oversight

Effective Fuel Conservation Programs Could Save Millions of Gallons of Aviation Fuel

Published by the Government Accountability Office on 1977-08-15.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

REPORT TO THE CONGRESS




Effective Fuel Conservation~
,Programs Could
Of Gallons
Department 6f Transportation
Civil Aeronautics Board
Federal Energy Admitaistration
Aviation   fuel conservation  has not received
the attention   it deserves. The Federal Gov-
ernment needs to do more; specifically:

      --Congressional action is needed to re-
        duce the fuel consumed    in transport-
        ing empty seats. About 4.2 billion gal-
        lons were used for this purpose in
        1976.

      --The Federal Aviation         Administration
        also needs to (1) monitor       its fuel con-
        servation programs, (2) hold all aircraft
        on the ground to the extent possible
        when excessive delays are encountered
        at destination    airports, and (3) develop
        program guidance to evaluate trade-offs
        between noise abatement and fuel con-
        servation      objectives   when conflicts      ’
        occur.




CED-77-98                                                   AUGUST 15, 1977.
                      COMPTROLLER     GENERAL     OF THE     UNITED   STATES
                                    WABHINQTON,   D.C.   20648




B-164497(1)




To the    President       of the       Senate     and the
Speaker    of the      House of        Representatives

        In 1976 the airlines      used about    9.5 billion     gallons    of
jet   fuel.    This  report  discusses    Federal    actions    to conserve
fuel    used by the airlines      and suggests     ways additional      fuel
savings     can be realized.

        We made our review       pursuant   to the Budget    and Accounting
Act,     1921 (31 U.S.C.    53),    and the Accounting    and Auditing
Act    of.1950   (31 U.S.C.    67).

       We are sending        copies      df this     report   to               the   Director,
Office     of Management      and Budget:         the Secretary                  of Transporta-
tion:    the Administrators          of the Environmental                       Protection
Agency     and the Federal         Energy    Administration:                    and the
Chairman,     Civil    Aeronautics         Board.




                                                  Comptroller   General
                                                  of the United   States
 COMPTROLLER GENERAL'S                               EFFECTIVE FUEL CONSERVATION
 REPORT TO THE CONGRESS                              PROGRAMS COULD SAVE MILLIONS
                                                     OF GALLONS OF AVIATION FUEL
                                                     Department     of Transportation
                                                     Civil   Aeronautics    Board
                                                     Federal    Energy Administration
               DIGEST
               ------
               An increase     in the ratio  of occupied      seats to
               available    seats on commercial      airlines    (the
               load factor)      above the 53- to 55-percent        range
               of recent    years could improve the fuel effi-
               ciency    of U.S. airlines   substantially.
               In 1976 the U.S. airlines         achieved     an industry-
               wide load factor    of about 55 percent.             Thus
               with 45 percent    of seats empty, the airlines
               used an estimated     4.2 billion      gallons      of fuel
               transporting   empty seats.        Reducing     flights
               to achieve   a 65-percent      load factor      could have
               reduced domestic    trunk airline        (the largest)
               fuel consumption    by almost a billion           gallons.
               Neither  the Federal   Government    nor the airlines
               have made major efforts     to increase    load fac-
               tors since the fuel crisis     of 1973.      GAO found
               that:
               --The Civil            Aeronautics    Board,  the Federal
                  regulator           of U.S. airlines,     cannot require
                  airlines'           compliance    with minimum load fac-
                  tors as a           means of improving     fuel efficiency.
               --Board    efforts          to reduce domestic     flight
                  frequencies,            which can increase    load factors,
                  were canceled            as a result   of court     action.
               --Federal     Energy Administration      fuel alloca-
                  tions   to the aviation     industry    in 1974,
                  successful     in reducing    the number of airline
                  flights    and increasing     load factors,    have
                  since been relaxed.
               Proponents    of regulatory      reform   claim that
               improved   regulation     of the aviation       industry
               could increase      load factors      to 60 percent      or
               higher   and save as much as 300 million            gal-
               lons of fuel annually.         Several    bills    were



JP=V S&e&    Upon removal,   the report
cover date should be noted   hereon.             i                       CED-77-98
introduced       in the 94th             Congress,     and    this
matter     is   being  further            evaluated     by    the    95th
Congress.         (See p. 6.)

The Federal          Aviation       Administration           (Agency)       ,
which     controls        the Nation’s          airways      through
its   air    traffic        control       system,     reported       to
the Congress           that    its    fuel     conservation        pro-
grams would          reduce      aviation       fuel    consumption
by more than           1.2 million         gallons       a day.

However,      the Agency          had no assurance          that     its
fuel    conservation           procedures      were effective
in achieving          about      800,000   gallons      of these
estimated       savings.          It had neither        monitored
program      implementation            nor required       reports
on program        use.       In several      instances,         the
fuel    conservation           procedures      were (1)       infre-
quently      used,       (2) impractical         to implement,
or (3)     ineffective.’

Since      the remaining         fuel  savings--over        400,000
gallons       a day-- were attributable             to fuel
conservation          procedures      beyond     the Agency’s
regulatory        control,       it is questionable         whether
they    should      have been included           in its   conser-
vation       accomplishments.           (See p. 15.)

In 1975 nearly          400 million            gallons      of fuel      at
a cost     of over      $110 million            were wasted          be-
cause    of delays        in airline           operations.           Rather
than getting        better,       airline          delays      increased
from about        400,000     hours         in 1969 to 500,000
hours    in 1975 although              airline        operations
decreased.         The Agency          has several           procedures
and is developing           others          to reduce        delays,     but
to date      these    procedures           have been ineffective.
 (See p. 24.)
To minimize        the effects            of extensive       delays
on fuel     consumption,            the Agency        is developing
a landing      delay      notification           system    at Chicago’s
O’Hare    International             Airport.         Tests   indicate
that   it can save fuel,                but considerably          more
fuel   could     be saved         if all     aircraft      were re-
quired    to take       ground        rather     than airborne
delays    when possible.                (See pp. 28 and 44.)




                                    ii
             The Agency's   concern    for reducing  delays  at
             major airports   led to a task force study of
             delay causes at O'Hare.       The study determined
             that annual delays     there
             --were    significant        (93,000       hours);
             --cost    the   airlines      $44.3    million;
             --consumed      67 million       gallons       of fuel;    and
             --resulted     from a series  of factors,  many of
                 which are controllable,     such as the number
                 of flights    that can be handled.

             The study outlined     a comprehensive    program of
             delay reduction    which,  if implemented,      can
             reduce delay costs by as much as $34 million.
             A second task force          is following         up on the
             study's      recommendations.          Studies       have been
             initiated       at seven other major airports;                 how-
             ever, the Agency has no definitive                     plans to
             expand these studies.             Instead       it is developing
             additional        in-house   capabilities          that will
             permit     it to perform       other needed studies              at
             reduced cost.           GAO believes      that,      although
             this effort         to reduce cost has merit,              addition-
             al benefits         might be realized        by performing
             such studies          now at other major airports.
             (See Pp. 29 and 44.)
             One of the Agency's       regional     offices      developed
             procedures     for metering     and spacing        arriving
             aircraft,    which can save up to 170 million
             gallons    of fuel annually.        The Agency did not
             act on these procedures         for 2 years.           Progress
             is now being made to implement             similar      pro-
             cedures    at major airports,       but nationwide
             implementation     is still     not a reality.            (See
             p. 33.)
             The Agency's      efforts  to abate noise,       a res-
             ponsibility     it shares with the Environmental
             Protection     Agency, can also conserve         fuel,
             but conflicts      with fuel conservation        efforts
             have occurred       at some airports.     Airline
             proposals     which would save 3 million         gallons
             of fuel at one airport       were rejected       by the



Tear Sheet                                   iii
Agency     or were implemented             slowly      because      of
noise     considerations.              As a result,       more than
3 million       gallons       of fuel     were wasted.           Noise
abatement       procedures         at other     airports       also
increased       fuel      consumption.

Both aircraft          noise     and fuel     conservation        are
national      issues,       but the Agency         has neither
developed       nor explored         the feasibility        of
establishing         program      guidance      for evaluating
trade-offs       between       the two when conflicts
occur.       GAO   believes       that   neither      issue    should
be treated       lightly       or given      precedence      without
evaluating       the trade-off          between      each.     (See
PP* 35 and 44.)

GAO believes       more attention          to aviation        fuel
conservation       is needed        and it recommends           that
the Congress       establish        higher    airline      load
factors      as one of its major           objectives        and pro-
vide    the Board with        legislative         guidance
for    achieving     this    objective.         (See p. 45.)

GAO also       recommends      that     the Secretary        of
Transportation         direct      the Federal      Aviation
Administration         to give       greater   attention        to
fuel    conservation        by

--establishing            a monitoring       and reporting
    system      to provide        management      with   informa-
    tion     on the effectiveness            of aviation       fuel
    conservation          procedures,      the frequency
   with      which    these     procedures      are used,      and
    the fuel       saved;

--requiring        aircraft     to take ground      delays,
    when possible,          when excessive   delays      are
    being   incurred        at a destination    airport;
    and

--exploring          the feasibility          of establishing
    program      guidance      to evaluate       trade-offs
    between      noise    abatement      and fuel       conserva-
    tion    objectives       when conflicts          occur     and,
    if feasible,        provide      such guidance          to its
    field    offices,      after     consulting       with     the
    Environmental         Protection       Agency.        (See
   p. 45.)




                                  iv
                                                                                       .


             AGENCY           COMMENTS AND OUR EVALUATION
             --I-------------------------------
             The Civil         Aeronautics         Board     stated       that      the
             Federal       Aviation        Act of 1958 precludes                  it from
             requiring         compliance        with    its     standard        or any
             mimimum       load factor.            It also       stated       that
             studies       cited      in the report,           which     argue        for
             higher      load     factors,       were theoretically                 designed
             and considered             the airline        system       as a collec-
             tion     of mutually          exclusive       routes       between         two
             cities.

             GAO recogniies            that      the studies           arguing      for
             higher      load     factors       are theoretical,               although
             they    were based on actual                     experiences        of less
             regulated        intrastate           airlines.           However,       GAO
             believes       the final         outcome          of deregulation
             and higher         load     factors         will     continue       to
             remain      theory      without         an actual         test    or
             experiment.

             The Federal         Energy      Administration             stated       that
             GAO’s conclusions             regarding         higher       load     factors
             and the need to give               greater        attention         to
             fuel     conservation         appeared        similar        to its
             views.       However,       it believed           the report          lacked
             sufficient         detail     and depth         to allow        the
             Congress       or the Secretary             of Transportation
             to act and did not fully                  address         agencies’
             responsiveness            to certain        provisions          of the
             Energy      Policy      and Conservation             Act.

             GAO      has     revised      the report       to reflect        addi-
             tional         information       called     to its      attention
             and      believes        the report      is in sufficient              de-
             tail       and depth        to prompt      action.        The matters
             not      fully      addressed     were outside          the scope
             and      timing       of GAO’s review.

             The      Federal      Aviation         Administration          stated
             that

             --the      establishment             of a monitoring            and     re-
                 porting       system         for   its   fuel     conservation
                 procedures         was       beyond    its    role    in fuel
                 conservation,

             --it       had no basis     to dictate              to   the   airlines
                    where  delays   will   be taken,




Tear Sheet
                                                    V
--GAO’s      discussion        on the inefficiency              of the
   air   traffic       control     system   ignored          several
   important       factors      and accomplishments,               and

--it       recognized       the need to study           noise   abate-
       ment/fuel      conservation        trade-offs        as evi-
       denced    by actions        it already        had underway.

GAO continues        to believe        that    the Agency            should
establish      a monitoring        and reporting             system
for    its  fuel    conservation         programs,         that      the
agency     has sufficient        tools      to require          airlines
to take     ground     delays,     and that        efficiency            of
the system       has deteriorated.

The Environmental              Protection        Agency    concurred
with   the recommendations                 and indicated       that
the Federal          Aviation       Administration         should
more fully         investigate          the use of auxiliary
power     (towing)        to move aircraft           on the ground
for   both     noise      abatement        and fuel     conservation,




                                   vi
                            Contents
                            --m-c------
                                                                Page
                                                                ---
DIGEST                                                            i

CHAPTER
   I      INTRODUCTION                                            1
              Federal  initiatives     to conserve    fuel        1
              FAA                                                 3    '
              CAB                                                 4
              Airline  efforts     to conserve   fuel             5
              Scope of review                                     5

   2      INCREASED LOAD FACTORS COULD SAVE MILLIONS
            OF GALLONS                                            6
              Effects    of load factors         on fuel
                 consumption                                      6
              CAB's standard         load factor                  8
              Capacity     limitation     agreements              9
              Fuel allocations                                   11
              Regulatory      reform of the airlines             12

   3      FAA's FUEL CONSERVATION PROGRAMS: ARE
            THEY WORKING?                                        15
               Reported      accomplishments                     15
               Program implementation           and actual
                  accomplishments        are unknown             16
                     Gate-hold     procedures                    17
                     Flow-control      procedures                18
                     ATC procedures                              20
                     Simulators                                  21
                     Optimum descent        landings             21
                     Lateral     spacing                         22
               Programs beyond FAA's control                     23

   4      FAA PROGRAMS HAVE NOT EFFECTIVELY DEALT
            WITH A MAJOR CAUSE OF FUEL CONSUMPTION
            PROBLEMS: AIRPORT CONGESTION AND DELAYS              24
              Increased     inefficiency        in the ATC
                 system                                          24
              Effect     of delays on fuel consumption           26
              FAA efforts      to reduce delays                  26
                     Quotas at O'Hare                            27
                     Fuel advisory       departure    program    28
                     Delay task force studies                    29
CHAPTER
       5   FAA DELAYEDIMPLEMENTINGFUEL CONSERVATION
             PROCEDURES   THAT COULDSAVE MILLIONS OF
             GALLONS                                                     33
               Delays in nationwide   implementation
                 of locally  developed fuel efficient
                 procedures                                              33
       6   FUEL CONSERVATIONOR NOISE ABATEMENT                           35
               Noise abatement and FAA responsibilities                  35
               Effects of FAA noise abatement actions
                  on fuel consumption                                    37
       7   CONCLUSIONS,RECOMMENDATIONS,  AGENCY
             COMMENTS,AND OUR EVALUATION                                 43
               Conclusions                                               43
               Recommendation to the Congress                            45
               Recommendations to the Secretary of
                 Transportation                                          45
               Agency comments and our evaluation                        45
                   CAB                                                   45
                         FEA                                             46
                         FAA                                             48
                         EPA                                             51
APPENDIX
       I   Airports   designated by FAA for            initial
              implementation    of a metering          and spacing
              program                                                    53
  II       Letter dated May 5, 1977, from the Acting
             Chairman, Civil Aeronautics Board                           54
 III       Letter dated April 20, 1977, from the Admin-
              istrator, Federal Energy Administration                    56
  IV       Letter dated May 13, 1977, from the Acting
             Assistant  Secretary for Administration,
             Department of Transportation                                60
       V   Letter dated May 18, 1977, from the Acting
             Assistant Administrator   for Planning and
             Management, Environmental    Protection Agency              64
  VI       Principal       officials     responsible    for admin-
              istering      activities     discussed    in this report   65
                                     ABBREVIATIONS
                                     -----w------I
ATA   Air Transport                Association        of America
ATC   air     traffic         control
CAB   Civil      Aeronautics             Board
EPA   Environmental                Protection        Agency
FAA   Federal           Aviation        Administration
FAD   Fuel     Advisory            Departure       Program
FEA   Federal           Energy      Administration
GAO   General       Accounting            Office
                                                                                  ,



                                                 CHAPTER
                                                 ---------   1

                                              INTRODUCTION
                                              ------------
        Aircraft        are important        to the U.S.        transportation
system      as long-distance          carriers       of people        and high-value
goods.       Speedy       and convenient,        air    transportation         has become
a popular        choice      over other      modes for       medium and even short
distances.

           In1976 U.S.         airlines      used an estimated       9.5 billion                   I
gallons      of fuel       to transport         223 million    passengers.         While
automobiles         consume         the largest     amount   of energy     (59 percent)
used for       transportation,            the airlines      use the second       largest
amount     (10 percent),              or about   3.5 percent    of total      U.S.    oil
consumption.

FEDERAL INITIATIVES
----------------------a-------------     TO CONSERVE FUEL

        In a special           message      to the Congress            on Energy          Policy
on April       18, 1973,        the President           said     that    all     levels      of
government        must provide           leadership         in energy        conservation.
Two months         later      he launched        a drive       to reduce         expected
U.S.    energy       consumption         by 5 percent          and directed           the
Federal     Government          to reduce        its    anticipated          consumption
by 7 percent           in 1 year.          He also      directed       the Department
of Transportation’s                Federal     Aviation        Administration             (FAA)
and the Civil            Aeronautics        Board     (CAB) to work with                the Na-
tion’s     airlines         to conserve        fuel     by reducing          flight       speed
and frequency.

        As the 1973 energy            crisis      heightened,     the Federal        Gov-
ernment     was forced        to allocate         fuel    among petroleum       users,
including      the transportation              modes.      In June 1974 the Fed-
eral    Energy    Administration             (FEA) was established         pursuant
to the Federal        Energy       Administration          Act of 1974 (15 U.S.C.
761) to insure        that      energy      shortages      were borne     with   equity
and priority       needs were met.

        The Energy      Policy     and Conservation          Act of December      22,
1975 (42 U.S.C.         6201),     established        new policies      for Govern-
ment agencies       for    conserving        domestic     energy   supplies    and
using    energy   resources        more efficiently.            The act set energy
conservation      targets       for broad      categories       of industry    and
all   forms    of transportation.

