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United States Pilots Association |
According to an article in The Wichita Eagle, more than 3,000 people involved in agricultural operations have been questioned by the FBI in recent months, concerned that the slow but specialized aircraft could be used to launch some kind of terrorist attack.
No arrests yet, according to the article, but the inquiry is continuing.
As if losing a family member isn’t bad enough, SpectraSite, a U.S. owned company of a 1,000’ telecommunications tower in Quebec, is suing the pilot’s family for $2.5 million to cover the costs of the tower’s destruction, the cost to rebuild, and lost revenue, after the tower had to be demolished to remove the single-engine plane that crashed into the tower in dense fog. The company states the pilot was at fault for flying in fog, according to CTV News.
A new trend to further attack GA?
See CTV News for details.
BRANSON, MO FEATURED IN AOPA ONLINE
I often get requests for information on Branson, and recently helped write an article on Branson’s many features that attract millions to the Ozarks every year. In case you might find it helpful and interesting, I thought I would pass it on to our USPA readers. By the way, I also took the aerials.
Enjoy!
Jan Hoynacki, Executive Director
United States Pilots Association
M. Graham Clark Airport (PLK) is your entry into the Southern Missouri
Ozarks, home of wholesome family entertainment. Branson, Missouri, was
discovered by tourists in the early 1900s because of its natural beauty,
but in recent years Branson has become famous for its wide variety of
entertainment options. Musical genres from pop and swing to rock and
roll and country can be found here. Theme parks abound also, as well as
great shopping. PLK is extremely busy in the summer, but it is staffed by
College of the Ozarks students, so visiting pilots are greeted warmly.
To read the complete feature, see AOPA Online
http://www.aopa.org/epilot/redir.cfm?adid=4139
USPA VP Dr. Bob Worthington wrote NW Airlines President Richard Anderson in response to Anderson’s scathing article in the NWA in-flight magazine, in which he blamed general aviation for the high price of airline tickets and the airport delays experienced by commercial airline passengers.
In response to Worthington’s email, he received an email from Renee Berg, Customer Care, Northwest/KLM Airlines (see continued for full email) attesting to the accuracy of Anderson’s statements, to which Worthington responded on April 23 (see continued for full email).
I think you will enjoy Bob’s email, as he tells it like it is. Unfortunately, the airline passengers who read Anderson’s article are not likely to hear “the rest of the story.”
Dear Renee,
I do appreciate your response and never expected to hear back from NWA.
From your reply I assume four things. One, you are not a GA pilot. Two, you
are not an airplane owner. Three, you have never served on a GA airport
board. And, four, all the info you cite in your reply to me has been spoon
fed to you from other sources aimed at proving that GA doesn't pay its fair
share.
I don't think that it is profitable for either of us to spend our time
using the email to try and out-shout each other. I have been in the
aviation business for about thirty years. I am an aviation writer, an
instrument rated pilot, have owned many planes (and own one now), and am an
officer on an airport board. Also I have owned and operated several
businesses. I am a business consultant, a business writer and a former
business professor. So I do have a bit of understanding of aviation and
running a business.
Commercial aviation, ie, transporting people, is big business, but
unfortunately, as a big business, most airline CEOs do a poor job of running
their business. While SW Airlines has a good track record of how to run an
airline most other airline CEOs laughed at the strategic concept and
business philosophy initially envisioned by SW. Sort of like how the major
US newspapers giggled at the introduction of USA Today in 1982. The basic
business plan of USA Today projected it would take ten years to achieve
profitability and look at it today, the nation's newspaper.
Back to the airlines vs GA. I think you are examing the issue with such
a narrow viewpoint that you are essentially trying to compare apples to
oranges and surprised that they are different in color, texture, and taste.
Commercial air travel is big business, large corporations. GA is more like
a sole proprietorship. Corporations are subject to double taxation (first
the corp and then the shareholders on their dividends) while sole props just
put business revenues and expenses on the Schedule C and it goes on the
business owner's 1040. Now I don't note any ranting and raving that the
sole proprietors are getting any massive tax breaks and not paying their
fair share of the cost of doing business in America.
You constantly point out how the airlines have to pay the freight for
the airports they use while GA doesn't (thats one reason why I doubt if you
have any real experience in GA). Lets look at the major airports the
airlines use: DFW, LAX, O'Hare, JFK, SFO, DEN, etc. These are not GA
airports and are used almost exclusively by the big iron, not the small
Mooneys, Pipers, Beechcrafts, Cessnas, etc. All the cost and expenses of
creating and maintaining these airports are not for the benefit of GA so why
should we pay for NWA's cost of doing business?
To be more specific. For people flying to Houston, TX, your type
airplane will land at IAH. A public airport created soley for the airlines,
not GA. Now I go to Houston I will fly into West Houston Airport (IWS) and
park there. Do some research and then tell me how much of the taxes the
airlines collect went into IWS. I will pay a parking fee and I will buy gas
and the airport will collect federal taxes on the fuel flowage. Do some
more research and then tell me how much of those federal avgas taxes
collected will return to the airport to improve the airport. IWS is a
reliever airport for IAH. To save you time looking up the answer to the two
questions I will tell you. The answer to both questions is none. IWS is a
privately owned airport and therefore doesn't qualify for federal funds,
even though it collects federal taxes from airplane users and owners.
I keep my airplane in a hangar. The hangars are privately owned but
when the lease expires the airport (city owned) will eventually become the
owners of the hangars. What I pay for my monthly rent is not subsidized by
federal dollars. I'm on the board of a relatively new airport and the
county owners want the airport to be self-sufficient where the income, at
the very least, covers all expenses of owning and operating the airport. In
other words, this airport must be self sustaining.
How about Homeland Security expenses? How much federal funds are going
into the cost of providing security for the airports NWA uses? The county
airport where I am an officer of the airport board has to comply with the
same basic security concerns that the airports NWA uses but all of the
federal funding for increased security has gone to the airports you use, not
the airports I use. Out of whose pocket do the fence and gates costs come
for the county airport I have a fiscal responsibility for? By the way I do
not keep my plane on this airport so there is no conflict of interest. As a
GA pilot and user of the ATC system I have a personal interest in keeping
small GA airports alive and well. For that reason I volunteer to serve on
the board and contribute about 10-12 hours per week for free, no charge.
There are small GA airport boards all over the US where people like me
donate, for free, untold countless hours to their own local airports.
