Good morning Mr. Chairman and members of the Subcommittee. I am Captain Dennis Dolan, First Vice President of the Air Line Pilots Association, International (ALPA). I appreciate the opportunity to appear before you in place of ALPA President, Captain Duane Woerth, who has testified at previous hearings on this subject. I want to assure you that he and I, as well as our entire Association, place the highest importance on identifying the causes and resolving the problem of delays in the air traffic control system.

At the first hearing on March 15th, ALPA presented five action items to address the question: "What are five things that your organization can do to help alleviate the problem of delays and limited capacity?" At the May 3rd hearing, an update was provided on these issues, and that is also my intent today.

To address item one: we will continue our high level of participation on the RTCA Free Flight Steering Committee to ensure that this committee is properly focused and defining systemic needs associated with delay and capacity issues, and that correct priorities are established to address these issues in a timely manner.

A quarterly meeting of the Free Flight Steering Committee will be held next week, on Wednesday, August 8th. Captain Woerth will be attending this meeting along with ALPA’s Director of Engineering and Air Safety, who is our key staff member on safety and air traffic issues. The main agenda item to be discussed at the meeting is the proposal to combine Free Flight with the FAA’s Operational Evolutionary Plan (OEP).

As noted at the last hearing, ALPA pilot and staff safety representatives are committed to work on all levels of RTCA activities. They will continue to stay involved with the RTCA Special Committees that develop minimum operational performance standards for equipment. ALPA will also make resources available to specifically deal with the RTCA Federal Advisory Committee, a functioning committee within RTCA that has been charged with facilitating the planning of National Airspace System (NAS) improvements based on the NAS Architecture.

As part of this effort, on July 24 through 26 the RTCA Free Flight Working Group began a work program to review and validate the NAS Architecture 4.0. ALPA representatives are an integral part of that work. The goals of this Work Group are to ensure that this Architecture properly addresses Free Flight Phase 1 and 2, Task Force 3, the Free Flight Action Plan, and other initiatives such as Safe Flight 21. Additionally, and of great importance, this Work Group needs to ensure that these initiatives can be traced back to the NAS Concept of Operations and to the Operational Evolutionary Plan (OEP). This work is critical to establishing a level of credibility to ensure that all of the stakeholders have confidence in the process, and that it directly relates to the proposal before the Free Flight Steering Committee regarding the management of the OEP.

Turning to the second item: we are working to improve our liaison efforts with NATCA to identify areas where our joint efforts may produce potential solutions to issues surrounding delays and capacity enhancement, and perhaps expedite their implementation. I was appointed to head this effort within ALPA and we have had two meetings with NATCA in the past several weeks. At our last meeting we came to an understanding of how our two organizations would work on areas of mutual concern and identified some technical areas that we have agreed to work on together. Among these are procedures for land and hold short operations (LAHSO), simultaneous offset instrument approach procedures (SOIA), and the planning and mutual support for the Communicating For Safety Conference scheduled for September.

The third item we are working diligently to accomplish is to bring the Air Line Dispatchers Federation into the ALPA-NATCA liaison process. We are convinced that the dispatchers play a critical role in the airline operations process, and that we would all be better served to receive the benefit of their input and experience. In fact, with the concurrence and support of our colleagues at NATCA, we invited them to our most recent liaison meeting on July 5^th, and they were quite enthusiastic about becoming part of the process. Unfortunately, they were unable to attend the July 5^th meeting, but are planning to attend the next meeting. Additionally, we have invited the dispatchers and NATCA to the ALPA Annual Safety Forum to be held August 15 through 17. Both organizations have responded positively to the invitation and both have stated that they will send representatives to this event. This will be an excellent opportunity for these representatives to meet and interact with many of ALPA’s pilot safety volunteers and staff. In addition, both groups have been invited to a number of our technical committee meetings that precede the Forum. I plan to personally meet with representatives from both organizations during this event.

