Tuesday, December 23, 2008

More on LGA’s Caps

Just in case you’d like to see how the Federal Government operates, this Notice of Proposed Amendments for LGA is a pretty good example. I’ll provide some portions below. You can download the whole document here. Pay particular attention to the “Background” information.

Federal Aviation Administration
[Docket No. FAA-2006-25755]
Operating Limitations at New York Laguardia Airport; Proposed Amendments
AGENCY: Federal Aviation Administration (FAA), DOT.
ACTION: Proposed Amendments and Request for Comments

SUMMARY: The Federal Aviation Administration (FAA) has tentatively determined that it is necessary to amend further its December 12, 2006 Order that temporarily caps scheduled operations at New York’s LaGuardia Airport (LaGuardia), pending the implementation of a longer-term regulation to manage congestion at the airport. In particular, we now propose to accept from air carriers voluntary reductions in scheduled operations at the airport to a targeted average of 71 hourly scheduled operations for the duration of the Order. This proposed reduction in flight operations at LaGuardia would not affect the number of unscheduled operations at the airport.

I. Background

As a result of the limited capacity of LaGuardia’s two-runway configuration, the airport cannot accommodate the number of scheduled flights that airlines would like to operate there without causing significant congestion-related delays. This circumstance long ago led the FAA to limit the number of scheduled arrivals and departures at LaGuardia during the peak hours of demand. 1 The FAA ultimately relied on the High Density Rule 2--its initial mechanism to control congestion at LaGuardia--for nearly 40 years. The High Density Rule limited the number of scheduled operations at the airport to 62 per hour.

In a statute enacted in April 2000, Congress began to phase out the High Density Rule at LaGuardia and other airports. 3 Before fully extinguishing the High Density Rule at LaGuardia on January 1, 2007, the statute immediately authorized a number of exemptions from the High Density Rule for specific types of scheduled operations. 4 Demand for exemptions to operate scheduled service at LaGuardia soared. By November 2000, the debilitating delays that resulted from the surging demand required the FAA to roll back and cap the number of scheduled operations at LaGuardia. 5 The FAA did not roll back the scheduled operations to the number that airlines conducted before the surge, instead capping the operations at a more elevated total of 75 hourly departures and arrivals.

In the ensuing years, the FAA examined and proposed various alternatives to the High Density Rule in an effort to control congestion at LaGuardia. 6 When it became apparent that the FAA would not have a replacement rule in place before the High Density Rule expired at LaGuardia, and recognizing that LaGuardia is prone to overscheduling, the FAA proposed and finalized an interim Order that capped the number of operations at the airport until the FAA could finalize a rule. 7 The interim Order, which is the subject of this proposed amendment, retained the cap of 75 hourly scheduled operations that originally took effect in November 2000.

The FAA published a final rule with respect to LaGuardia on October 10, 2008. 8 As a result of the continued and aggravated congestion-related delays at LaGuardia, the rule, in part, reduced the hourly cap on scheduled operations at LaGuardia. In this respect, the rule specifically identified a reduced cap of 71 hourly scheduled operations at LaGuardia from 6:00 a.m. until 9:59 p.m., Eastern Time, effective March 8, 2009. 9 this number is substantially higher than the 62 hourly scheduled operations permitted under the High Density Rule. On December 8, 2008, the United States Court of Appeals for the District of Columbia Circuit issued an order staying the effectiveness of the LaGuardia final rule, pending the outcome of litigation over disputed elements of the final rule. 10 The FAA is now proposing this amendment to the LaGuardia Order to reduce scheduled operations to an average of 71 hourly departures and arrivals should carriers currently allocated operating authorizations under the Order choose to voluntarily reduce operations.

The “statute enacted in April 2000” was the Wendell H. Ford Aviation Investment and Reform Act for the 21st Century -- better known as AIR-21. That link to Wikipedia won’t help you much for this subject. It was a big bill that covered a lot of ground. But give credit where credit is due. It contained the provision to do away with the High Density Rule.

As I suggested in my previous post, I thought 71 ops per hour (35-36 arrivals per hour) was a little high for LGA. 75 per hour is better than no caps, 71 is better than 75 and 62 would be even better for controlling delays. Some of you might be interested in knowing where that 71 operations per hour figure came from. That would be MITRE.

In relation to the final rule that is currently stayed, MITRE Corporation’s Center for Advanced Aviation System Development modeled the effect of reducing the hourly cap on scheduled operations at LaGuardia from 75 to 71. The MITRE queuing model reflected that the reduction could generate an average delay savings of 41%. 12 The FAA calculated the resulting annual benefit from this delay reduction at LaGuardia to be $178 million. 13

You’ll have to download the document to read the footnotes. I just hope you’re as amazed as I am at how easy it is for the Federal Government to say they’re saving somebody money. Somewhere. Somehow.

Don Brown
December 23, 2008

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