Aviation Policy News #168
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Aviation Policy Newsletter

Aviation Policy News #168

Climate change and major environmental challenges to aviation, a political attempt to micromanage airline maintenance, and more.

In this issue:

Aviation Faces Major Environmental Challenges

Growing concerns about climate change are creating a newly hostile situation for airlines and air travel, especially in Europe. New aviation taxes are on the way in France and Germany, and there is serious discussion at the European Commission about a Europe-wide tax on aviation kerosene (jet fuel). Perhaps more daunting is the growth of European protest movements seeking to “save the planet” by shaming people into not flying (Sweden) or attempting to shut down London Heathrow by flying drones around its edges.

It’s not only aviation organizations, such as the International Air Transport Association (IATA) and Airlines for Europe (A4E), that are worried. Financial analysts at Jefferies Financial Group in June released a 51-page report on the threats to airline business due to climate-related concerns. “It may currently be confined to European airlines . . . [but] there is a risk of contagion. More uncertainty ahead feels probable; an adverse event possible. There is a new risk, in our view.”

Alas, as a recent Bloomberg headline put it, “Airline chiefs have no easy answers for flight-shaming critics.” They point out, correctly, that there are currently no alternative fuels available that would materially reduce CO2 output. They note that each new aircraft model is more fuel-efficient than the last one, but the reality is that these are long-lived (20 years or more) vehicles that cannot simply be scrapped.

Just as a discussion point, here are some estimated numbers provided by a long-time airline pilot on an online aviation discussion group approximating the fuel burn on medium-length trips over the past 26 years:

Year Aircraft Passengers Fuel burn
1992 727 150 11,100 lbs./hr.
1997 MD80 139   7,400
2010 737 165   5,400
2018 737 (newer) 170   4,400

That’s a major reduction in fuel used per passenger mile over the last two and a half decades. And global aviation accounts for only 2.5 percent of worldwide anthropogenic CO2 emissions.

Unfortunately, pointing out such information will not suffice. So let’s take a closer look at other aspects of the problem. An Aug. 2 Washington Post story, “Europe’s flight-shame movement has travelers taking trains to save the planet,” used as an example a Swedish traveler to Austria who could have flown there in two hours. Instead, his trip via rail, bus, and ferry took more than 30 hours. And he was convinced that this lowered his carbon footprint. Well, maybe not. A detailed 2008 study by the Union of Concerned Scientists, a credible environmental group, compared the carbon footprints of various-length U.S. trips via bus, train, car, SUV, and plane. For trips of anywhere from 100 to 2,500 miles, buses had a lower carbon footprint than air travel. Trains (Amtrak, mostly diesel-powered) were slightly less carbon-intensive for trips up to 1,000 miles but worse than planes for 2,500-mile trips. To be sure, most passenger trains in Europe are electric, but simplistic carbon calculators often omit the carbon-intensity of electricity produced by coal (as is the majority of German electricity, for example).

Looked at from an economy-wide perspective, the question that must always be asked is how much CO2 reduction is possible in an industry and at what cost? Many kinds of carbon emissions can be reduced at costs of $50 per ton or less. There is no actual carbon price at which the carbon-intensity of air travel can be significantly reduced in the near term. The implicit assumption of environmental groups and most regulators is that every carbon-based activity must reduce its intensity by the same amount by some future date. But if there are numerous economic activities that can make large reductions at a cost of $20 or $30 per ton, those reductions produce more bang for the buck than spending large sums trying to reduce those that cost $100 or $200 per ton.

This idea is what led economists to the second-best concept of a carbon tax. Under this approach, governments would agree to a mid-range tax, such as $50/ton, applied to all generators of CO2. This would provide a strong incentive for all those industries that could significantly reduce their CO2 output at a lower cost to do so, to save money longer-term. For those (such as airlines) without the ability to reduce CO2 in meaningful amounts in the near term, the carbon tax would increase their cost of doing business and would increase their interest in research on such things as biofuels and other alternative fuels, hybrid and electric propulsion, etc. The tax might also lead to somewhat accelerated retirement of older fuel-guzzling planes.

Many knowledgeable observers have suggested that the revenues from any new taxes that may be imposed on airlines in the name of CO2 reduction be dedicated to research and development on the above kinds of technologies. That strikes me as a sensible approach.

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How Close Are We to Electric Airliners?

