JIM BURNETT
Transportation Safety Consultant
Telephone 501-745-2480
FAX 501-745-6445

April 25, 2001


Honorable Norman Y. Mineta
Secretary of Transportation
400 Seventh Street, S.W.
Washington, D.C. 20590

Dear Mr. Secretary:

Congratulations on your appointment as Secretary of Transportation! You bring a wealth
of knowledge and experience to this critical position from your years of service in the Congress and as Chairman of the National Civil Aviation Review Commission (NCARC). The transportation industry and traveling public will be well served under your guidance.

I am writing to share my concern about airport surface safety and to urge the Department
to become more proactive in efforts to address the prevention of runway incursions and accidents. As you know, during my tenure as Chairman of the National Transportation Safety Board (NTSB) during the administration of President Reagan I was actively engaged in investigating these occurrences and issuing recommendations to the Federal Aviation Administration (FAA). The last accident I investigated was the 1991 surface collision in Los Angeles involving U.S. Air and the last public hearing I chaired involved the surface collision of two Northwest Airliners in Detroit.

Although I have returned to Arkansas to practice law, I continue to closely monitor this
safety issue by reviewing Congressional testimony, "Aviation Week and Space Technology" magazine, "Air Safety Week", and other technical and media reports. 1 also maintain numerous contacts in the aviation industry with whom I communicate regularly about safety and capacity matters, and especially the runway incursion hazard. I teach advanced accident investigation and safety decision making for the Southern California Safety Institute. I also follow aviation safety issues as a member of the Air Traffic Control Association and International Society of Air Safety Investigation.

It is my sense (and many others in Congress, Government, and the aviation industry) that
runway incursions are the most critical safety issue confronting the National Airspace System today. Runway incursions, with their potential for an actual collision, are a serious and growing safety problem:

• Since 1993 the number of runway incursions has increased 130
  percent from 186 to 429 in 2000; the rate increased 110 percent
  from .30 (per 100,000 airport operations) to .63.
• In the most recent year runway incursions increased 33 percent
  (321 in 1999 to 429 in 2000); the rate increased 28 percent (from
  .47 to .63).
• During the first three months of 2001 runway incursions increased
  15 percent (84 to 97) when compared to the same period during
  2000. If this trend continues runway incursions will approach 500
  in CY 2001, two and a half times the incidents occurring in 1994.
  [Source of above date: FAA Runway Safety Web Site]

Also, six fatal runway collision accidents have occurred in the United States since 1990.
These accidents, at Atlanta and Detroit in 1990, at Los Angeles in 1991, at St. Louis in 1994, at Quincy in 1996, and at Sarasota in 2000, resulted in 63 passenger and crew fatalities. On October 31, 2000, at the Chiang Kai Shek Airport in Taipei, China, a Boeing B-747-400 collided with barriers and construction equipment during an attempted takeoff on a closed runway resulting in 83 fatalities.

Further, critical runway incursions involving air carrier aircraft that narrowly miss
colliding with another aircraft continue to occur all too frequently. There are 30-40 such critical occurrences annually which have a high potential for an actual collision. Examples of critical runway incursions that have occurred this year to date include:

• 1/22/01 - At Seattle - Tacoma a TWA MD-80 flew directly over an American MD-80 on the same runway with an estimated minimum vertical distance of 50 feet between the two airplanes.
• 1/24/01 - At Los Angeles an America West B-737 taxied onto the
  same runway where a Norontair B-737 was on landing roll out with
  an estimated minimum distance of 100 feet on the surface between
  the two airplanes.
• 2/21/01 - At Boston an American Eagle Saub-340 taxied onto a
  runway in front of a United B-757 who was on takeoff roll with an
  estimated minimum distance of 50-100 feet on the surface between
  the two airplanes.
• 3/4/01 - At Ft. Lauderdale a Delta B-767 flew directly over a US
  Airways B-737 (in position and hold on the runway) and landed
  on the same runway with an estimated minimum vertical distance
  of 50-100 feet between the two airplanes.

