User Fees – The Safety Angle

February 1, 2012 by Bruce Landsberg

There is enough heated rhetoric regarding the topic to warm up an NFL stadium but what sends cold chills down my back is the very real possibility that some pilots will try to save a buck. We won’t discuss class warfare, party affiliation, collection efficiencies, big government, the fuel tax or inherent fairness. The politics of this can and should be handled by AOPA but the potential safety ramifications are real and should not be left out of the calculus. The stated plan by the government is that a $100 per flight segment would only apply to turbine powered aircraft. Before we get into how this concept could mutate let’s just look at it at face value.

On short flights – say to reposition, some jet operators could easily decide that they should fly lower and under VFR to avoid the fee. Today almost every turbine  fixed wing aircraft operates with the protection of IFR. The jets typically fly higher because of fuel burn and there is guaranteed separation from all other IFR aircraft. Good idea! But under the new rules it’s easy to see the rationalization that could take place.

The unintended consequences are myriad: Low altitude unpressurized turbine aircraft such as the Caravan or the Kodiak routinely ply the skies below 10,000 – guess who will now go VFR whenever possible? It may not necessarily be safe in marginal VFR but why pay when you can go for free? Much of the helicopter fleet is turbine and they routinely fly low altitude. Does this make sense?

As new variants of very light jets come into the mix they too may eschew the systemic protection because they are not in the same economic strata of Gulfstreams or Challengers. Is the rule to be based on turbine fuel? I predict that we’ll start to see diesels coming into the light aircraft fleet and they use turbine fuel or jet A. Where is the line drawn?

The fee proposal mentions controlled airspace. In most areas east of the Mississippi it starts at 1,200 feet agl, lower in transition areas around airports. Let’s suppose that isn’t what the government meant but rather mandatory communication airspace such as Class D, C, B, or A. Do we really want some of the turbine fleet routinely trying to avoid the system that was put in place to keep us all from colliding? Given the choice between paying the fee every single time the turbine  flies out of a towered airport, it seems economically  rational that there would be a migration to non-towered airports where much of the non-turbine fleet lives. That is not the safest mix in the world.

Now take all this and extrapolate it to other parts of the fleet. No – that couldn’t possibly happen, could it? And the per segment fee couldn’t possibly increase during times of economic downturn or because the fee itself reduces demand? Look at the history of user fees in other parts of the world. I’ve spent some time talking with non-aviation friends about this and when it’s explained in this way, almost all of them agree that our present system, funded by fuel taxes and some contribution from the general fund makes far better sense. We’d like to hear your safety thoughts.

Bruce Landsberg
Senior Safety Advisor, Air Safety Institute

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12 Responses to “User Fees – The Safety Angle”

  1. Lawrence Stalla Says:

    Bruce, you make a number of excellent points about the implications of proposed user fees for general aviation, but you neglect to mention the possible negative safety and economic repercussions for the air carriers themselves. As an example: I am based in southeast Colorado but, when I have business in northeast Colorado, I file and fly IFR, and let the Denver TRACON controllers vector me low and to the west, to remain clear of their Denver International traffic. Faced with a $100 user fee, I would remain VFR, and fly arguably the more direct route, either above or to the east of the Denver Class B airspace, and not talk to the Denver controllers, as is my legal right under VFR. For at least part of this journey, I would transit across several arrival and departure corridors, and force the air carriers to avoid ME (TCAS II is a wonderful technology). This would boost the workload on both the Denver controllers and the air carrier pilots, and boost the fuel burn on the air carriers as well. It could compromise air carrier safety as well, particularly during high-traffic times of day. But, I would save $100.

  2. Don Griffin Says:

    Lawrence has it right. When I file IFR, it is usually as a courtesy to larger aircraft and to give ATC the opportunity to contact me and move me, if desired. Add $100 to a flight and I’ll be VFR. I can save other money as well by not staying IFR proficient or buying charts & keeping the GPS updated every 28 days. I would save far more than $100 by not participating. I can fly over the top or skirt class B at STL but choose instead to participate. While the $100 is a deal breaker, the real cost would be in safety and convenience to others. There’s also the very real concern that for now it is only one group of aircraft but like most fees and taxes, it will spread. The bureaucracy needed to police and collect such fees would probably absorb all revenue generated and more. Just what we need.

  3. Brian Klutenkamper Says:

    I fly a T210 for business travel purposes and always file IFR. We are looking to move up to a TBM that would be affected. I think it is also safe to say that once the fee is in place for turbine aircraft, it would only be a matter of time until it applies to all IFR flight. I think it makes sense for me, other aircraft and ATC that I fly IFR. It adds safety for all involved and I take the small inconveniences of being directed with vectors and assigned altitudes that I really don’t want flying in and out of the STL area and other busy hubs I traverse. I can avoid these little hassles going VFR weather permitting. Another concern is for pilots flying into headwinds stronger than expected and making a decision for a fuel stop. When flying IFR this will add another $100 to the cost. Many pilots may let that extra $100 fee affect their decision and take the chance of running out of fuel.

    It is obvious that fuel tax is the way to go. The tax has not changed in many years and needs to be increased. Using the existing system will not create another bureaucracy to collect the fees either.

