The argument over user fees for general aviation activities doesn’t seem to be going away. The President keeps putting them back into his budget proposals. Outside the U.S., user fees have had significant effects on GA activities in other countries. A recent article (http://www.aopa.org/whatsnew/newsitems/1999/99-2-002.html) highlighting significant increases in New Zealand, an example that should scare us here in the U.S.
The concept of user fees has seen strong opposition by aviation organizations, the strongest opponent being AOPA, and the vast majority of the GA community, but that opposition hasn’t made the discussion go away. Perhaps it is time we think about this differently. What if we had to live with some sort of a user fee? Is there any user fee structure that we could manage, one that would actually do something positive for our aviation community? Many different proposals have been discussed ranging from pay for access to airspace to landing fees, per flight fees and flight plan fees. In many of these proposals unintended consequences would be difficult to foresee, but some simple ones may be easily forecasted. If we charge for airspace access it would be logical to think that pilots who wanted to avoid the airspace charges may avoid it, perhaps scud-running or landing at airports that would not be inside airspace, but that may not be the best location for their aircraft (think shorter runways, crosswinds, etc). Pilots seeking to avoid landing fees may do the same, and even if the aircraft are capable of and appropriately able to utilize airports that do not have overlying airspace, this may drive traffic volumes to airports that are not capable of managing them. Any proposal to incur flight plan filing fees may result in pilots avoiding filing them, the result being less coordination with ATC who provides traffic separation and potentially longer response times or increased costs in emergency situations. Safety could be jeopardized by the unintended consequences of user fee implementation.
Real economic evaluation is necessary in any fee proposal. While it is only my opinion, I don’t think the math will be accurate when contemplating revenue generation from most user fee implementation methods. If estimates of revenue generation are based on current traffic volume and pilot operational habits, any changes in these behaviors of any user fee implementation would not account for the changes that are made. Imagine the implementation of user fees for airspace usage. If pilots avoided entry into these airspaces in an attempt to avoid the fees, previous estimates of traffic volumes would not accurately represented any changed levels and thus the revenue estimates would be inaccurate. To calculate any economic value, we would have to be able to predict the changes in pilot behavior that would result from any changes made, then, and only then, try to calculate any real benefit.
Administration costs of user fees would have to be a part of the consideration. I am reminded of a trip to Cleveland Burke Lakefront Airport a few years ago which had a $5.00 landing fee for single-engine GA aircraft. I certainly consider this to be a very reasonable fee for the use of the airport, but can’t imagine that it is profitable. The fee was (at that time) not able to be paid in person. It required a person at the airport to keep track of landing aircraft, send a physical bill out (after researching who the aircraft owner was), the owner to receive the bill, send a check, and then the staff member to process the payment. By the time this process was completed, I can’t imagine that it was profitable in consideration of staff costs, mailing costs, and any other associated ancillary expenses. While this is a microcosmic example, it isn’t a great leap to think that any national program of tracking access, billing pilots, and administrating a program could become overly bureaucratic and would not in fact generate revenue (think about toll booths that don’t generate revenue in some locations, just generating enough revenue to pay for the staff to collect the tolls) that would offset our national costs for the aviation system. Logic in economics must be strongly focused upon if any real benefit is to be gained.
Of course this doesn’t mean that logic will prevail. Media and public perceptions help fuel the promotion of the viewpoint that GA aircraft are only toys of rich individuals and large corporate interests. We know this isn’t the case, that passionate individuals who enjoy GA flight are no different than similar individuals who enjoy boating, golf, scuba diving, or any other hobby. Corporations that utilize GA aircraft in their operations do so to enhance business efficiency and in many cases their success results in the employment of thousands of individuals throughout the country. This logic is hard to promote widely, and as a result, the user fee push continues.
So what if GA can’t win the fight against user fees? Is there any structure we could “live with” that would do any good?
Any per use fee is likely to incur more costs than revenue generation. Administration costs would need to be at a minimum if any user fee would actually generate revenue. An option may be modification of the aircraft registration fee much like most states have for motor vehicles. Currently, we are finishing the aircraft re-registration process that is allowing us to have a more accurate database of aircraft in our aviation system. The fee associated with this registration is minimal. If the registration fee was higher, perhaps even yearly, the revenue of this process could be used to assist in the support of our aviation system.
As a GA pilot, there are hooks I would want if we agreed to a higher aircraft registration fee. I would strongly advocate that any revenue gained from an aircraft registration fee would be mandated to directly flow back into our aviation system. Perhaps we could even go so far as to require that any fees generated from non-air carrier aircraft registration would be used only for support of systems at non-air carrier airports. I’m sure some other protections could be considered beyond these.
Maybe there would be multiple levels of registration. Registration for un-usable or non-airworthy aircraft could be completed on a less frequent timeframe, perhaps keeping with our 3-year registration process. A different level of registration, perhaps designated as an active use registration, could be applicable and might be required on a yearly basis. Aircraft owners who have aircraft that are not in a flyable condition or do not operate in the national airspace system could be exempt from the active use registration fee. Would we police this? I can’t imagine that it would be cost effective to go out and seek to find aircraft that were in violation, but it would make sense to incorporate a check of registration in FAA ramp checks as are current checks for airworthiness certificates, weight and balance, etc. I have confidence that our aviation participants would be good stewards of the system and self-comply if a reasonable fee were required, helping us avoid any further need for more onerous restrictions.
I know that it seems somewhat blasphemous for a strong supporter of GA such as me to talk about any consideration of a user fee, but I am concerned that we cannot avoid this forever. If we are ever going to end up with any fee, I would rather it be one that is manageable, one that is livable, and one that might actually help the GA system. Our country’s budget concerns must be solved, and general aviation won’t be able to stay out of the crosshairs forever. Any real solution that is not damaging to GA (and in reality, beneficial to the U.S. overall) must be simple, require low overhead for administration, and directly benefit the system that it supports.
I don’t like the idea of a user fee, and I am concerned that any implementation would not do any real good. Our government’s track record of collecting fees and having them actually support what they were intended for is not exactly spotless. If we had to subject our industry to any fee, some trust building would be needed. However, if, and I say IF, we could get to a point where we could trust that, perhaps it is time that we as an industry take charge of the discussion and consider if there are any workable solutions beyond just saying “No to User Fees.”