The runway incursion hazard will only be exacerbated by future increases in aircraft
fleets, airport operations, and passenger enplanements. Just last month at the FAA's 26th Annual Commercial Aviation Forecast Conference you were quoted as saying that:

"commercial aviation will continue its tremendous growth rate over
the next decade, further underscoring our nation's reliance on this
vital form of transportation, and

of course, guaranteeing the safety of the traveling public is and
always will be our number-one responsibility, and

however, working to close the gap between demand and the
capacity of our transportation infrastructure is a central challenge
for us in the aviation community"

FAA's forecasts include the following:

• Domestic passengers on U.S. airlines are forecast to increase from
  604.1 million in 2000 to 927.4 million in 2012 (3.6 percent
  increase per year).
• The fleet of large air carrier jets is expected to grow from 4417
  aircraft in 2000 to 6313 in 2012 (3 percent increase per year).
• Commuter airline enplanements are forecast to increase from 79.6
  million in 2000 to 154.1 million in 2012 (5.7 percent per year).
• The regional jet fleet is expected to increase from 569 aircraft in
  2000 to 2190 in 2012 (11.9 percent annual increase).
• The cargo fleet is forecast to increase from 1073 aircraft in 2000
  to 1760 aircraft in 2012 (4.2 percent increase per year).

During 2000 the FAA held nine Regional Workshops across the U.S. and a Human
Factors and Runway Safety Symposium to solicit ideas and input from the industry on the causes and prevention of runway incursions. This was followed by a Runway Safety National Summit in Washington, D.C. Nearly 1000 recommendations aimed at runway incursion prevention were received from these meetings. These recommendations were condensed into 60 potential initiatives by combining similar proposals and eliminating duplication. Ten initiatives were identified as "Ten Near-Term Initiatives" because of their high potential for reducing runway incursions and because they could be completed by the end of calendar year 2000. The results of this process were published as the National Blueprint for Runway Safety in October 2000.

The FAA has been slow to implement the initiatives in the Blueprint, as has been the case
with its previous "Action Plans." For example, most of the Ten Near-Term Initiatives have not been completed. Many are months behind schedule, and in some cases no action has been taken to date. The remaining fifty initiatives lack specific schedules, milestones, and funding. In fact, the DOT Inspector General has testified twice this year (2/14/01 and 3/8/01) concerning the FAA's failure to "follow-through to ensure initiatives were completed, evaluated, and the best ones spread to other airports where they could make a difference."

My concern here is that very little is actually being done to address the runway incursion hazard. The FAA convenes meetings and issues action plans and blueprints, but falls short in its follow-up and implementation of corrective actions. Simply, very little actually gets changed. The FAA testifies that safety is its "primary goal," but the agency's actions don't match the rhetoric, often superseded in favor of enhanced system capacity and airport acceptance rates. I believe that the potential for another fatal runway collision accident is high - we can not continue to experience incidents where air carrier aircraft are missing an actual collision by 100-200 feet and believe otherwise. In many of these critical incursions the fact the airplanes did not collide was by chance alone. There is an urgent need for proactive intervention before another collision occurs.

Mr. Secretary, I urge you to focus your personal attention and the full resources of the
Department on this very serious safety issue. It is time to energize the FAA into action and
demand executive accountability. I recommend a four-part focused agenda: organizational
changes, traffic management at the busiest airports, cockpit tools, and an automated collision avoidance system for surface operations. The first two could be done relatively soon while the remaining two will take longer.

First, I recommend that the FAA's Runway Safety Program Office management be
reassigned to the Office of the Secretary or the Office of the Assistant Secretary for Safety. This would facilitate direct oversight of the program by the Department. This new organization should be directed to complete the initiatives contained in the Blueprint in an expedited manner. Funding, schedules, and milestones should be established and adhered to. I know this seems to be a radical recommendation but the FAA has proved itself either unable, or more likely unwilling, in the face of industry pressure, to handle this issue.

Second, there is a need to manage traffic flow and complexity at the busiest airports to
reduce the potential for runway incursions. I believe there is a significant correlation between the incidence of runway incursions and the busy airports that are currently experiencing traffic delays. For example, seven of the leading airports with delayed flights are also on the top ten list of airports with the highest number of runway incursions (all ten of the leading capacity constrained airports are on the list of top 20 airports with runway incursions). Current efforts intended to increase airport capacity and acceptance rates at these already overloaded airports will only further jeopardize aviation safety. I recommend that a study be performed immediately to validate this correlation. The data need to be normalized and analyzed to measure frequency congestion and controller and pilot work load to determine if these factors increase the risk of runway incursions and, if they do, measures need to be implemented to reduce and spread out the traffic to an appropriate level. A study to address this issue is included in the FAA's Blueprint under the Data, Analysis, and Metrics Thrust. I note that in recent testimony the acting Chairman of NTSB addressed this same issue; that the push to reduce delays "has the potential" to erode safety. Until these studies can be completed preemptory measures must be taken to reduce congestion at critical airports before this summer's peak loads.

