Challenges at the FAA

I just posted a comment in the on-going discussion at National Journal’s transportation blog on NextGen and other high-tech challenges at the FAA. View my comments and other comments, including A4A’s Nicholas Calio, there or read my full-text below:

Congratulations to The Honorable Michael Huerta, sworn in Wednesday as America’s 17th Federal Aviation greg-blog-photoAdministrator!   One of the first challenges that Administrator Huerta will need to deal with is how to allocate limited federal resources to a broad range of NextGen system development and implementation.  Unless the federal funding landscape changes significantly going forward, it will be essential for FAA to effectively prioritize NextGen investments on operational capabilities where benefits are most likely to accrue.  Fortunately, important progress has been made towards this prioritization both through the RTCA’s Task Force 5 and now via the NextGen Advisory Committee. (U.S. airports are fortunate to have extremely capable representation on the NAC with Sue Baer/PANJNY and Kim Day/DEN.)

With respect to “NowGen” investments, NextGen doesn’t address the fact that critical infrastructure at many of our most important airports is approaching or exceeding its design life.  From aging  terminals to aging runways, U.S. airports have basic infrastructure maintenance and improvement needs that still must be met.  Similarly, despite NextGen advancements, legacy air traffic control systems will still need to be maintained and in some cases, upgraded, until such time that NextGen systems are considered reliable replacements for these systems.

Regarding unmanned aerial systems, we believe the watch phase needs to be “do no harm.”  The increasing use of unmanned aircraft systems in domestic airspace has to be managed in a way that ensures aircraft are not adversely impacted either through loss of airspace access, reduced airspace capacity, increased environmental impacts, or reduced margins of safety.  These are extremely tall orders for aircraft that have been typically used in environments where civil aviation considerations have been secondary.  From an airport perspective “doing no harm” involves the development of common sense airspace rules that ensure these drones do not affect manned aircraft operations especially during safety critical landing and takeoff phases of flight as well as reasonable limitations on the airports at which drone operations can be based.

Will there be sequestration? I don’t think so

I was at an aviation event the other day and ran into a friend who runs another aviation association.  Say something about sequestration, she asked.  Ok. Here are a few thoughts.

First, I strongly believe it will not happen.  That Congress and the president will figure something out.  For a whole variety of reasons, I think the climate is right for some sort of deal.capital dome

I do agree that if sequestration happens, NextGen would take a big blow.  This cannot be permitted to happen.  But pardon me for being a little jaded.  I’ve been working on air traffic control reform and modernization since 1993 when I authored a presidential commission report calling for satellite based navigation by 1997.  It didn’t happen then because certain interests didn’t want it and, frankly, the airlines did not care.

In the end, the best way to move this along is to change the way it is financed, allow access to capital markets, as proposed by our 1993 commission and so many others.  The real lesson from sequestration is that getting air traffic control modernization out of the usual Washington way of doing things is the best answer.

The same is true with airport infrastructure. Although the federal grant program is not impacted by sequestration, it just shows how unreliable Washington is as a partner.  We must allow airports more freedom to generate their own resources.

Bottom line.  Doubt it will happen, but I think sequestration really shows how we need less Washington in the matter of aviation infrastructure.

Just before I started writing this I learned of the death of Sen. Daniel Inouye.  Senator Inouye is the second longest serving senator ever, and one of the greatest Americans of the 20th century.  He was a true war hero, who left his arm on a battlefield in Europe during World War II.  He was a great patriot and senator, one of those people who knew how to get something done.  He was an important part of the Watergate Committee in 1973. Such was his integrity that, even though he was a Democrat, no one ever questioned his aggressive pursuit of the truth.  When I arrived in the Senate as a young staffer six years later, I could easily see the quality of this man.  Later, I had the honor of testifying before his committee.  And I still recall going to some ceremony in the Senate a few years ago, taking my seat and then looking up a moment later as Senator Inouye asked if he could sit next to me.  No pretense, no “great man” vibe.  Just one of the greatest people this country ever produced politely asking if a seat was taken and if he might be able to sit there.  I can’t stop smiling thinking about it.  What a great man.  They say his last word was “Aloha.” So I will say Aloha, Senator Inouye.

Brookings study does a real service

A short time ago, I posted a guest blog on the National Journal transportation blog site,  the topic this week is on recent Brookings study on international air travel and our international airports. The study found them lacking due to the inability to invest in needed upgrades. More importantly, it spelled our a series of recommendations to fix the situation.