        To determine                   the progress      made    by FAA, CAB, and other
specified     Federal                  agencies,    section      382(a)  of the act re-
quired    them to
          I’*  *  *   report    to the Congress within     60 days
          after     the date of enactment      of this Act with
          respect       to energy conservation    policies     and
          practices       which such agencies    have instituted
          subsequent         to October 1973.”              I

        Section    382(a) also directed        each specified    agency to
report     to the Congress within          120 days of enactment      on the
content      and feasibility      of their    proposed  programs    for
additional      savings      in energy consumption.       The goal of
these proposals        was to reduce energy consumption          in the
first    year by at least        10 percent    of 1972 consumption.
        In addition,    section               382(a) of the act required    each
specified      agency to report                to the Congress within    1 year
after     enactment  on
          ‘I* * * any requirement        of any law * * * or any
          major regulatory     action      which the agency deter-
          mines has the effect        of requiring,        permitting
          or inducing    the inefficient        use of petroleum
          products,   coal,  natural       gas, electricity,          and
          other forms of energy,         together    with a state-
          ment of the need, purpose,           or justification
          of any such requirement          or such action,         * * *‘I
      The fuel crisis       left   a lasting    impression    by increasing
the price    of aircraft      fuel by more than 150 percent.           Fuel
now accounts     for about 19 percent        of the operating      cost of
an aircraft    compared to 12 percent         in 1973.     The following
table   shows this     fuel cost increase       in comparision     to air-
line operations      (take-offs     and landings)     and fuel consump-
tion.
                  Total       number of                                          Average
              airline         operations--          Fuel       consumed   by        cost
Year
-a--        take-offs
            --------------------and landings -               airlines
                                                             --v-v---           per
                                                                                 e-w gallon
                                                                                      B-B--
                        (millions)               (billions        of gallons)    (cents)
1972                        9.7                                 10.0             g/11.6
1973                        9.9                                 10.4                12.8
                                                                 9.3                24.3
1975
1974                        i-2                                  9.2                29.2
1976                        9:6                               b/4.7              b/31.3
a/Second         half     of year     only.
b/First         half     of year     only.
FAA

         FAA was established              in 1958 to (1) regulate               air commerce
to foster     aviation         safety,        (2) promote     civil      aviation     and
a national      system       of airports,           (3) achieve      efficient      use of
navigable     airspace,         and (4) develop           and operate          a common
system     of air    traffic        control       and air    navigation         for both
civilian     and military           aircraft.

         To provide          for   the safe      and efficient         use of the navi-
gable      airspace,         FAA operates        an air    traffic      control     (ATC)         I
system,        a network         of 451 air      traffic     control      towers,    25 air
route      traffic        control      centers,      and over      300 flight     service
stations.            ATC is the one area where               FAA can contribute
significantly             toward     fuel    conservation.           As one airline
official          stated:

        “Once an airplane         departs,         and is in the oper-
        ating   phase of flight,            he   (the    pilot)       is at the
        mercy   of ATC.        He is    obligated        to     operate      on
        routes    and altitudes         dictated       by ATC.          This
        brings    up some very         important       questions.            Is
        ATC routing      aircraft       along      the most efficient
        route   and altitude        available?           Is ATC making
        the most efficient           use of all        airspace         available?
        Is * * * [a] circuitous               route    necessary         to safe
        and efficient        movement       of traffic?”

        In response      to the President’s          1973 fuel       conservation
program,       FAA announced     a seven-point         fuel    conservation
program      in November     1973,     which     was to be implemented            within
90 days.        In June 1974 the Administrator               of FAA also        adopted
an intermediate        program     for    aviation     fuel    conservation,
which     was to be implemented           during    1974-76.        (See ch. 3.)

        In addition,         FAA is looking      for    long-term           jet   fuel     con-
servation     actions.         Long-term      FAA alternatives              to save      fuel
consist    primarily         of technological        options      for       improving       the
ATC system.

       FAA also     is developing            a Fuel Advisory       Departure      Pro-
gram to reduce        aircraft-engine-running                time.    This   program
is designed      to conserve          fuel    by calculating       and assigning
an aircraft      departure         clearance      time    based on projected
delays     at the destination            airport.

      All  of the above FAA efforts         were included      in FAA’s Feb-
ruary  1976 report      to the Congress     pursuant   to section      382(a)
of the Energy    Policy    and Conservation       Act.   FAA’s    second




                                                3
report   to the Congress      in April      1976 described    actions
already    underway and options        available    to FAA for increasing
aviation    fuel efficiency.      FAA’s third       and final    report  on
the energy efficiency        of agency regulations         was submitted
to the Congress      in December 1976.
CAB
        CAB, an independent             regulatory       commission,       has broad
authority      to promote and regulate                domestic      and international
operations       of the U.S. civil            air transport         industry.      CAB
authorizes       (certificates)           U.S. airlines         to engage in inter-
state     and foreign        commerce and determines              the legality
(including       increases)         of air cargo rates and air passenger
fares.      It approves         or disapproves          proposed      mergers,    acguisi-
tions     of control,        interlocking        relationships,         and agreements
between airlines           considering        the interest        of travelers,
shippers,      and other airlines             which may be adversely            affected.
It also grants          subsidies       to airlines        to finance       air trans-
portation      to the Nation’s            small communities           which would
otherwise      be without         such services.
       In October    1973 CAB authorized        U.S. airlines    to discuss
flight   frequency    reductions      to conserve    fuel.    Subsequently
CAB approved     agreements      that resulted     in reduced flights
between 64 city pairs.
        In November 1973 CAB relaxed                   the requirement            that local-
service      airlines      provide       two daily       round trips         to inter-
mediate      stops on assigned             routes.       Thus, the airlines            were
permitted        to reduce service            at all intermediate              points   to
one round trip         5 days a week.              This reduced service,              however,
was based on a proposed                fuel reduction           which did not take
place and, except            in a few markets,             service      was not reduced.
In December 1973 CAB also authorized                        airlines       to suspend
service      temporarily--       until       June 1976--at         certain      points    in
their     route systems.
         In January     1975 CAB approved    a joint    application       of
two U.S. airlines         for a temporary    exchange of portions          of
their     Pacific     and transatlantic   route systems,        thereby    re-
ducing     their    fuel consumption.     A similar     agreement      covering
Pacific,      Car ibbean,    and Bermuda routes      was approved       in July
1975.
      These CAB energy-saving       policies  and practices   insti-
tuted   since October     1973 were reported   to the Congress      in
February    1976 pursuant     to the Energy Policy   and Conservation
Act.    CAB’s second report      to the Congress   in April 1976



                                              4
described     future    prospects      for improving    fuel efficiency
under then existing         conditions.      CAB submitted        its third
and final     report    to the Congress      in February       1977 on the
requirements       of law or major regulatory          actions      which re-
quire,    permit,    or induce inefficient         fuel use.
AIRLINE        EFFORTS TO CONSERVE FUEL
           Officials    of five major airlines     and three regional
airlines          told us that they had programs      to conserve  aviation
fuel.         These programs    included  such things    as                                             ,

           --use       of computerized          flight      plans;
           --use of optimum           altitude,          speeds,      routes,      climbs,        and
              descents;
           --recalculating           aircraft        fuel    loads;
           --turning         off   unneeded       engines     while      taxiing      aircraft;
               and
           --maximum         use of flight         simulators.
SCOPE OF REVIEW
       We evaluated    (1) CAB and FAA fuel conservation                                efforts
on the airlines'      daily   operations    and (2) the fuel                           conser-
vation   effects    of increasing      load factors.
       We reviewed      CAB and FAA energy policies,               practices,
and procedures;       interviewed       their  officials;         and reviewed
their    records.     We also interviewed          officials       and obtained
records     from various      airlines     and airline        associations.
Our review was made at FAA and CAB headquarters                        in Washing-
ton; FAA's Southern,          Southwestern,     Great Lakes, Central
Rocky Mountain,       Western,       and Northwest       regions;      and at
selected      FAA-ATC facilities.




                                                     5
                                   CHAPTER 2
                         INCREASED LOAD FACTORS
                    COULD SAVE MILLIONS        OF GALLONS
       Load factor--  the ratio    of occupied     seats to available
seats-- is an effective     method of measuring        airline     efficiency.
In 1976 U.S. airlines     achieved     an industrywide        passenger      load
factor    of about 55 percent,     with 45 percent      empty seats.
The airlines     used an estimated     4.2 billion     gallons     to trans-
port these empty seats,       or enough fuel to fly a Boeing 727
more than 1.2 billion     miles.
      Since low load factors         result   when flight    frequency
is greater      than passenger    demand, higher      load factors     would
necessitate       reduced flight   frequency,     which could save mil-
lions    of gallons     annually,    Neither   the airlines     nor the
Federal     Government    have made major efforts        to address this
major waste of fuel since the fuel crisis               of 1973 to 1974.
We found that:
      --CAB cannot require  airlines’           compliance     with minimum
         load factors as a means of           improving    fuel efficiency.
       --CAB efforts     in 1973 to reduce domestic  flight             fre-
          quencies   were canceled  as a result  of court            action.
       --FEA fuel allocations       to the     aviation   industry in
          1974, successful     in reducing      number of airline    flights
          and increasing    load factors,       have since been relaxed,
      Proponents   of regulatory      reform of the aviation        industry
claim that improved     regulation      could increase      load factors
to 60 percent    or higher,     saving as much as 300 million           gal-
lons of fuel annually.        Several    bills    were introduced     in
the 94th Congress,     and this matter         is being further    evaluated
by the 95th Congress.
EFFECTS OF LOAD FACTORS ON FUEL CONSUMPTION
      In 1976 U.S. airlines       made about 4.8 million       flights
with a seating     capacity   of about 400 million.      With an
average load factor       of about 55 percent    for that year,        about
180 million    seats (the equivalent      of 2.1 million    flights)
were empty.     We estimated    that over 4.2 billion     gallons
of fuel were used to transport        these empty seats,      enough
fuel to fly a Boeing 727 more than 1.2 billion           miles.




                                       6
        The low use of aircraft            is illustrated          by operations
 at Chicago’s     O’Hare International             Airport.       At yearend
 1975 there was an average of 550 flights                      scheduled        daily,                        I
 6 days a week, between Chicago and 11 other                       cities.         Based
 on the load factors       for these flights,               47 percent        (the
 equivalent     of 261 daily      flights)       were flown        empty.        We
 estimated    that over 300 million             gallons      of fuel were used
 annually   just   to transport        empty seats.           Between Chicago
 and Los Angeles,      for example,          there were 97 flights               daily.
 The load factor      averaged       47 percent;        the equivalent           of
 51 of the 97 flights,        or an average of 2 planes                    each hour,
 were flown empty.        Details      on each of the 11 markets                   follow.
             1975 Fuel
             ----------------    Consumption
                                         ---e------for       Equivalent
                                                               -----------      Empty
                                                                                   -
          Planes
          ---------    Flying
                            --      Between
                                  --------------   Chicago ----------------
                                                               and Other            Cities

                                                                   -Equivalent
                                                                      -----------       em ty planes
                                                                                                 --a--
                                   Total       Load factor                              Gaf 10;s
                                   daily         percent           Number               consumed
                                 fliqhts
                                 --     ---     (note
                                                 --w--w a)         daily
                                                                   ----                 annually
                                                                                        -------
                                                                                (000,000           omitted)
Los Angeles                         97                  47             51                     95
Atlanta                             57                  49             28                     18
Seattle                             25                  49             12                     22
Dallas-Ft.     Worth                49                  48             25                     21
Boston                              39                  43             22                     21
New York (Kennedy)                  22                  49             11                      9
Washington,     D.C.
    (National)                      61                  59             25                     16
San Francisco                       56                  53             26                     52
Denver                              41                  51             20                     19
Philadelphia                        27                  57             11                      8
New York (La
   Guardia)                         76
                                  e-m                   60             30
                                                                     -we                      24
                                                                                             Be-
     Total                        550                                --261                   305
                                                                                             -Be
 a/Rounded        to the        nearest       percent.
         The low load factors    in the flights    between Chicago
 and the above cities      are attributable     to the high number                                     of
 flights    provided versus demand.
        Reduced flight    frequencies     or use of smaller      aircraft
 would yield   higher   load factors.         Fewer flights   also would
 help to reduce congestion         at airports,    a major cause of
 landing   and take-off     delays    and the associated    fuel waste.
  (See p. 24.)

                                                    7
CAB’S      STANDARD LOAD FACTOR
----------1---1-----------
        In 1971 CAB established         a 55-percent   load factor        for
use in setting        fares and approving      fare increase     for domes-
tic trunk airline         l/ operations    in the continental        United
States.     CAB, howeyer,      does not have statutory        authority
to require     airlines’     compliance    with its standard       load
factor.
       The domestic      trunk airl,ines    first     achieved    the 55-
percent     standard    on an industrywide        basis    in 1974, 3 years
after    establishment.        If they had been required          to comply
with this      standard    from the start,      they could have saved
about 756 million        gallons    of fuel in 1972 and 1973, as
follows.
                                                                Estimated       gallons
                                              Actual               saved with a
                                              airline               55-percent
                          Year
                          -w-B            -----------factor
                                          load                      load factor
                                                                    -----------
                                            (percent)            (000,000      omitted)
                          1972                     52.4                     337
                          1973                     51.9                     419
                                                                            W-B
                                 Total                                      756
                                                                            m-w
            Since 1969 the               data-base   period  CAB used in establishing
the       55-percent      load           factor,   two major events have altered
air       transportation:
            --The introduction                    and rapid  integration      of wide-body,
               three and four               jet     engine aircraft      into the airlines’
               fleet.
            --Burgeoning              fuel prices          following     the Arab oil embargo
               of early             1973 and the          concomitant      need for fuel con-
               servation..
The price     of aviation  fuel,    remarkably stable      at about 11
cents a gallon      in 1971 and 1972, had more than doubled by
1974 and has continued       to rise since then.        (See p. 2.)
Concurrently,     more seats on U.S. airline      flights     became

-----------------------

&/Trunk   airlines include    the largest                           airlines       and provide
   most of the domestic    air service.




                                                          8
available        as wide-body          jets, such as the B-747,                   DC-10
and L-1011        aircraft,         were added to the arlines’                    fleet.

         According         to CAB, past         increases        in airline         costs,      in-
cluding      fuel,       were charged        to the public           through        higher
fares--     coach      fares     have increased           about     26 percent         since
1969--and        if-fuel        prices   continue         to rise,       this     will     provide
impetus      for      even higher      fares.         This     conversion         of increased
costs     to fares         decreases     traffic.           Accordingly,          the balance
between       supply       and demand will           be continually           altered,
resulting        in more empty         seats.

        An alternative            to higher       fares    is to absorb        these    costs
through    more efficient             operations--higher           load    factors.
But this,      just    as higher         fares,       has an implied       cost     to the
consumer.        Fewer flights           and seats       would    be available         and
the consumer’s         ability        to move at the most desired                 time    on
the most desired           flight       would     be limited.        Thus,     whether
through    higher      fares        or less     service,      the consumer        will    bear
the burden.

         In its       April      1976 report          pursuant       to the Energy           Policy
and Conservation               Act,    CAB stated           that    because      of the rise
in fuel        prices       and the national              program      aimed at fuel          con-
servat     ion s it is reviewing                 its    standard       load    factor      to
determine          whether       a higher        standard        should     be established
for    ratemaking           purposes.           The table        below     shows our estimate
of the fuel           savings       that     could      have been realized              in 1976
had the domestic               trunk     airlines         operated       at load      factors
higher       than     the achieved            load    factor      of 55.8 percent.

                                              Estimated    1976 gallons      saved
                   Load    factor              from higher     load  factors

                     (percent)                          (000,000       omitted)

                           60                                         479
                           65                                         968
                           70                                      1,387
                           75                                      1,751

CAPACITY       LIMITATION           AGREEMENTS

        Beginning       October       1973 CAB authorized                  U.S. airlines
to discuss        reduced      flight      frequencies           to conserve         fuel.
These discussions            resulted        in capacity           limitation        agree-
ments     between     9 airlines         providing         for     a reduced      number     of
flights      between      38 city      pairs.         Similar        agreements        to reduce
flights      between      26 U.S.      and foreign           cities        were entered
into    by 10 U.S.        and foreign          airlines.



                                                    9
       CAB's report    to the Congress,      pursuant    to the Energy
Policy   and Conservation      Act (see p. 4), stated         that these
agreements   saved about 260 and 140 million           gallons     annually
in domestic    and international      service,    respectively.
          The Department        of Justice           filed      petitions           with the
U.S. Court of Appeals                for a review of CAB's July 1974 order
renewing       certain      capacity        limitation           agreements.              In United
States      v. CAB, 511 F.2d 1315 (1975),                        the Court ruled Ehat-
xs=gh          emergencies         (fuel      shortages)           justified           CAB's
approval       of capacity        limitation            agreements           in October          1973,
the conditions           no longer        existed        at the time of its July
1974 order;         therefore,         the order had to be set aside.                              The
ruling      stated     that CAB's approval                 of voluntary              anticompeti-
tive agreements,            which confer           an immunity             against        antitrust
liability,        must rest on a justification                        of serious            trans-
portation        need or important              public       benefits,           with need for
CAB to show an appropriate                    factual        predicate.              The Court
stated      that the record            in this case presented                     little        more
than speculation            under emergency conditions                         that competitive
market response            would waste energy.                   Also it stated               that
there was no subsequent                  procedure,          either        for a hearing            or
an experiment          in certain         markets,          and no system for testing
or opportunity           to examine CAB's assumptions                          as to the
consequence         of the competititve                 alternative.
        After    this decision,     CAB terminated         agreements    covering
domestic      services.     A CAB official         told us that CAB had
continued      to approve capacity       limitation        discussions     and
agreements       for international      services       but that as of May 1977
there had been no such agreements                in effect     or discussion
authority      outstanding      for about the last         6 months.
        Urban Systems Research and Engineering,                     in a study l/
made for FEA, pointed             out that a strong        case could be maae
that capacity       limitation        (frequency     reduction)        agreements
were not consistent            with CAB's existing         legislation        to pro-
mote competition.            The study stated        that competition           in a
city-pair     market      is inherently        unworkable     in an environment
with fixed     prices       where the airlines         must all provide           equal
capacity     and comparable          service    at peak hours,         or suffer
a competitive       disadvantage.            The study concluded          that too
many flights      are scheduled          at peak hours and the introduction


L/Conservation            Paper Number 48, "Baseline                      Energy Forecasts
   and Analysis           of Alternative      Strategies                for Airline   Fuel
   Conservation,"           Office     of Transportation                  Programs,  FEA.