When I was a Civil Air Patrol search and rescue pilot I flew my own
plane in hundreds of search missions for the USAF. I was reimbursed only
for gas and oil. So if my plane cost $125/ hour to fly the federal and
state govt would pay me back only about $40 per hour of my costs. The rest
came out of my pocket. I also used my plane to conduct CAP Cadet
orientation flight rides, all at my expense. Most likely several of these
young people (looking at the total program throughout the entire US)
eventually went into commercial aviation and probably NWA has a pilot who
was first introduced to aviation through the CAP.
People who ride the airlines are paying for this cost when they buy
tickets to fly. I know it sure doesn't come out of Anderson's pockets.
For me to fly my own plane I have the same types of costs as NWA does. I
have my initial investment in the plane; plus insurance, maintenance,
training, etc, etc. Everywhere I have owned and based my planes the state
and/or local govt has levied a fee (a tax) based on the value of the plane ;
this charge went toward funding the cost of flying in the state and airport
upkeep. I fly about 230-250 hours per year, how many hours per year does
any one NWA plane fly? So which plane spends more time using the ATC
system? Also please keep in mind that NWA must always use ATC but many of
my flights have no contact with any part of ATC. My plane holds one
passenger and about 66 % of the time I fly with a passenger. How many
people fly in a NWA plane? So while I only have one or two people using
ATC you may have huindreds benefiting. Any commercial passenger has the
right to own and fly their own plane but for a variety of reasons they
prefer someone else to incur the debt, take the training and assume the
risks to do the flying for their personal benefits. So why shouldn't they
pay the costs for this privilege?
I could continue for hours but when people try to tell me GA is getting
a free ride in the US and the airlines are forced to subsidize GA flying I
become angry and frustrated. As I stated in my first email this belief is
either based on ignorance about GA or a deliberate attempt to use partial
and/or distorted facts to mislead the recipient of the message. I put your
CEO in the latter category. He is misleading a group of people who, for the
most part, have no knowledge of aviation other than flying commercially, and
will now see GA as only those evil rich guys and gals with their expensive
toys who are to blame for everything bad when using the airlines. These
rich playboys and playgirls can afford to fly because your passenger tickets
are priced to pay their way. And the reason we (the airlines) don't land
on time has nothing to do with our inefficient management or the fact that
thirty airliners are trying to land at O'Hare at exactly the same time but
because all these small planes flown by all those rich folks are clogging up
our system (ignoring the fact that we don't use O'Hare). How much of this
blame does Mr Anderson pass on to the US military? They also use the system
and when I was in the military I don't recall getting any bills for using
the system.
I have some former NWA pilots who are GA pilots and aircraft owners who
also believe your CEO was way off-base when he used his position to blame GA
for problems created by the airlines or to deceive the unknowing public.
I do not expect this email to change your views at all but my thirty
years in many aspects of aviation provides me with enough "real" experience
to understand the total aviation picture and all its attendant costs and who
pays what. To tell me I'm getting a free ride only reveals the lack of
knowledge on the subject on the part of the messenger.
Thank you for your reply,
Bob Worthington
----- Original Message -----
From: "Northwest Airlines"
To: "Bob Worthington"
Sent: Wednesday, April 21, 2004 10:15 AM
Subject: Re: WorldTraveler Article (KMM559588V63929L0KM)
Dear Mr. Worthington,
We regret your negative reaction to Richard Anderson's article in our
WorldTraveler publication concerning the taxation of general aviation.
Neither the service nor the economic benefits provided by general
aviation are in dispute. Rather, our position is that both private
aircraft and commercial aircraft should pay their share of airport costs
on a fully allocated basis.
While you may disagree, let's examine the law and facts in a
disinterested manner concerning the current funding for our National Air
Transportation System. It is fairly straightforward. General Aviation
does not pay to use the ATC system and small airports are significantly
subsidized by large airports. (In the case of MSP, the reliever
airports are subsidized 100% on CAPEX investment and 80% on operations.
Hangars are $.03 per foot as the MSP relievers and we pay $4.00.)
Let's review the basic functions and funding mechanisms under the
various FAA Reauthorization Acts. FAA has three principal functions.
· Air Traffic Control System Operation
· Safety Oversight and Certification
· Airport Infrastructure Investment (AIP Program)
How are these funded? Air 21, passed by Congress in the late 1990s,
basically set up the mechanism we operate under today by using airline
ticket excise taxes, airline segment fees, and general funds. In
addition, we pay Passenger Facility Charges to fund runways and airport
infrastructure. Our ticket sales tax burden on Northwest is about 28%
(based on an average domestic round-trip ticket) paid to the government
to run the ATC system, fund FAA, and make capital investment in
airports. General aviation does not pay any fees to use the ATC system
nor does it collect segment fees, excise taxes, or pay Passenger
Facility Charges. General aviation pays fuel flowage fees, landing
fees, and hangar rents on airports that do not fully cover allocated
costs.
The ATC system is free for general aviation because Northwest and the
airlines pay the taxes to fund the system. If our tax burden were cut
in half we would be substantially closer to profitability. Instead, we
are taxed more than liquor or cigarettes (so-called ?sin? taxed items.)
Thus, it is in the interest of Northwest Airlines to have a fully
compensatory funding mechanism for the ATC system, so that all users pay
a compensatory fee for their actual consumption of ATC capacity.
Likewise, general aviation should pay their share of airport costs on a
fully allocated basis. If not, our taxes will go up.
The airfare example in the article is a $200.00 base fare for a
round-trip ticket from FAR to MSN with a connection at MSP, to which
$53.00 in taxes and fees must be added. We have reconfirmed the quoted
fare (at our website, www.nwa.com). It is a 14-day advance purchase
fare for travel June 10-15, 2004. The fare breaks down to:
$172.09 Base fare
12.94 US % tax
12.40 US segment tax
18.00 PFC's
10.00 Security fees
$225.40 Round-trip airfare
Taxes add 30.978% to this base fare, an even higher percentage than
referenced in the WorldTraveler article and a hefty burden not being
shared by private aviation.
Be assured that your comments will be forwarded to Richard Anderson.
Sincerely,
Renee Berg
Customer Care
Northwest/KLM Airlines
Original message follows:
--------------------------------
-----Original Message-----
From: Bob Worthington [mailto:rworthin@zianet.com]
Sent: Monday, March 15, 2004 8:51 PM
To: MEDIA
Subject: ET-Media
From:
Bob Worthington
Email Address:rworthin@zianet.com
========
Message:
This message is directed to Richard Anderson, CEO, regarding his
editorial, A WORD FROM Northwest on your website Corpinfo.
