at the airport where the test is to be conducted (duh, again!). And to provide a comparison of its testers’ performance, Security Ops began adding periodic covert tests using TSA headquarters staff, and compared the success rate of its own covert testing with tests at the same airport carried out by headquarters testers.

The local covert tests done by Security Ops were still a mess. GAO found that in one of the tests they reviewed, the TSA official in charge of testing was present at the checkpoint, which “may have provided advance notice to TSOs that testing was in progress.” And GAO then learned that this was a routine practice when testing was going on. GAO also learned that “TSA airport officials use the same test bag to conceal threat items across all tests performed at the airport.” Further, GAO discovered that the 80 different teams of Security Ops testers “use[d] non-standardized items to build and conceal threat items for tests,” which “can affect how easy or difficult it is to detect a threat item.” These kinds of flaws help to explain why the reported results of the tests done by Security Ops field forces were significantly better than those carried out—using more-standardized procedures—by testers from TSA headquarters.

These kinds of deficiencies may well stem from TSA field forces, inadvertently or otherwise, hoping to show that TSA screening since the 2016 changes was better than the dismal results reported by previous assessments by outside firms, the DHS Inspector General, and GAO. It’s a natural bureaucratic tendency to lean on the scale to make your performance look better. This would be far less likely to occur if TSA/security regulator were a separate organization from TSA/screening provider. In other words, arm’s-length regulation would be the best way to hold security screening providers accountable.

The only good news that resulted from the GAO’s latest assessment is that, prior to the results being released, TSA decided to take Security Operations out of the covert testing business, putting all the responsibility on the better-run Inspections division. As of early this year, that transition was still under way, so some of the flawed practices by Security Ops testing may still be taking place.

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What Should Replace the Airport Slot System?

In last month’s issue, I explained that last year’s record flight delays in Europe—with airline demand greatly exceeding air traffic capacity—has led to serious conversations about rethinking how airspace is managed, including discussions of a reform of ATC pricing and possible competition among providers. But it’s not only the airspace that suffers from limited capacity; that’s also true of airports (and not just in Europe). As of last year, 104 airports in Europe are defined as operating at capacity and therefore required to allocate their capacity via level-3 slot coordination. Worldwide, that situation exists at 189 airports (21 of which are in China). So while this is, indeed, a global problem, the current center of attention is Europe.

The existing slot-allocation system is based largely on the Worldwide Slot Guidelines promulgated by IATA, the global airline trade association. IATA calls it “the globally accepted best practice for governments and airport regulators.” Critics, however, call it a method for protecting incumbent airlines from competition, since existing slots are viewed by the airlines that have them as de-facto property, and only “surplus” slots are available to non-incumbents. Academic proposals for all slots to be periodically auctioned at market-based prices have gotten nowhere.

The anti-competitive nature of the slot system is increasingly leading to its being questioned in Europe. For example, the UK’s Competition and Market Authority has a study under way, finding that the current system is, indeed, anti-competitive. Also questioning the slot-system status quo is Henrik Hololei, Director General for Mobility and Transport of the European Commission. Last year at the European Aviation Club in Brussels, he said the current slot system does not encourage competition and typically blocks new-entrant airlines. And in a 2018 presentation in Mexico, Angela Gittens, the Director General of Airports Council International/World, suggested that airports should play a much stronger role in decisions about creating and allocating additional airport capacity. And just last month, Hololei challenged the slot system, saying it is no longer fit for purpose, in a March 12th address at the World ATM Conference in Madrid. He repeated this point on April 12th in a speech at an IATA conference in Bucharest.

So what could (or should) replace the anti-competitive slot system? In the March 2019 issue of Aviation Intelligence Reporter, Andrew Charlton showed readers a graph known to every highway traffic engineer of speed vs. traffic volume, which reflects massive real-world data showing that beyond a certain traffic density, smooth flow and speeds break down, resulting in both lower speed and lower volume. What highway policy has recognized over the past 30 years is that the only realistic way to manage traffic flow so as to maintain the optimal combination of speed and volume is variable pricing (which keeps a lane from getting overcrowded at peak times). Today, in a growing number of major U.S. urban areas, variably priced express toll lanes are delivering that combination during morning and afternoon peak periods. According to a database maintained by the Transportation Research Board’s Managed Lanes Committee, there are 42 such projects in operation around the country, with many more in the planning or construction stage.

A growing number of transportation researchers have modeled airport runway pricing, and without belaboring this, I will point once again to a detailed Reason Foundation policy paper from 2007 that simulated a variable runway pricing regime for slot-controlled LaGuardia, Kennedy, and Newark Airports. That study helped persuade the U.S. DOT to change its airport rates and charges policy to permit airport congestion pricing—a regulatory change that survived a legal challenge from the Air Transport Association. The only cases I know of where some form of airport congestion pricing has been implemented are privatized London Heathrow and London Gatwick.