                                                  10
of wide-body            jets        by one     airline       has forced         others        to    follow
suit,   resulting              in     excess     capacity       in many        markets.

         In addition,       the study     discussed                  other    changes      in the
industry      structure       that  could     achieve                reduced     capacity,
namely     pooling      agreements,      alterations                   in CAB route        awards,
mergersp      and Government        control       over              schedules      and routes.

FUEL-ALLOCATIONS
-1-e----
          Because       of emergency           fuel      shortages        during        the 1973
energy       crisis,       FEA and its           predecessors           l/ allocated            fuel
between        the various          transportation              modes-and         other      users      of
petroleum.             Under     the mandatory             aviation       fuel      allocations
initiated          between       November        1, 1973,         and May 6, 1974,              the
airlines         were to receive             each month           95 to 100 percent               of
the fuel         they     used in the same month of 1972 (base                               level),
provided         suppliers         had sufficient             fuel     available.            An FEA
official         told     us that       because        of fuel       shortages          from
November         1973 through           March      1974,      suppliers        generally          did
not have enough              fuel     to meet the airlines’                  base levels;
therefore,           the airlines          received          only    a prorated           share      of
the base.            This prorated           share       ranged      from 70 to 75 percent
of base levels             between        November         and December           1973 and from
75 to 95 percent               of base between               January      and March          1974.
As the crisis             eased,      allocation           levels      were relaxed.
According          to FEA almost           all    airlines          were receiving             100
percent        of base by May 1974.

         During      the fuel             crisis       the airlines          curtailed          service,
reducing        the number             of flights          on an average            day by about
 1,200.        With     fewer       flights,           load factors          averaged         56 percent
between        November         1973 and March 1974 compared                           to 50 percent
during       the same period                  in 1972 and 1973.                As the crisis
eased,      load      factors          just      about     returned        to their         precrisis
level,       49 percent           for       the period         November        1974 to March             1975.
Although         fewer      flights           undoubtedly          accounted         for    higher
load     factors        during          the crisis,          other     factors         also     contrib-
uted.       For example,               an official           from the Air            Transport
Association           (ATA) told              us that      because       of gasoline            shortages
during      the crisis,             more people            used the airlines                rather
than the automobile                     for     shorthaul        transportation,              then
returned        to the automobile                    after     the crisis         eased.



l/Fuel      allocations            were initiated     on November   1, 1973,     by
- the      Off ice of          Oil and Gas, Department       of the Inter   ior,
    and    continued           by the Federal     Energy  Off ice and FEA.




                                                     11
         The Urban       Systems        Research         and Engineering                study
(see p. 10) stated              that     fuel     allocations             are probably              the
most direct         method      of conserving             airline         fuel      and that          the
allocations         established          to handle           the 1973 energy               crisis
showed      that    allocations          could       effectively            reduce        aircraft
fuel     use without         severely       limiting           the ability            to travel
by air.        The study        indicated          that      allocations            that      limit
the growth        of airline          fuel     use could          significantly               reduce
forecasted        fuel     consumption           (baseline)           for    domestic           passenger
service       and increase          load     factors.            Details        follow.

     Rate of growth
allowed            in airline                           Fuel use
                                         ---i~86’------iV4a’-’                      Load factor
                                                                                   msn--‘-igB5
  fuel        utilization
  --------------a-                             -B-w               -w--             --a-               ----




                                          (billions        of   gallons)                  (percent)

Baseline                                       9.88               16.31             55.1                55.6
3.5 percent            per      annum          8.96               12.64             60.5                71.2
2.4 percent            per      annum          8.23               10.47             65.7                86.0

          The study         also    stated      that     if fuel      allocations           are used
to reduce          future      consumption,           it might      be useful          to remove
some restrictions                on airline         service      to allow        airlines         full
flexibility            and inventiveness              in using      their      allocations.
For example,            greater       freedom       to unilaterally            curtail        service
could       create      more opportunities               for   fuel     conservation.
Alternatively,              the fuel       allocation        regulations           could      mandate
capacity         reduction        discussions           among carriers           on routes
where       average       load    factors       are below        some specified             level.

        As an alternative,                  the study         indicated          that      increases
in fuel       pr,ices,        either      directly         or by additional                Federal
fuel     taxes,        could      in principle           achieve       fuel      reductions
comparable           to those        implied        by fuel       guotas       (allocations).
The study          indicated         that     these      fuel     reductions           would      be
possible        even if increased                 prices      or taxes         were passed           on
to passengers              in higher        fares,       provided        airline        capacity
were reduced             to compensate            for    the reduced           demand resulting
from higher            fares.        The study         also     discusses          other      alterna-
tives,      such as regulation                  of the overall             fare      level      and fare
discrimination.

REGULATORY REFORM OF THE AIRLINES
--wemm---------------------------
        Several     studies        on the effects        of              relaxed      CAB controls
over    the airline         industry     indicate      that                this   action   might
increase      load    factors        to 60 percent       or              higher.       If accom-
plished     by a net reduction             in flights,                   fuel    savings   could




                                                      12
result.      If accomplished            by increased         passenger        demand,    in-
duced by lower         fares,      fuel     use on a passenger             basis   would
be lower,      thus    optimizing         airline    fuel     efficiency.          Several
bills   that     would     reform      Federal    regulation          of the airline         in-
dustry    were introduced            in the 94th Congress,                and this    matter
is being     further       evaluated       by the 95th Congress.

          Dr. Thoedore              E. Keeler,        in a 1972 study            on “Airline
Regulation           and Market          Performance,”           assumed       that     in the
long      run the removal              of CAB’s regulatory                 powers     over     airline
 industry         entry,        exit,    and fares        would      result      in improved
airline        efficiencies,             including        a load       factor      of about         60
percent         in high-density              markets.        Dr. Keeler          applied       these
efficiencies             to 30 high-density               routes       served      nonstop       by
CAB-regulated              airlines.           He found      that      published        air    fares
for     these      routes        were 20 to 95 percent                 higher      than     the fares
that      might      have existed            in the long         run had the assumed
efficiencies             been achieved             on these       routes      by the airlines
in a fully           competitive           airline      industry.

        Our report            l/ on Dr. Keeler’s                   results         stated        that     his
assumption         that       unregulated            airlines          could       achieve          a 60-
percent      load      factor        in high-density                 markets         was reasonable
based on average                load      factors         achieved         by certain            less
regulated        intrastate             airlines          and by trunk             airlines            in the
decade     before        their       substantial             use of jet            aircraft.             How-
ever,     we expanded             and modified              Dr. Keeler’s             study        in several
respects.          For example,               our study          included          markets          of
various      densities,            distances,             lengths,         and load          factors.
To approximate              load     factor        variations,             we assumed            the air-       -
lines     would      achieve         an industrywide                 load      factor        of 60 percent,
but varied         the load          factor        by trip         length        in the same pro-
portion      as actually             occurred          during        each year            analyzed,
1969-74.       Therefore,            flights         in high-density,                  medium-distance
markets      were assumed               to achieve           more than a 60-percent                       load
factor,      and flights             in short-            and long-distance                  markets        were
assumed      to achieve            less       than 60-percent                load       factors.          We
believed       this      adjustment             better       showed what would                   occur
if the trunk           airlines           achieved          an industrywide                 60-percent
load    factor      m

        Based on our overall    extensions                              and modifications                to
Dr.    Keeler ‘s study, we stated     that                        our     -study   offered           reliable



l/“Lower    Airline  Costs  Per Passenger                            Are Possible               in the
    United  States  and Could  Result   in                          Lower Fares”              (CED-77-34,
    Feb. 18, 1977).




                                                      13
evidence   that airlines        could have profitably               operated     at a
lower cost per passenger           from 1969-74,          resulting       in lower
fares of between $1.4 billion                to $1.8 billion         per year.
These results       could have been produced              mainly     by putting
more seats on each aircraft,              filling      more of the seats
available     on each flight        (higher       load factors),        increasing
average aircraft        use, and using some of the more efficient
aircraft    available     while maintaining            average annual rates
of return     on investment      comparable          to those of the entire
corporate     sector.     Although      our study found the argument                for
greater   reliance      on a more competitive             market to determine
 service  and price      persuasive,         our study did not answer a
 number of questions        about what might happen if the form of
 airline  regulations       were changed or if regulations                   were
 abandoned completely.
        Another   study,       entitled      "'Energy Impacts of Proposed
Changes in Airline           Regulations"         and prepared       in 1975 for
FEA by Dr. George W. Douglas,                  showed that industrywide
average load factors            would increase          from current      levels      to
an average at or exceeding                62 percent       if changes in airline
regulation      as proposed          in the administration's           draft     bill
(H.R. 13504, 94th Cong., 2d sess.)                    cause the industry          to
vigorously      compete with prices.               Dr. Douglas stated          that
this would reduce fuel use by 2.5 to 7.8 percent                          a passenger
mile.      Dr. Douglas'        study also indicates            that relaxation
of certificate        restrictions          and limitations        which would
enable airlines         to fly more direct            routings     with fewer
stops could further            reduce fuel use by 2.5 percent                or more
a passenger      mile.       He stated       that fuel savings         could also
result     from substituting            more appropriately         sized aircraft
in very small or very large markets.
       For the level     of traffic     carried   in 1974, Dr. Douglas'
study showed aggregate        fuel savings      would range from 500
to 700 million     gallons    annually.       However,   because of the
expansion    of air traffic       from increased     passenger    demand
induced by lower fares,         Dr. Douglas concluded        that fuel
savings   would be less,      perhaps on the order of 100 million
to 300 million     gallons    annually.
         In its February    1977 report    to the Congress pursuant
to the Energy Policy        and Conservation     Act, CAB stated      that
it had recommended to the Congress that commercial                air
transport,       following  a period   of gradual     and monitored
transition,        should be more substantially      governed    by compe-
titive      market forces.    CAB also believed       that any legisla-
tive     changes that result     in an increase     in economic effi-
ciency may also result        in a more efficient        use of energy.



                                           14
                                     CHAPTER 3
                    FAA'S FUEL CONSERVATION PROGRAMS:
                               ARE THEY WORKING3

       FAA estimated       that    its seven-point         and intermediate       fuel
conservation       programs would reduce aviation                fuel consumption
by more than 1.2 million             gallons      a day.    This equals about
440 million       gallons    a year,      or about 5 percent         of the esti-
mated fuel consumed by airlines                 in 1976.      It had no assurance,
however,     that the fuel conservation               procedures     under its con-
trol   saved 772,800 gallons             a day.     FAA did not monitor       pro-
gram implementation          or require       reports     on the frequency     that
fuel conservation         procedures       were used and the fuel saved.
In several      instances,      the procedures         were (1) infrequently
used, (2) impractical           to implement,         or (3) ineffective.
       FAA's remaining    fuel savings,    an estimated   432,600 gal-
lons a day, were attributable        to fuel conservation     procedures
beyond its regulatory       control.    As such, it is questionable
whether    they should have been included       in FAA's fuel conser-
vation   accomplishments.
REPORTED ACCOMPLISHMENTS
        FAA, in its February    20, 1976, report     to the Congress
pursuant    to the Energy Policy    and Conservation       Act, stated
that its seven-point     jet fuel conservation       program imple-
mented in November 1973 was designed         to save up to 20,000
barrels,    or 840,000 gallons,    of fuel a day.        FAA also stated
that the seven-point     program had been refined         and improved
since November 1973 and was still        producing     fuel savings.
       FAA stated      that its intermediate       fuel conservation        pro-
gram, adopted        in June 1974 for implementation         during     1974-76,
would save an estimated          8,700 barrels,      or 365,400 gallons,
a day.      In total,     FAA estimated     that the seven-point        and
intermediate      programs vould save over 1.2 million             gallons
a day, or about 440 million           gallons    a year.
        The procedures        included      in each program and the esti-
mated    savings    attributable        to each one are shown below.
These    procedures       are discussed       in more detail in subse-
quent    sections    of this       chapter.




                                         15
                                                                    Estimated
                                                                   gallons    saved
                                                                         a day
Seven-point     jet fuel program:
     Revised gate-hold         procedures     (note a)                  105,000
     Revised flow control          procedures      (note a)             117,600
     Increased     use of optimum cruising            speeds             16,800
     Revised ATC procedures
        (note a)                                                        159,600
     Turning    off unneeded engines          while
        taxiing    aircraft                                             252,000
     Increased     use of simulators        for training
        and testing       (note a)                                      138,600
     Accelerated      construction      of runway and
        taxiway    improvements                                          .50,400
                                                                     _I----
           Total                                                     -w--84O;OOO
Intermediate        program:
      Aircraft      towing                                                (b)
      Improvement       of major landing        system                    (b)
      Additional/improved           runway exits                        113,400
      Optimum descent         landing     (note a)                      252,000
      Reduce lateral         spacing    for simultaneous
         approaches       (note a)
           Total                                                     _ 365,400
                   Total                                             1;205,400
                                                                     m-w
a/Procedures     for which program            implementation   and actual         ac-
   complishments     were unknown.
b/FAA determined    that these         procedures       were not   economically
   feasible  to implement.
c/Fuel   savings       were not   estimated      by FAA.
PROGRAM-IMPLEMENTATION
----                   AND ACTUAL
ACCOMPLISHMENTS-ARE-UNKNOWN----
--m-
        FAA had no assurance      that fuel conservation        procedures
under its control       (see note a, above) saved 772,800 gal-
lons a day.     Although      FAA headquarters     had issued instruc-
tions    on the fuel conservation        programs,   no guidelines      were
established    for monitoring      program implementation        and
for reporting     on the freguency       that procedures    were used
and fuel savings      realized.



                                        16
        In the five        regions      visited,      FAA officials      told us that
they were not responsible                 for monitoring        implementation        of
their     fuel conservation            programs.        FAA regional     officials       also
told us that all the procedures                     in FAA's conservation          programs
could save fuel          if implemented            by those responsible--FAA            air
traffic      facilities,        airlines,        and airports.       However,      as dis-
cussed below, FAA's fuel conservation                      procedures      were (1)
used infrequently,             (2) impractical,          or (3) ineffective;          there
is no assurance          that reported           fuel savings      were realized.
Gate-hold      procedures
       Under FAA's revised       gate-hold     procedures,    an aircraft
was to be held at the terminal            with its engines      off when a
departure     delay exceeded 5 minutes.           FAA estimated     that this
procedure     would save 105,000 gallons          of fuel a day over
prior   gate-hold    procedures,     which were not to be used until
departure     delays   exceeded 15 minutes.         The revised     procedures
were used infrequently        or, in some cases, were impractical.
      At the Dallas-Fort     Worth Regional       Airport      and at Chicago
O'Hare International     Airport,    FAA officials        told us that be-
cause of a gate shortage        it was not possible         to hold aircraft
at the gates and yet accommodate        incoming      aircraft     without
compounding    incoming  delays.
       At the Atlanta       and the San Francisco            International        Air-
ports,    FAA officials       told us that gate-hold            procedures      were
used occassionally,         but the frequency          of use was unknown.
FAA officials       at San Francisco        International         Airport    also
told us that it was not practical                 to impose gate-hold          pro-
cedures    until    departure     delays    reached 10 to 12 minutes.                Ac-
cording    to these officials,          imposing      gate-hold      for shorter
delays    would cause gaps in the takeoff                and landing       sequence
due to the time it takes to taxi                from the terminal          to the
runway takeoff        area.
         FAA regional     officials     told us that gate-hold            had not
been successful         at Denver's     Stapleton      International        Airport
because of a lack of airline              cooperation.         FAA officials
at the airport        confirmed     that gate-hold        was not practical
or effective.         They said reserved        departure        times for an
aircraft      were missed because reservations               were being made
before     the aircraft       was ready for departure.




                                             17
         FAA instructions       at the Los Angeles      International         Air-
port provided        for using gate-hold       procedures     at night       in
connection      with noise abatement        procedures     and when bad
weather     and traffic     conditions    create    departure      delays.       FAA
officials      estimated    that gate-hold      procedures     were used 15
percent     of the year.        During a 20-minute      observation        at the
airport,     we observed      that gate-hold      was not used although
from five      to six planes were at all times awaiting                takeoff
at the end of the runway with at least                a lo-minute      wait for
each.
        FAA officials       at the Minneapolis-St.        Paul and the
Seattle-Tacoma        International    Airports      told us that gate-hold
was seldom used because departure              delays    of 5 minutes  or more
were infrequent.
Flow-control         procedures
      To reduce fuel consumption,          FAA revised certain     of its
ATC procedures     to improve the flow of air traffic          into con-
gested airports,     considering       demand and the capacity     of ATC.
The revised    procedures     included:
       --Dissemination       of information        and instruction    to field
          facilities,     selected      airline    offices,    and the Air Force
          when arrival,      departure,        or enroute   delays exceed 30
          minutes     at an airport.
       --Increased        spacing          between   aircraft.
       --Spacing   aircraft          over fixes          (navigational            points)
          in equal units           of time.
       --Routing       traffic       around      congested       areas.
       --Restricting       flight operations              at a facility              to a
          specific      number of aircraft              an hour.
       --Holding     aircraft         at departure     airport            until      congestion
          at destination           airport   is relieved.
       In its February      1976 report   to the Congress,     FAA con-
tended that these measures reduce airborne            delays   by 25 per-
cent and save 117,600 gallons          of fuel a day.     These fuel
savings,     however,   are probably    overstated  because revised
flow-control     procedures    have not reduced airborne       delays.
       Based on airline             data     and FAA estimates,  we estimated
that   total airborne            delays      were about 14,245,OOO minutes


                                               18
in 1973.          In comparison,          FAA estimated            airborne         delays      at
about      14,255,OOO        minutes      in 1975.          This     reduction          of  about
20,000      minutes       represents        a reduction          of less         than 1 percent--
far    from the 25-percent              reduction         claimed        by FAA.         During      the
same time         period,      actual     airline       operations           (takeoffs        and
landings)         decreased       by almost        700,000       from      about      9.9 million
to about        9.2 million         between       1973 and 1975 respectively,                      or
about      7 percent.          When the decreased              operations           are considered
with     the small        reduction       in airborne          delays,         the average         air-
borne      delay     for    each operation           increased         slightly,         as shown
below.

