Next Generation Air Transportation System: FAA Faces Challenges in Responding to Task Force Recommendations
Released: 2009-10-28T00:00:00

Letter

FAA Faces Challenges in Directing Resources and Addressing Environmental Issues to Ensure Timely Implementation

Developing Navigation Procedures with Significant Benefits in a Timely Manner

Developing Area Navigation (RNAV) and Required Navigation Performance (RNP) procedures, often called performance-based navigation procedures, with significant benefits is one way to leverage existing technology in the near term and provide immediate benefits to industry, but developing these procedures expeditiously will be a challenge for FAA. According to the Task Force, developing RNAV and RNP procedures could be a key part of relieving current congestion and delays at major metropolitan airports. Benefits of RNAV and RNP can also include reduced fuel usage, reduced carbon emissions, reduced noise, shorter flights, fewer delays, less congestion, and improved safety. For example, Southwest Airlines demonstration flights show that RNP can reduce fuel burn and carbon dioxide emissions by as much as 6 percent per flight. In 2008, Alaska Airlines estimated that it used RNP procedures 12,308 times and saved 1.5 million gallons of fuel, thereby reducing carbon dioxide emissions by approximately 17,000 metric tons and operating costs by $17 million. Even greater benefits can be realized when the procedures are part of a comprehensive airspace redesign that includes more efficient flight paths, and are not simply overlays of historical aircraft flight paths.

Deriving benefits from RNAV and RNP technology depends less on equipping aircraft with the technology required to fly these procedures, than on developing procedures with significant benefits in a timely manner. MITRE Corporation, which collects and retains data on equipage levels for the existing fleet, estimates that for aircraft in commercial operations in 2009, equipage rates are more than 90 percent for RNAV, more than 60 percent for RNP, and more than 40 percent for RNP equipment that allows for higher levels of precision. These figures indicate that the equipment necessary to take advantage of RNAV and RNP technology is already substantially deployed. However, comparatively few procedures have been developed for airlines to use the equipment. Since 2004 FAA has published 305 RNAV procedures, 206 RNAV routes, and 192 RNP approaches, but much remains to be done (see table 1). FAA believes that it can annually develop about 50 RNAV and RNP procedures, 50 RNAV routes, and 50 RNP approaches. At this pace of development, a simple calculation suggests that it would require decades to complete the thousands of procedures currently targeted for development.

The Task Force report suggests that FAA and industry create joint teams to focus on performance-based navigations issues at certain locations and to prioritize procedures for development at these locations. Such an effort would likely lead to changes in FAA’s current development targets. Nonetheless, accelerating the development of procedures would require a shift in FAA’s resources, or additional human resources and expertise. In addition to FAA, numerous companies have expertise and experience to develop procedures and are doing this work for air navigation service providers around the world. FAA recognizes the potential benefits of involving these private companies and has taken steps to use them more. FAA recently authorized one such company, Naverus, which has a long history of expertise in procedure development, to validate public and private flight procedures that the company has developed for the U.S. market. This authorization will allow the company to validate performance-based navigation flight procedures from beginning to end. While private sector development may be one way to accelerate procedure development, issues related to FAA’s capacity to approve these procedures remain, according to some stakeholders. In addition, questions such as who can use the procedures and how oversight of third-party developers is to be provided must also be resolved.

While FAA tracks the number of navigation procedures completed, stakeholders have told us that developing procedures with significant benefits is more important than developing a specific number of procedures. For example, according to Southwest Airlines, FAA has developed 69 RNP procedures for the routes it flies, 6 which they view as useful to the airline because of the resulting reduction in flight miles or emissions. Some stakeholders have suggested that FAA use other metrics that better capture benefits to industry from advanced procedures, such as fuel savings, time savings, or mileage savings, which could lead to more of a focus on the development of procedures that maximize these benefits.