So there is a robust alternative to the anti-competitive Worldwide Slot Guidelines. Perhaps Europe’s airport capacity crunch will lead to a serious examination of this alternative approach. In addition to maximizing the productive use of existing runway capacity (via incentives for airlines to up-gauge), runway pricing would generate additional revenue that could help fund additional runway and terminal capacity—which is surely what Europe needs.

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News Notes

Atlanta Airport Authority Rejected
Despite having passed the Georgia Senate in March, the bill to create an airport authority to take over control of the airport (from the corruption-plagued City of Atlanta) failed to gain support in the House. That chamber converted the bill into merely a state oversight committee (plus a fuel tax break for airlines serving Hartsfield-Jackson International). However, the airport authority bill’s sponsor, Sen. Burt Jones, reminded reporters that, under legislative rules, his original bill remains alive when the current session resumes next year.

Aireon Expands Collaboration with Thales on Space-Based ADS-B
ANSP-owned Aireon, provider of global, space-based ADS-B surveillance, last month announced an alliance with French aerospace company Thales. The latter has developed key systems in use for air traffic flow management and collaborative decision-making, as well as being the prime contractor for Australia’s forthcoming civil/military air traffic management system, TopSky. Separately, Aireon announced a partnership with the Flight Safety Foundation to use space-based ADS-B data to identify safety risks in global aviation.

Airlines Lose Australian Airport Charges Claim
Under Australia’s “light-handed regulation” of its privatized airports, there is no explicit regulation of airport rates and charges. Instead, airports are subject to normal competition law (antitrust law in U.S. parlance). Concerns about pricing can be submitted to the Australian Competition and Consumer Commission—which Qantas and others did last year. The ACCC referred the airlines’ complaint to the Productivity Commission, whose draft report in late February found no grounds for government intervention in the matter; the draft is now open for public comment, with a final ruling expected in June.

Dickson Nominated as FAA Administrator, But Faces Question
As widely expected, the White House last month formally nominated retired Delta Airlines pilot Steve Dickson to be FAA Administrator, a position that requires Senate confirmation. However, as Politico reported recently, Rep. Peter DeFazio (D, OR), who chairs the House Transportation & Infrastructure Committee, suggested that the House may play a role. DeFazio said that federal law prohibits the Administrator and the Deputy Administrator from both being former military officers, which Acting Administrator Dan Elwell and Dickson both are, as former military pilots.

German ANSP Expects Difficult Summer
Deutsche Flugsicherung (DFS) has said it expects greater delays in the airspace over Germany this summer than in the horrible summer of 2018. Due to its central location, DFS handles about 30 percent of all European air traffic. A shortage of controllers has led to hiring and training, but the full impact is not likely to be felt until 2025, when all new hires are fully trained. Hence, DFS is calling for structural changes in European airspace, in addition to the technology changes under way via the Single European Sky program.

Two Major U.S. Airports Plan New Terminals
Earlier this month DFW and LAX each announced plans to add another terminal. At DFW, the plan is to build Terminal F, which would be the airport’s sixth terminal, likely adding 30 to 35 new gates. Anchor tenant American Airlines has approval rights over such expansions at DFW; American’s lease-and-use agreement expires in 2020, and must still be negotiated. At LAX, the proposed Terminal 9 would be built east of Sepulveda Blvd., with at least 21 gates for domestic and international flights. The site is currently used for hangars, maintenance facilities, and a concourse for American Eagle. Both new terminals will likely be financed by long-term airport revenue bonds.

$1.5 Billion Expansion of Privatized Lima, Peru Airport
Fast-growing Jorge Chavez International Airport has announced a $1.5 billion expansion project. Lima Airport Partners (70 percent owned by Fraport) runs the airport, under a long-term P3 lease that began in 2001, and has led to $400 million in improvements since that time. The new expansion plan includes both a new runway (by 2022) and an additional terminal (late 2023 or early 2024). In 2018 the airport served nearly 20 million passengers, a 14 percent increase over 2017. The planned expansion is based on serving 35 million.

New Firm Enters U.S. Airports Market
Munich Airport International (MAI) and CAG Holdings (linked to Carlyle Global Infrastructure Opportunity Fund) announced their new U.S. joint venture company, Reach Airports, late last fall. The two have been working together on the project to redevelop Terminal One at JFK International Airport. Last month, Reach Airports announced the hiring of Ginger Evans as the company’s CEO.  At the Chicago Department of Aviation, she managed the massive redevelopment and expansion of O’Hare, and was also heavily involved in the construction of the current Denver International Airport. Both CAG and Munich Airport have been involved in airport P3s and privatization internationally.

Security Changes Promised in Canada
Responding to long-standing airline complaints, the Canadian government’s 2019 budget proposal calls for two important changes for airport screening. First, the new budget promises increased funding to better match increased passenger volumes. Second, as airlines have urged, the government will introduce legislation to transition the Canadian Air Transport Security Authority (CATSA) into an independent, nonprofit entity (the model used for Nav Canada and the country’s airport authorities).