Here is my blog and my thoughts on two of the recommendations:

The Brookings study shines an important light on a key fact: that a very few airports support a great percentage of this country’s international traffic, even traffic that begins elsewhere. In an increasingly global economy we must make the best of this tremendous asset; our competitors are certainly doing so. Yet, we have a set of policies in this country that utterly fail to take this into account.

Happily, the Brookings study proposes two policy changes long championed by Airports Council International – North America that could make a big difference: making permanent the exclusion from alternative minimum tax of airport private purpose bonds and – most importantly – allowing airports to generate their own resources by removing artificial federal restraints on those airports.

In particular, this second tool is one that is used all over the world. Airlines and others like to point to places like Dubai and China and say they are investing in new facilities and we need to do the same. Yet, those places use exactly the tools that federal law prohibits here – a passenger user fee. In the United States, we largely rely in a system of government grants that is under severe pressure and the issuance of debt that can never be a long-term stand-alone strategy. The passenger user fee is severely limited, at the insistence of airlines who believe it gives airports too much control over their own future, and supported by the federal government, at least tacitly, which supports the current Washington-based system.

So, I believe the Brookings study does a real service in pointing out the importance of our international gateways and the fact that current policies hold them back. I do not think doubling down on Washington is the answer. And I also think we need to keep in mind that we have a system of airports in this country. If anything, the federal involvement should be re-oriented, and airports need to be able use the same tools in use by our competitors all over the world. It will help our economy, our communities and, I would argue, our airlines. If we do this, our international gateway airports will be able to do their part to undergird our national competitiveness.

We Spoke, They Listened

Sometimes you can’t tell if they are listening.  And, then, you get indisputable evidence that they are – and that what you’ve said has had an effect.

I had one such moment recently.

For years now, ACI-NA has been arguing for a number of initiatives to make travel easier across the U.S.-Canada border; and by extension all foreign travel into the United States.  We have pushed for the elimination of the redundant re-screening of bags when a traveler – American or Canadian – leaves from a Canadian airport and transfers at a US hub.  We have pushed for greater reliance on known traveler programs and use of information to speed the facilitation of travel from those who we know pose no threat.  We have pushed for visa reform and all sorts of other common sense initiatives to facilitate travel.

We know that international travel is a proven economic generator.  And, we want more of that.  We also know we live in difficult times, and have to best focus our security resources on known threats or travelers about whom we know very little.  And we need to find ways to do that.

A couple of weeks ago, President Barack Obama and Canadian Prime Minister Stephen Harper signed an agreement that includes a robust travel facilitation component.  Most of the ideas were identical to proposals we had made over the years.

During a trip to Ottawa I made last week, this was pointed out to US officials and it was confirmed to us that our proposals, and the arguments for them, were used to form the core of this initiative.  Someone, it seems, was listening.  And travelers from both countries, the economies of both countries, and the security of our transportation system will all be the better for it.

Speaking of people who have been dedicated to security and facilitation, I want to note, with great sadness, the passing of TSA Chief of Staff Art Macias.  Art was totally dedicated to TSA and its mission.  More importantly, he was one of those people who always “said what he meant and meant what he said” and made things happen.  Usually, if I was calling him, it was because we either needed something to happen or there was some problem we were hoping to solve/de-fuse before it became something that might be too hot to handle.  Every time, without fail, he either made things happen or he found a solution to whatever problem there was.  He never, in my experience with him, kicked a can down the road.  And he was always, it seemed, in a good mood.  And good moods can be tough to come by in jobs like his.

A couple of years ago, Art became a father.  My kids are grown, so I always enjoyed talking to Art about his child, watching him light up, and sharing stories.  It always took me back.  I don’t think I ever knew anyone who was more excited about being a parent than Art.  Though he never smoked, Art somehow developed lung cancer.  I am told that at the end, he was able to hang on for his child’s second birthday, dying four days later.  I also saw in an article about him that his last words to his wife were simply, “thank you.”

Art was a classy guy in a town and time with too few of them.  A great man.  Art Macias.  RIP.