  4. Bruce Snyder Says:

    I completely agree with Bruce’s article. Faster, heavier aircraft trying to occupy the same space as lighter slower aircraft is not the only safety issue with user fees. Today, if I need ATC assistance for any reason, I know that I have already paid for it with my fuel taxes so I don’t worry about added cost. If user fees are implemented, then every pilot of every aircraft will start to weigh the cost of asking for help against the risk of avoiding the system. Whether I’m flying my C182 or paying someone to fly me on a commercial flight, I don’t want the pilot of any flight thinking cost versus risk when the pilot needs to be fully focused on dealing with a less than ideal situation and bringing it to a safe conclusion.

  5. David Kurman Says:

    @Bruce Snyder…that’s an excellent point you make in your last sentence. I fly light airplanes with the occasional turbine thanks to good friends and there is PLENTY to do without having to start calculating cost of services and having that get in the way of safely flying the airplane. The big government power grab that has been going on in BOTH the last administration (TSA) and obviously this administration is going to cost us big time in the long run for little and more likely zero benefit. It’s everything but the right thing when it comes to Washington D.C. nowadays.

    From a day to day flying perspecitive it’s very expensive for me to fly my Warrior around, but I do what I can to satisfy the itch. If faced with fees at every turn for contacting the tower or for flight following…I can tell you that I personally would immediately fly less and over time (as we know the fees will increase) I would be forced to give it up.

  6. John Ritchie Says:

    This is the problem with goverment taxacrats; they assume the activity that they tax will remain static. It doesn’t, and that leads to expansion of the tax until the activity is effectively killed or leaves the country.

  7. L. Masters Says:

    Those of you who think they will cause the airlines problems by flying through their routes VFR (legally) are not thinking long term. The obvious response of the FAA will be to extend Class B, C or D airspace to fully encompass those areas. This has been the standard response of the FAA over the years to virtually all conflicts between “flibs” and the airlines. Thus another consequence of user fees will be to vastly expand airspace requiring a clearance from ATC. You can bet they are already salivating over that. And, of course, the more controlled airspace, the more user fees demanded. Nice little cycle.

  8. R. Sorrells Says:

    As an airsafety investigator for my company, I am positive that user fees will result in an increase in midair collisons. Bruce is correct when he notes that pilots will opt to go VFR instead of IFR to save the $$. If anyone has ever seen the Human Factors program at USC showing the 8 seconds till impact, they would quickly realize 1) how difficult it is to see something, even as large as a military KC-135 and 2) how quickly it fills the cockpit window. Very scarey indeed.

    So for a bit of additional tax revenue (and added bureaucracy) we will have people die. Is this what the FAA has for a goal? I thought the goal was Zero Accidents.

  9. G Dyer Says:

    User fees will definitely put a damper on GA.

    The politicians in the US are proposing to tax us twice; Once when we buy avgas, then another time with their proposed user fees. In addition, our income taxes also end up being used to fund the NAS. But when has double taxation ever gotten in the way of spendthrift politicians?

    I would think twice before using ATC if it cost $100 on top of all the other taxes I pay.

  10. Jim Rose Says:

    Everyone above has just reinforced what a Nobel Prize winning economist has said, what you subsidize you get more of, what you tax you get less of. Taxing fuel results in less flying in general, but is fair to everyone and applies to the whole of a flight’s economics. User fees for participating in the safety of the air traffic control system, and participation clearly increases the safety to pilots, passengers and those on the ground, will result in less participation in that system. The comments above are unanimous that this is true. The fight against user fees should concentrate on the safety impact and not the short sighted economics of trying to raise revenue. The pilots in the congressional GA caucus likely understand this (thank you!) but the administration wonks obviously don’t and need to be reminded, regularly.

  11. Gregg Lyle Says:

    I’m a very new pilot (less than two months) and still staggering from the cost of getting my license. Not a big fan of possibly getting hit with more fees that will effectively ground me altogether. That having been said, though, I also hold to the idea that if I’m the beneficiary of a service, I should be responsible for paying my fair share, and I shouldn’t depend on handouts from others to keep me flying (or anything else, for that matter.) Unless I’m missing something, one of the problems here seems to be that the proposed fees don’t treat all the beneficiaries the same. For instance, a large jet carrying 300 passengers, will pay the same fee that a smaller plane carrying only the pilot will pay, even though all passengers benefit equally from the added safety provided by ATC. A freight carrying plane, carrying huge numbers of packages, would pay the same price as well, even though everyone on the sending and receiving end of the packages benefit from having their packages delivered safely. I keep coming back to the idea that the only cost effective and even handed approach is to adjust the fuel tax. As has already been stated, the system is already in place, so we wouldn’t need yet another beauracracy. Additionally, entities would end up paying more or less their fare share based on how much fuel is required to push their airplanes around.

  12. M White Says:

    In 1987after delivering an aircraft to Austria, I hitched a ride to Germany with 3 guys in a Cessna 421. I was sitting behind the pilots and noticed that we were at 3000 ft. squawking 1200 in IMC. I asked the guy beside me (also a pilot) why? He simply said to avoid “Airway Fees !” SOP in Europe, is that what you want here?

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