The third recommendation involves the use of technology in the cockpit to help pilots
maintain situational and navigational awareness. Today's pilots taxi 75 million dollar aircraft
around the airport surface using paper charts of the airport layout, looking out the cockpit
windows for signs, markings, and lighting (often misleading or inadequate) to guide them. The use of this "flintstone" technology is in stark contrast to the automation, flight management systems, satellite and inertial navigation, auto land/brake systems, and conflict alert and resolution technology (TCAS I & II, GPWS) that have been developed and implemented for flight crew use during terminal and enroute operations. Yet, we all can rent a car from AVIS that has a "never lost system" to provide precise navigation guidance. This includes a moving map supported by Global Positioning System data that presents detailed information about your current position and your planned route to the point of destination. This technology has been demonstrated successfully by the National Aeronautics and Space Administration (NASA) in its simulators and B-757 aircraft. Pilot deviations from cleared taxi routes and hold short restrictions were virtually eliminated during simulator sessions with pilots taxiing around Chicago O'Hare airport, which is one of the most difficult to maneuver around. This technology — electronic moving maps and head-up displays — is needed now. It could conceivably prevent 50-75 percent of the runway incursions currently being experienced by air carrier transport aircraft. The FAA needs to issue rule making to require implementation and use of this technology by a date certain: the use of an electronic moving map in two years, and a head-up display with automatic dependent surveillance - broadcast (ADS-B) of other aircraft in four years.

The fourth recommendation involves the need to develop and implement an automated
collision avoidance system for surface operations. It should be based on GPS surveillance of all aircraft and ADS-B broadcasting the location, heading, acceleration, and other data (aircraft ident) to every other aircraft. NTSB has been recommending the need for such a system for years. Its most recent recommendation, dated July 6, 2000 is as follows:

Require, at all airports with scheduled passenger service, a ground movement
safety system that will prevent runway incursions; the system should provide a
direct warning capability to flight crews. In addition, demonstrate, through
computer simulations or other means that the system will, in fact, prevent
incursions. (A-00-66)

There is a striking precedent to such a collision avoidance system for surface operations.
It is the one - TCAS - developed for airborne operations. From 1965 to 1986 there were 17 midair collision accidents (14 which were fatal) involving air carrier aircraft in U.S. domestic airspace. These collisions resulted in a total of 408 passenger and crew fatalities. The NTSB investigated these midair collisions and repeatedly made recommendations to the FAA 10 develop and implement a collision avoidance system. The FAA "fumbled" along for years attempting to develop a system, always waiting for the best rather than implementing the good, similar to the FAA's current record of trying to implement the Airport Movement Area Safely System (AMASS). Finally, the Congress became so frustrated with the FAA's lack of progress that it directed the FAA (Administrator Helms) to implement TCAS II for transport aircraft. The results are startling: there have been no midair collisions involving air carrier aircraft in the U.S. since 1986 (Cirritos, CA). There is an urgent need lo accelerate the development and implementation of a collision avoidance system for surface operations.

In summary, I urge you to involve yourself in this serious safety issue. Despite good-faith
efforts by the FAA, NTSB, and the aviation industry to develop and implement improvements to prevent runway incursions and accidents, they continue to occur. The number and rate of reportable runway incursions have increased significantly during the past years. Critical incursions involving air carrier aircraft continue to occur all too frequently. Aircraft fleets, airport operations, and passenger enplanements are forecast to increase dramatically during the next ten years. This record provides clear evidence that the potential exists for future runway incursions and accidents, and it underscores the importance and urgency of the need for immediate action to implement effective and realistic solutions directed at runway incursion and accident prevention. The need is for proactive intervention. The seriousness of this problem and the urgency of preventing additional surface accidents justify the highest level of attention to these efforts on the part of the Department.

To put this issue even more starkly, we are presently in a crisis. I consider our country's
most congested airports to be UNSAFE. They will remain unsafe until remedial action is taken. The short-term action required will be painful, but will have the added benefit of hastening the implementation of longer-term measures. Our nation is fortunate to have your leadership during this crisis.

Should you need additional information or wish to discuss this matter more in detail,
please telephone me at (501)745-2480. I have no business or commercial interest in this issue and write to you solely out of concern of the present risk of an aviation disaster involving two or more airplanes.

Respectfully yours,

Jim Burnett
JB/es