Russia Unveils World’s Largest WAM Surveillance System
Air Traffic Management reports that Russia’s State ATM Corporation has deployed a wide area multilateration (WAM) system covering about 1 million square kilometers of airspace, with coverage up to 60,000 feet. The North-West WAM system consists of 32 ground stations with an update rate of less than one second. The region covered is 1,000 km west to east and 1,500 km from north to south.

Vienna’s Third Runway Approved
The Supreme Administrative Court has approved Flughafen Wien’s plan to add a third runway to privatized Vienna International Airport. The plan, begun in 1999, has survived several legal challenges, and has now finally been resolved in the privatized airport’s favor. Vienna is the main hub for Austrian Airlines and is part of Lufthansa’s multi-hub strategy.

Five Bidders for 35-Year Sofia Airport P3 Lease
After delays stretching back several years, a revamped procurement process has led to five responses to the Bulgarian government’s Request for Qualifications. They include teams led by Aeroports de Paris, Copenhagen Airports, Fraport, Manchester Airport Group, and Munich Airport (with Meridiam). The winning bidder will obtain a 35-year concession and be expected to invest $676 million in airport improvements.

White House Would Reform Essential Air Services Program
The 2020 federal budget proposal calls for a slight decrease (from $288 million to $276 million) in EAS funding. The 40-year-old program subsidizes flights to small airports more than 70 miles from a larger commercial airport. Since 1996, spending on EAS has grown by 600 percent (and by 132 percent since 2008). Supporters admit that EAS flights “aren’t very full and sometimes fly empty,” but still maintain that the program is necessary and should be expanded. Others suggest that shuttle bus service could be a more cost-effective alternative.

Amazon Plans Main Air-Shipping Hub Change
As it expands its leased fleet of 767 freighters, Amazon plans to move its main hub airport from Wilmington, OH to Cincinnati/Northern Kentucky International Airport. It also plans to build a regional hub at Alliance Airport in Fort Worth. Aviation Week reported that a study by Bernstein finds that Amazon’s air freight business does not compete with customer-delivery giants Fedex and UPS, since Amazon’s focus is internal, serving selected distribution centers. Its current fleet totals 40 of the 767s, and plans to lease at least 10 more in the near term.

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Quotable Quotes

“NATS doesn’t see building physical towers as something that is going to continue. I am not suggesting that someone who already has a physical tower has to throw that control tower away. We can enhance it with digital control tower capability. However, if that tower comes to the end of its life, a 100 percent digital tower facility will provide a perfect replacement, and it will give the airport far more than a physical tower can ever provide.”
—Andy Taylor, quoted in David Hughes, “Digital Tower Technology Goes Big with NATS at Heathrow,” The Journal of Air Traffic Control, Spring 2019

“It was noted by some—well, Ryanair anyway—that the current [EU] system of disincentivizing poor [ATC] performance might be back-to-front. Rather, we should incentivize good performance, and then share that incentive with the airlines that make it happen. That might work by giving a price break to airlines that have equipment that reduces controller workload, for example. As we have discussed before, why expect extremely intelligent airframes to be lovingly hand-escorted across skies when they are perfectly competent to manage on their own with their Flight Management Systems? That way we could save the controllers for the busy bits of airspace, where they add the most value. Yes, that would not fit in with the ICAO guidelines. Yes, it would mean there would be differential pricing—and over time, different levels of service. Think of it as First, Business, and Economy, if you wish.”
—Andrew Charlton, “A4E Learns How to Spell ATM,” Aviation Intelligence Reporter, January 2019

“Currently, Aireon, working as a hosted payload on the Iridium constellation, maintains a ‘first-mover’ advantage for ATS [air traffic services] surveillance-level services. There are no equivalent service offerings with protected ‘safety-of-life’ spectrum, global coverage, and operational satellites and ground systems. There are no other ATS surveillance entrants. It will take years, along with substantial investment, for another ATS surveillance offering, competitive to Aireon, to be available.”
—Karl Baker, “Countdown Commences,” Air Traffic Management, Issue 1, 2019

“The [FAA] rule touches on ways a [UAS] manufacturer can reduce the potential harm to individuals on the ground . . . . The manufacturer will have to demonstrate that their design complies with FAA standards by testing and collecting data. This is the advantage of a performance-based regulation: individual companies will decide how to comply with the performance standards. In fact, because the government is not pointing to a specific ‘fix’ to reduce risks, there is a possibility that manufacturers may choose to develop or operate in a way that reduces risk even further than the government standards. We might find that the risk of a lawsuit and the cost of insurance pushes the UAS industry to develop safety standards that go beyond government performance requirements. Performance standards allow other market factors to play a positive role in regulating a dynamic industry.”
—Peter F. Dumont, “The Next Step to Integrating UAS,” The Journal of Air Traffic Control, Spring 2019

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