If some form of electric propulsion proves feasible and cost-effective for long-distance commercial air travel, everyone connected to aviation would be overjoyed. And the interest is certainly at a high level. One can hardly pick up an issue of Aviation Week without finding articles about start-up electric or hybrid aircraft companies or survey articles about the whole field. A sampling of the latter includes:

  • “Plug to Play,” Aug. 20-Sept. 2, 2018
  • “UTC’s Electric Transformation,” April 8-21, 2019
  • “The French Revolution,” July 1-14, 2019
  • “Shaped by Electric,” Aug. 19-Sept. 1, 2019

As a former would-be aeronautical engineer, I’m fascinated by the wide array of new aircraft configurations and proposed propulsion concepts. But I’m learning to take expansive visions of near-term electric airliners with several grains of salt.

First, it is important to note that the few prototypes actually flying or about to fly are conversions of existing single-engine piston planes. Among the most interesting designs from a start-up company is Israel-based Eviation’s prototype “Alice” design, with its design optimized for low drag, large cabin (for nine passengers), and large battery volume.

Second, there appears to be more near-term promise in hybrid electrics, in which a conventional gas turbine generates the electricity to drive distributed propellers. United Technologies, for example, is developing a hybrid 39-passenger Dash 8 with a smaller turbine engine driving a one-megawatt electric motor. The turbine can operate efficiently at a constant power setting throughout the flight, with the motor adding additional power for takeoff and climb; the result is a projected 30 percent fuel savings. UTC thinks hybridization is a good match for short commuter flights, in which a significant portion of the trip is climb and descent. Airbus and Rolls-Royce are likewise developing a hybrid-electric RJ 100, a larger regional jet with a passenger capacity in the 70-seat range. Neither of these prototypes has flown yet, and the weight and range penalties remain to be seen.

Several hybrid-electric studies are underway in Europe, under its Clean Skies 2 program’s Large Passenger Aircraft project. The Dutch project team selected the most promising three concepts from among 35 possible configurations of an A320-class airliner. HS1 is a parallel-hybrid, while HS2 and HS3 are serial-hybrid concepts. The study assumed a not-yet-existent battery capacity of 500Wh/kg (which NASA has dubbed “achievable but not impossible”). Alas, the mass of the hypothetical plane in the HS2 and HS3 concepts was increased by 600 percent and 730 percent, respectively, leading to greater overall energy consumption (and reduced passenger load). HS1, however, looked more promising, with a 10 percent decrease in energy consumption, but this does not count the weight of the additional power conversion, cooling, and distribution systems. My initial assessment is that serious hybrid-electric airliners (other than small ones for short hops) are unlikely to be found feasible.

A few weeks ago NASA announced six-month research grants for single-aisle electrified transport aircraft. The selected firms are Boeing, GE Aviation, and UTC. The aim is to demonstrate the integration of megawatt-plus electrification into regional transport aircraft. These projects all appear to be hybrids. NASA’s mid-term goal is to reduce energy consumption for this category of aircraft by 50-60 percent compared with 2005 technology, sometime in the 2025-2035 time-frame.

Thus, a lot of research and development is going on, but the chances that we will be able to book seats on an all-electric 737 or A321 within the next decade are essentially zero. We’ll be lucky if such aircraft begin service by 2040.

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Enabling Space Launch and Aviation to Live Together

I travel fairly often between Washington, DC, and my home office in South Florida. More than once my return flight has been diverted to the west of Cape Canaveral due to an impending space launch there. This used to be pretty uncommon, but last year saw 31 U.S. launches to orbit and 14 re-entries to earth. An extreme example was the first launch of a SpaceX Falcon Heavy in February 2018. The launch window, in that case, was two and a half hours, and the FAA’s declared Aircraft Hazard Area excluded aircraft operations in that large area for the entire time. More than 500 flights experienced delays that day, and flew an extra 34,841 nautical miles, burning extra fuel and delivering passengers late.

The reason for this kind of interference with air travel is that FAA is still using a manual system, without real-time data inputs about the actual launch. But since 2014 it has had a new system under development to fix this problem: the Space Data Integrator (SDI). The prototype SDI receives telemetry data directly from space vehicle operators and sends it to the FAA Traffic Flow Management System, operating at the FAA Tech Center in Atlantic City and at the Air Traffic Control System Command Center in Warrenton, VA. Currently, space missions are being monitored in “shadow mode” at the Command Center, so the large Aircraft Hazard Areas (AHAs) remain in effect, for now.

The Tech Center has also developed a Hazard Risk Assessment Management prototype, and used it to show that the time to reconfigure an Aircraft Hazard Area, based on new, real-time data, can be reduced to seconds. Once this becomes operational, data on real-time AHAs will be shared with TRACONs and centers via their current software, STARS and ERAM. This is called Phase 3 of the ongoing SDI program. And Phase 4 will deliver hazard-avoidance guidance to pilots via Data Comm text messaging or other means.

