ISSUE: Realignment – the consolidation, deconsolidation or reorganization – of FAA facilities and services must be implemented only when such changes address a specific operational need in addition to providing a cost benefit. The Federal Aviation Administration (FAA) has begun to separate radar and tower air traffic services at several airports across the country, despite serious outstanding concerns over the effect such changes would have on safety and doubts over the operational benefit. Such plans for Miami and Philadelphia were terminated after congressional and public pressure forced the FAA to review configuration alternatives that better addressed the situation at these facilities. The FAA ultimately agreed that the proposed configuration would resolve the issues at-hand without creating additional safety risks. This sudden course correction revealed the need for a thorough and open selection and review process for FAA facility realignment initiatives.
NATCA’s Position: NATCA is not categorically opposed to all realignment initiatives. However, we believe that they must be done only when an operational need exists that cannot be addressed using better alternatives. The FAA should be prohibited from moving forward on any realignment activity until a thorough review procedure that is inclusive of all stakeholders – including NATCA - is codified into law.
FLAWS OF CURRENT PROCESS: The FAA has an obligation to involve Members of Congress, the public, airport operators, aviation operators, and other stakeholders in the decision-making, planning, and implementation process of any agency effort that could affect the safety and efficiency of the airspace. Regrettably, the agency’s has chosen instead to exclude stakeholders from the process, ignore their concerns, and inform the public only after their decision has been made.
This go-it-alone method ignores authentic and substantial inadequacies in FAA planning. For instance, splitting air traffic functions currently worked by one facility into two or more facilities (as the FAA has proposed in Memphis, Charlotte, Philadelphia, Miami, Palm Beach, Denver, and Houston) requires additional staff because of a loss of flexibility. Unfortunately, current controller-staffing levels are too low (25% below the scientifically-determined staffing need) to execute the plans.
Combined Tower/TRACONs are Safer than Split Facilities
- Statistically, there are fewer operational errors per operation at Up/Down facilities than at their severed counterparts.
Narrowed Field of Knowledge
- In Up/Down, controllers must learn all aspects of operations required for safe and efficient arrivals and departures. This enables controllers to understand how their actions at one position effect the operation of the adjacent positions, enabling controllers to optimize their performance for both safety and efficiency.
- New trainees will not only be denied the opportunity to train on all dimensions of the operation, they will not even have the opportunity to observe operations at other sectors. Narrowing controllers’ responsibility in this way is akin to training one pilot to perform take-off and landing and another to fly the plane.
Barriers to Coordination
- Combined Tower/TRACONs allow for simpler communications and more face-to-face interactions, resulting in greater efficiency. Barriers to communication caused by physical separation necessarily reduce efficiency, potentially causing additional unnecessary delays.
- Experience at other split facilities has shown the deterioration of communication and coordination caused by the separation.
Inefficient Use of Resources
- Combined/Tower TRACONS have a lower cost per operation than separate facilities (See Attached)
- Nearly every FAA staff study of realignment initiatives has determined that a split Tower/TRACON requires more staffing than a combined facility, due to a loss of staffing flexibility. Splitting the facility is an inefficient use of personnel.
ATC Facility Realignment Done Wrong:
Case Studies of Pueblo and Palm Springs
When the FAA has collaborated with NATCA and other realignment stakeholders, we have collectively been able to make realignments work. Unfortunately, the Agency’s track record when deciding to go-it-alone is not as good. The Idaho congressional delegation, for example, has struggled to obtain convincing justification from the FAA for its proposal to move the radar functions at the Boise Airport to Salt Lake City, leading Idaho Senator Mike Crapo to hold field hearings and issue press statements like the one below to express the Senator’s frustration with the Agency’s lack of openness and responsiveness:
“Of serious concern to me is the frustrating lack of information from the FAA and, when pressed, the inadequacy of the information that comes out. The cost savings amount is highly questionable… [A]irport users, pilots and private experts testified that safety and efficiency could NOT be guaranteed at that distance. This sounds like a decision in search of a rationale…I’m a firm believer in reducing government waste, but this move by the FAA was made without local and regional considerations. [The]TRACON carries out a critical functions that must be performed by the federal government, and the government must conduct these operations responsibly and safely.”