                                                                                              Average
                      Total                              Total                      airborne          delay
                    airline                    airborne          delays               per operation
Year
----              -operations
                      ----a---                     (in------w---
                                                             minutes)                 (in-------a-
                                                                                                minutes)

1973               9,900,000                        14,245,OOO                                 1.4
1975               9,200,000                        14,225,OOO                                 1.5

         FAA reported              that     it reduced            nationally         the number        of
aircraft         delayed         over     30 minutes           by more than             30 percent       be-
tween      1973 and 1975.                 This      accomplishment,               however,       is mis-
leading        in that         FAA’s reporting                system       permits       an aircraft
to be delayed              as much as 4 times                   for    up to 29 minutes             each,
or a total           of 1 hour and 56 minutes,                         without       reporting       a
delay      of 30 minutes               or more.          As illustrated               in the follow-
ing diagram,             for a flight             from Los Angeles                to Chicago,        the
Chicago        center        can hold         aircraft          in its       airspace       when de-
lays     at the Chicago                tower      are approaching                30 minutes.         When
delays       at the Chicago               center        start       approaching          30 minutes,
an adjacent            center        can hold         the aircraft             in its     airspace,
and when delays                there      approach         30 minutes,            the Los Angeles
tower      can hold          the aircraft             on the ground.                A delay      at any
one point          for     less      than 30 minutes                would      not be reported,
although         the total           delays       enroute         could      far    exceed     30 minutes.




                                                    19
                        DIAGRAM OF POSSIBLE DELAYS ENCOUNTERED BY
                         A FLIGHT BETWEEN LOS ANGELES AND CHICAGO

                                         Palmdale,
                      Los                Cal. and              Kansas               Chicago          Chicago
                      Angeles            Denver                City                 ATC              ATC
                      ATC tower          ATC centers           ATC center           center           tower

                      Terminal           No delay              Dela$up              Delay2 up        DelayQup
                      delay up                                 to 29                to 29            to 29
                      to 29                                    minutes              minutes          minutes
                      minutes                                  by adjacent
                      on the                                   center
                      ground                                                                     .


        Los       t                                       (Flight    Path)                                      W     Chicago
        Angeles


        UDelays       can take the nature      of diverting     or circling   the aircraft.




         FAA’s program           to reduce        the number       of aircraft           delayed
over     30 minutes         or more,      however,        has helped        to conserve          fuel.
Aircraft         delayed      on the ground          at the departure            airport       use
no fuel,         and aircraft       delayed         enroute     at higher       altitudes          use
less     fuel      than aircraft        delayed        at lower      altitudes        awaiting
landing        into     congested     airports.           However,       because      airborne
delays       have not been noticeably                  reduced,     we question           whether
savings       of the magnitude            FAA reported          were realized.              Fuel
savings       could      have been determined               had FAA monitored             program
implementation             and required         reports      on the frequency             with
which      these      procedures      were used.

ATC
-m-e Erocedures
      v-------w
         In revising                 its ATC procedures       to                         conserve              fuel,         FAA
also     amended     its             policies  and instructed                               FAA air              traffic
controllers        to

        --allow             aircraft      in the area of the terminal                                               during
            periods             of congestion      to operate at higher                                             altitudes
            where           less     fuel   is used,

        --assign                cruise        altitudes               best        suited        to      fuel         effi-
            ciency,               and

        --minimize                 circuitous                 routings.



                                                                20
FAA estimated     that these revised      procedures   could save 159,600
gallons  of fuel a day.      We found,      however, that there  is no
reliable   information    on the number of times the procedures
were used or fuel savings       realized.

--Simulators
         In December 1973 FAA amended its regulations                      to permit
airlines     to increase     simulator       use for pilot        training       to re-
duce the number of training            flights.         FAA estimated         that
simulators     would save 138,600 gallons               a day; however,          FAA
had not obtained       reports     from the airlines          concerning         the
use of simulators        and related       fuel savings.          After      FAA's
February     1976 report,      ATA told FAA that simulators                  were eli-
minating     177,000 landings        and takeoffs        annually,       enabling
the airlines      to save 170 million           gallons    annually.
Optimum
     -         descent   landings
         FAA recognized       that aircraft         landing     approaches       to an
airport,     when taken in stages--stair                 stepping--could         result
in premature        descent     to and level-off           at low altitudes         where
fuel consumption         is high.     To remedy this,             in 1973 FAA au-
thorized     use of optimum descent             landing      which can be described
as a continuous         unrestricted      descent,         except when level         flight
is required        for speed reduction,           from a cruise         altitude     to the
assigned     altitude      for final    approach         to any airport.           A com-
parison     of the two procedures           follows.
                                                                     FINAL
                                                                     APPROACH
                                            DESCENT                  TO AIRPORT


          24,000   ft.



                                        OPTIMUM       DESCENT




                         STAIR   STEEPING




                                                                36                0

                                              NAUTICAL      MILES



                                                21
       According   to FAA, a Boeing 727 landing,               for example,        con-
sumes about 84 fewer gallons            in a continuous        descent     than in
one taken in steps.           FAA estimated      that,   on the basis of
average traffic      activity,     optimum descent         landings     would
save at least     252,000 gallons         a day.      We found,     however,     that
although    FAA-ATC personnel        at two airports         had either      accepted
or were testing      this procedure;        others     had rejected      it.
      FAA adopted optimum descent           landings      for use at the
Kansas City International       Airport       in June 1976 after             2 years
of development      at that airport.        Two major       airlines        estimated
between 149 and 269 gallons          of fuel were saved on each land-
ing . At O’Hare Airport,       optimum descent          landings         were tested
for several     months in 1976.        Since the initial           test,     some
modif ications     have been made,      and   new  tests     were     still      being
conducted     as of October   1976.
       Optimum descent           landings     were not used at Seattle-Tacoma
International,          Denver’s      Stapleton,      Los Angeles,   and San Fran-
cisco     International       Airports.          FAA’s Western Region officials
told us they had tested               the procedure      and concluded   that,
although        the concept      had considerable        merit  and would save
fuel,     traffic     would be slowed during            peak hours.
          In November 1976 FAA issued an order to require                      FAA
facilities          at all airports      where high performance           aircraft
operate       to develop      an operational     plan,     including      imple-
mentation        dates,    to provide     for maximum use of optimum des-
cent landings          as part of a local-flow         traffic      management
program.          (See p. 33.)       The order also requires           each FAA
region      to evaluate       the progress    and effectiveness           of this
program.          It indicates     that optimum descent          landings      can
save about 50 gallons            of fuel for each landing,             about 250
million       gallons     a year based on an average of 5,000,OOO ar-
rivals      annually.
Lateral -- spacing
       FAA amended its procedures             in September      1974 to reduce
the lateral     spacing     between aircraft        runways from 5,000 feet
to 4,300 feet.        This change would permit             some airports    to
begin using parallel           runways concurrently,         thus increasing
their   landing   and departure         rate.    The change also would en-
able other airports         with limited       or restricted      land area to
add and operate       parallel      runways.     FAA, however,       had not
estimated     any fuel savings         as a result     of this change.
         Lateral  spacing    was not a factor     at the airports     visited,
except      Los Angeles   International.      There,   parallel   runway



                                         22
capability    existed           before       the       change     in regulations,           but
the change    added          runways        which       could     be operated        parallel
to other   runways.

PROGRAMS BEYOND FAA’s
-----------------------------         CONTROL

        Of the 1.2 million              gallons       of estimated        fuel    savings     a
day due to FAA’s fuel               conservation,          over    one-third,        about
433,000        gallons,      was attributable            to energy      conservation        pro-
cedures        developed      and implemented           by the airlines           and air-
port    operators.           Because      these     procedures      were beyond         FAA’s
regulatory          control,     their      inclusion       in FAA’s February           1976
report       to the Congress           seemed inconsistent            with     the require-
ments      of the Energy         Policy       and Conservation          Act.

         Section      382(a)(l)         of the act stated             that      FAA was to re-
port     within      60 days after            the act’s      enactment          on the energy
policies        and practices           which     it instituted           after      October        1973.
We believe         the language           of the act and its              legislative           his-
tory     indicate        that     the policies          and practices           to be reported
were to be those              under     FAA’s regulatory             control        and not energy
conservation          policies         and practices         developed          and implemented
by those        that     FAA regulat.es.            Our view       of section          382(a)(l)
is supported          by the conference               report     (S. Rept.          No. 94-516),
which      states     that      the agency         “* * * shall         study       and prepare
a report        * * * assessing             its   policies       and reviewing            its     au-
thority       with     respect       to energy        conservation           * * *0”

        The following           table    shows those         energy     conservation       pro-
cedures       that     were beyond       FAA’s regulatory           control       but were
included        in its     report      to the Congress          on fuel     conservation
programs,         those    responsible       for    their     development         and imple-
mentation,          and the estimated          fuel     savings     claimed       by FAA in
its   report.

                                             Group         responsible                   Estimated
                                                for development                      gallons        saved
         Procedure
         ---------                       and/or          implementation
                                         --v------e-----------                              a
                                                                                            ---- day

Increased         use of
   optimum        cruising
    speeds                                  Airlines                                        16,800
Taxiing       aircraft
   with     fewer       engines             Airlines                                      252,000
Accelerated           construc-
    tion    of runway         and
    taxiway       improvements              Airport        operators                        50,400
Additional/improved
    runway      exits                       Airport        operators                      113
                                                                                          ---b-,- 400
       Total                                                                              432 600
                                                                                          ,--L-*-


                                                    23
                                  CHAPTER 4
                                  --u--m
               FAA PROGRAMS-HAVE NOT u__-m-y_----
               ---I-I--Y-----        EFFECTIVELY                DEALT

          WITH A-MAJOR
                  ------I_---CAUSE-OF.FUEL      CONSUMPTION.PROBLEMS:
                                                               ----
                     AIRPORT CONGESTION AND
                     -------_I          --m--mDELAYS
        Since 1969 airline       delays   have increased     although     air-
line operations       (takeoffs     and landings)     have decreased.
Because of delays        the airlines     wasted nearly     400 million
gallons     of fuel   in 1975.      In addition,    this wasted fuel cost
the airlines      over $110 million.         Over 40 percent      of the
delays     in 1975 occurred      at five major airports.          FAA efforts
to improve the efficiency           of its ATC system to reduce de-
lays have been ineffective            to date,   but recent    FAA efforts
undertaken     appear promising.
 INCREASED.INEFFICIENCY.IN-THE
--_I_-             -----e-m--              AT@ SYSTEM
        The ATC system became increasingly                  less efficient        in
handling    airline       operations      between 1969 and 1975.              During
this period,       airline      arrival     and departure       delays    (as esti-
mated by FAA on the basis of data provided                      by the airlines)
increased     from about 24 million             to over 30 million         minutes
in 1969 to 1975, respectively.                  During this       same period,
airline    operations        decreased      from about 11 million           to about
9 million     in 1969 to 1975, respectively.                   Using 1969 as the
base year,      the graph on the following             page shows the percent-
age increase        in total      delays    and the percentage         decrease
in airline      operations.           The increasing      gap between delays
and operations         depicts      the decreased     efficiency.
        Delays at 25 airports         accounted     for about 75 percent
of the 30 million         minutes   of delay incurred        in 1975.
Five airports--      Chicago's     O'Hare,    Atlanta,    New York's
Kennedy and La Guardia,           and San Francisco       International--
accounted      for over 40 percent        of all delays;      O'Hare incurred
the most, 14 percent.            In 1975 delays       at O'Hare totaled          4.3
million     minutes,   an increase       of more than 1 million           minutes
since 1969.        In comparison,      total   aircraft     operations       at
O'Hare decreased        from about 676,000 in 1969 to 668,000                  in
1975.




                                         24
                                           AIRLINE          DELAYS AND OPERATIONS

PERCENTAGE

         130 I I m
                                                                                                                   127%

                                                                                 ;EfMyTED           TOTAL/




                                                                                                                 BASE
                  I’d

                                                                                                             I




             80




             70 b                                                                                        I            I
              1969                                                                                    1973          1975
                                                                         YEAR       (NOTE      b)


         a        Decreases in airline operations      at an alrport can be offset b; increases in
                  other types of aircraft  operations;     however,  total alrcraft   operations
                  decreased  in 7 of the 10 highest delay airports       between    1969 and 1975.
         b        Delay   data   was not available   for   years other    than    those   shown.




                                                                         25
EFFECT OF DELAYS ON FUEL CONSUMPTION
------------------------------------
         Fuel consumed during          delays depends on the type of
aircraft      and on whether        the delay occurs on the ground or
in the air.          Using FAA's estimate          of ground and airborne
delays     and the fuel usage by a Boeing 727 (the most common
aircraft      in commercial       use), we estimated         that over 395
million      gallons     of fuel were consumed because of delays                  in
1975.      According       to FAA estimates,        delays   cost the airlines
over $195 million            in operating     expenses in 1973, and we
estimate      that about 26 percent           of this was for fuel.
Estimates       of the airlines'         operating     costs attributable         to
delays     in 1975 were not available,              but we estimate       that the
395 million        gallons     of fuel alone cost the airlines              about
$133 million.
FAA EFFORTS TO REDUCE DELAYS
--------------a-------------
        FAA has several     procedures       to reduce delays but to date
its efforts     have been ineffective.            Revised    flow-control
procedures    were implemented         in 1973 as part of FAA's seven-
point    fuel conservation       program;      however,   they did not
noticeably     reduce airborne       delays.      (See p. 18.)       Also FAA
established     quotas at five major airports             as to the number
of aircraft      operations    that can be handled          during    peak hours.
Quotas at least       at one of these airports          were not being
enforced.
         FAA is implementing         a metering     and spacing      program to
help reduce airport           congestion.       (See p. 33.)        Although
this     program will     not eliminate       delays    entirely,       it does
attempt      to minimize      the effects     of delays      on fuel usage.
FAA is also developing             a fuel advisory      departure      program,
intended       to alert   airlines      of extreme delays         at destination
airports       and permit     them to adjust      their    flight    plans ac-
cordingly.        FAA tests      of this program show that fuel can be
saved.
      FAA participated       in a recently     completed    task          force
study of delays      at Chicago's     O'Hare Airport.       The         task force
suggested     a comprehensive     program of delay reduction                  meas-
ures,   and a new task force has been established              to         follow
up on implementation       of the recommendations        of the           first
task force.      FAA also has similar       studies    underway           at seven
other   airports    having major delays.




                                         26
Quotas
---------------- at   O’Hare

        To provide       relief        from excessive             delays    at O’Hare       and
four     other     major     airports,         FAA amended           its  regulations          in
December       1968 to establish               quotas        on the number         of aircraft
landings       and takeoffs.              Since      then,      the regulations         have
been amended          to eliminate            quotas       at one airport          and to
liberalize         the time periods              quotas       are in effect          at two of
the other        four    airports.            The regulation,            as amended,        re-
stricted       total     hourly        operations         at O’Hare       between      3:00 p.m.
and 7:59 p.m.           each day as follows.

                                                                  Operations
                                 User
                                 ----                        ------m-w------ an hour
                                                             allowed

                               Airlines                                115
                               Air taxis                                10
                               Other                                    10
                                                                       m-w
                                      Total                   135
                                                             ---
                                                              ---
      After     airlines        mutually        agree     on their         proportion       of
the quota,        they may schedule              their      arrivals         and departures
without      regard       to other       users’      schedules.            If the airlines
do not use their            entire       quota     of 115,        air    taxis      can use all
or part      of the remainder.               Other      aircraft         can use any part
not used by the airlines                  and air       taxis.         The regulations
are violated          only    if total       operations           during       the specified
hours     exceed      135.

       Our analysis         of          FAA reports      on O’Hare      showed     that      total
operations--       takeoffs               and landings     by airlines,        air     taxis,
and other      aircraft--               exceeded     the quota     by 35 percent           of the
measured      quota      hours            from January     1 through       June 30, 1976.
There     were 910 quota                  hours   during   this    period,     but FAA had
reports      on only      848           of these.

                           Measured
                           ----------------‘--- quota      hours       Percent          of measured
                                                 Operations                    quota      hours
                                                    exceeded              in which         quota
                           In
                           ---w-w-month          --------_quota
                                                 135                        was exceeded
                                                                            -----------_
       January                  139                     15                             11
       February                 129                     38                             30
       March                    128                     34                             27
       April                    149                     63                             42
       May                      153                     66                             44
       June                     150
                                ---                  ---78                             52

                Total           848
                                ---                  294
                                                     ---                               35
                                ---                  -mm

                                 I
                                                        27
       As shown in the following       table,   our further     analysis
of FAA reports    on O’Hare     showed     that quotas   during    the
period    January 1 through    June 30, 1976,        were exceeded
because:

      --FAA    allowed    the airlines        and air                taxis to schedule
         more operations      than     their    quota                of 125 during   41
         percent     of the quota      hours.

      --FAA    allowed    other    aviation              users   to schedule           opera-
         tions     in excess     of their             quota    of 10 during           36 percent
         of the quota       hours.

                                     Scheduled operations                       Other operations
                                   exceeded 125 (note a)
                                 “““““““P~r~en~-~~-                                  exceeded 10
                                                                         “‘-“-““-^‘~ercenF-oT
               Measured
              quota     hours    Hours within          measured          Hours within      measured
               in month
               --------          guota
                                  ----- Eeriod
                                         -----         ----------hours
                                                      quota              quota
                                                                          ----- period
                                                                                 -----     ----------hours
                                                                                          quota
January               139               38                  27                27                   19
February              129
March                 128                z1’                :8”               i:                   ::
April                 149                69
May                   153                57                 i8”                E                   ti
June                  150
                      ---             ---72                 47              ---66                  44
    Total             848
                      ___             348
                                      D-w                   41              302
                                                                            --a                    36
a/Quota hours in which scheduled operations   exceeded 125 did not always
   coincide with those quota hours in which actual operations   exceeded the
   135 quota because of early or late arrival  and departure  delays.


