May 12, 2009
The Honorable John D. Rockefeller The Honorable Kay Bailey Hutchison
Chairman Ranking Member
Senate Committee on Commerce, Senate Committee on Commerce,
Science, and Transportation Science, and Transportation
254 Russell Senate Office Building 560 Dirksen Senate Office Building
Washington, DC 20510 Washington, DC 20510
Dear Chairman Rockefeller and Ranking Member Hutchison:
We are writing to urge you to oppose any and all attempts to include language in the
Senate version of the Federal Aviation Administration (FAA) Reauthorization bill that
would either legislate changes in the current aircraft rescue and fire fighting (ARFF)
standards or legislate that an unfair rulemaking process be undertaken to make changes in
the standards. If enacted into law, these proposals could unnecessarily increase costs for
airports and airlines as well as jeopardize commercial air service to small communities.
As you may know, H.R. 915, the FAA Reauthorization Act that the House Transportation
and Infrastructure Committee approved earlier this year, contains a provision that could
force airports of all sizes to comply with controversial National Fire Protection
Association (NFPA) standards. Although each of us supports various sections in the
House bill, we are unified in our opposition to Sec. 311, in part, because it could impose
huge costs onto airports and the airlines without any benefit to aviation safety.
To meet NFPA standards, airports of all sizes would be required to dramatically increase
the number of fire fighters and add additional facilities without any evidence that these
changes would improve the safety of airports. Increased capital and annual operating
costs resulting from the NFPA standards would force airports to divert their already
limited funding resources from other necessary safety and airport improvement projects.
For communities that rely on Essential Air Service, adopting NFPA standards without
careful evaluation could further damage a program that is already under stress. These
increased costs would be passed on to the traveling public at a time when many can least
afford it.
A survey of 55 airports conducted by Airports Council International – North America
(ACI-NA) in October found that the capital costs to comply with the NFPA standards
would range between several thousand dollars and $33 million, with the average cost of
compliance being $6.5 million. The responding airports also reported that the NFPA
standards would increase their annual operating costs by between $25,000 and $10
million, with the average cost of compliance being $2.5 million per year.
The American Association of Airport Executives (AAAE) has also been compiling
information from airports around the country about the cost to comply with NFPA
standards. Based on feedback the association has received from approximately 50 large,
medium, small and non-hub airports, AAAE expects that the increased operating
requirements could cost the airport industry as much as $1 billion per year and $4 billion
in increased infrastructure and equipment costs.
Updates to the FAA ARFF standards have been evaluated by the Aviation Rulemaking
Advisory Committee (ARAC), which allows all interested stakeholders, including
airlines, pilot organizations, airports, the FAA and fire fighters to participate, and the
final report is being sent to FAA. In addition, a study conducted under the well-respected
Airport Cooperative Research Program (ACRP) on how proposed ARFF standards would
impact airports will be released this summer. The FAA needs time to properly evaluate
the information put forth by both the ARAC and the ACRP study to determine what, if
any, changes are needed to the ARFF standards.
Please reject any efforts to include any language in the Senate version of the FAA
Reauthorization bill that would either legislate changes to the current ARFF standards or
legislate that an unfair rulemaking process be undertaken to make changes in the
standards. Instead, we urge you to allow the FAA to continue to work with aviation
stakeholders as the ARAC process comes to a close and carefully review the ACRP
report data.
Thank you for your leadership on aviation issues. We look forward to continuing our
working relationship to ensure that our nation’s aviation system remains safe and secure.
Sincerely,
Greg Principato James C. Coyne
President President
Airports Council International-North America National Air Transport Association
James C. May Henry M. Ogrodinski
President and CEO President and CEO
Air Transport Association National Association of State Aviation Officials
Charles Barclay Roger Cohen
President President
American Association of Airport Executives Regional Airline Association
Thomas E. Zoeller
President
National Air Carrier Association