Why is it that corp chiefs today seem so prone to say anything,
regardless of the truth, just to placate customers and investors? Your
recent dribble about how airline passengers are having to pay extra so
general aviation can survive is mostly lies but you probably don't even
know that. Do you pay any federal income taxes? I do and income taxes
help fund the federal govt to include the FAA.
For the airlines to function you need a system to control IFR
traffic, I don't need that system if I fly VFR. Airlines need large
airports with terminal buildings, long runways, a whole lot of extra
security for protection. I don't. I always know who my passengers are
and I know what is in their baggage. I require no federal guards to
conduct searches of my passengers or their baggage.
Many large airports I land at charge me a landing fee. I pay
parking when I stay overnight at an airport (and for some airports even
if I'm there a short time). I use FBOs, not terminal buildings so I pay
the FBO directly or indirectly. I'm light (3000 pounds and under) so I
don't create the wear and tear that your planes do. Usually I land at
smaller reliever airports so you have the larger airports for your use
without small planes being there.
How often do you use one of your planes soley to take an ailing
person and spouses or parents to a medical facility because they can't
afford to buy an airline ticket? How often do you take one of your
planes off-line to search for a missing aircraft? How often do you take
off with only school children aboard to teach them about aviation
without charging someone?
How many of your pilots learned to fly by starting out in an
airliner? I can go on quite a bit more but I just want to point out
that while many of your passengers will probably accept your lies about
general aviation as the truth, there are many of us who are general
aviation pilots who very quickly recognize your words as just more of
the trash that is becoming too common with so many large corporate
leaders who will say anything or blame anyone attempting to make their
leadership failures less obvious.
Bob Worthington
========
Submitted: 03/15/2004 22:03:48
Form Navigation:
Field1: Cargo, Media and Investor Relations
Field2: Media
© Northwest Airlines 2004
Interested in moving the new Sport Pilot-Light-Sport rule along? Like to sign an EAA petition demanding action?
Directed to the Office of Management and Budget (OMB), the petition asks the agency to “approve the proposed regulations as written … as expeditiously as possible.”
Click here to sign: "http://www.eaa.org/communications/eaanews/040415_omb_petition.html"
Jan Hoynacki, Executive Director
United States Pilots Association
In its 4/14/04 editorial, USA Today further spreads the untruth of the recent NWA in-flight magazine editorial. Click Continue for the article and the responses of EAA and AOPA.
April 14th Editorial
Why should overtaxed fliers subsidize private planes?
Every passenger who flies on a commercial airline pays hefty taxes: On a $100 ticket, nearly 20% goes for levies to direct flights, improve airports and fund the extra security mandated after Sept. 11, 2001.
Now, as air travel climbs back from a post-9/11 downturn, the federal government needs more resources to modernize an outdated air traffic control system. Only a limited number of realistic sources exist for that money — the airline industry, passengers or the well-heeled owners of corporate and other private planes.
Yet those who operate private aircraft shoulder a far smaller burden for the use of airspace and runways than commercial airlines and passengers. And their powerful lobbies are determined to keep it that way. So determined, in fact, that Northwest Airlines CEO Richard Anderson suggested in a column in the March edition of Northwest's onboard magazine that commercial fliers "are subsidizing" private aircraft owners.
The column drew protests from private fliers, who say they pay their fair share through federal excise taxes on airplane fuel. But government studies show that the approximately $190 million a year in fuel taxes paid by "general aviation," as non-commercial flights are known, don't come close to covering the services these planes use.
That leaves at least some of the costs to be picked up by financially stressed commercial carriers and their heavily taxed passengers. It also deprives the Federal Aviation Administration (FAA) of money it would have to upgrade air traffic control if general aviation paid its full costs.
What's needed is a more equitable system. And twice in the 1990s, the White House or Congress called for a new structure of fees to even out disparities. But both proposals were beaten back by the private-plane lobby.
About 500,000 pilots are licensed to fly the nation's more than 200,000 private aircraft. The fleet includes 7,800 corporate jets that ferry Fortune 500 executives and other business people. A majority of the planes use government services that provide weather forecasts, keep planes safely separated and guide them to landings.
A 1997 study commissioned by the FAA estimated the cost of such government services at $800 million in 1995. However, fuel taxes paid by private and corporate planes covered only about 25% of those costs, according to the study, the latest conducted on the issue. By contrast, commercial airlines picked up more than 100% of the cost of the services they use through passenger taxes. Private planes also pay no federal fees for post-9/11 security or airport improvements.
The Aircraft Owners and Pilots Association disputes the FAA's finding that private planes pay only a small share of their costs. The group also claims that commercial jets make heavier demands on air traffic control.
While that's true at many large airports, it is not the case at scores of airports used exclusively by general aviation. Indeed, the Van Nuys, Calif., and Phoenix Deer Valley airports, which cater only to private planes, are among the nation's 20 busiest airfields.
An air control system stressed by rising traffic, aging equipment and federal deficits can't afford to subsidize fliers who don't pay for all of the services they use. Forcing commercial airlines and passengers to pay the difference is an unfair burden to bear.
--------------------------------------------------------------------------------
EAA COUNTERS USA TODAY USER-FEE EDITORIAL
April 15, 2004 - The Experimental Aircraft Association today (April 15) strongly criticized a USA Today editorial that urged a shift of airport tax burdens, from airlines and their passengers who primarily use the facilities, to general-aviation pilots who are minimum users of those facilities and services.
In particular, EAA criticized USA Today for describing all general-aviation operators as “well-heeled” and alluding to the “private-plane lobby” that is preventing user-fee operations to be established. Part of EAA’s mission of protecting the right to fly includes ensuring that recreational aviation participants are not burdened with unfair expenses for facilities and services they rarely, if ever, use.
“It is apparent that USA Today is pandering to its large readership that travels through the nation’s major airport terminals,” said Earl Lawrence, EAA’s Vice President of Government and Industry Relations. “General aviation operations are not causing municipalities to build expensive new terminals, longer runways and parking garages. Airline operations are. And those tremendously expensive facilities are being paid for by those who demand those facilities and services - the airlines and their passengers.”
Phil Boyer, president of the Aircraft Owners and Pilots Association, presented the counterpoint in USA Today on behalf of the general-aviation community. Along with fair distribution of expenses, he noted that the current system has created the world’s safest air traffic system.
“We concur with Phil Boyer’s counterpoint editorial,” Lawrence said. “We would add that EAA members, who mostly pursue recreational aviation activities in day VFR conditions, use primarily noncommercial airports and even fewer services during their flying. That means if the USA Today proposal were to become reality, these pilots would be paying a higher, disproportionate share of the expense for something they rarely use.”