The fourth item we identified is the standardization and modernization of flight and duty time limitations. On May 3, 2001, we testified about why these rules need to be standardized and modernized. We believe that if the rules are updated and enforced by the FAA, carriers will begin to schedule their flights in a more realistic manner. Such realistic scheduling will produce accurate historical data, which the airlines can draw upon to develop their future schedules. As these practices are refined, we believe future scheduling will be more realistic and more predictive, and will lead to an improvement in on-time performance.

Although all interested parties, including the FAA, are in agreement that these regulations need to be revised, the FAA has taken no action to date to accomplish any revisions. One must wonder why that is the case. In fact, the FAA is being subjected to external pressures that may be having a chilling effect on taking these necessary actions. For example, the FAA recently ruled that it would strictly enforce the requirement to provide pilots with a minimum 8-hour rest during every 24-hour period. As soon as the FAA announced that it would enforce this rule, which has been in existence since 1985, the Air Transport Association filed suit to stop the FAA from requiring carriers to comply with this requirement. When one considers the time it takes for a crew to be transported to and from the layover hotel, together with personal hygiene needs, even the strict enforcement of this 8-hour rule only provides a 5-6 hour sleep opportunity. This situation, coupled with the ATA's current position that seeks to permit carriers to require pilots be on duty beyond 16 hours, is not only unsafe but will encourage carriers to continue unrealistic scheduling practices. Action by the FAA can resolve these scheduling issues, but a formal proposal for industry comment has not yet been issued. We would appreciate the assistance of this Subcommittee in encouraging the FAA to immediately act on this important undertaking.

The last item is ALPA's pledge to work to improve airport capacity, where possible, by affirming our commitment to working toward building industry consensus on programs that will improve efficiency and increase capacity, while ensuring that these programs maintain the highest level of safety.

In the last hearing, it was suggested that this item is redundant to other items being worked by the FAA. However, ALPA believes this item is still appropriate as a stand-alone issue. In September 1999, the ALPA Executive Council endorsed an ALPA National Airspace System Modernization Strategic Plan as a vital step toward assisting in the restructure of the NAS and the pilot’s working environment. An Oversight Committee was established within ALPA to coordinate the work of our Communications, Economic & Financial Analysis, Government Affairs and Engineering & Air Safety Departments. Funding was established outside our safety structure budget to support a six-year program to assure that the pilot perspective would be an integral part of, all NAS Modernization initiatives. As a result of this high priority initiative within ALPA, additional pilot safety volunteers have been recruited to interface with the myriad of projects associated with NAS Modernization.

The goals of ALPA's NAS Modernization initiative are: to secure appropriate levels of funding for NAS Modernization programs; encourage basic research, development and implementation for new and improved Air Traffic Management tools; continue to assist in developing a joint U.S. industry/government document that is truly responsive to user needs on future NAS requirements that would be in addition to the NAS Architecture; work to insure that the National Civil Aviation Review Commission’s report on funding and aviation is considered in the modernization plan; work to strengthen and maintain industry consensus that will be critical to the success of NAS Modernization; and ensure effective pilot input into the modernization effort.

The ALPA NAS Modernization Initiative rates safety as the highest priority and, as Captain Woerth stated in October 2000, can be summed up as follows: "Modernization is all about change, implementing new ideas and concepts, using new technology, equipment and procedure, to better serve the public’s needs, and doing so in a timely and economical manner."

To fulfill that mandate, ALPA pilot volunteers and staff are active in a variety of industry groups working on closely spaced parallel runway operations, land and hold short operations, regional airspace redesign work groups, airport planning groups, reduced vertical separation procedures, and many more initiatives.

In closing, ALPA remains committed to work to resolve delay problems while ensuring that the safety of operations in the National Airspace System is maintained and, hopefully, enhanced. ALPA will continue to provide the line pilot input that is essential to achieving that goal. Thank you for the opportunity to present ALPA’s views to the Subcommittee, and I will be happy to respond to any questions.