Fuel advisory
------------            departure
                       w-w  -------        eroqram
                                             -- W-B
        On January     18, 1974,     FAA issued      procedures        for devel-
oping     a Fuel Advisory       Departure      Program      (FAD) for       testing
at Chicago’s        O’Hare  Airport.        The major      objectives         of the
program      are to (1) reduce        fuel   consumption,         (2) contain
arrival      delays    to 60 minutes       or less    within      the Chicago
ATC center’s        area,  and (3) distribute           delays      equally       among
aircraft.

        After      a series      of simulations,         FAA revised        the FAD
procedures           in June 1975.         Under    these     procedures       FAD was
to be initiated              at O’Hare     when weather,         equipment       failures,
or other         constraints         at the airport        reduced      the airport’s
arrival         capacity       to such an extent         that    delays     could      be
forecast         to exceed       1 hour    for   an extended        period.        To con-
serve       fuel    when FAD procedures           were used,        FAA alerted         air-
lines       of extreme        delays    at O’Hare      so that      the airlines
could--       subject      to the availability           of airspace,         ATC system



                                                 28
efficiency,      and safety --take          a ground                  delay     at     the departure
or an intermediate          airport,       an airborne                   delay,        or both   a
ground      and an airborne         delay.

      The FAD procedures       were first        tested      at O’Hare        on January
7, 1976.     On March      1, 1976,    the FAA Administrator                reported
that,    as a result     of the test,       658,446      gallons       of jet      fuel
had been saved.         These savings       were determined            by comparing
the time    aircraft     spent   holding      on the ground           and in the
air on January       7, 1976,    with    delays     on a similar         day when FAD
was not used.        The FAA Administrator            also     stated     the results
had been verified        with  the airlines.

        Only     two airlines            had reported             fuel     savings         to FAA,
which      totaled        about       9,000     gallons.            One major         airline         par-
ticipating           in the test           disagreed          with      FAA on the reported
savings        and,     in general,           with      the overall           success         of the
test.        Three      airlines         indicated         that       FAD’s basic            objective--
to minimize            engine-running             time--was           sound,      but that          ac-
curate,        timely        forecasting          of delay          times     was impossible
to achieve           because       FAA lacked           real-time          computer          capability
to assess          the numerous            variables          affecting         traffic         at con-
gested       airports.            Four airlines            also       indicated         that      FAD
attempts         to control           delays,       rather        than     to eliminate             them.

        FAA officials           told   us that     the reported          savings      of
658,446       gallons       was inaccurate.            Subsequently,          the FAA
Administrator,            in testifying         before     a subcommittee           of the
House Committee             on Appropriations           on March 15, 1976,              stated
that      FAD saved “something             like    110,000     gallons.”          FAA also
testified         that    FAD could      be used 58 times            a year      and save
over      40 million        gallons     annually.        FAA officials,           however,
told      us that      they expected          to use FAD only         10 to 15 times
a year.

       FAA issued         revised      FAD procedures              on June 8, 1976.
Subsequent        tests       were conducted            for    10 hours       on December         6,
1976,     and for       2 hours       on December           20, 1976.         FAA’s     analysis
of the December             6 test      indicated         that     FAD saved       184,147
gallons      of fuel.           Because      52 percent          of the aircraft           that
could     have accepted            ground      delays       took     airborne      delays,       FAA
estimated       that      an additional           185,518        gallons      could     have been
saved had all           aircraft       choosen        ground       delays.       Data was not
available      on the December               20 test.

Delay  task      force
w--m -e----m------------        studies

       Late    in     1974 FAA, Chicago,    and the airlines                             serving         that
city     formed       a task force  to study   air  traffic                           delays     at




                                                     29
 O’Hare.      According      to its    July    1976 report,                                the       task     force
 found   that    O’Hare    experienced       significant                                annual         delays,
 an estimated       93,000     hours,    which

       --cost         the      airlines             $44.3      million,

        --consumed             67 million             gallons           of     fuel,      and

        --caused            delays        of   4.6        million         passenger           hours.

        An earlier         FAA study          in January        1974 on airport            capac-
  ity    at eight      major      airports,         including         O’Hare,      had con-
 cluded      that     nearly      all    delays       were attributable               to weather
 problems        and most severe             delays      were weather           related      and
 largely       unavoidable.            The O’Hare          task     force     study,     however,
 questioned         whether       such delays          were largely           unavoidable.
 According        to the study,             delays     may result          from     a series     of
 factors,       many of which            are controllable               (such     as the number
 of flights         that     can be accommodated                by ATC facilities),
 which     compound        into     severe       system      delays      when triggered          by
 weather       or other        problems.

        The principal                 causes         of     delays        at    O’Hare        were       identified
 by   the task     force              as

        --the        proximity            of   other         airports           to     O’Hare;

        --ATC        rules,          regulations,              and      procedures;

        --physical             properties              of    the     airspace           and      airfield;

        --weather;

       --operational                  procedures;              and

       --aircraft              operating             demand.

        Although         it did not identify                 any individual        panacea     to
  the problem,           the study       report        outlined     a comprehensive          pro-
‘gram     of measures         which,       if implemented,            could     dramatically
  reduce      the current        level       and cost         of delays      at O’Hare.       The
  study     identified        current        delay      reduction       options      in three
  areas     which      could   reduce        the cost         of delays      $16 million
  to $34 million.            The options             in each area and the amount
  of reduction           in delay      cost     follow.




                                                              30
                                                              Reduction      in
Area/options
------    -w-w-                                                delay    cost
                                                               -a-- --m-w
                                                            (000,000                 omitted)
Air   traffic           operating     procedures:                 $ll-$16

      --Develop      and implement    a plan
         to select     the optimal    runway
         configuration      to minimize    delay.
      --Develop    and implement   a real-
         time delay information      system to
         use in selection    of optimal     run-
         way configurations     and control
         traffic   volume.

      --Immediately      implement     procedures
          to reduce separations        when
         existing    equipment    indicates
         wake vortices      (wind turbulence)
          are not a problem.
Management          of demand:                                                  3-    13

      --Enforce            quota    rule.
      --Assess      the cost of changes in the
         level    and distribution          of demand
         as a basis for.reevaluation               of
         airline      scheduling     policy     or
         adjustment       of current      quota
         regulation.
      --Refine       flow-control         procedures
         controlling        O’Hare traffic         under
         abnormal       operating       conditions     in
         order to limit           delays.
Airfield         improvements:                                                  2-      5

      --Plan    and coordinate     airfield
         construction     to minimize       delay.
      --Implement      specific             physical
          improvements.                                                ----we




                Total                                              $16-$34




                                                 31
      Two elements         in FAA’s engineering         and development           pro-
gram which could have a major impact on O'Hare's                         future
capacity     and delays         and which the O’Hare task force study
also identified          are (1) a wake vortex          advisory/avoidance
system and (2) an upgraded ATC automation                     in the form of
automated      metering        and spacing.      The task force believed
that without        these two ATC improvements,              O'Hare's      capacity
would continue         to deteriorate        through    the post-1985         period
and delay costs would escalate                 due to projected        increased
use of larger         aircraft.       The study stated        that measured
against    the conditions          that would occur without            them, the
potential      net delay savings          from these two proposed             ATC
improvements        ranged from $13 to $47 million               annually       in
future    periods.       The study recommended that FAA give the
highest    priority        to developing       and installing       wake vortex
and metering        and spacing       equipment     and, if necessary,            adjust
the timetable         of other engineering          and development         projects
so that these two projects               could be expedited.
      FAA officials         told us that a new task force had been
formed to follow          up on implementation         of the first     task
force's    recommendations.            This task force met in December
1976 and had another            meeting    scheduled     for February     1977.
One FAA official          told us that action        taken on the recom-
mendations      before      completion     of the study has already          re-
sulted   in improvements           for 1976-- one airline      operating       at
O'Hare reported         that delays have stayed the same although
its operations        increased       10 percent.
       An FAA official        said that besides     the O'Hare task force
study,    similar     studies     are underway at seven other major
delay airports--Atlanta,             Denver,  Kennedy,    La Guardia,   Los
Angeles,     Miami, and San Francisco --and           that these studies
are expected      to be completed         in 18 to 24 months.       An FAA
official     told us that these seven airports             and O'Hare had
been selected       for study based on ATA's identification             of
airports     having major delay problems.
       These eight      airports      account     for almost 50 percent             of
all delays,       and FAA has no definitive              plans for making
studies     at this time at other major airports                    experiencing
delays.      FAA officials,         however,      told us that FAA was cur-
rently     developing      additional       in-house     capabilities--current
studies     were being performed            in part on a contract             basis--
that would permit          other needed studies            to be made at re-
duced cost.        To develop       additional       in-house      capabilities,
FAA plans to work closely              with those contractors              involved
in the seven ongoing            studies,      and it expects         to complete
this project       within     24 months.




                                          32
                                    CHAPTER 5
                                    ---------
  FAA DELAYED IMPLEMENTING FUEL CONSERVATION PROCEDURES
  -----------------------------------------------------
                 THAT COULD SAVE MILLIONS
                 -----------------------------------   OF GALLONS
       For over 2 years,    FAA headquarters      did  not act on fuel
efficient    ATC procedures    developed     by FAA’s Southwest
Region that could save U.S. airlines           up to 170 million
gallons    of fuel annually.      Although    progress    is now being
made, nationwide     implementation      of these procedures     is still
not a reality.
DELAYS        IN NATIONWIDE IMPLEMENTATION OF
------------------------------------------
LOCALLY         DEVELOPED FUEL EFFICIENT PROCEDURES
-------------------------------------------
       More than 3 years ago FAA’s Southwest                 Region developed
and began a metering             and spacing     program to reduce the amount
of circling,        speed control,        and vectoring       (change in course)
FAA air traf’fic         controllers      imposed over aircraft         at low
altitudes      during     descent     and landings      at the Dallas-Fort
Worth Regional         Airport.       Under this program spacing           of air-
craft     begins when aircraft           are still     at high altitudes      and
fuel usage rates          are low.       The preplanned       time sequencing
technique       involves     formulating      an arrival      time for each
aircraft      as it passes over a fixed             point   and adjusting
the spacing        between aircraft         to maintain     required    minimum
time intervals         between landings.
       This program was started        in June 1973 at Dallas’          Love
Field.      FgAA Southwest    Region officials      told us that system
development      and refinement     had been handle,d entirely          by the
region     because attempts,     to obtain    headquarters     assistance
in its development         had been unsuccessful.          In January    1974        ,
the system was placed         into operation      at the new Dallas-Fort
Worth Regional       Airport.
       In January 1975 FAA’s Southwest            Region proposed       to
FAA headquarters         that the metering       and spacing     program be
in nationwide       use by January       1977.    The region     estimated
that 168 million         gallons   of fuel could be saved annually            if
the program were employed throughout                the country.       Region
officials     stated     that the program also would help minimize                   1
air traffic      controller      workloads     by reducing    radio contacts
with aircraft       and the number of aircraft           under surveillance.
      The two major airlines       having the most flights    into and
out of the Dallas-Fort       Worth Airport     endorsed the program
and encouraged      FAA to adopt it for use at other major
airports    experiencing   landing     delays.


                                         33
      Also,     in January      1976 ATA recommended          to the then new
FAA Administrator          that    local flow    procedures,       such as those
developed       for  the Dallas-Fort       Worth     Regional    Airport,    be
adopted     during     1976 at other     major     airports     when practicable.

        In March       1976 FAA announced                   that    a local         flow-traffic
management         system,         combining          the metering           and spacing             concept
with      optimum      descent         landing        (see p. 21),           was to be tested
at the Denver            Airport         and on November             15, 1976,            FAA issued
guidelines         to formally             establish          this   program.             Each FAA
air     traffic      facility          is to conduct              an indepth          review       and
revise,         as necessary,            procedures           at all     airports          where       high
performance          aircraft         operate.           It     is also      to forward            to FAA
headquarters,            within        150 days,         operational           plans,         including
projected         dates       for    implementing             local    flow-traffic              manage-
ment procedures.                  According         to the guidelines,                  every      effort
will      be made to implement                  the program          as soon as possible,
but no later           than

       --12   months         after          the       date     of    the guidelines             for    the
           16 major        airports               listed       in    appendix    I,

       --16     months       for      the         remaining         major    airports,           and

       --20     months      for all           other           airports      where        high    performance
           aircraft        operate.

The 16 major       airports         listed        in appendix      I were required             to
establish      a metering         and spacing         program.         Those air       traffic
facilities      where     total        implementation         is impracticable             were                to
provide     adequate      justification             to the region         for approval,
and the regional          analysis          of approved       alternate        plans     are
to be submitted         to FAA headquarters.                  In addition,          each
region     must continually              evaluate     the progress          and effective-
ness of the programs.




                                                        34
                                        CHAPTER
                                        ----m-d-- 6
                  FUEL CONSERVATION OR NOISE ABATEMENT
                  -----------------------I---------------
      FAA, in consultation            with the Environmental             Protection            ’
Agency (EPA) is responsible                for protecting        the public       from
unnecessary       aircraft     noise.        FAA efforts      to abate noise
can also help conserve            fuel,     but at times these objectives
can result      in conflicts.,          For example,      proposals       to improve
fuel efficiency          were rejected        or were implemented           slowly
because of noise considerations.                    In addition,        some existing
noise abatement          procedures      resulted     in increased        fuel consump-
tion.     FAA has not developed              program guidance         to determine
the trade-offs         that can be made between noise abatement
and fuel conservation            efforts      when such conflicts           occur and,
according     to an FAA official,             this matter       has not been
explored    to determine         whether       it is feasible       to establish
such guidance.
NOISE       ABATEMENT AND FAA RESPONSIBILITIES
-----------c----------------------------
      An estimated     6 million      people are subjected         to aircraft
noise that creates        a significant      annoyance;       Aircraft     noise
disturbs     the normal activities         of airport     neighbors--their
conversation,      sleep,, and, relaxation--degrades           their     quality
of life,     and decreases      their   property    value.
      Legal suits        are being filed            in some communities             because
of these problems.             Over the past 5 years,                airport     proprietors
have paid over $25 million                 in legal        judgments      or settlements
and have spent over $3 million                    in legal      fees,     expert     testi-
mony, and similar           defense      efforts.          In response       to public
opposition       to noise,      some airports             have imposed or are con-
sidering      various’use       restrictions.              These measures         include
discontinuing         night    operations,          limiting      airport      use to cer-
tain types of aircraft,              and limiting            the number of landings
and takeoffs.         1
      The Federal   Aviation     Act of 1958 (49 U.S.C, 1421),                 as
amended by the Aircraft        Noise Abatement        Act of 1968 (49
U.S.C. 1431),,and      the Noise Control         Act of 1972 (42 U.S.C.
4901), gives FAA responsibility            for protecting         the public
from unnecessary     aircraft      noise and sonic boom, for prescribing
and amending standards        for measuring,        end regulations          for
controlling    and abating      aircraft     noise and sonic boom.               The
act requires     FAA, in considering         proposed    aircraft       noise
regulation,    to (1) consult        with the Secretary         of Transporta-
tion and EPA and (2) consider            whether proposed         regulations



                                   I



                                             35
are consistent       with      the highest      degree      of safety                   in    air
commerce and     transportation            (FAA’S    basic    mission),                      economi-
cally reasonable,          technologically         practical,        and               appropriate
for a particular         aircraft       type.

       Although        the control            and abatement            of aircraft          noise
and sonic         boom were to rest                with     FAA, the Noise           Control        Act
requires        EPA to (1) study                the adequacy           of FAA flight            and
operation         noise      controls         and present          aircraft       noise      emission
standards,          the implications               of achieving            levels    of cumulative
noise      exposure       around        airports,        and additional             measures
available         to airport          operators         and local          governments          to con-
trol     noise      and (2) submit             recommendations               for  regulations           to
FAA, which          EPA believes            are necessary            to protect         the public
health      and welfare.              The act requires               FAA to publish             EPA’s
proposed        regulations           in the Federal             Register;        hold      public
hearings        on them;        and to adopt,            reject,         or modify        them within
a reasonable           time.       Our report           entitled         “Noise     Pollution--
Federal       Programs        To Control           It Have Been Slow and Ineffective”
(CED-77-42,           Mar. 7, 1977)            discusses         the progress           in finali-
zing     aviation        noise      control        regulations           and the lack          of
coordination           between        FAA and EPA.

       The Department             of Transportation’s                  aviation        noise     abate-
ment policy           of November           18, 1976,         states       that     FAA’s existing
authorities           preempt       the authority             of State         and local        govern-
ments      and airport          proprietors           in the areas             of airspace         use
and management            , air     traffic        control,         aviation        safety,      and
the regulation             of aircraft           noise      at its       source.         The policy
states       that     the power and authority                     of airport         proprietors
is limited          to such things             as the selection                of airport        sites,
land acquisitions,               and airport            design       and operations,             pro-
vided      the use of this              authority         does not interfere                with
Federal        regulatory         responsibilities               over      airspace        management
and national            and international               air     commerce.          Authority         of
State      and local         governments           is limited          to land-use          controls
and other         police      measures         not affecting             aircraft        operations.

        FAA has adopted,               where      possible,        air    traffic          and airspace
management        operational            procedures         to help       control          noise     at
and around        particular           airports.           For example,            airport       ap-
proaches       have been designed                  to avoid      residential             neighbor-
hoods.      At some airports,                  landings       and takeoffs             are made over
water.       Steep      climbs       are also         used over        water       to get aircraft
higher     on takeoffs           than      they would         be otherwise             when they
reach    inhabited          areas.        Where aircraft            must climb             over    resi-
dential      areas,       they     often       do so with        reduced        power        to
minimize       excessive        noise        from greater          engine        thrust.         Some
FAA fuel       conservation            procedures,          such as optimum                descents
and increased           use of simulators                (see ch. 3),           not only         con-
serve    fuel,      but also         abate       noise.