Lawrence continued that general aviation already pays for the facilities it uses, such as local runway maintenance and GA facilities, through local fees and government taxes on items such as aviation fuel. Airlines are exempted from paying taxes on most airports in the U.S., because many individual states exempt airlines from paying these taxes, hoping to draw their business. That means that general-aviation operators already bear the brunt of the expenses to maintain and improve these facilities.
--------------------------------------------------------------------------------
AOPA defends GA against USA Today call for user fees
Apr. 15 — AOPA on Thursday defended general aviation against a USA Today editorial that claims airline passengers "subsidize" general aviation. In an opposing view piece published alongside the paper's editorial, AOPA President Phil Boyer explained to USA Today readers that the current system is a single structure, designed for the airlines.
"Our elected representatives in Congress wisely created a national air transportation system," Boyer wrote. And just as trucks — which place a greater strain on the national highway system — pay higher taxes and fees than family cars, the airlines must carry a greater portion of the financial burden for the nation's air traffic control system.
The USA Today editorial was prompted by and uses much of the same rhetoric as an editorial that Northwest Airlines CEO Richard Anderson wrote for his airline's in-flight magazine.
Virtually all of the problems with the air traffic control system cited in the USA Today editorial are problems of the airlines' own making. The delays that the FAA and the airlines are already forecasting for this summer are largely due to the hub-and-spoke system that the major airlines rely on. The hub-and-spoke system creates unrealistic arrival and departure schedules at the major hub airports. Summertime storms only compound the problem.
The USA Today editorial claims incorrectly that most GA flights use air traffic control separation services. In fact, the vast majority of GA flights are conducted under visual flight rules, requiring only minimal contact with controllers and placing almost no direct burden on the system.
"The air traffic control system is designed to serve the airlines," wrote Boyer in USA Today. "Most small planes use few, if any, of these services.
"The airlines pay a modest federal fuel tax of four cents a gallon. Conversely, general aviation flights fund their use of the system through a fuel tax five times what the airlines pay."
* * * * * * * * * * * * * *
Mad? Want to tell USA Today how you feel? Click on the link below and file your comment with them.
http://www.usatoday.com/marketing/feedback/feedback-online.aspx?type=12
Let’s not allow the FAA to put many good folks out of the flightseeing business. If you haven’t already done so, please log your comment with the FAA today, as the comment period closes on Monday, April 19.
Go to http://dms.dot.gov/ to file your comment online. Click on “Comment/Submission” and enter docket number FAA-1998-4521.
For a personal story on how the proposed rule would affect a family business in SFO, see http://media.aopa.org/sfo_final.asx.
USPA member Leslie Weinstein of Boise ID is a member of the Small Business Administration’s Office of Advocacy which recently petitioned FAA Administrator Marion Blakey to drop the proposed charity flight rule as it failed to accurately account for the economic impact of the rule. USPA is indeed pleased to have a USPA member in this prestigious position.
(Click "Continue" to read contents of Letter)
April 2, 2004
The Honorable Marion C. Blakey
Administrator
Federal Aviation Administration
800 Independence Avenue, S.W.
Washington, D.C. 20591
RE: National Air Tour Safety Standards (FAA-1998-4521); 68 Fed. Reg. 60572
(October 22, 2003).
Dear Administrator Blakey:
The Office of Advocacy (Advocacy) of the U.S. Small Business Administration
(SBA) submits this comment in response to the above referenced notice of
proposed rulemaking. The proposed rule establishes national regulations for
commercial air tours conducted in certain powered aircraft. The proposed rule
eliminates an existing exemption for Part 91(1)
sightseeing flights, requires all air tours to operate in accordance with either
Part 121 or Part 135,(2) sets new pilot flight hour
requirements for certain charitable flights, and establishes several new
operational and equipment standards for existing commercial air tours.
Advocacy’s comment relays concerns expressed by small entities about the
proposed rule. As written, the proposed rule is likely to have a significant
economic impact on regulated entities, including a substantial number of small
sightseeing and air tour operators. After reviewing the proposed rule and the
accompanying initial regulatory flexibility analysis (IRFA), Advocacy recommends
that the Federal Aviation Administration (FAA) withdraw the rule until the
agency is able to obtain adequate data on the operators affected by the rule.
I. Background on the Office of Advocacy
The Office of Advocacy, created in 1976, monitors and reports on agency
compliance with the Regulatory Flexibility Act of 1980 (RFA), as amended by the
Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA).(3)
The RFA requires federal agencies to determine a rule’s economic impact on small
entities and consider significant regulatory alternatives that achieve the
agency’s objectives while minimizing the impact on small entities. Because it is
an independent office within the SBA, the views expressed by the Office of
Advocacy do not necessarily reflect the views of the SBA or the Administration.
On August 13, 2002, President George W. Bush signed Executive Order 13272,
requiring federal agencies to implement policies protecting small businesses
when writing new rules and regulations. Executive Order 13272 instructs Advocacy
to provide comment on draft rules to the agency that has proposed a rule, as
well as to the Office of Information and Regulatory Affairs (OIRA) of the Office
of Management and Budget.(4) Executive Order 13272 also
requires agencies to give every appropriate consideration to any comments
provided by Advocacy. Under the Executive Order, the agency must include, in any
explanation or discussion accompanying publication in the Federal Register
of a final rule, the agency’s response to any written comments submitted by
Advocacy on the proposed rule, unless the agency certifies that the public
interest is not served by doing so.(5)
II. Background on Existing Sightseeing and Air Tour Regulations
Commercial air tour operators must be certificated under the requirements of
Part 119 of Title 14 of the Code of Federal Regulations as complying with
the operational, safety and training rules outlined in either Part 121 or Part
135.
Currently, an exemption from the certification requirement is provided in
Part 119.1(e)(2) for certain nonstop sightseeing flight operators that use the
same airport for takeoff and landing and fly within a 25-mile radius. These
sightseeing flights currently operate under safety rules in Part 91 of Title 14
and are referred to as Part 91 operators.
The proposed rule would remove the exemption and require all Part 91 flights,
except certain charitable and community flights, to be certificated under Part
119 as commercial air tours. The current exemption would sunset six months after
the rule is finalized, at which time the Part 91 operators would be required to
obtain the certification.
The new rule would also impose new operational and equipment standards on
existing commercial air tour operators, referred to as Part 135 operators.