Overall, this effort will replace a process that is slow, manual, and labor-intensive with one that is dynamic and real-time. This should greatly reduce the size and duration of AHAs, meaning far less interference with aviation operations despite the expected growth in space launch operations. But the big question is when will this needed change be implemented? My most up-to-date source for the above is a detailed article by Bill Carey in Aviation Week, July 1-14, 2019, which provides no timeline.

Complicating the process is a disagreement between aviation trade associations and groups like the Commercial Spaceflight Federation. In commenting on the FAA’s recently proposed revision of commercial space-launch licensing, the aviation groups want the licensing to expand its scope to include effects on other airspace users, not just safety impacts on non-participants on the ground. It appears the airlines and others want to impose the same kind of prescriptive safety regulation on space launch companies as apply to airlines and private aviation. The new space industry argues, correctly in my view, that space launch is still a fledgling, entrepreneurial industry that has made major advances because it has not faced prescriptive regulation. They fear that airlines and others are over-reacting to the recent increase in launches, and would like to see it slowed down, which prescriptive regulation would likely do. Faster implementation of FAA’s SDI would be a far better way forward.

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A Political Attempt to Micromanage Airline Maintenance

Airline mechanics’ unions for decades have opposed the common airline practice of outsourcing portions of their aircraft maintenance to other companies, especially when those companies are based overseas. Earlier this year, Rep. John Garamendi (D, CA) introduced a bill the unions love. Rather than banning such outsourcing (which is practiced by airlines worldwide), it would merely require disclosure. Sounds innocuous enough, but here is how the congressman describes the required disclosure (as reported by Sandy Murdock in JDA Journal, June 13, 2019):

“The bill would require carriers to display notices providing the public with the location at which [the] aircraft most recently underwent heavy maintenance, as well as the date of such maintenance. That information would have to be prominently displayed on carriers’ websites and boarding documents, and airline workers at the ticket counter would be required to communicate it clearly to passengers.”

This seems intended to create fear, uncertainty, and doubt among passengers, which could lead to outcries by consumer groups and put pressure on airlines to bring all maintenance in-house or at least back to the United States. It could also be intended to create enough pressure that Congress would direct FAA to mandate such actions by airlines.

in a recent issue of JDA Journal, Sandy Murdock, a former FAA chief counsel, made several pointed criticisms of this proposal. First, it would not be feasible to provide this information for specific airline flights, without major modification of computer reservation systems. He also noted that ticket wallets are printed months before flights. And how many passengers actually check in at a “ticket counter” these days?

More substantively, Murdock reminds us that aircraft repair stations are already regulated by the FAA, and those in Europe are regulated by European air safety regulators. Lufthansa is a global provider of aircraft maintenance to other airlines and would run afoul of any ban on overseas repair station use. The union contention that outsourced maintenance is risky has been made by unions and their allies repeatedly over several decades, and we have yet to see an accident involving a U.S. airline caused by faulty maintenance at an outsourced repair station. This has been a theme of several muck-raking books in the 40 years since airline deregulation, but there is still no “there” there.

As Murdock’s headline aptly put it, “Rep. Garamendi’s Outsource Maintenance Disclosure Will Not Add One Iota to Aviation Safety.”

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Expanding TSA PreCheck Still Not a Priority

Some years ago. TSA announced a goal of having 20 million PreCheck members. Last summer (July 2018), the agency put the achieved number at only 6.4 million—but you will look in vain if searching the TSA website for any updated total a year later. The best that Acting Deputy Administrator Patricia Cogswell could do in Senate Commerce Committee testimony on Sept. 11, 2019, was to state that 20 percent of those passing through screening checkpoints each day are TSA members.

The only change in PreCheck currently active in Congress is the TSA Credential and Endorsement Harmonization Act of 2019. It would extend PreCheck membership to people who have already passed some other TSA security review, such as those with Transportation Worker Identification Credentials (TWIC). The bill, by Sens. Tammy Duckworth (D, IL) and Todd Young (R, IN), has passed the Senate and gone to the House for consideration.

Apparently down the memory hole is a PreCheck expansion effort that was moving forward last year, with strong support from Airports Council International-North America, the Global Business Travel Association, and the U.S. Travel Association. S. 1872 would permit competing companies, under contract with TSA, to market PreCheck more widely, breaking the long-standing monopoly contract held by MorphoTrust, which last year changed its name to IDEMIA. The key change the bill would permit is to allow the companies to do background checks without requiring fingerprints. The companies would have to develop screening algorithms to vet applicants, and only those algorithms that passed TSA testing would be approved.