The Task Force report identified the establishment of performance metrics as an important part of following up on and tracking the implementation its recommendations, and we have ongoing work for this committee reviewing FAA’s performance metrics related to this and other aspects of NextGen development.

Completing Timely Environmental Reviews and Addressing Local Concerns

As FAA develops new procedures to make more efficient use of airspace in congested metropolitan areas, it will be challenged to complete the necessary environmental reviews quickly and address local concerns about the development of new procedures and airspace redesign. Anytime an airspace redesign or a new procedure changes the noise footprint around an airport, an environmental review is initiated under the National Environmental Policy Act (NEPA). Under NEPA, varying levels of environmental review must be completed depending on the extent to which FAA deems its actions to have a significant environmental impact. There are three possible levels: 1. Categorical exclusion determination. Under a categorical exclusion, an undertaking may be excluded from a detailed environmental review if it meets certain criteria and a federal agency has previously determined that the undertaking will have no significant environmental impact. 2. Environmental assessment/finding of no significant impact (EA/FONSI). A federal agency prepares a written environmental assessment (EA) to determine whether or not a federal undertaking would significantly affect the environment. If the answer is no, the agency issues a finding of no significant impact (FONSI). 3. Environmental impact statement (EIS). If the agency determines while preparing the EA that the environmental consequences of a proposed federal undertaking may be significant, an EIS is prepared. An EIS is a more detailed evaluation of the proposed action and alternatives.

The more extensive the analysis required, the longer the process can take. A full EIS can take several years to complete. EAs and categorical exclusions, by contrast, take less time and resources to complete. Because NEPA does not allow consideration of the net impact of an action such as the introduction of new procedures or broader airspace redesign—which may increase noise in some areas but increase capacity at an airport and reduce noise and emissions overall—these actions can often result in extensive and time-consuming reviews. FAA is exploring situations in which it might be more appropriate to use a categorical exclusion or an EA instead of an EIS. The 2009 FAA reauthorization legislation includes language that may expedite the environmental review process. For example, the legislative proposal would allow airport operators to use grant funds for environmental reviews of proposals to implement flight procedures. The proposal would also allow project sponsors to provide FAA with funds to hire additional staff as necessary to expedite completion of the environmental review necessary to implement flight procedures.

FAA Faces Challenges in Changing Its Culture and Business Practices in Order to Respond Effectively to the Task Force’s Recommendations

Changing from an Organization and Culture Focused on System Acquisition to an Emphasis on Integration and Coordination

According to stakeholders and Task Force members, and as we have previously reported, FAA faces organizational and cultural challenges in implementing NextGen operational capabilities. FAA has traditionally developed and acquired new systems through its acquisition process. However, most NextGen technologies and capabilities, such as Automatic Dependent Surveillance Broadcast (ADS-B), rely on components in the aircraft, on the ground, and in space for their use. They also require controllers and pilots to be trained and flight procedures to be developed in order to maximize their benefits. Different offices within FAA— including its Aircraft Certification Service, Flight Standards Service, and Air Traffic Organization (ATO), among others—are responsible for ensuring the completion of all the activities required to maximize the use of a technology or capability. While FAA has recently made organizational changes to address integration issues, several stakeholders told us, and our previous and ongoing work suggests, that FAA’s structure and culture continues to hamper its ability to ensure that all the actions necessary to maximize use of a technology or capability in the national airspace system are completed efficiently. For example, stakeholders identified coordination and integration as particular challenges to implementing operational capabilities in the surface operations area identified by the Task Force. Implementing capabilities in this area will require greater coordination among offices within ATO, airport operators, pilots, and controllers, among others.