III. The FAA Did Not Comply with the Regulatory Flexibility Act
When developing a proposed rule, an agency must prepare an IRFA if it
determines that the proposal may impose a significant economic impact on a
substantial number of small entities.(6) Under Section
603 of the RFA, the IRFA must include: (1) a description of the impact of the
proposed rule on small entities; (2) the reasons the action is being considered;
(3) a succinct statement of the objectives of, and legal basis for the proposal;
(4) the estimated number and types of small entities to which the proposed rule
will apply; (5) the projected reporting, recordkeeping, and other compliance
requirements, including an estimate of the small entities subject to the
requirements and the professional skills necessary to comply; (6) all relevant
federal rules which may duplicate, overlap, or conflict with the proposed rule;
and (7) all significant alternatives that accomplish the stated objectives of
the applicable statues and minimize any significant economic impact of the
proposed rule on small entities. In preparing its IRFA, an agency may provide
either a quantifiable or numerical description of the effects of a proposed rule
or alternatives to the proposed rule, or more general descriptive statements if
quantification is not practicable or reliable.(7)
In the proposed rule, the FAA acknowledged that “virtually all of the
entities affected by the proposed amendments are small.”(8)
The FAA recognized that the proposed rule would have a significant economic
impact on a substantial number of small entities, and therefore performed an
IRFA. However, Advocacy is concerned that the IRFA is deficient in several
areas, which are discussed in detail below.
A. The FAA Does Not Adequately Explain the Reasons for the Proposed Rule
According to the FAA, the objective of the proposed rule is to “provide a
higher and uniform level of safety for commercial air tours… [and] to
significantly reduce the accident rate for those currently operating under Part
91.”(9) However, the agency does not explain the impetus
for this rulemaking. Given the numerous federal regulations governing the
commercial air tour industry (Part 135 operators), it is unclear why the FAA
initiated this rulemaking at this time. Advocacy recommends that the FAA clarify
whether higher accident rates, differences in data, or other circumstances
changed, warranting new rules. Advocacy also recommends that the FAA explain its
assertion that Part 91 accidents could be significantly reduced by requiring
those operators to be certified under Part 119. If the FAA believes that the
accident rate data for Part 91, or current Part 135, operations reveals a
significant trend that could be addressed by the measures in this proposed rule,
Advocacy recommends this be made clear to the public.
B. The FAA Appears to Have Underestimated the Number of Small Entities
Affected by the Proposal
1. Limited Data on Part 91 and Some Part 135 Operations
The agency estimated that 1,672 Part 91 operators and 453 Part 135 operators
would be affected by the rule.(10) However, operators
affected by the proposed rule informed Advocacy that the FAA’s estimates do not
accurately reflect the industry. Presently, the FAA does not collect data on
Part 91 operators. While the FAA has established systems for monitoring and
collecting data on Part 135 operators, corresponding systems do not exist for
Part 91 operators. The agency’s estimates of Part 91 operators are based on a
survey of its Flight Standards District Offices (FSDOs) and the FAA’s 1995
General Aviation and Air Taxi Activity and Avionics Survey (GAATA Survey). The
economic analysis for the rule states that the estimates “may understate the
true proportion of small operators because FSDOs are less likely to have
accurate information on Part 91 sightseeing activity.”(11)
Similarly, in a report titled “Estimates of the Sightseeing Air Tour Industry
Final Report,” (GRA report) GRA, an FAA contractor states, “Because there are
few periodic reporting or inspection requirements for Part 91 operators, the FAA
has limited contact with them. As a result, little information on their fleets,
operations or revenues is available.”(12) The GRA
report reveals no systematic means to quantify the number of Part 91 operators.
Advocacy believes the numerous assumptions in the FAA’s economic analysis
undermine the quality of the data used in the IRFA.(13)
There is also some indication that the agency does not have adequate methods
for collecting and tracking flight data for certain Part 135 flights. The
National Transportation Safety Board (NTSB) raised questions regarding the FAA’s
assertion that Special Federal Aviation Regulation 71 (SFAR 71),(14)
which governs air tours in Hawaii, caused a decrease in air tour accidents in
that state. The NTSB questioned the FAA’s claim, stating that the “Board does
not believe that there is a reliable basis for this conclusion because of the
current lack of an accurate, verifiable method of collecting and tracking flight
activity data for the specific segments of nonscheduled 14 CFR Part 135 flight
operations.”(15) The documentation supporting the rule
and statements by the NTSB suggest that the FAA is not fully aware of the number
of operators affected by the proposal.
2. Flight Schools and Charitable Organizations
It is not clear that FAA’s estimates include flight schools or other
charitable organizations such as flight museums, an important and sizeable
segment of Part 91 operators. These entities could be significantly affected
because they conduct Part 91 sightseeing flights either as a marketing tool or
to raise funds. For example, a survey conducted by the Aircraft Owners and
Pilots Association (AOPA), indicated that of 373 responding flight schools 92%
stated that they offered sightseeing rides to the public and over 45% of the
respondents stated that they conducted more than 40 flights per year for the
purpose of sightseeing.(16) These responses represent
only a fraction of the 1,500 potentially affected flight schools in the United
States.
By not including flight schools and certain charitable organizations in its
analysis, the agency failed to capture a large number of small entities that are
likely to be affected by the proposed rule. Advocacy urges the FAA to perform
outreach to the sightseeing and air tour industry to obtain a more complete
understanding of the regulated entities. This will help the agency to more
accurately identify the number of small entities that will be affected.
C. The FAA Did Not Accurately Calculate the Economic Impacts of the
Proposed Rule on Small Entities
1. Revenue and Flight Hours Estimates
In its IRFA, the FAA states that it does not have information on the
potential impact of the proposed rule on revenues and profits.(17)
Advocacy appreciates that the agency solicited comments on this issue and we
have encouraged the regulated entities to comment on the revenue information
used by the FAA to estimate the economic impact on small entities. Despite
limited information, the FAA generated revenue data using a mix of the FSDO
survey responses, the GAATA survey, data from other sources, and a number of
assumptions about the industry. The absence of source data and transparency in
the process used to arrive at these estimates make it difficult for Advocacy or
the regulated small entities to determine whether the estimates reflect actual
revenues earned by Part 91 operators.
Advocacy is concerned, in part, because the revenue figures employed in the
IRFA rely on uncertain flight hour estimates for operators. Revenue figures are
intended to reflect the number of flight hours a Part 91 operator flies each
year as well as the average revenue per flight hour. The agency states that “89
percent of part 91 sightseeing aircraft are estimated to log fewer than 50
sightseeing hours per year.”(18) The FAA calculated the
revenues for all operators based on this 50 flight hour figure.(19)
Except for reference to the total number of flight hours in the GAATA survey,
which has incomplete coverage of Part 91 operators, the FAA provides little data
to explain the 50 flight hour average estimate for Part 91 operators.