There’s a long history of TSA starting and later stopping procurements along these lines, which I have chronicled in this newsletter. The most recent efforts were stymied by a lawsuit filed by Morpho, which led TSA to give up that effort. Last year’s Senate bill, which passed the Commerce Committee in June 2018, would have given TSA clear authority to carry out such a program.

I’m not enough of a security tech analyst to venture an opinion on whether higher-risk applicants could be weeded out via a system that does not include fingerprints. But before TSA’s previous attempts were stymied by litigation, it appeared that the agency had tested one or more industry algorithms and judged them to be effective. If that is the case, then IDEMIA’s objections should not prevail, and competing providers of PreCheck recruitment should be authorized.

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News Notes

Foreign Airlines and Puerto Rico Airport
Economically ailing Puerto Rico and its three international airports have asked federal permission to become a regional air traffic hub for air travel between Europe and Latin America. The idea seems worth a try but is being opposed by two airline unions and Delta Air Lines. They argue that this would somehow lead to “cabotage”—the transfer of passengers between two domestic points by a foreign airline. The Commonwealth government also notes that what it is asking for has already been provided to Alaska and Hawaii.

Poland Plans Revised Airspace, Major New Airport
The air navigation service provider (ANSP) of Poland, PANSA, has begun a consultation with stakeholders over a proposed restructuring of the country’s airspace. The impetus for this is the government’s plan for a Central Transport Hub in the center of the country, including a new Solidarity Airport, located between Warsaw and Lodz. Planned to open in 2028, the new airport expects an initial volume of 45 million annual passengers, with growth potential of 100 million. Airspace modernization will include free-route airspace and performance-based navigation, consistent with the Single European Sky program.

Flyht Signs Airbus Deal for Real-Time Flight Information Reporting
Customers buying the new Airbus A220 may now opt to have Flyht’s automated flight information reporting system (AFIRS) installed during production or retrofitted on in-service aircraft. The system permits an array of services, including real-time flight tracking, data streaming, and equipment monitoring, using the Iridium satellite network. AFIRS is already in use on numerous A320 and A330 aircraft.

Anchorage Seeking P3 for International Terminal
Anchorage International Airport (ANC) is seeking expressions of interest for a public-private partnership (P3) to operate and manage its international terminal. The aim of the P3 would be to bring the terminal up to modern standards and assist in developing more international air service.

Raytheon Enters U.S. Remote Tower Market
Major aerospace supplier Raytheon has partnered with Frequentis USA to offer Remote Virtual Towers as replacements for aging conventional control towers at some 150 U.S. airports. The joint venture is looking at $2 to $3 million for a small-airport RVT, compared with an estimated $8 million or more for a replacement conventional tower. The RVT includes Raytheon’s STARS, which is standard in terminal airspace at more than 600 locations across the country.

100 Percent Airport Employee Screening Proposed
The International Civil Aviation Organization (ICAO) is studying revised airport security standards that would require all airport employees to be screened daily. TSA is studying the implications of the proposal, which Airports Council International estimates would cost hundreds of millions of dollars per year and might be difficult at some airports. To the best of my knowledge, only three U.S. airports do this: Atlanta, Miami, and Seattle. And as noted in a recent Reuters article, 100 percent screening did not stop a ground service worker at SeaTac from stealing a small plane and crashing it last year.

Phoenix Airport P3 RFPs Due Out This Fall
Sky Harbor Airport is preparing requests for proposals for two P3 projects, both using the design-build-finance-operate-maintain (DBFOM) model. One would replace 3,000 surface parking spaces with a new parking structure; the other would build and operate an upscale airport hotel. Both projects would be financed based on the revenues generated by the project, and the airport would receive a share of the revenue. Four teams have been shortlisted for the parking project and three for the hotel.

North Dakota Seeks Statewide Drone ATC
The state’s legislature this year allocated $28 million for development of a statewide network to manage flights of unmanned air vehicles. It builds on work undertaken by the Northern Plains UAS Test Site, in cooperation with the FAA. It will use radar and radio transmissions, the latter making use of existing towers for the state’s emergency services radio network. With the design nearly completed, the next step will be an RFP for a vendor to install the hardware and software. North Dakota has considerable UAS use in both agriculture and for monitoring utility lines.

Chile Seeks P3 to Upgrade Regional Airports
Last month Chile’s public works ministry published a notice of its intent to offer a long-term P3 to expand two regional airports: Carlos Ibanez del Campo Airport and Balcameda Aerodrome. Interested teams have until October 30th to submit their qualifications for the project. The term of the P3 agreement is expected to be 15 to 20 years.