We have a Good ‘Green’ Story to Tell, So Let’s Tell It

Greetings from Geneva. I’m writing this sitting by Lake Geneva during a break from the Aviation and Environment Summit, which includes representatives from every sector the aviation, from governments all over the world, and non-governmental organizations who advocate for pro-environment policies. Prior to this meeting, I attended two days of ACI World board meetings. So this is my first time outside during the daylight hours since Monday and I’m enjoying it.

World aviation leaders after signing Declaration Towards Sustainable Aviation in Geneva.

One of the greatest untold environmental success stories in human history has to be aviation’s success in mitigating its impact on the environment. It now, for example, takes 70 percent less fuel to fly from point A to point B than it did 40 years ago. Aircraft noise levels have been reduced to levels that were once hard to imagine. And airports, on the ground, have put into place numerous initiatives designed to reduce environmental footprint. Airports are, have been, and will be, excellent stewards of the community’s resources.

A lot of this has been accomplished outside government mandates. Fuel efficiency, for example, is driven by economic imperatives we can all understand. And as I said, airport initiatives are undertaken by airport managers who want to operate their facilities in an effective manner and as good members of the community. A number of those initiatives were profiled in two editions of ACI-NA’s publication, Going Green and Going Greener.

And, I haven’t even gotten to the fact that aviation is the most efficient (and safest) method of traveling long distances ever invented; nor to the fact that (as shown in ACI-NA’s Economic Impact Study) aviation is a powerful economic engine which not only improves standards of living but also helps generate resources to pay for environmental protection.

Picture from top of Cathedral St. Pierre in Geneva with the iconic fountain in Lake Geneva in the background.

But few seem to know this story. Someone yesterday said perhaps it is because when we talk about these things we are either defensive or technical. And that is right and we need to stop. We need to proactively tell the positive story and we need to do so in ways that appeal to, and are understood by, mass audiences.

At the end of the meeting, the leaders of the global organizations representing the world’s major aviation sectors signed a declaration describing goals and achievements and calling on government to work with us. Angela Gittens, Director General of ACI World, signed for airports.

We have a great story to tell and a great future to build. Let’s get started!

And now I have to leave the lakeside, go back inside, and lead a workshop on airport sustainability. More to come.

Facilitate International Travel – And Watch the Economy Grow

There is a lot of talk on the campaign trail these days about jobs.  Even as the overall economy improves, many have yet to feel any positive impact.  So, talk about jobs resonates.  But the fact remains there is little government can do to directly create jobs.  In the end, the best way to do this is to invest in critical infrastructure.  Not only do you create jobs building the road or runway or railway or waterway, but those things help foster growth for years and decades.  And some candidates do seem willing to talk about this.

But there is one other way, maybe the only other way, the federal government can directly create jobs.  And that is through ensuring that our customs and border protection resources are adequate and well deployed, and by ensuring that people who want to  travel here for legitimate purposes can get a visa.

This might not be where you thought I was going with this.  It might not seem obvious.  But it is true, and it has never been more true than it is now.  I say that because the parts of the world that are growing fastest:  Asia, the Pacific, Latin America and certain parts of the Middle East, feature literally billions of people with disposable income who want to travel for business or please and who, compared with travelers from North America or Europe, spend a lot more money.  And, we are making it harder and harder for these people to come to our country.  And, those people are going elsewhere!

You might ask how this could be.  After all, we have more than 100 open skies agreements, can’t anyone who really wants to come travel freely?

The answer is no, for a couple of reasons.  First, we do have all those open skies agreements; and agreements with other countries, by and large, are more liberal than a quarter century ago.

But in reality, the skies are only as open as Customs and Border Protection says they are.  If they can staff a flight or an airport, then sure, come on in.  But if they can’t, if they do not have the resources, then those travelers will end up going somewhere else.

Even with a community able to generate the market.  Even with an airline or airlines willing to serve it.  Now I don’t want to blame Customs and Border Protection, entirely.  They are resource constrained and have to make do with what they have.  But the administration (like most before it) has not bothered to make the argument for more resources to welcome these high spending travelers (by the way, a dollar spent here by a tourist counts on the positive side of the trade balance ledger).  Indeed, even though they are now collecting fees from Canadian and other Western Hemisphere travelers that were not previously levied (and that we were told would be used to facilitate travel) the administration has not asked for an increase in its budget.  And, don’t tell me we don’t have the money, a dollar spent on facilitating travel is earned back many times over.

And, I am not letting Congress off the hook on this; they need to provide those resources.