Advocacy’s discussions with the sightseeing industry suggest that many
operators, perhaps even a majority, conduct in excess of 50 flight hours each
year. For instance, Advocacy spoke with two Part 91 operators who did not
operate near major attractions or under any special circumstances. The operators
indicated that they flew in excess of 200 hours annually despite providing Part
91 sightseeing tours on a part-time basis.(20) Further,
the AOPA surveyed 49 members providing Part 91 flights to ascertain
characteristics of their business operations, with 63% responding that they
conducted more than 50 hours of Part 91 flights annually.(21)
In summary, based on the information available to Advocacy, it is unclear
whether FAA’s average operator statistics for flight hours and revenue represent
even a small portion of the Part 91 industry. While many operators are small and
offer Part 91 sightseeing tours only part-time, many others are sophisticated
business operations that are not accurately depicted in the FAA’s analysis.
Discussions with sightseeing and air tour operators suggest that the FAA’s use
of average flight hours and average net revenues for the industry
mischaracterizes many full time operators as part-time and thus underestimates
the impact of the rule on operators. Advocacy urges the FAA to talk with the
sightseeing and air tour industry to obtain data that more accurately reflects
the variation in average number of flight hours and revenues across Part 91
sightseeing flight operators.
2. Business Closures
According to the FAA, approximately 700 of the 1,672 Part 91 operators
estimated by the FAA to provide sightseeing flights would choose to stop
offering such flights rather than comply with the proposed rule.(22)
The FAA defined the 700 operators as “marginal” because they are assumed to
provide ten hours or less of sightseeing flights per year. The agency determined
that the marginal operators would stop offering sightseeing services but could
remain in business by obtaining revenue through other means. According to the
FAA, sightseeing represents only a small percentage of the marginal operators’
total revenue. The FAA did not provide sufficient data in the IRFA to support
these claims. The absence of necessary data makes it difficult for Advocacy or
an affected small business to ascertain how the “marginal” characterization was
derived and whether the FAA is correct in its characterization.
Advocacy is concerned because the FAA recognizes that the rule could cause
hundreds of entities to leave the air tour business, yet the agency seems to
have taken no steps to mitigate this result. However, the sightseeing and air
tour industries contend that requiring a Part 119 certificate would cause
thousands, not hundreds of small operators to go out of business. Because the
FAA likely underestimated the number of small Part 91 operators and failed to
provide accurate data on Part 91 operations, revenues and costs, Advocacy
believes the industry’s estimate may be sound. Consequently, the actual
incidence of business closure is likely to be significantly higher than
estimated in the IRFA.
3. Economic Impact on Existing Part 135 Operators
The FAA estimates that the proposed rule will cost existing Part 135
operators about $69 million over ten years. The air tour industry asserts that
many of the Part 135 operators are small entities who will not be able to absorb
such high costs and remain in business. Additionally, a majority of the existing
Part 135 operators primarily provide air tour services in and around national
parks and are already subject to federal requirements more stringent than those
currently required under Part 135. Thus, the requirements in the proposed rule
are duplicative and will impose significant financial burdens on affected Part
135 air tour operators while not obviously improving safety. The FAA should
evaluate whether the proposed rule unduly burdens existing Part 135 operators,
given the existence of other federal regulations governing their operations.
4. Other Significant Costs Not Considered by the FAA
The FAA estimates that Part 91 operators converting to Part 135 operations
would incur approximately $150 million in expenses for the first ten years after
certification. However, the FAA did not include in its calculation costs
associated with insurance and down-time while waiting for certification.
The FAA assumes that a Part 91 operator converting to a Part 119 certificate
“would experience no difference in liability and, therefore, no difference in
insurance costs…”(23) Small operators have expressed
strong reservations about the FAA’s assumptions. Part 91 operators contend that
their insurance costs will significantly increase if they convert to Part 135
operations. In fact, some operators are worried they will not be able to obtain
insurance coverage once they convert to Part 135. The inability to obtain or
afford insurance could create a barrier to entry for small operators seeking
certification to perform Part 135 operations. The removal of the Part
119.1(e)(2) exemption, coupled with the inability to undertake Part 135
operations could leave many small operators no choice other than to exit the
industry. Advocacy recommends that the FAA speak with operators and insurance
carriers to conduct additional research before assuming insurance costs will not
change as a result of the rule.
The FAA estimates that the certification process will take about three months
to a year.(24) The Part 119.1(e)(2) exemption is slated
to expire six months after the final rule is published. Given the large number
of Part 91 operators and limited FSDO personnel, affected entities are concerned
that the exemption will expire before they receive certification. Entities will
suffer significant revenue loss if this occurs. The FAA intends to require all
Part 91 operators to obtain certification within six months. However, by its own
estimation, the process may take longer, which could result in the grounding of
many Part 91 operators. The agency should evaluate whether six months is
sufficient time for affected Part 91 operators to obtain Part 119 certification.
D. The FAA Did Not Adequately Analyze Viable Alternatives That Would
Achieve Regulatory Objectives While Minimizing the Potential Impact on
Affected Small Entities
Section 603(c) of the RFA requires a regulatory agency to include a
description of any significant alternatives to the proposed rule that minimize
the economic impacts on small entities while still accomplishing the agency’s
regulatory objectives. The adoption of significant alternatives can often
provide regulatory relief to small entities severely affected by agency
rulemakings.
In the proposed rule, the FAA analyzed three possible alternatives. The
agency did not choose any of the listed alternatives because it asserted the
safety objectives of the rule would not be met if any of the alternatives were
adopted. Advocacy understands that the FAA desires to improve the safety of air
tours to protect the flying public. However, to comply with the RFA, the FAA
must describe significant alternatives that minimize the economic impacts on
small entities. Significant alternatives should meet the objectives of the rule,
in this case, improving safety and minimizing the economic impact on small
entities. If the agency is unable to identify regulatory alternatives that meet
these criteria, it should conduct outreach to interested groups or solicit
comment on the issue.
IV. Conclusion and Recommendations
Due to weaknesses in the data used for the IRFA, Advocacy recommends that the
FAA carefully review the comments provided and withdraw the rule to give further
consideration to the concerns raised by Advocacy and others commenting on the
proposed rule and IRFA. Advocacy encourages the agency to conduct additional
research and outreach to identify affected small entities, determine the
potential economic impacts of the rule, and identify less burdensome
alternatives. If after evaluating the new data, the FAA determines a rule is
warranted, the agency could then re-propose the rule with a revised IRFA that
reflects the impacts on small entities and analyzes less burdensome
alternatives. Advocacy offers the following alternatives for consideration by
the FAA to address their objectives while minimizing the regulatory burden on
affected small entities.