Reprioritizing or Changing Some Aspects of Plans and Programs to Implement the Task Force’s Recommendations

While many of the operational improvements identified by the Task Force align with FAA’s current plans, a senior FAA official indicated that in several instances, FAA may need to adjust its plans, budgets, and priorities as it decides how it will respond to the Task Force’s recommendations. According to this senior FAA official, potential budgetary changes are already being identified, and a comprehensive analysis of what additional changes to existing plans would be necessary to respond to the recommendations is underway. Until this analysis is completed, it is difficult to know exactly what changes FAA would need to make to implement the Task Force’s recommendations. In some cases, the Task Force’s recommendations, if accepted and fully implemented, will require altering the course of initiatives that are already underway or programs that are being implemented. For example, a recommendation to expand surveillance of airspace around certain general aviation airports may require an increase in the scope of the current ADS-B program, which does not cover those areas. In addition, recommendations to expand information sharing to improve surface situational awareness and traffic management could affect the current plans for FAA programs such as System-Wide Information Management (SWIM), according to one stakeholder. Responding to the Task Force’s recommendations will require a willingness to change and reprioritize current plans and programs.

Streamlining Certification, Operational Approval, and Procedure Design Processes

Inefficiencies in FAA’s certification, operational approval, and procedure design processes constitute another challenge to delivering near-term benefits to stakeholders, instilling confidence in FAA plans, and investing in new equipment. Our prior work has identified this issue and concluded that the time required to complete such activities will have to be balanced against the need to ensure reliability and safety of procedures and systems before they are used in the national airspace system. Stakeholders, including airlines and general aviation groups, including one that represents avionics manufacturers, as well as the Task Force, have said that these processes take too long and impose costs on industry that discourage the stakeholders from investing in NextGen aircraft equipment. For example, the President of GE Aviation Systems recently testified, and other stakeholders have told us, that the process of approving and deploying RNP navigation procedures remains extremely slow and that FAA’s review and approval of a given original RNP design often takes years. A 1999 RTCA task force also identified a need to streamline the certification and operational approval processes and made a number of recommendations to FAA. According to a senior FAA official, while FAA has made progress in addressing many of these recommendations, it has yet to take action on others and some challenges remain. For example, the NextGen Task Force reports that FAA aircraft certification offices face resource issues and applicants for many required installation approvals wait about 6 months until FAA engineers are available to oversee their project. Other suggestions to streamline the equipment certification process include increasing staffing at FAA’s certification offices to process applications and having NextGen-specific equipment certification processes that allow quicker approvals of equipment.

Effectively Engaging Stakeholders

Another challenge for FAA will be to continue involving stakeholders-— including industry and controllers, as well as others as appropriate—in implementation and key decisions related to the Task Force’s recommendations. The Task Force recommends, and we agree, that FAA and industry establish institutional mechanisms to facilitate continued transparency and collaboration in planning and implementing actions to address the Task Force’s recommendations, particularly as these actions lead to changes in the NextGen Implementation Plan. The Task Force recommended the creation of a NextGen Implementation Workgroup under the RTCA Air Traffic Management Advisory Committee (ATMAC). An FAA official indicated that several mechanisms, including a variety of advisory boards and working groups, currently exist and can also be used to improve collaboration among stakeholders. We have previously reported that the roles of these various groups have become somewhat unclear, even to stakeholders involved in them. FAA will need to work with industry and key stakeholders to come to agreement on how, where, and when stakeholders will be involved. Continued transparency and collaboration are key to developing industry’s trust that FAA is making changes to implement NextGen.