                                                  36
EFFECTS         OF FAA NOISE ABATEMENT ACTIONS
--------------------__________I_______
ON    FUEL      CONSUMPTION
-------------------
      In January  1974 a task force representing          the airlines
using the Seattle-Tacoma      International   Airport       made four
proposals    for revisions  to ATC procedures      there,     which they
believed   would reduce fuel consumption.
       FAA’s Northwest      Region was aware of the additional                       fuel
consumption     resulting        from existing        ATC procedures           at the
airport.      The regional         director,      however,      believed       that any
significant     change in procedures              would be strongly           opposed
by citizen     and civic       groups because the people within                    10
to 15 miles of the airport               were extremely         noise-sensitive
and well-organized.            For this       reason,     FAA accepted         one of
the proposals,        did not accept two others,                and finally        ac-
cepted another        over a year later.            Airline       estimates       show
that FAA’s refusal        to implement           two proposals         resulted      in
an additional        2.2 million        gallons    of fuel being used yearly
and the delay in adopting               one proposal        resulted      in an ad-
ditional     1 million    gallons        being used.
      One proposal     suggested    that aircraft    inbound from the
southeast    be routed     directly    over Olympia,     Washington,    into
Seattle-Tacoma.        This change, which affected         only one air-
line,    was estimated     to reduce average flight        time for each
arrival    by 9 minutes      and save 134,000 gallons        of fuel yearly.                ’
FAA’s Northwest      Region accepted       this proposal     in February
1974.
       Another     proposal       concerned     aircraft       departing      from the
Seattle-Tacoma          Airport      for cities      in the eastern         or south-
eastern      part of the country             and taking       off to the north.
The proposal        requested        that these aircraft            be permitted       to
turn right        8 miles     from the runway if they had reached at
least    4,000 feet altitude.                The airlines        estimated      this
change would reduce average flight                     time for each departure
5 to 7 minutes          and save 914,000 gallons               of fuel yearly.
In March 1975, about 14 months after                       the change had been
proposed,       FAA’s Northwest           Region notified         the airlines       that
it was implementing             the proposed        change on a test basis
to determine         the noise impact on the community.                     After    7
months of testing,             FAA had received          only one citizen’s          com-
plaint     about noise from the revised                  right    turn procedure
and decided        to continue         its use permanently.             The airlines
estigated       that during        the 14 months before              the procedure
was adopted,         1 million       gallons    of fuel were used by fol-
lowing     the old procedures.




                                           37
        The airlines        also proposed         to revise       the routing        of
aircraft       arriving       at Seattle-Tacoma          from the east to make
a more direct           approach      to the airport        during      clear     weather.
As shown in the map on the following                       page, in good weather
aircraft        fly west to Puget Sound 17 miles                    north of the air-
port,      then    turn    south   and    approach     the    airport       over Elliot
Bay.       The airlines        proposed       that aircraft         be allowed       to fly
over the city           to intercept        the runway’s        final     approach      about
8 miles out, reducing               the mileage      flown for each arrival
38 miles.          This route       is normally      used during          restricted
visibility         conditions.         The airlines        estimated        this change
would reduce average flight                   time by about 5 minutes               and
save 731,000 gallons              of fuel yearly.           FAA did not accept
this proposal,            however,      because it would have increased
noise in heavily            populated       areas of Seattle.




                                            38
                FLIGHT PATHS FOR ARRIVALS FROM THE EAST
                   LANDING AT SEATTLE-TACOMA AIRPORT

r




 lakely

t ESTORATIOM




?ke Is.
Ime State Pk.




                        _CURRENT    (Used    in good    weather)

                         PROPOSED    (Used    in poor    vislb~lltyl




                                             39
          Another       airline         proposal       would       allow     departing        south-
  bound aircraft             to take       off     to the north           and make a left            turn
  south     of Elliot          Bay upon reaching               an altitude            of 5,000     feet.
  The airlines          estimated          that      making      this     turn     would    reduce
  average       flight       time     by 5 minutes          for      each southbound           depar-
  ture    and save 1.5 million                  gallons        of fuel        yearly.       FAA ’ s
  Northwest         Region       rejected        this    proposal         because        it would
  have increased             noise      in a heavily           populated         and highly
  noise-sensitive              area.       The map below              shows the difference
  between       the current           and proposed          flight        paths.
                    FLIGHT PATHS FOR SOUTH BOUND DEPARTURES




                                         CURRENT



          At the Los Angeles               International            Airport,         the noise
  abatement          procedures      require         arriving        and departing             air-
  craft     to use an over-ocean                 route      between       12:00      and 6:30        a.m.
  According          to ATA officials,             this      route     adds 18 to 26 miles
  for    about       53 aircraft       arriving          from,     or departing           for,      east-
  ern airports           during    this      period,        thus     increasing         the mileage,
                          and fuel      consumption            of these      aircraft.
- flight      time,-


                                                    40
         The over-ocean           route,      as shown by the map below,              also
requires       arriving       aircraft        to land to the east and departing
aircraft       to take off to the west.                   To insure     flight     safety
and facilitate           the movement of arriving               and departing         air-
craft,     arrivals        and departures           are handled      in batches;        that
is, a number of arrivals                   are landed one after            the other,
and then a number of departures                      take off one after          the other.
To do this,         arriving        aircraft      must circle      in the terminal
area, causing           additional         fuel usage.       ATA estimated         that
about 60 percent             of the arrivals           (about 38 out of 63 air-
craft     arrivals)        on the over-ocean            approach     must circle
before     landing,        using      about     380  gallons    of   fuel for each
circle.
OVER-OCEAN      ROUTE FOR ARRIVALS          FROM, AND DEPARTURES TO, THE EAST




      FAA-ATC officials      responsible     for directing      aircraft
into and away from the San Francisco            International      and
Metropolitan    Oakland International        Airports      told us that
they revised    arrival   and departure      routes     to reduce fuel
consumption.     However,    they said some circuitous          arrival
and departure    routes,   although      not fuel efficient,       were
still    used to reduce noise.       For example,       to reduce noise
in communities      south of San Francisco,        one of the departure



                                            41
     routes    from San Francisco    Airport    adds between 5 to 7 miles
     to the flight;    a more direct     route could be used if fuel
     conservation    was a primary    consideration.
                                                NOISE ABATEMENT DEPARTURE ROUTE
                                                    FROM SAN FRANCISCO AIRPORT




                                                Saudi
I            OSAN FRANCISCO
          FARALLON         a
            ISLANDS
                               c   ,Q




                                                    A Santa


i-                                                       NOISE   ABATEMENT       ROUTE

I     I       I       em                R   I   a    m   FUEL    CONSERVATION        ROUTE

             At Chicago's     O'Hare Airport,       FAA-ATC policy          requires
     changing     runways every 8 hours for noise abatement                    pur-
     poses.     A July 1976 FAA task force study at O'Hare (see
     PO 29) indicated       that a disproportionate            number of these
     runway changes occur near the beginning                 of or during          peak
     operating      periods   and escalate     the level       of delays,        in-
     creasing     fuel consumption.         In addition,       the study indicated
     that the most efficient           runway configuration--used              only 5
     percent    of the time because of noise and other considera-
     tions--   could result      in an 8-percent       increase       in O'Hare's
     capacity.       The study also indicated          that the most efficient
     runway configuration          could be used without           hindering       FAA's
     efforts    to spread the noise impact equitably                  among all
     populated      areas around O'Hare.         Increases       in O'Hare's         capac-
     ity would help reduce congestion              and associated          delays     (see
     p. 24) and therefore          save fuel.


                                                                                42
                                              CHAPTER
                                              ---------      7

                     CONCLUSIONS                       RECOMMENDATIONS
                     ,,,,,,,,,,,L--,,------------I,,,-,-------              AGENCY

                            COMMENTS                 AND OUR EVALUATION
                            ,,,,---,L-,,,-,,--,,--------
CONCLUSIONS
-----------
         Section        382(a)        of the Energy         Policy       and Conservation
Act indicates             that      the Congress         wanted      to be informed             of
CAB’s and FAA’s               efforts        to conserve        energy      since      the 1973
energy       crisis;        their       proposed      programs       for    additional
savings        in energy;           and any law,         or major        regulatory         action
which      required,          permitted,         or induced        the inefficient              use
of petroleum            products.           This    report     demonstrates            that     avia-
tion     fuel      conservation            has not received            the Government’s
fullest        attention          and that       more could        be done to conserve
aviation         fuel.

         An increase         in load       factors        above the 53- to 55-percent
range      of recent       years      could      substantially         improve       the fuel
efficiency         of U.S.      airlines.           Although       any significant
increase        in load      factors       may have an implicit                cost    to the
public       because     of the reduction               or elimination          of flight
services        to some communities,                 the potential         for    fuel     conser-
vation       warrants      further        action       by the industry           and the
Federal       Government        to achieve           improvements        in load       factors.
Achievement           of higher       U.S.     load     factors     should       be a major
objective         of any regulatory              reform      by the Congress.

        Although         FAA reported             that     its  fuel    conservation                pro-
grams were saving                1.2 million           gallons     of fuel        a day,         it
had no assurance               that      these      programs      were working.               If
FAA had monitored                program        implementation          and had required
reports        on the frequency               that     program     procedures           were used
and fuel         was saved,          it would        have realized          that      its     fuel
conservation           programs          were not always           used,      practical             to
implement,          or effective.               FAA overstated          its     accomplishments
by including           in its        fuel     conservation         program        procedures
beyond       its    regulatory           control.          FAA’s recent         order       to re-
quire     its     regional         offices        to evaluate        the effectiveness
of one of its            procedures           in its       fuel   conservation            program--
optimum        descent       landings--         should       be expanded        to provide
for monitoring             the entire           program.

        Airport         congestion      increases      the flight      times                 of many
airline      flights,         resulting      in a waste      of millions                   of (1)
gallons      of fuel,         (2) hours      of delays     to passengers,                       and
(3) dollars           in unnecessary         operating     costs    to the                 airlines.



                                                  43
FAA efforts      to        reduce    congestion,               primarily      through          quotas
and flow-control              procedures,        have          been ineffective.

        Other        initiatives            undertaken           by FAA, however,            offer
promise        for     reducing         airport        congestion         and delays         or
minimizing           their        impact      on fuel        consumption.            FAA’s develop-
ment of a Fuel Advisory                       Departure          Program      at Chicago’s
O’Hare       Airport          indicates         that     this     program,        when fully
developed          and expanded             to other         airports,        could    save a con-
siderable          amount        of the fuel           now consumed           by extensive         de-
lays.        However,           more fuel         could      be saved       in this      program        if
all    aircraft           were required             to take ground,             rather     than
airborne,          delays        when gates           and space        at the departure            air-
port     permit        this.

          Also,       the study          of delays        completed          at O’Hare     has identi-
fied      measures          which      can reduce         the cost         of delays     there       by
$16 million             to $34 million,             and studies            are now underway            at
seven other             major       delay    airports.           Although       FAA   has     no   de-
finitive          plans        now for making           studies        at other      major      delay
airports,           it is developing              additional           in-house      capabilities
that      will      permit        it to perform           such studies          at a reduced
cost.          This     effort       to reduce         cost    has merit;         however,
additional            benefits         might     be realized           by performing          such
studies         now at other             major    delay      airports.

        Other       matters      which     we believe             indicate        that     FAA has
not given         its    fullest      attention      to         conserving          aviation    fuel
include

         --failure          to  help   one of            its   regions     develop     fuel
             efficient        ATC procedures                for metering       and spacing
             aircraft        and delays       in         accepting     this    concept      for
             nationwide         implementation                and

         --failure      to develop      and provide        to field     offices
             program   guidance     for    evaluating        the trade-offs                        between
             noise   abatement     and fuel      conservation        objectives.

        Noise     abatement        and fuel       conservation            can be complemen-
tary    but can also          result     in conflicts,            such as those           that
occurred       at some airports             reviewed.          Since      both    issues      are
of national         importance       , no one issue            should       be taken      lightly
or given       precedence        over    the other         without        fully     evaluating
the trade-offs          between       each.       To resolve          conflicts        when they
occur,     FAA should         explore       the feasibility             of establishing
program      guidance       for    evaluating         trade-offs          between
noise     abatement       and fuel       conservation            objectives
and,    if feasible        , provide       such guidance            to its




                                                    44
field     offices.  This effort          should be undertaken           in consul-
tation     with EPA because of         its responsibilities           for noise.
RECOMMENDATION TO THE CONGRESS
------------------------------
       In our prior         report    (see p. 13), we recommended that
the Congress provide            CAB legislative        guidance  defining       cur-
rent national        objectives      for air transportation           and the ex-
tent to which increased             competition       should be used to achieve
those objectives.             To achieve     increased     fuel efficiency        in
the airline       industry,       we recommend that the Congress             establish
higher    airline      load factors       as one of its national          objectives
and provide       legislative       guidance      for achieving     this objective.
RECOMMENDATIONS TO THE SECRETARY
---------------------~~~~-~---~~
OF TRANSPORTATION
-----------------
        We recommend      that the Secretary         direct       FAA to give
greater    attention      to fuel conservation.               Specifically,
FAA should:
         --Establish   a monitoring    and reporting     system to pro-
            vide management with information        on the effectiveness
            of fuel conservation    procedures,     the frequency     with
            which these procedures     are used, and the fuel saved.
         --Require    aircraft     involved in the fuel           advisory   de-
            parture   program    to take ground delays            when possible.
         --Explore      the feasibility      of establishing        program
            guidance      to ,evaluate   trade-offs        between noise abate-          ’
            ment and fuel conservation             objectives     when conflicts
            occur and, if feasible,          provide       such guidance    to its
            field   offices     after   consulting       with EPA.
AGENCY        COMMENTS AND OUR EVALUATION
----------------------------------
CAB
        CAB stated    it had no authority           to require       the airlines
to comply with its standard            or any minimum load factor.                It
specified     that section      401(e)(4)     of the Federal          Aviation    Act
of 1958 (49 U.S.C. 1371(e)(4))             precludes      CAB from imposing
any term restricting         the airlines’        rights   to add to or change
schedules,      equipment,     accommodations,         and facilities         for
performing      the authorized      transportation        and services.
       CAB stated  that our illustrations              on the potential      fuel
savings   from operations  at Chicago’s              O’Hare Airport     (see p. 7)



                                         45
were subject         to misinterpretations           and should be eliminated.
CAB stated        that excluding        an equivalent      of 261 daily            flights
in the Chicago market to save 300 million                     gallons        of fuel,
as shown by our report,              implies     that all remaining            flights
would operate          with loo-percent        load factors.          CA5 stated          that
this    implication         was not only totally         impractical,         but would
also generate          intolerable      levels     of passenger       rejection         con-
sidering      the strong        peaks of demand by season, day of week,
and hour of day.
         In addition,       CA5 stated      that our cited        studies,       which
argue for higher          load factor       standards       (see p. 121, were
theoretically         designed    and consider         the airline      system as a
collection       of mutually      exclusive      city     pairs.     CAB believed
this was an unrealistic             description        of the character          of
supply and demand as it exists                 in the industry        today.        CAB
stated     that its staff       was reviewing          a massive body of daily
traffic      and capacity      data supplied         in its Domestic         Load
Factor     Case, which it hoped would make possible                     for the first
time a determination           of the amounts of passenger                rejection
that could be expected            if higher      load factors        were achieved
through      changes in supply.           It stated       that an analysis          of
this data would be available                in the near future,
       A loo-percent      load factor        would be needed to eliminate
the equivalent        of 261 daily      flights    in our Chicago illustra-
tions.       We recognize    that a loo-percent          load factor is
unrealistic,       but the illustration          was used to show that
there is room for substantial               improvement.
       The studies    we cite    that argue for higher            load factors
are theoretical      as to what will      actually      happen if the air-
lines   are deregulated,      but these theories          are based on the
actual   experiences     of the less regulated          intrastate     airlines.
The daily    traffic   and capacity     data obtained         and now being
analyzed    by CAB should shed additional           light     on this    sub-
ject.     However, without     an actual     test or experiment,           the
final   outcome of deregulation       will     remain theory.
FEA
       FEA stated    that our conclusions       appeared similar                     to
the views expressed       previously   by FEA toward achieving
conservation      in the air sector,    specifically
        --higher    load factors      should be an integral                  part    of
            any conservation     effort    and
        --CAB and FAA need to give                fuel    conservation         greater
           attention.

                                             46
       FEA, however,        did not believe        our recommendations             were
developed      in sufficient         detail   and depth to allow either              the
Congress or the Secretary               to implement    legislation        or
programs     aimed at eliminating            energy inefficiencies.              FEA
stated    that our discussion             of CAB’s regulatory        practices
and policies       lacked     sufficient      depth and analysis,          which may
be why there were no recommendations                  to CAB. FEA be1 ieved
a complete       and balanced        report   should have included           an in-
depth examination          of CAB policies        and procedures        which will
continue     to play a major role in determining                  future     airline
load factors       despite     the movement toward regulatory                reform.
       FEA also believed          that agency response   to the Energy
Policy   and Conservation           Act has been somewhat passive  and
that our report    would         be remiss if it did not include
       --a     review and analysis          of   the   reports    submitted       under
             section  382(a) (3) of       the    act   and
       --each    agency’s      progress,   or lack thereof,       in response
          to section      382(b) of the act, which requires            the
          issuance     of an energy impact statement           for all major
          regulatory      actions     (the definition  of “major”        to
          be determined        by each agency through      rulemaking
          proceedings).
        Our report     shows the tremendous       waste in jet fuel that
results    from the unused capacity           of our airlines       and demon-
strates    in sufficient     depth and detail         that this waste has
been largely       ignored.    Further , the report         discusses    four
major areas which offer         opportunities       for increasing       load
factors    to reduce this      unused capacity        and conserve     fuel
or use it more efficiently.            In addition,       the report     draws
attention     to another    study which discusses           some of these
same areas as well as others.
        Because the Congress           is attempting        to reform        the regu-
latory     structure      of the airline        industry,       one of the major
factors      having an impact on load factors,                  we believed          it was
appropriate        to direct     our recommendation           to the Congress.
By providing         CAB with legislative          guidance      for increasing
fuel efficiency         through     higher    load factors,         the Congress
 in effect      would be requiring          CAB to achieve         a load factor
that the Congress considers               reasonable.         Such a mandate
should favorably          affect    the way CAB exercises             all    its regu-
latory     powers.      If complete       regulatory      reform or a mandate
for CAB is not forthcoming,               the report      contains        sufficient
 information       on other measures that the Congress could take
to help increase          load factors       and thus conserve            fuel.