1. The FAA should consider retaining the Part 119.1 (e)(2) exemption and
adding Part 91 data requirements.
Many operators suggested that the FAA retain the Part 119.1 (e)(2) exemption
and leave sightseeing flights under Part 91. Rather than converting Part 91
flights, the agency could amend the rule to include certain data reporting
elements. For example, the agency could require Part 91 operators to report
insurance coverage to the local FSDO. This would alleviate the financial burden
of certification under Part 119 while still providing necessary information to
the FAA about Part 91 flights.
2. The agency should assess whether regional rulemakings are more
appropriate than national standards.
As pointed out by the Office of Information and Regulatory Affairs (OIRA) in
its post review letter, the data included in the FAA’s regulatory evaluation
indicates that about half of the air tour fatalities were based in Alaska during
1993-2000. Given these statistics, the FAA should review its data to determine
whether regional rules are more appropriate than a national regulation. The
existence of Special Federal Aviation Regulation 71 in Hawaii and Special
Federal Aviation Regulation 50-2 at the Grand Canyon National Park underscore
the effectiveness of regional regulations.
3. Advocacy recommends that the FAA withdraw the proposed rule and
convene either an Aviation Rulemaking Committee (ARC) or an Aviation Rule
Advisory Committee (ARAC).
Small entities suggested that an ARC or ARAC would be a more appropriate
method of developing national standards for the sightseeing and air tour
industries. This alternative would allow the industry to participate more fully
in the development of a rule that affects their businesses. It would also allow
the FAA the opportunity to evaluate a variety of alternatives with the benefit
of industry input and experience.
4. The FAA should consider delaying the expiration of the Part 119.1
(e)(2) exemption.
Advocacy encourages the FAA to delay the expiration date of the Part
119.1(e)(2) exemption, if it continues with this rulemaking. This would allow
Part 91 operators to continue conducting sightseeing flights and maintain
revenues while they seek Part 119 certification. This will alleviate potential
revenue losses and give small operators additional time to complete the
certification process.
5. Advocacy suggests that the agency separate the Part 91 helicopter
accident rates and Part 91 airplane accident rates.
Advocacy agrees with OIRA’s recommendation that the FAA revise the IRFA to
differentiate between the helicopter and airplane accident data. A review of the
FAA data suggests that combining the Part 91 helicopter accident rates with part
91 airplane accident rates skews the accident percentage for all Part 91
flights. According to FAA’s statistics, Part 91 helicopter flights have a higher
accident rate than Part 91 airplanes. Advocacy encourages the FAA to analyze the
data to determine whether separate requirements for helicopters and airplanes
are appropriate.
As written, the proposed rule could cause a substantial number of small
operators to exit the commercial air tour industry and impose significant cost
burdens on existing air tour operators and others seeking Part 119
certification. However, because of data inadequacies, the full extent of the
economic impacts is uncertain. In future rulemakings, if the FAA lacks
information about the industry to be regulated, Advocacy suggests the agency
issue an advanced notice of proposed rulemaking (ANPRM). An ANPRM that solicits
information from interested parties will help the agency to gather the data
essential to developing a more informed rule.
Advocacy encourages the FAA to review the comments provided and withdraw the
rule to conduct further outreach with interested parties. To comply with the RFA,
a more complete analysis of viable alternatives and the potential economic
impacts on small entities is necessary.
Thank you for your consideration of these issues. Should you have any
questions or require additional information, please contact me or Carrol Barnes
of my staff at (202) 205-6890.
Sincerely,
Thomas M. Sullivan
Chief Counsel for Advocacy
Carrol L. Barnes
Assistant Chief Counsel for Advocacy
Charles Maresca
Assistant Chief Counsel for Advocacy
Cc: Dr. John D. Graham, Administrator, Office of Information and Regulatory
Affairs,
Office of Management and Budget
ENDNOTES
1. Throughout this comment letter Part 91 will refer to
sightseeing flights.
2. Throughout this comment letter Part 135 will refer to
commercial air tours.
3. Pub. L. No. 96-354, 94 Stat. 1164 (1980), (codified as
amended at 5 U.S.C. §§ 601-612).
4. E.O. 13272, at § 2(c), 67 Fed. Reg. at 53,461.
5. Id. at § 3(c), 67 Fed. Reg. at 53,461.
6. 5 U.S.C. § 603(a).
7. 5 U.S.C. § 603 and 5 U.S.C. § 607.
8. 68 Fed. Reg. 60584 (October 22, 2003).
9. Id.
10. Id.
11. Office of Aviation Policy and Plans, Federal Aviation
Administration, Preliminary Regulatory Evaluation, Initial Regulatory
Flexibility Analysis, and Trade Impact Assessment, page 66 (2002).
12. GRA, Inc., Estimates of the Sightseeing Air Tour
Industry Final Report, page 4 (1998).
13. A Guide for Government Agencies: How to Comply with
the Regulatory Flexibility Act, Chapter 2, available on Advocacy’s website,
14. 14 C.F.R. § 91 (2003). Special Federal Aviation
Regulation No. 71.
15. Comments of the National Transportation Safety Board, to
the Notice of Proposed Rulemaking in Dkt. No. FAA-1998-4521, at 1 (Jan. 22,
2004).
16. Aircraft Owners and Pilots Association. Air Tour NPRM
Flight School Online Survey, February 2004. See,
17. 68 Fed. Reg. 60585
18. Office of Aviation Policy and Plans, Federal Aviation
Administration, Preliminary Regulatory Evaluation, Initial Regulatory
Flexibility Analysis, and Trade Impact Assessment, page11 (2002).
19. FAA designates a portion of the operators as “marginal,”
defined as flying 10 or fewer hours annually. The marginal group’s revenues are
estimated separately in the IRFA based on the 10 flight hour assumption largely
because the FAA assumes that these operators will exit the industry due to the
high costs of Part 119 certification.
20. February 6, 2004 meeting with air tour industry
representatives at the Office of Advocacy.
21. Aircraft Owners and Pilots Association. Air Tour NPRM
Air Tour Operators Online Survey, February 2004. See,
22. 68 Fed. Reg. 60585.
23. Office of Aviation Policy and Plans, Federal Aviation
Administration, Preliminary Regulatory Evaluation, Initial Regulatory
Flexibility Analysis, and Trade Impact Assessment, pp. 18-19 (2002).