The other problem we have is that it takes too long and is too costly for legitimate travelers from countries such as China, India and Brazil to get visas to come to the United States.  Here, I will pat the administration on the back – once.  They have announced efforts to deploy additional people to those countries and have set goals for quick visa issuance.  But even with that, it is still too difficult.  I will tell you straight up that even people in the airport business tell me they do not like coming to the United States because of the time, expense and hassle that is involved.

I was speaking earlier today to Mario Diaz, who runs the Houston Airports.  One of our smartest airport leaders.  He put it well.  The problem, he said, is that too many people look at these things as simply cost centers.  They do not look at the result.  If someone came along and said that if the government turned a switch on some shiny new machine it would result in hundreds of billions of dollars of guaranteed annual impact to the economy, and  said that the machine cost a half a billion or so each year, Congress would appropriate the money in a heartbeat.  But spending that kind of money to facilitate travel for the same result seems a bridge too far (to mix modal metaphors) because these things are seen simply as cost centers.

People, we are getting our brains beat in by our international competitors.  There are lots of reasons for that, and I will return to some of them in later posts, especially the investments they are making in critical infrastructure.  But a key reason is this self-inflicted wound.  We are not putting the effort we need to into facilitating legitimate, lucrative, travel to the United States.

We cannot blame any kind of improper subsidy or unfair trade practice.  We are doing this to ourselves.  Self-defeating is an apt description of the result.  Stupid is the better term to use to describe our whole approach.

So, let’s put the resources where they need to be.  Let’s buy this shiny new guaranteed job creating machine.

Airports Have Greater Economic Clout than the Economies of South Korea, Mexico or Switzerland

Sometimes you might wonder exactly why people care so much about debates over investment in infrastructure.  Isn’t it just all politics?  Does it matter?

A study released today by ACI-NA, Economic Impact of Commercial Airports in 2010, offers an emphatic YES.  (Go to www.airportsforthefuture.org to see the study).

See, in 2000, two very important airport infrastructure policy decisions were made.  The first, allowed local communities to raise more local resources to finance infrastructure by increasing the cap on the passenger facility charge from $3 to $4.50.  The second decided that funds sitting in the aviation trust fund and paid by air travelers should not just sit there, but should be invested.  So the Airport Improvement Program was increased and money paid by air passengers for capital improvements was spent on its intended purposes.

As a nation, we (through our Congress and President) decided to increase our investments in airport infrastructure.  Our study, the first undertaken since those policy changes went fully into effect, shows the very positive results.

America’s airports support 10.5 million jobs.  America’s airports support $1.2 trillion in economic activity, larger than the GDP of South Korea.  “Airports, Inc.” directly employs 1.3 million people, making it the second largest employer in the nation, behind Wal-Mart.  Total airport payroll equals the total payroll of the State of Michigan.  The total economic clout of airports:  8 percent of U.S. GDP and 7 percent of U.S. employment.

Those are big numbers.  But if you are still not convinced, consider this:  during that time, the jobs number increased by 56 percent.  Total payroll has gone up over 90 percent.  And the total contribution to the output of the American economy has more than doubled.  All this has happened despite the industry being devastated by the largest terrorist attack in history.  All this has happened despite the most severe economic downturn since the Great Depression, including spikes in the price of fuel.

This economic growth occurred because we decided to invest in our economic future.  In economic times as difficult as most of us will ever experience, those investments paid off.

That is why it is so discouraging that the recent FAA bill leaves in place federal limits on what airports and local communities can do to generate resources.  That is why it is so discouraging that the president’s budget reduces investment in airports.  That is why it is so discouraging that local communities cannot raise their own resources because of decisions made in Washington.  We are putting the future in peril, just as we are set to take off.

Some have called for a new national airline policy, designed to promote the financial strength of airline companies.  I am a strong proponent of strong airline companies.  But the purpose of the air transportation system is the movement of people and products to destinations and markets.  It is not to ensure shareholder value for airlines; that’s what airline executives and boards are supposed to do.

We do need a new national AVIATION policy, looking at all aspects from NextGen to financing airport infrastructure to the regulatory environment in which aviation must operate to the tax structure, all of it.  It must be designed to strengthen the air transportation system, not merely any one component of it.