                                           47
          FAA and CAB reports     pursuant   to section     382(a)(3)      of
 the act pertain     to laws and regulations        which induce the
 inefficient     use of fuel.      FAA and CAB issued these reports
 in December 1976 and February          1977, respectively,        when our
 review had been substantially          completed;    therefore,      they
 were not reviewed      in detail.
         We also did not review FAA's and CAB's efforts                        to comply
 with section       382(b)     of the act.         The issuance       of regulations
 defining    major actions          for which energy impact statements
 will    be required       does not in itself          conserve     fuel,     which
 was the area of our concern.                 However,      agency efforts        to
 promptly     comply with the requirements                of this     section     with
 the issuance       of meaningful         regulations      also indicates         an
 agency's     desire     to give energy conservation              the attention
 it deserves.        In this respect,           it took CAB about a year to
 issue proposed        regulations        and FEA's comments on them indi-
 cate that CAB's proposals               were less than meaningful.               FAA
 issued proposed         regulations        on March 31, 1977.           Although
 this was 15 months after              the law's      enactment,      FAA had issued
 interim    guidance       in February       1976 to require        energy consump-
 tion to be considered            for each regulatory          action      promulgated.
 FAA
 a--
          FAA stated      that our recommendation                that FAA establish
  a monitoring        and reporting          system for its fuel conservation
  procedures      reflected        a basic misunderstanding                of FAA's role
  in fuel conservation.              FAA viewed its role as one of pro-
  moting    and encouraging           fuel conservation            by system users
  and providing        a safe,      efficient        systems environment            within
  which fuel conservation               techniques        or strategies       may be
  practiced     by the users,           as illustrated         by its recent         air-
  space procedural          modifications          to accommodate profile
  (optimum)     descents.         FAA said it had no statutory                   authority
)to require       compliance        with fuel conservation               programs      and
  that the success of such programs                     requires     the cooperation
  of controllers,         airlines,        and airport        operators.         Further,
  it stated     that it had neither              the staff       nor resources         to
 monitor     program effectiveness               and believed        this,     if required,
  should be assigned            to FEA or the soon-to-be-formed                   Depart-
 ment of Energy.
        In response     to our recommendation       that aircraft                  be
 required     to take ground delays when possible           in FAA's                fuel
 advisory     departure   program,     FAA stated   that participation
 in this program is strictly           voluntary   and that there                  is no
 basis    for FAA to dictate       to the airlines     where delays                  will
 be taken.      FAA, however,     stated     the FAD program is in                   the



                                            48
financial      interest     of the airlines    and this alone should
motivate     them to achieve         maximum savings  from the program.
In addition,        FAA stated     it was gathering   data it hopes will
influence      the airlines      to accept ground delays.
        FAA stated        that our discussion         in chapter            4 on the
efficiency        of the ATC system ignored             several         important        fac-
tors and accomplishments.                 FAA stated      that,       although       airline
operations        have declined , general          aviation         operations         have
increased       significantly.          In addition,        the introduction               of
wide-body       jets during        this period     has required            greater       sepa-
ration     between aircraft           because of wake vortex               problems        with
safety,      the primary        oonsideration.        FAA stated           that,     as a
result,      delays     have increased         due to limited           airport      capacity
rather     than a decline          in the ATC system’s            efficiency.            FAA
stated     that wide-body          jets have enabled          airlines         to carry
more passengers          a flight,      which has led to greater                 effi-
ciency.        FAA stated       that air carrier        revenue ton miles a gal-
lon, which it believed               was a better     measure of efficiency
than aircraft          operations,      had risen over 30 percent                  since
1969.
        FAA stated     that it recognized          the need to study noise
abatement/fuel       conservation     trade-offs         as evidenced      by
actions    already     underway in this area.             (See p. 37.)        FAA
was hopeful      that one of its studies             would yield     guidance
for application        where operational        flight     changes proposed
for environmental         purposes   impact negatively           from a fuel
conservation       sense.
        FAA’s revised        gate-hold,         flow control,      and ATC pro-
cedures were designed              for implementation          by ATC facilities
and air traffic          controllers.           Also FAA’s field        offices     were
directed     to revise       their     procedures       to provide      for maximum
use of profile          descents      in accordance        with specific        require-
ments prescribed           by FAA. Surely           when an agency establishes
procedures      or procedural           requirements       for implementation          by
its field      offices,      its role is more than that of encouraging
or promoting         compliance.          In addition,       FAA has sufficient
power and tools          to assure that pilots             and aircraft       comply
with ATC instructions.                For example,        under gate-hold        pro-
cedures air traffic            controllers         must clear    the aircraft         to
leave the gate or the airport,                    and under ATC procedures
controllers        are to allow aircraft              to operate    at higher
altitudes      and assign cruise            altitudes      best suited       to fuel
efficiency.
        In authorizing   increased use of simulators                        for pilot
training,     FAA’s role is to promote and encourage                          as it is




                                             49
in  the case of those programs   beyond  its                              regulatory        control.
(See p. 23.)   However,  even these efforts                                 should       be moni-
tored to determine where its promotional                                  efforts        should be
directed.
         Since      FAA established                these      fuel    conservation            programs
and many of the related                       procedures         require       implementation
by its      own facilities,                 FAA should          monitor      them.         FAA has
directed        its     field      facilities            to evaluate         the progress and
effectiveness             of profile            descents        and local        flow-traffic
management          (see pp. 22 and 33),                    and it should             assign      the
necessary         staff       and resources              to monitor        all      its    fuel     con-
servation         efforts.           An effective             monitoring         and reporting
system      would       enable       FAA to determine                whether       field      offices
are maximizing              the use of these                procedures         and would          provide
data     on the frequency                 with     which      these     procedures           were used,
thus     enabling         more reliable              estimates        of the fuel            saved.
In addition,            periodic          reports        from    the airlines            should       be
requested         to confirm           the effectiveness                of FAA’s efforts               and
to provide          data      on the effectiveness                   and fuel         saved     for
fuel     conservation            procedures           beyond       FAA’s direct            control.

        A reading        of the FAD procedures              indicates        that     this
program      was intended        to be more than voluntary.                      Under      these
procedures         FAA was to have the authority                    to assign       later
departure        clearance     times       to reflect       delays      at the destina-
tion    airport,       to spread       delays     equitably         among all       system
users,      and to approve         and disapprove           airline       re?juests       to
take    airborne       delays.      If     the judicious          use of these          powers
is inadequate          to assure       aircraft       take ground         delays      when
possible,        FAA could     make such procedures                 mandatory       by adop-
ting    them as regulations.

        Concerning         the ATC system’s             efficiency,          general       avia-     ’
tion    operations         may have        increased        significantly           nationwide,
but at the 25 airports                 experiencing           the greatest          delays       and
accounting         for   almost      75 percent          of all      delays,      total     opera-
tions,      including        both general          aviation         and airlines,          de-
creased       by almost        1 million        between       1969 and 1975.             Decreases
in operations           occurred       at 19 of the 25 airports                   and increases
occured       at six airports.               Wide-body        jets     do require        greater
separation,          but these       jets     accounted         for only      about      14 per-
cent    of the hours           flown     by all      turbine-powered            aircraft         in
1975.

         FAA’s comment       that   delays   increased                   because    of limited
airport      capacity    rather     than a decline                    in the ATC system’s
efficiency       implies     that   FAA has little                    control    over  airport
capacity.        Such implications,        however,                   are inconsistent         with




                                                   50
other   FAA statements.          For example,     in its fiscal         year 1978
budget hearings,        FAA stated      that savings      in traffic       delays
and fuel costs of a more efficient               ATC system could offset
any extra    research       and development      cost.      Also,     FAA’s lo-
year national       aviation     system plan for 1977-86 estimates
that 40 percent        of delays      could be reduced by airport             and
ATC system improvements,            use of secondary        airports,      and
upgrading    existing       or building     new airports.          Regarding     air-
port improvements,          FAA administers      an airport        and airway
development     program to identify          the type and cost of develop-
ment needed for airports            and provide     grants      for airport      plan-
ning and development.            Further,    Chicago’s      O’Hare delay task
force   study indicated        that FAA could do more to minimize
delays    or their     impact.
       Air    carrier    revenue ton miles per gallon             is a more
useful      measurement     of fuel efficiency         than a measurement         of
ATC system efficiency.              Aircraft   operations      have been the
traditional        means of measurement         in FAA; for example,         they
are used to account           for delays     over 30 minutes        (see p. 19),
establish      ATC towers,       determine    ATC tower and center         staffing
requirements,         and measure controller        productivity.
         The 30-percent      increase      in revenue ton miles per gallon
since 1969 shows that airlines                 have become more fuel effi-
cient     by reducing     their    level     of operations,        introducing
wide-body      jets with greater         capacity,      and increasing         passen-
ger load factors        from 50 to 55 percent.              Although      the intro-
duction     of the wide-body         jet has enabled        airlines       to carry
more passengers       on a flight,         the full     potential       of these
aircraft     has not been realized.              CAB data on departures            in
the continental       United      States     in 1974 showed that 62 to 70
percent     of the wide-body         jet departures        had load factors
of 50 percent       or less and, when adjustments                 were made to
reflect     standard    seating      arrangements,       78 to 82 percent          of
wide-body      jet departures        had load factors         of 50 percent        or
less.
EPA
W-M
        EPA concurred   with the general          recommendations     to the
Secretary    of Transportation,       but urged that we also recom-
mend that FAA more fully        investigate         towing aircraft     with
auxiliary    power, such as tow trucks,             to move aircraft     from
the gates to the runway takeoff            position       for both noise and
fuel conservation     benefits.
      According to FAA; aircraft      towing             has been investigated
and found to be economically     infeasible               unless   the price   of
fuel  increased 150 to 200 percent       over            1974 prices.      In


                                          51
addition,         a number    of operational            problems      would  have to
be overcome.            The Urban    Systems        Research       and Engineering
study      (see p. lo),       which    included         a review      of an FAA-
sponsored         study    by Lockheed      Aircraft         Service    Company on
alternative          methods    for moving        aircraft        on the ground,
stated       that

        --current         towing       equipment        was   not    adequate      to   handle
            all   taxiing        aircraft;

        --complete      towing    systems,              which  also guide   the            air-
            craft,   would     be necessary              to save a reasonable                level
            of fuel;

        --it        was likely     that    due to their     high   cost,  towing
               sytems   would    be installed       at only    the 25 largest
               and busiest     airports       where   they  could   be used exten-
               sively   each day:       and

        --towing      systems     would        also      benefit         the environment
            by reducing      pollution           and     noise      at     the airport.

         The Urban        Systems        study    estimated       that   1990 baseline
fuel     consumption         could       be reduced       250 million       gallons,        or
1.2 percent,,,        with     towing        at the 25 largest         airports.          The
study      concluded       that      the costs       of installing         and operating
such systems          must be weighed             against     the benefits         on a
case-by-case          basis      and that       the appropriate          Federal      role
appears       to be to insure              that   such investments          are not dis-
criminated         against       relative       to other     categories          of airport
facility        development.




                                                   52
APPENDIX I                                                                     APPeNDIX I

             AIRPORTS        DESIGNATEDBY FAA FOR INITIAL
             --------I-----------------------------
     IMPLEMENTATIONOF A METERINGAND SPACING PROGRAM
     ------------------------------------------------
     O’Hare,       Chicago,     Ill.
     La Guardia,       New York,          N.Y.
     Kennedy International,                New York,            N.Y.
     Washington       National,          Washington,            D.C.
     Hartsfield,       Atlanta,          Ga.
     Lambert Field,           St. Louis,            MO.

     Cleveland-Hopkins,                Cleveland,         Ohio
     Newark, Newark, N.J.
     Philadelphia        International,               Philadelphia,          Pa.
     Pittsburgh,       Pittsburgh,             Pa.
     Logan Field,        Boston,         Mass.
     Miami International,                Miami,       Fla.
     Dallas-Fort       Worth Regional,                Irving,      Tex.
     Los Angeles        International,               Los Angeles,         Calif.
     San Francisco        International,                  San Francisco,           Calif.
     Stapleton,       Denver,          Colo.




                                               53
APPENDIX II                                                                         APPENDIX II

                               CIVIL     AERONAUTICS               BOARD
                                       WASHINGTON.        DC.   20420




                                              May 5, 1977




    Mr. Henry Eschwege
    Director
    Community and Economic Development               Division
    Il. S. General Accounting Office
    Washington,   D. C. 20548

    Dear Mr. Eschwege:

         The Board has reviewed the draft of your proposed report to
    Congress on "Effective  Fuel Conservation  Programs Could Save Millions
    of Gallons of Aviation  Fuel", as requested in your letter  dated
    March 10, 1977. Our comments are as follows:

           1.   Your illustrations      on the potential       fuel savings from
    operations    at Chicago's O'Hare airport          are subject to misinterpreta-
    tion and should be eliminated         from this study.        It is stated that
    if all the empty seats transported           in the Chicago markets were
    removed by excluding       an equivalent    of 261 daily flights,         300 million
    gallons of fuel could be saved.           This implies,      however, that all
    remaining   flights    would operate at 100 percent load factors.
    Considering     the strong peaks of demand by season, day of week and
    hour of day, this implication         is not only totally        impractical,    but
    it would also generate intolerable           levels of passenger rejection.

           2. The studies cited here that argue for higher load factor
    standards are theoretically          designed and consider the airline        system
    as a collection      of mutually     exclusive  city-pairs.     This is an
    unrealistic     description    of the character      of supply and demand as it
    exists    in the industry     today.     The Board's staff is currently
    reviewing    a massive body of daily traffic          and capacity  data supplied
    in the Domestic Load Factor Case, Docket 27417.               It is hoped that
    these data will.       for the first     time. make possible    a determination
    of the amounts of passenger rejection           that-can be expected to result
    from higher load factors         achieved through changes of supply.          An
    analysis    of these data should be available          in the near future.

          3.
                                 [See GAO note,                         p.   55.1




                                                     54
APPENDIX II                                                                           APPEND’IX II



    Mr. Henry Eschwege           (2)


                                      Although   the Board has the power to
     establish    load factor standards for rate-making         purposes, the Board
     has no authority       under the Act to require the air carrier6         to com-
     ply with this load factor standard or any minimum load factor.
     Section 401(e)(4)       of the Federal Aviation     Act of 1958 (49 U.S.C.
     1371(e)(4)),      in effect,   precludes the Board from imposing any term
     restricting      the right of an air carrier      to add to or change sched-
     ules, equipment, accommodations and facilities            for performing    the
     authorized     transportation    and services.   [See GAO note below.]

            We thank   you for    the opportunity        to comment on this   draft    study.




                                                    Acting     Chairman




GAO note:        Portions of this letter     have been deleted                                  because
                 they are no longer   relevant   to the matters                                  dis-
                 cussed in this report.




                                                    55
APPENDIX      III                                                                  APPENDIX              III



                    FEDERAL ENERGY ADMINISTRATION
                                 WASHINGTON,   D.C.   20461

                                    APR2 0 1977
                                                                         OFFICE   OF   THE   ADMINISTRkTOR




 Mr. Monte Canfield,    Jr.
 Director
 Energy and Minerals    Division
 U.S. General Accounting      Office
 Washington,  D.C.   20548

 Dear Mr.     Canfield:
 The Federal       Energy Administration              (FEA) appreciates      this
 opportunity       to review and comment on the General Accounting
 Office's       (GAO) draft      report   entitled        "Effective    Fuel Conser-
 vation      Programs Could Save Millions               of Gallons     of Aviation
 Fuel."       FEA has long concerned           itself      with the need to and
 the opportunities           for achieving       fuel conservation        within   the
 energy intensive          air transportation           industry     and as such, is
 particularly        interested      in the GAO's views and recommendations
 as they relate         to energy conservation             in the air industry.
 In general,        we were pleased to note that the basic conclusions
 reached by ,the GAO in this                report    appear to be similar             to
 the views expressed             previously       by the FEA toward achieving
 conservation         in the air sector.             These were that higher              load
 factors       should be an integral            part of any conservation               effort
 directed       toward the air industry              and that the Civil
 Aeronautics        Board (CAB) and the Federal                 Aviation     Administration
  (F-1,      the agencies        responsible       for regulating         the air
 industry,        need to give fuel conservation                  greater    attention        in
 carrying       out their      respective       responsibilities.            While we do
 not disagree         generally      with the thrust           of the GAO's recommenda-
 tions     to Congress and the Secretary                 of Transportation,            there
 are a number of areas wherein                  the report        needs to be corrected
 and supplemented          if it is to serve as a basis for legislative
 or administrative           program initiatives.                These areas are outlined
 in the enclosed          detailed      comments.
 I hope that our comments on this report       will    prove useful to
 your staff   in the preparation  of the final      report.   In
 addition   to the FEA comments referred   to in the GAO report,




                                               56
APPENDIX III                                                    APPENDIX III


                                    -2-


    the FEA has conducted     several     studies   on airline   conservation
    measures which might be useful         to the GAO. If you would like
    a copy of any of these reports,          or have additional    questions
    regarding    the FEA's activities      in this area, please contact
    Mr. Robert Bowles, National       Programs,     Conservation   and
    Environment,    telephone   254-9755.