In addition, FAA will need to continue to work toward changing the nature of its relationship with controllers and the controllers’ union to create more effective engagement and collaboration. In September 2009, FAA and NATCA signed a new 3-year contract. FAA views the new contract as a framework for helping meet the challenges of implementing NextGen. NATCA states that the contract starts a process to discuss ways for getting NATCA representatives involved in all NextGen-related issues. One particular change that would affect the relationship between controllers and FAA, as well as facilitate NextGen’s implementation, would be to modify the incentives that influence how controllers apply FAA’s aircraft separation standards. More specifically, a change that encouraged controllers to decrease the separation between aircraft during landing or takeoff would improve system capacity and efficiency and was one of the Task Force’s overarching recommendations. Currently, according to NATCA, controllers are encouraged to increase the separation between aircraft, because they are penalized if separation thresholds are crossed. Moreover, according to MITRE, controllers often separate aircraft by more than the prescribed minimum distances to address any uncertainty about the actual positions of aircraft as well as to reduce the likelihood of violating the required separation distances. NextGen technologies and procedures can provide controllers with more precise information about the locations of aircraft and allow for aircraft to operate closer to one another. Recent changes to the Operational Error program and the Air Traffic Safety Action Program (ATSAP) program are aimed at establishing a nonpunitive safety reporting program and are a positive first step towards changing the culture and establishing a more collaborative relationship with controllers.

FAA Faces Challenges to Provide Incentives to Accelerate New Equipage as NextGen Progresses

The Task Force’s focus was on making better use of the equipment that has already been installed or is available for installation. However, as NextGen progresses and as the Task Force’s recommendations are implemented, operators will need to acquire additional equipment to take full advantage of the benefits of NextGen. In some cases the federal government may deem financial or other incentives desirable to speed the deployment of new equipment. Appropriate incentives will depend on the technology and the potential for an adequate and timely return on investment. A discussion of options to accelerate equipage discussed in our prior work and identified by the Task Force follows.

Mandating Equipage

The first option is mandating the installation of equipment. Traditionally, FAA mandates the equipage of aircraft for safety improvements and provides several years for operators to comply. According to academic researchers, among these mandated safety improvements are ground proximity warning sensors, extended ground proximity warning sensors, and traffic collision and avoidance systems. Mandates can be effective because they force operators to equip even when there may not be clear and timely benefits to operators that justify the cost of equipping. In the NextGen context, FAA has proposed a rule that mandates equipage with ADS-B Out for affected aircraft by 2020. However, operators may not equip until the deadline for compliance is near because the cost of early investment in new technologies is often high and the return on investment limited. This is particularly true for general aviation operators who typically do not fly enough to recoup a large investment in new aircraft equipment. According to a general aviation stakeholder, general aviation operators typically fly hundreds of flight hours a year, while scheduled airlines fly thousands a year. Our prior work has identified a variety of other disincentives to early investment. These disincentives include the possibility that a technology may not work as intended, may not provide any operational benefits until a certain percentage of all aircraft are equipped, or may become obsolete because a better technology is available. Other risks to early investors include potential changes in the proposed standards or requirements for the technology, later reductions in the price of technologies and installations, or the risk that FAA may not implement the requisite ground infrastructure and procedures to provide operators with benefits that would justify their costs to equip. Moreover, because equipage mandates are designed to cover a broad range of users in a single action, they may lead to objections and lobbying from users, such as general aviation operators, on whom significant costs are imposed.

Making the Best Use of Equipment that Is Widely Deployed

A second option to accelerate equipage is to develop operational improvements that make use of equipment that is already widely deployed to produce benefits for operators to justify the costs of equipage. The Task Force’s recommendations are geared toward this option. A large part of the fleet is equipped with technologies that operators cannot fully use until FAA has implemented operational improvements. If FAA can implement such improvements for operators that have this equipment, it could provide a return on investment for them and create a financial incentive for others to equip. But because FAA has not always taken the actions needed for operators to take full advantage of investments in equipage, such as for Controller Pilot Data Link Communications, some industry stakeholders question whether FAA will now follow through with the tasks required to allow operators to achieve the full benefit of their investment in a timely manner. Early success in implementing some of the Task Force’s near-term recommendations will help build trust between FAA and operators that FAA will provide operational improvements that allow operators to take advantage of the required equipment and realize benefits.