We are now stepping back from investments in aviation at the same time as our competitors around the world are stepping up.  We are in peril of becoming what the steel industry became in the 1970’s and 1980’s, out of date and non-competitive.

We have a chance to avoid that.  Our study shows the benefits in terms of job creation and economic impact when good decisions and good investments are made.  I worry that the next study will show when the opposite happens.

Beyond the Borders – Common Sense Wins Out?

Just recently, President Barack Obama and Canadian Prime Minister Stephen Harper announced an important initiative to bring more coherence to the policies governing how we manage the border between our countries.  This is an initiative that is long overdue and most welcome.

Canadian Prime Minister Stephen Harper and President Barack Obama

It is well-known that the U.S.-Canada border is the longest peaceful border in the world.  When you especially consider the borders China, for example, has with both Russia and India and the tensions caused in those places, you can see how fortunate we are here to have a neighbor such as Canada.  I must admit, I did not know a lot about Canada before I took this job and had only traveled there a couple of times.  I now go to Canada several times a year, have a NEXUS card, and have visited seven of the 10 provinces (still have Manitoba, New Brunswick and Newfoundland to go).  It has become a favored travel destination.

With all the security problems and challenges the U.S. has to face, it has always amazed me how little common sense is used in border policy with Canada.  For example, if you fly from Montréal to Denver, you and your bags are deemed safe and secure; indeed, you pass through U.S. customs and immigration in Montreal.  So, for all intents and purposes, for the Montréal to Denver flight, over 2,000 miles of the United States, you are considered a domestic passenger and you and your bags are considered secure.  But once you land in Denver, while you can walk to your connection to Grand Junction, your bags must be re-screened.  It makes no sense, it is a waste of resources and diverts attention from something that might actually be a threat.  I am told that nearly 10 percent of the bags screened in Minneapolis are re-screened bags from Canada.  It is nuts.

But through the recently announced initiative this bag re-screening requirement, something ACI-NA has led the fight to get rid of for some time now, will be gradually eliminated.  This is great news for travelers, and even better news for the security of our aviation system.  There are a number of other key initiatives in the Obama-Harper agreement that, I hope, will one day lead to our two countries being considered a single perimeter.

Next, I would like to see this requirement lifted for flights from the European Union, and perhaps from other key allies.  These were important recommendations of a federal commission I served on in the last administration, appointed by Secretary of State Condoleezza Rice and Secretary of Homeland Security Michael Chertoff.  Called the Secure Borders and Open Doors Advisory Commission, we made these and other common sense recommendations to enhance national security while ensuring that legitimate travel was well-facilitated.  During that commission, my seat mate was J.W. Marriott, Jr., CEO of the Marriott hotel chain.  Marriott put a great deal of energy and passion into the commission’s work, though I am sure he had been on lots of commissions before.  We had a number of good conversations about these and other issues; he’s a good man.  Marriott announced his retirement yesterday, which was big news in the Washington area as Marriott is a locally based company, and it was big news in the travel business, for obvious reasons.  I certainly wish him well and thank him for his courtesies to me.

International Visitors – A Stimulus That Works!

Over the past several days and weeks, I have heard a great deal of talk about how difficult it can be for foreign visitors to come to the United States.  Visas are often difficult to get.  Understaffed Customs and Border Protection facilities mean long waits and result in some people deciding to go elsewhere.  I have seen it when international airport meetings are scheduled in the United States; many airport executives from around the world do not really want to come here because it can be difficult.

One article I saw recently spoke about how much international visitors spend when they are here.  A vacationer from Japan or China spends several times what a domestic U.S. vacationer will spend, for example.  The implication of the article – we need to do a better job of importing SHOPPERS.  Every dollar they spend goes to the plus side of the trade balance ledger.  The spending of an international visitor is an EXPORT, essentially.

Foreign carriers at JFK.

I have had several discussions with our members about this; it is a growing issue.  The large international gateways are frustrated because staffing and resource constraints mean longer wait times.  Smaller markets that have the ability to attract international service are often frustrated because CBP will not staff their facilities so they lose the service.  The difficulty in getting a visa means it is harder to attract service from countries such as China, India and Brazil – rapidly growing countries with HUGE middle class populations.  Strong allies like Poland can’t get into the visa waiver program.  A lot of this does not make any sense.