24. Id. at 14.
If you like to read good aviation books, here’s one that USPA VP Bob Worthington highly recommends: FLYING AMERICAN COMBAT AIRCRAFT OF WW II, Edited by Robin Higham, Stackpole Military History Series, 2004. Published by Stackpole Books www.stackpolebooks.com first edition, 344 pages with B&W photos, price $19.95.
Says Dr. Bob: “Here is some information on a new book that most of you will find fascinating. I just bought it and I have never read any other book like it.”
(Click "Continue" for book review)
USPA and NMPA members, Here is some information on a new book that most of you will find fascinating. I just bought it and I have never read any other book like it.
The editor, Robin Higham (a fromer WW II RAF pilot), in the 1970s was the editor of the Air Force Historical Foundation's magazine, AEROSPACE HISTORIAN, when he came up with a way to preserve the knowledge of how WW II aircraft were flown. He began to contact (in the mid 1970s and early 1980s) numerous pilots of WW II USAAF planes and asked each one to write an article of 14-16 pages on the airplane they flew. He has now turned these articles into chapters of this book I am reviewing. The following is what makes this book so good.
Each person was to follow a specific format, and the writing style was to read as if the writer were talking to you, personally, describing how to fly the plane he flew. Each article begins with a short description of the plane and what it was designed to do. Also it becomes apparent in the beginning of each article what the author's role in the story was (such as student pilot when first starting to fly the plane, test pilot, combat pilot, instructor pilot, etc). I might mention that each author had several hundred hours in the plane being described as well as having flown over a hundred or more hours in combat in the plane. About 1/3 through the book it becomes apparent that each writer is an authority and expert pilot on the plane he is writing about. Also of interest is that each writer thinks the plane he is writing about was the best plane to fly in combat in WW II.
Most interesting to me is the end of the article written by retired LT GEN James Edmundson (on pg 29) when he describes his last flight in a B-17 bomber, some 15 years after he had last flown it in WW II. He was very disappointed becase the B-17 he flew from AZ to a USAF base in CA in the late 1950s was underpowered, slow, sluggish, unable to climb, hard to turn, etc. He wondered what had happened to the powerful, fast, quick resonse, nimble plane of WW II? He finally realized that over a thousand hours flying the B-47 Stratojet had severely altered his sense of values and what was the best in the early 1940s simply couldn't compare what was the best in the late 1950s. I recently restored a 37 year old Jeep back to its new, original condition but it no longer drives as the first new one I bought and loved in 1967. Instead of the quick, nimble, fast responding, sure-footed 4 wheeler I used to love, it is now big and boxy, drives like a rough army tank, and is very hard to turn and manuever. It hasn't changed changed, my driving experiences have.
Each author then takes the reader through pre-flight, start-up, taxi, run-up, take-off, climb, cruise/combat, descent, approach, landing, taxiing back to parking, and shutdown. Another aspect covered by most authors is how to bail out of the plane and how to best crash land the plane. As the reader gets into the book several aspects of what the different pilots do exactly the same (for example no pilot could fly any plane until, blindfolded, they could locate and use every switch, knob, lever, gage, etc only by feel and memory, without any hesitation). There are a few fighter planes described in this book which start like my Mooney and use cruise settings close to what I use (although their take-off settings of 55" MP and 3500 rpms and climbouts at 3000 fpm sort of out does my Mooney). But this book brings all aspects of flying WW II planes to a point where pilots like us can visualize what it was like and making it readily understandable, especially as we mentally compare what the writer is describing to how we fly our planes.
All the aircraft are only USAAF, no USN or USMC. There are about 29 articles, each one becoming a chapter covering gliders, trainers, fighters, bombers, and cargo transports. The writing is just like the reader is sitting in the cockpit with a WW II flight instructor sitting next to you telling you what to do next.
I learned many things which had long puzzled me such as: in many photos of the P-40, one will see a man riding on the outboard end of a wing. It looks like someone taking a joyride while the plane is taxiing but actually it is the plane's crew chief guiding the pilot to the run-up area as the pilots couldn't see over the nose and the narrow dirt taxiways were not wide enough to use S turns. I thought that one way to bail out of all fighters was to invert and drop out. Doesn't work in a P-40. The airflow over the windscreen is such that the resultant air actually pins the pilot into the seat and he cannot get out. The safe way is a rather complicated ritual that offers a safe egress that doesn't remove limbs by striking the rear of the plane during bailout. There are other fighters where falling out while inverted is okay. Combat fighters had engines replaced every 70-75 hours (if my plane did that I'd run through three engines a year and at $40,000 a pop would increase my hourly use of the Mooney from $124/hr to almost $660/hr).
I highly recommend this book to all who have always wondered what it would be like to fly a WW II plane (I do have about 45 minutes in an AT-6 and reading that chapter brought back that enjoyable short time). It is both a fun book to read and very informative. Bob Worthington
FLYING AMERICAN COMBAT AIRCRAFT OF WW II Edited by Robin Higham, Stackpole Military History Series, 2004. Published by Stackpole Books (www.stackpolebooks.com), first edition, 344 pgs with B&W photos, price $19.95.
The Texas Pilots Association has lined up a great day of flying and exploring Shepard AFB at Wichita Falls, TX, for May 7, 2004.
After Flying in to Kickapoo Downtown Airpark (T47) from 8:00 a.m. to 8:30 a.m., a bus will depart at 8:45 a.m. for Shepard, where a busy day begins after a 20 minute ride to the base. Included in the tour is the NATO pilot training facility, altitude chamber, T-37 and T-38 simulators, flight line tour, and tower tour. The program wraps up with a 2:00 p.m. crawfish boil and a 3:00 p.m. ride back to T47.
Sound like fun? Want to go? TPA has invited USPA members to join in. For more information contact flyout organizer Chuck Huber at 940 387-3140 or huberair@wmconnect.com.
Jan Hoynacki, Executive Director
United States Pilots Association
Among the many airports attracting pilots with special prices on fuel during Sun ‘n Fun, Michael Curtis of Neosho MO (EOS) is sending a special invitation to USPA members to stop in and enjoy $1.90 per gallon on both 100LL and Jet A during April 10-20.
Mike tell us that since the USPA Executive Director wrote a letter to the City of Neosho last year, EOS now has a courtesy car available for anyone desiring to sample local fare, etc. So stop in and see Mike and check out the new car.
Mike also invites you to see a unique aircraft based as EOS—a helicopter that does aerial tree trimming! That I’ve got to see.
EOS will also be featuring special fuel prices during Oshkosh time this summer. Stay tuned.
Jan Hoynacki, Executive Director
United States Pilots Association