Providing Operational Incentives to Equip

A third option proposed by FAA and known as “best equipped, best served” requires that FAA ensure some form of operational benefit for operators that do equip, such as preferred airspace, routings, or runway access, which can save time or fuel. If early equippers get a clear competitive advantage, other operators may be encouraged to follow their example, providing further incentive for all operators to fully equip their fleets. An advantage of pursuing this option is that no federal financial incentives are required for equipage, so costs to the federal government are generally lower. However, designing such incentives and analyzing how they will work in practice is a major challenge and has only begun to move forward. For example, giving a better-equipped aircraft preference over lesser-equipped aircraft to land or depart may increase delays and holding patterns for the lesser-equipped aircraft, potentially increasing delays and fuel usage overall, and resulting in lower systemwide benefits. Furthermore, according to airline stakeholders, the best equipped, best served option will require controllers to accept procedures that they have expressed safety concerns about in the past. Mechanisms will also have to be created so that controllers know which aircraft are best equipped, and these mechanisms cannot adversely affect controller workload or safety. The Task Force’s report does not address the practical implications of how a best equipped, best served option would work, but recommends that the option be explored in the context of specific operational capabilities and locations.

Providing Financial Incentives

A fourth option is to provide financial incentives where operators do not have a clear and timely return on investment for equipping aircraft. Financial incentives can accelerate investment in equipment, which, in turn, can accelerate the operational and public benefits expected from implementing additional capabilities. According to the Commission on the Future of the United States Aerospace Industry, one argument for some form of federal financial assistance is that the total cost to the federal government of fully financing the communication, navigation, and other airborne equipment required for more efficient operations would be less than the costs to the economy of system delays and inefficiencies that new equipment would help address. In previous work, we concluded that the federal government’s sharing of costs is most justifiable when there are adequate aggregate net benefits to be realized through equipage, but those who need to make the investments in the equipment do not accrue enough benefits themselves to justify their individual investments.

Financial assistance can come in a variety of forms including grants, cost- sharing arrangements, loans, and tax incentives. As we have previously reported, prudent use of taxpayer dollars is always important; therefore, financial incentives should be applied carefully and in accordance with key principles. For example, mechanisms for financial assistance should be designed so as to effectively target parts of the fleet and geographical locations where benefits are deemed to be greatest, avoid unnecessarily equipping aircraft (e.g., those that are about to be retired), and not displace private investment that would otherwise occur. Furthermore, it is preferable that the mechanism used for federal financial assistance result in minimizing the use of government resources (e.g., some mechanisms may cost the government more to implement or place the government at greater risk than others). We also reported that, of the various forms of assistance available to the federal government, tax incentives have several disadvantages because (1) many scheduled airlines may not have any tax liability that tax credits could be used immediately to offset, (2) a tax credit would provide a more valuable subsidy for carriers that are currently profitable than for those that are not, and (3) using the tax system to provide a financial incentive can impose an administrative burden on the Internal Revenue Service.

One financing option proposed by the Task Force to encourage the purchase of aircraft equipment is the use of equipage banks, which provide federal loans to operators to equip their aircraft. Recent legislation proposes that FAA establish a pilot program that would permit the agency to work with up to five states to establish ADS-B equipage banks for making loans to help facilitate aircraft equipage locally. The Task Force suggests that equipage banks could be used to provide funds for operators to equip with a NextGen technology when there may not be a benefit or return on investment for doing so. By providing for a variety of NextGen technologies, an equipage bank can avoid penalizing those who have already invested in a particular NextGen technology. The federal government has used a similar financing option in the past to fund other infrastructure projects including highway improvements.

Thank you Mr. Chairman. This concludes my prepared statement. I would be pleased to answer any questions that you or Members of the Subcommittee may have at this time.

GAO Contact and Staff Acknowledgments

For further information on this testimony, please contact Dr. Gerald L. Dillingham at (202) 512-2834 or dillinghamg@gao.gov. Individuals making key contributions to this testimony include Andrew Von Ah (Assistant Director), Amy Abramowitz, Kieran McCarthy, Kevin Egan, Bess Eisenstadt, and Bert Japikse.

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