We have more than 100 open skies agreements with countries all over the world.  Open skies, to most people, means that any flight that can sustain itself economically can operate between the two countries.  And with today’s aircraft equipment and airport facilities, it means many more cities can serve as international gateways, in a sense.  That is the theory…

….BUT in reality, the skies are only as open as U.S. Customs and Border Protection (CBP) says they are.  If they do not have the staff, or if they decide they are unable to staff a flight for whatever reason, the skies become closed.  Totally.  This is not right, we are shooting ourselves in the foot.

And, by the way, I recently saw a study conducted at one airport, a smaller one, that showed the amount paid by travelers in government fees alone (this is not counting any impact from their shopping or buying) dwarfs the amount it costs to staff the extra flight.  If this were a business, that would be called a profit.

There is plenty of blame to go around for this.  I have mentioned U.S. CBP, but they have to operate with the resource constraints Congress places upon them – especially difficult in the current environment.  And one of the negative side effects of the current environment is that arguments like the one I made in the previous paragraphs are too often assumed, out of hand, to be mere rationales for more spending.  Even when you can demonstrate what would be called in the private sector a “business case.”  I do think Customs and Border Protection can be more imaginative in the way they do things, and I am starting to see evidence that CBP Commissioner Alan Bersin is moving in that direction.   But they have a ways to go.

And the State Department can and should be more imaginative in the ways it deals with requests for visas.  Making people in places like Brazil and India travel thousands of miles and pay huge sums of money for an in person interview does not seem to make sense when there are other ways to do this.

These issues too often fly under the radar.  But the facts speak for themselves and they speak loud and clear.  International visitors are a huge economic benefit to the United States economy.  No one has ever even tried to argue the opposite.  This seems to be something everyone agrees is good, but then no one can figure out how to make it work.  ACI-NA will be spending a lot of time in the coming weeks and months working on this.

We Agree with ATA on Some Things

I’ve been out of town most of the past two weeks, visiting the ACI Latin America/Caribbean conference in Montego Bay, Jamaica; participating in an event at DePaul Law School in Chicago with the smartest person I’ve ever met, former Virginia Governor Jerry Baliles (also had a chance to meet Rosie Andolino, Chicago’s innovative aviation commissioner); and speaking at the Western Regional Airport Property Managers meeting in Portland (and meeting with Steve Schreiber and his great team at PDX).

Sometimes when you travel a lot you miss some things back home. In this case, I missed an interesting and important speech given by my colleague and counterpart at the Air Transport Association, Nick Calio.

Much of the speech was about what you would expect from the ATA president. But there were two things I want to comment on.

First of all, Nick came out strongly in opposition to the administration’s proposal to levy a new FEDERAL fee/tax/whatever to pay for aviation infrastructure. I suppose this is not news in itself, but you might be surprised to hear that I share his concern about this idea. We have been pushing for the federal government to get out of airport financial affairs; this proposal doubles down on an approach that continues to tether airports to Washington. We want more freedom, not less!  So, I must say I agree with Nick and do not think this is the best way forward.

"We are not ready to sing around the campfire. But we have more in common than we may sometimes want to acknowledge and we ought to continue to communicate with each other to try to find a way forward."

Which brings me to my second observation about his speech. As did President Obama, Nick pointed to places around the world, like China and Dubai and Abu Dhabi, that are making major investments in airport infrastructure. Just so. We are falling behind and need to do something.

What was not mentioned, though, was that these places use passenger user fees (what we call Passenger Facility Charges) to finance this development. Now I presume Nick does not favor Chinese or UAE-style government involvement in aviation. Absent that, the ONLY way to make those investments is to give airports the ability to generate their own resources, as happens in those places.

So. It seems we may agree on not wanting the federal government to collect even more money and be any further involved in our affairs. I continue to think that airports and airlines have much more in common than we may sometimes want to admit. I will continue to call airlines on their inconsistency — wanting the federal government out of THEIR way while wanting the federal government to mess in airports’ financial lives, especially to protect airlines against competition. I will continue to say that the ATA call for a National AIRLINE policy betrays a view that the purpose of aviation is happy airlines. These are important differences.

We are not ready to sing around the campfire. But we have more in common than we may sometimes want to acknowledge and we ought to continue to communicate with each other to try to find a way forward. Especially when the presidents of ATA and ACI-NA agree that we should not impose this new FEDERAL tax and also that certain airports that happen to use a PFC-approach are worthy of emulation.