Russia Considering Remote Towers
Flight Global reported recently that Russian air transport regulator Rosaviatsia has been hosting discussions on remote towers with the transport ministry, the state-run ANSP, and the state civil aviation research institute. The next step is expected to be a pilot project at an airport, to provide practical experience and define the legal and regulatory implications of remote towers.

Another One Bites the Dust in Atlanta
The latest episode in the ongoing corruption scandal at Atlanta’s Hartsfield Jackson International Airport took place on Sept. 5, when the city’s top contract compliance officer, Larry Scott, pleaded guilty to wire fraud and tax evasion for failing to report $220,000 in income received over five years for “helping companies obtain government contracts.”

Hamburg Airport Hosts New Airport Radar Display
Germany’s ANSP—DFS—has developed a web-based air situation display to add to its existing PHOENIX system that provides apron management and air/ground traffic management. The displays are provided in airport ground vehicles to increase situational awareness. Drivers can view all air and ground aircraft movements in real-time, and plan their routes accordingly.

P3s for General Aviation Airports
The Airport Cooperative Research Program has produced a 74-page report, “Attracting Investment in General Aviation Airports Through Public Private Partnerships.” It should be of interest to city and GA airport officials interested in considering P3s to upgrade such airports. The document is ACRP Synthesis 94 and is available here.

Correction Re ADS-C and Altitude Bursts
An alert reader provided additional information on what is available from ADS-C compared with space-based ADS-B. He noted that under ICAO PANS-ATM (Doc. 4444), aircraft operators using ADS-C can include in their service agreements for procedural airspace a feature that alerts controllers when an aircraft deviates by 400 ft. from its assigned flight level. This is “not as real-time as space-based ADS-B,” but does provide a means of notifying controllers of unexpected deviations.

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Quotable Quotes

“I’m not someone who finds public entities to be an anachronism, but there are instances where it could make sense. If your airport authority is using revenues from its commercial airport to subsidize smaller general aviation facilities, it might make sense to privatize the small airport. Privatization isn’t a cure-all for airports, nor is it something all of you should look at doing. But if there are some issues in the system you can’t address or some challenges that are impossible to tackle due to current restrictions, it might be worth at least kicking the tires on privatization to see if there’s any potential solution.”
—Joe Petrie, “Should Your Airport Be a Private Affair?” Airport Business, August/September 2019

“[I]t is challenges faced in developing a megawatt-class hybrid-electric propulsion system that provide a lasting lesson. Some key startups in the electric-aircraft market are developing their own motors and generators because a supply chain does not yet exist. But getting to megawatt-class and beyond may not prove as easy as they hoped. Enthusiasm for electric propulsion may not be reduced by the premature burnout of the [Aurora] LightningStrike, but an edge of realism has been introduced.”
—Graham Warwick, “Leading Edge,” Aviation Week, May 7-20, 2018

“For many regulations on commercial issues, the market, not the government, should be the ultimate regulator. The pitch for seats or the organization of the boarding is not government business. It’s company business, and the market will arbitrate. If the pitch is too small, nobody will take the flight. When there is a safety issue, the regulator has a legitimate reason to intervene. . . . Usually [legislative proposals] start with an isolated event that someone capitalizes on to make a political point. It’s politically rewarding to capitalize on emotions triggered by a bad event and generalize it to make it appear that airlines are always behaving badly. It’s cynical—and it is easy politics, because it is simple to understand and regulate. We forget that these are isolated events. Millions of people are being properly transported to the right place at the right time.”
—Alexandre de Juniac, in Ben Goldstein, “Fast Five with IATA Director General and CEO Alexandre de Juniac,” Aviation Daily, Sept. 6, 2019

“Developing a one-size-fits-all surveillance solution [SENSR] can become a recipe for failure. The multitude of requirements to meet the multi-government entities introduces risk in scope management and successful test completion—all classic drivers to large-scale acquisition overruns. Considering the large inventory of current surveillance assets, a system of systems approach can enable the end state. . . . [W]idely distributed, decentralized surveillance assets can enable an agile network that morphs over time to the optimal end-state condition. [Making] the key requirement for all aircraft to be cooperative provides the first step in reducing the current cooperative/non-cooperative long-range radar footprint. . . . Redesigning the airspace could end up pigeonholing users—drones for delivery packages below 400 feet, urban air mobility vehicles operating up to 5,000 feet, upper-airspace users above 60,000 feet, and commercial rockets would all be required to equip so they can be cooperatively surveilled.”
—Frank Frisbie and Vincent Capezzuto, “If a Tree Falls in the Forest: Making a Case for Government-Industry Partnerships,” The Journal of Air Traffic Control, Summer 2019

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