    Enclosure




                                      57
APPENDIX III                                                                      APPENDIX III



                           DETAILED COMMENTS--GAO REPORT
                "Effective    Fuel Conservation     Programs Could
                Save Millions     of Gallons    of Aviation  Fuel"

  There is a basic similarity             between the general        thrust    of
  the GAO report       recommendations        and the historical        FEA views
  on energy conservation          in this sector.       FEA has indicated,
  for example,      that higher       load factors    should be integrated
  into energy conservation            programs for this       sector    and that
  the regulatory       agencies     involved     (CAB and FAA) need to give
  energy efficiency        and energy conservation          a higher priority.
  The recommendations,         however,      may not be sufficiently
  developed    or have enough discussion            in sufficient       detail    or
  depth to allow either         the Congress or the Secretary               to
  implement    legislation      or programs aimed at eliminating               the
  energy inefficiencies.
  The GAO's discussion              of the regulatory          practices        and policies
  of the CAB seem to lack sufficient                      depth and analysis.              This
  may be why there is an absence of any recommendations                                 to the
  CAB. If the air industry                   is to be expected          to conserve        fuel
  in any significant              quantities      in the future,          the air industry
  will     necessarily        have to achieve considerably                  higher    load
  factors.       Despite        the movement toward regulatory                  reform,      the
  policies      and practices          of the CAB will          still     play a major
  role in determining              what future      airline      load factors         will     be.
  Accordingly,         for a complete          and balanced         report,     the GAO
  should include           an indepth        examination      of the CAB policies
  and procedures           similar      to that regarding           the FAA policies
  and practices          already      contained      in this report.
  A major portion          of the draft        report     concerns     itself      with a
  review and analysis            of the reports         that the CAB and the FAA
  submitted      to Congress in response              to Sections        382(a)(l)      and
   382(a)(2)     of the Energy Policy              and Conservation         Act (EPCA).
  Accordingly,       the report        would be remiss if it did not also
  include     a review and analysis              of the reports        submitted       under
  Section     382(a) (3) of EPCA, as well as a review of each agency's
  progress,      or lack thereof,          in response to Section              382(b),
  which requires         the issuance        of an energy impact statement
  for all (Imajor"         regulatory      actions,       the definition        of "major"
  to be determined           by each agency through            a rulemaking         proceeding.
  The CAB issued its proposed rulemaking                      on December 22, 1976;
  the FAA, to the best of our knowledge,                      has yet to issue its
  proposed     rulemaking.          The FEA submitted          its comments and
  recommendations          to the CAB on March 16, 1977.                  A review of
  each agency's        response       to EPCA is necessary           to give to
  Congress a complete            picture     as to the impact of its efforts




                                                58
APPENDIX III                                               AP’PENDIX III


                                      2

  to set forth energy conservation     targets and improve energy
  efficiency  within the air industry.      Thus far, the response
  from the agencies involved has been somewhat passive and the
  GAO may wish to recommend that Congress strengthen this part
  of the EPCA.
  Attention   should also be directed to several     errors that   should
  be corrected before the report is finalized.'       They are:



                      [See GAO note        below.]



    2.      Throughout the discussion  of the CAB's load factor
            standard, reference in the text and tables refers
            to the load factors achieved by all certificated
            carriers.   The CAB's load factor standard is only
            applicable  to the 48 State operations  of the
            domestic trunk airlines.



GAO note:       Portions of this letter      have been deleted     becguse
                they are no longer    relevant   to the matters     dis-
                cussed in this  report.




                                      59
APPENDIX                 IV                                                                        APPENDIX   IV



                               OFFICE   OF THE   SECRETARY            OF TRANSPORTATION
                                            WASHINGTON,        0.C.     20590




 ASSlSTANr   SECRETARY
  FOR ADMINISTRATION

                                                                                  May   13, 1977
                                                                                           .




             Mr. Henry Eschwege
             Director
             Community and Economic Development                        Division
             U. S. General Accounting Office
             Washington,  D. C. 20548

             Dear Mr.         Eschwege:

             This is in response to your letter           of March 10, 1977,
             requesting    comments on the General Accounting          Office
             draft   report entitled    "Effective     Fuel Conservation
             Programs Could Save Millions          of Gallons of Aviation
             Fuel."     We have reviewed the report         in detail  and
             prepared a Department of Transportation            reply.

             Two copies         of the reply     are enclosed.

                                                          Sincerely,


                                                     LfiLtm4~~.
                                                         Edward W. Scott,                Jr.
                                                        Acting

             Enclosures         (2)




                                                          60
APPENDIX IV                                                                              Al!PENDIX       IV


                           DEPARTMENT OF TRANSPORTATION REPLY
                                           22
                           GAO DRAFT REPORT OF MARCH 10, 1977
                                           ON
                         EFFECTIVE FUEL CONSERVATION PROGRAMS
                     COULD SAVE MILLIONS OF GALLONS OF AVIATION FUEL

                                  Department of Transportation
                                    Civil  Aeronautics Board .
                                  Federal Energy Administration

                                  SUMMARY OF GAO FINDINGS AND
                                          RECOMMENDATIONS

 The General Accounting  Office (GAO) has concluded that aviation  fuel
 conservation has not received  the full attention  it deserves and that
 more needs to be done by the Federal Government to conserve aviation
 fuel.

 Regarding    the Federal Aviation         Administration’s         (FAA) fuel     conservation
 programs,    the GAO states  that:

 1.   The FAA had not monitored            implementation      of its programs or required
      reports     on the frequency       that program procedures         were used and
      resultant     fuel saved.        In several     instances,the     GAO found that FAA
      fuel conservation         procedures were either         implemented    infrequently,
      impractical      to implement,       or ineffective,        The GAO reconrnends that
      the Secretary      direct     the FAA to establish         a monitoring    and reporting
      system to provide management with information                  on the effectiveness
      of its aviation       fuel conservation         procedures,

 2.   The FAA is developing         a Fuel Advisory      Departure     (FAD) program which
      is intended     to alert    airlines    of extreme delays        at destination
      airports    and permit them to adjust         their   flight     plans accordingly
      to minimize     the effects       of such delays on fuel consumption.              The
      GAO states    that FAA’s tests indicate          that the FAD program does
      conserve fuel,but       that considerably      more fuel could be saved if all
      aircraft   were required        to take ground rather        than airborne      delays
      whenever possible.         The GAO recommends that the Secretary              direct
      the FAA to require       aircraft     in the FAD program to take ground delays
      whenever possible.

 3.   Noise abatement efforts           had an adverse effect         on fuel conservation          at
      some of the airports          reviewed.    The GAO concludes         that both noise
      abatement and fuel conservation            are of national        importance      and neither
      should be given a precedence over the other without                     fully    evaluating
      possible     trade-offs      between objectives       of the two programs after
      consultation      with the Environmental        Protection       Agency.      The GAO
      recommends that the Secretary           direct     the FAA to explore         the feasibility
      of establishing         program guidance for establishing            trade-offs      between
      noise abatement and fuel conservation               objectives,      and if feasible,
      provide    such guidance to its field          offices,




                                                   61
APPENDIX IV                                                                                APPENDIX IV

   .2-


                                       PQSITION STATEMENT

  1.     The first     reconnaendation     reflects       a basic misunderstanding            of FAA'S
         role in fuel conservation.             FAA’s role is one of promoting                and
         encouraging      fuel conservation        by system users and of providing                 a
         safe, efficient        systems environment         within     which fuel conservation
         techniques/strategies         may be practiced          by the users.         An illustration
         of the latter       is the airspace/procedural             modifications       recently
         developed      to accommodate the so-called             “profile     descent” which may
         be an enormous fuel saver in the months to come. The FAA has no
         statutory     authority     to require      mandatory compliance           with fuel
         conservation       programs.     The success of such programs requires                    the
         cooperation      of controllers,       airlines,      and airport        operators.       The
         FAA has neither        the staff    nor resources         necessary      to monitor     the
         effectiveness       of these programs.           This function,        if required,       should
          logically    be assigned      to an energy-oriented            agency such as the
         Federal Energy Administration              or the soon-to-be-formed            Department
         of Energy.

  2.     Air carrier      participation        in the FAD program is strictly   voluntary
         and there is no basis on which the FAA can dictate               to the airlines
         where delays will          be taken. The FAD program is in the best
         financial     interests        of the airlines  and this alone should motivate
         them to achieve maximum savings from the program.                However, the FAA
         is gathering       statistical       data which may be used to influence     the
         airlines    to accept ground delays if the results           are favorable.

   3.    The FAA does recognize            the need to study noise abatement/fuel
         conservation        trade-offs      as evidenced by actions            already underway
         in this area.          As part of a major contractual               study program, the
         agency will      be looking       into the operational          cost increments,
         including     fuel,      of future     class aircraft       related     to noise abatement
         technology.         Based upon considerations            such as fuel costs,          it is
         intended    that appropriate           future    noise abatement goals will             be
         established       frown this effort.           In addition,      the FAA is in the
         preliminary       stage of another study relating                to assessment of fuel
         costs associated          with noise abatement operational                requirements.
         Hopefully,      this effort       will    yield   guidance for application            where
         operational       flight     changes proposed for environmental                 purposes
         impact negatively          from a fuel conservation            sense.

         The implication           in the report     that noise abatement and fuel conservation
         efforts      are rarely,       if ever,    complementary      is not true.        For example,
         a recent regulatory           action was taken by FAA to require               turbojet    aircraft
         having a maximum weight greater                than 75,000 pounds to comply with noise
         standards       contained      in Federal Aviation       Regulations      Part 36.      In taking
         this action,          FAA specified      an d-year compliance        schedule to allow
         sufficient         time for the development        of new technology          aircraft    as a
         viable     replacement       option     for the carriers      involved.       The new technology
         aircraft      will     bring with it operating        efficiencies,       including     fuel,    that
         would not be available             through an immediate retrofit            response by the
         carriers      to comply with the regulation.




                                                     62
APPENDIX IV                                                                               AP'PENDIX IV


 -3-

 Additional     comments or observations            on the GAO draft        report     are shown
 below:

 1.    The introduction        on page 1 of the report does not specify              whether
       the 17 billion      gallons    number includes        military   and international
       fuel consumption.         If so, this should be clearly            stated.
                              [See    GAO note below.1
       By way of comparison,         the report      should note that automobiles         consume
       about 59 percent of the transportation                share of energy.       Also,  the
       10 percent of the transportation              share of’energy      consumed by airlines
       is equal to about 5 percent of total                U. S. energy consumption.
                              [See    GAO note         below.]
 2.    There is an error in the last paragraph on page 4.                      The FAA’s seven
       point jet fuel conservation           program was announced as a result            of the
       President’s     fuel allocation       program in response to the Arab oil embargo,
       not 8s a result       of the planning        conference.
                             [See     GAO note below.1
 3.    The first     paragraph on page 5 is misleading.               While it is true that the
       FAA is looking      for long-term       actions     to conserve jet fuel,       the GAO report
       incorrectly     assumes a 1973 perspective;            i.e.,   1977-1982 is no longer the
       long term,       Looking at alternatives          from the point of view of 1977, short,
       intermediate,      and long-term      options would reflect          time periods within
       which primarily       operational,      airport     capacity,   and technological      options
       could be implemented,         respectively.
                             [See GAO note              below.]
 4.    The discussion        in Chapter 4 of the GAO report which states                      that the
       air traffic      control     system has become less efficient                 since 1969 ignores
       several     important     factors.       Although    air line operations           have declined,
       general aviation         operations      have increased       significantly.           Furthermore,    t
       the introduction         of wide-body       jet aircraft      during this period has
       required     greater     separation      between aircraft        because of the wake vortex
       problem.      Safety is, of course,            the primary objective.              As a result,
       delays have increased           due to limited       airport     capacity       rather    than a
       decline     in the efficiency        of the air traffic          control      system,      Wide-body
       jet aircraft       have enabled airlines           to carry more passengers per flight
       which has led to greater            efficiency.        Air carrier       revenue ton miles per
       gallon    (RTM/G), which is a better              measure of efficiency            than aircraft
       operations,      have risen over 30 percent since 1969.                      The GAO report
       should note the accomplishments                 to date as evidence of the Federal
       agencies ’ and aviation           community’s      dedication      to fuel conservation
       efforts,

  5.   On page 51, the second sentence of the second paragraph should be
       changed by deleting      the last three words and adding the following:
       ,I . , , , airspace management, national and international  air commerce. ”
                             [See GAO note              below.]


                             $7
GAO note:          Page references     in this                    letter       refer
                   to the draft    report.

                                                     63
APPENDIX V                                                                                   APPENDIX V



            UNITED     STATES     ENVIRONMENTAL               PROTECTION          AGENCY
                                   WASHINGTON.         D.C.   20460

                                      MAY1 P 1977


                                                                                              OFFICE    OF
                                                                                  PLANNING     AND     MANAGEMENT




   Mr. Henry Eschwege
   Director,   Community & Economic Development               Division
   United States General Accounting   Office
   Washington,   D.C.   20548

   Dear Mr.   Eschwege:

         We have reviewed the draft   report  entitled  "Effective                    Conservation
   Programs Could Save Millions    of Gallons of Aviation     Fuel."

          We concur with the general recommendations                 to the Secretary     of
   Transporation.         However, we recommend that GAO recognize              that 'trade-
   offs " between fuel conservation               and noise abatement are not always
   required.      In particular,       requiring    aircraft    to take ground, rather       than
   air delays,       as recommended by GAO has positive            noise abatement as well
   as fuel conservation          implications.        In addition,     several  other fuel
   conservation       procedures     which FAA has attempted         to implement have positive
   noise abatement potential.              The FAA's "Seven-Point        Jet Fuel Conservation
   Program",      for example,     includes      "Revised gate-hold      procedures"   and
   "Increased       use of simulators        for training    and testing."      If both of
   those procedures        were implemented        by FAA, some noise abatement would be
   realized     from them.

         In addition,  we recommend that GAO urge the FAA to investigate       more
   fully   the use of auxilliary power (e.g. tow trucks)   to move aircraft
   from the gate to the runway take-off    position.  This measure will     also
   have both noise abatement and fuel conservation    benefits.

                                                         Sincerely       yours,




                                                         Richard D. Redenius
                                              Acting      Assistant   Administrator
                                                 for     Planning   and Management




                                                 64
APPENDIX VI                                                    APPENDIX VI
                 PRINCIPAL        OFFICIALS RESPONSIBLE
                 ----------------I--------------                     *
                  FOR ADMINISTERING ACTIVITIES
                  ----------------------------
                      DISCUSSED        IN THIS REPORT
                      ------------------------
                                                        Tenure of Office
                                               -------------------------
                                                    From
                                                      w-v                To
                                                                         --

                  DEPARTMENT         OF TRANSPORTATION
                  ----------------------------
SECRETARYOF TRANSPORTATION:
   Brock Adams                                Jan.     1977       Present
   William T. Coleman, Jr.                    Mar.     1975       Jan.    1977
   John T. Barnum (acting)                    Feb.     1975       Mar. 1975
   Claude S. Brinegar                         Feb.     1973       Feb. 1975
   John A. Volpe                              Jan.     1969       Feb. 1973
                 FEDERAL      AVIATION ADMINISTRATION
                 -------------------------------
ADMINISTRATOR:
   Langhorne M. Bond                          May      1977       Present
   Quentin S. Taylor (acting)                 Mar.     1977       May     1977
   John L. McLucas                            Nov.     1975       Mar. 1977
   James E. Dow (acting)                      Apr.     1975       Nov. 1975
   Alexander P. Butterfield                   Mar.     1973       Mar. 1975
   John H. Shaffer                            Mar.     1969       Mar. 1973
                     CIVIL     AERONAUTICSBOARD
                     -----------------------
CHAIRMAN:
   Alfred Kahn                                June     1977       Present
    Lee R. West (acting)                      May      1977       June 1977
    John E. Robson                            Apr.     1975       May     1977
    Richard J. O'Melia (acting)               Jan.     1975       Apr.    1975
    Richard D. Timm                           Mar.     1973       Dec. 1974
    Secor D. Browne                           Oct.     1969       Mar. 1973
           FEDERALENERGYADMINISTRATION (note a)
           -------------------------------------
ADMINISTRATOR:
   John F. O'Leary                               Feb. 1977 Present
   Gorman Smith (acting)                         Jan. 1977 Feb. 1977
   Frank Zarb                                    Dec. 1974 Jan.    1977
   John Sawhill                                  Apr. 1974 Dec. 1974
   William Simon                                 Dec. 1973 Apr.    1974
   John Love                                     June 1973 Dec. 1973
a/The Federal Energy Administration           superseded      the Federal
   Energy Office.



                                    65
APPENDIX VI                                              APPENDIX VI
   .
                                                Tenure of Office
                                        -----1----1--------------
                                             From
                                             m-1-                 T_2
                ENVIRONMENTAL           PROTECTIONAGENCY
                -------------------------------
ADMINISTRATOR:
   Douglas M. Costle                    Mar.    1977        Present
   John R. Quarles, Jr. (acting)        Jan.    1977        Mar. 1977
   Russell E. Train                     Sept.   1973        Jan.    1977
   John R. Quarles, Jr. (acting)        Aug.    1973        Sept. 1973
   Robert W. Fri (acting)               Apr.    1973        Aug. 1973
   William D. Ruckelshaus               Dec.    1970        Apr.    1973




                              66
    Copies of GAO reports are available to the general
    public at a cost of $1.00 a copy. There is no charge
    for reports     furnished      to Members       of Congress and
    congressional     committee        staff members.       Officials   of
    Federal,    State, and local governments               may receive
    up to 10 copies free of charge.                 Members        of the
    press; college      libraries,    faculty     members,      and stu-
    dents; and non-profit           organizations    may receive up
    to 2 copies free of charge. Requests for larger quan-
    tities should be accompanied              by payment.

    Requesters entitled   to reports        without     charge    should
    address their requests to:

                 U.S. General Accounting     Office
                 Distribution Section,   Room 4522
                 441 G Street, NW.
                 Washington,  D.C. 20548

    Requesters   who   are required     to pay for reports
    should   send their requests    with checks or money
    orders to:

                 U.S. General Accounting           Office
                 Distribution Section
                 P.O. Box 1020
                 Washington,  DC. 20013

    Checks or money orders should be made payable                      to
    the   U.S. General    Accounting    Office. Stamps                 or
    Superintendent     of Documents   coupons   will not               be
    accepted.   Please do not send cash.

    To expedite   filling your order, use the               report num-
    ber in the lower left corner and the                    date in the
    lower right corner of the front cover.




I   GAO reports are now available on microfiche.   If such
    copies will meet your needs, be sure to specify that
    you want microfiche  copies.
AN EQUALOPPORTUNITY    EMPLOYER,

       UNITEDSTATES                            POSTAGE   AND    FEES   PAID
 GENERALACCOUNTINGOFFICE           I’.   S.   GFNERAL    ACCOUNTING           OFFlCE

   WASHINGTON, D.C. 20548

        OFFICIAL BUSINESS
  PENALTY FOR PRIVATE USE,9300                                    THIRD CLASS