Below are two cases of the FAA providing Congress with assurances that realigning facilities in their state or district was not cause for concern, only to later reveal that in both instances the facility consolidations either led or contributed to troubling controller understaffing, decreased ATC services to users, and diminished safety margins.
Case I: Pueblo
February 15, 2008, Congressional Delegation from Colorado, in Letter to the FAA:
- "We feel that there are several outstanding concerns. These concerns include the safety of the Pueblo users…and the staffing challenges that the FAA is Experiencing at DIA (Denver International Airport) and surrounding airports… We do not believe that the FAA has demonstrated that its current consolidation proposal is in the best interest of Pueblo or the aviation community… We submit that your proposal to relocate the Pueblo Approach Control function in the Denver TRACON is short-sighted and request that it be reconsidered."
FAA Dismisses Congressional Concerns
April 23, 2008, then-Acting FAA Administrator Robert Sturgell, in response:
- "Staffing at Denver TRACON is a priority for the Agency. In fact, we have taken measures to retain experienced controllers... (and) the facility has received 11 newly hired air traffic controllers...(that) are in various stages of training."
- September 2008: FAA transfers PUB radar functions to Denver TRACON.
Post-realignment, FAA Admits Its Mistake
February 19, 2009, Kevin Stark, Acting Air Traffic Manager, Denver Center, in a letter to his employees explaining the detrimental impact that staffing at Denver TRACON was having on his en route facility and Denver airspace:
- "as the demand on the airport has continued to increase the situation has become untenable for the TRACON.”
- “The TRACON has indicated that the loss of a large number of their experienced employees, the relative inexperience of many of their current controllers, and the increase in volume has created a situation that they can no longer accept. They have indicated that the volume issues created by eight different routes flowing into their airspace routinely creates situations that put their controllers at risk, and they are unable to provide the level of service our customers deserve.”
- “…the facility manager at the TRACON determined that he could no longer accept aircraft in the manner that we have historically provided them.”
It is also important to note that the FAA assured the Colorado delegation that the radar transfer would result in “an immediate benefit for Pueblo once services are provided from Denver, including access to enhanced weather information.” A year later, however, the FAA is proposing to remove on-site weather forecasters from Denver and consolidate them into Kansas City.
Case II: Palm Springs
April 18, 2007, Congressional Delegation from Southern California, in a letter to then-FAA Administrator Marion Blakey opposing transferring the Palm Springs International Airport’s radar functions to the Southern California TRACON:
- “This proposal could serve to exacerbate the understaffing issues at both the SoCal TRACON and Los Angeles facilities… Terminating consolidation plans and instead focusing on increasing controller staffing levels at these two vital FAA facilities is a better approach.”
FAA Dismisses Congressional Concerns
May 16, 2007, then FAA-Administrator Marion Blakey, in response to the delegation:
- “Please be assured that SCT can handle the transfer of airspace from Palm Springs. Staffing levels at SCT are well within the FAA 2007 authorized staffing range of 186 to 228, with 210 controllers on board… after you review the facts, I hope you will agree that this will be a better situation for everyone involved.”
- July, 2007: FAA transfers PSP radar functions to Southern California TRACON.
DOT Watchdog Issues Staffing Warning
April 23, 2009, DOT Inspector General Report, Controller Staffing at Key California Air Traffic Control Facilities:
- “Retaining experienced controllers is an even more critical issue at SCT, where the number of CPCs has sharply declined since 2004 – from 236 to 161 (a decline of 32 percent), while the number of developmental controllers has increased… (to an expected 100, or 40 percent of the facility workforce, this year)… We are concerned that this will overwhelm the facility’s training resources.”
- [A]t SCT, the number of operations per controller has increased by 19 percent since 1997.”
- “Overtime hours at SCT increased from more than 7,300 overtime hours in FY2006 to nearly 36,700 hours in FY2008 (a 400-percent increase).”