HomeMy WebLinkAboutR-84-0454J-84-377
4/10/85
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RESOLUTION NO. 84-54
A RESOLUTION SUPPORTING THE EFFORT OF
MIAMI iNTERNATIONAI_ AIRPORT (MIA) AND THE
DADE COUNTY AVIATION DEPARTMENT TO SEEK A
THREE YEAR EXEMPTION FROM FEDERAL
AVIATION REGULATIONS (FAR) 36 AND 91E
UNTIL JANUARY 19 1988; URGING THE FEDERAL
AVIATION ADMINISTRATION (FAA) AND OTHER
AGENCIES INVOLVED IN THE DECISION OF
WHETHER TO GRANT AN EXEMPTION RELATING TO
MIA TO CONSIDER ALL. PERTINENT FACTORS AND
TO GRANT THE REQUESTED EXEMPTION FROM
FAR 36 AND 9 1 E FOR INTERNATIONAL
OPERATIONS AT MIA UNTIL JANUARY 1, 1988.
3
WHEREAS, implementation of Federal Aviation Regulations
(FAR) 36 and 91E promulgated by the Federal Aviation
Administration (FAA) relating to aircraft noise control will,
i
on January 1, 1985, prohibit all Boeing 707, Boeing
727 - 100, Convair 880 and most DC6 aircraft from operating
a
in the United States (U.S.) and at Miami International
Airport (MIA); and
k WHEREAS, there is currently on the market no FAA
t certificated quiet engine nacelle or "hush kit" to enable
i
such present aircraft to comply with FAR 36; and
WHEREAS, such hush kits will not be on the market in
i
full production until sometime in 1985 at the earliest; and
WHEREAS, it is therefore technically impossible for
these aircraft to comply with FAR 36 by January 1, 1985; and
WHEREAS, most of the airlines in the Caribbean and Latin
i
America use these aircraft exclusively, or almost
exclusively; and
1
i WHEREAS, 37 foreign airlines who own only non -FAR 36
I aircraft will be banned from MIA - the gateway to the
Caribbean and Latin America and this tremendous loss of
international airlines service will have a severe effect on
the international economy of South Florida and on the
F
ecbnomies of many other parts of the nation (e.g., the U.S.
F
3
i'
oil, auto, truck
and
agricultural machinery industries),
since many industries
depend on MIA's unique range of air
cargo service
to
ship
their specialized products on the only
available air
freighter
routes to U.S. trading partners south
of Miami; and
WHEREAS,
MIA
and
the Miami community will lose 6,000
jobs; and
WHEREAS,
MIA
will
lose 48% of its international cargo,
valued in 1983
at
more
than $1.2 billion; and
WHEREAS,
due
to their present economic situation, most
of the affected Caribbean and Latin American countries and
carriers cannot afford FAR 36 - compliant new or reengined
aircraft; and
WHEREAS, it is therefore financially impossible for
these a.ir].inesaircraft to comply with FAR - 36 by
January 1, 1985; and
WHEREAS, the FAA possesses and has used on behalf of
U.S. air carriers its exemption authority with regard to
FAR 36 to grant many U.S. airlines exemptions to FAR - 36
until January 1, 1988; and
WHEREAS, the exemption sought by MIA on behalf of the
carriers operating international routes from Miami is until
January 1, 1988; and
WHEREAS, the International Civil Aviation Organization,
of which the U.S. is a signatory member, has recommended that
these or similar noise regulations should not be applied to
aircraft of foreign airlines until January 1, 1988; and
WHEREAS, Great Britian and other European Economic
Community countries are utilizing the January 1, 1988 date
for compliance with similar noise regulations relating to the
aircraft of foreign airlines; and
WHEREAS, implementation of FAR - 36 will reverse the
potential economic advances made possible by the Caribbean
Basin Initiative and other efforts;
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84-454
NOW, THEREFORE, BE IT RESOLVED BY THE COMMISSION OF THE
CITY OF MIAMI, FLORIDA:
Section 1. The City of Miami hereby supports the effort
of Miami International Airport (MIA) and the Dade County
Aviation Department to seek a three year exemption from
Federal Aviation Regulations (FAR) 36 and 91E until January
1, 1988.
Section 2. The Federal Aviation Administration (FAA)
and other agencies involved in the decision of whether to
grant an exemption relating
to
MIA
are hereby urged to
consider all pertinent factors
and
not
prejudge the issue.
Section 3. The FAA
and
the
U.S. Department of
Transportation are hereby urged to grant a three year
exemption from FAR 36 and 91E for international operations
at MIA until January 1, 1988.
PASSED AND ADOPTED this loth day of April , 1984.
Maurice A. Ferre
ATTEST:
PREPARED AND APPROVED BY:
DEPUTY CITY ATTORNEY
APPROVED AS TO FORM AND CORRECTNESS:
op
/ITKYATTORNEY
84-454
ALCALDE, HENDERSON & O'BANNON
GOVERNMENT & ruSLIC AFFAIRS CONSULTANTS
April 2, 1984
Mr. Maurice Ferre
Mayor of Miami
3500 Pan Am Drive
Miami, FL 33133
Dear Maurice:
As per our recent telephone conversation, I have
included a draft resolution for your review regarding
Miami International Airport's exemption request to FAR 36
on behalf of 37 foreign air carriers serving Miami.
As we discussed, implementation of FAR 36 would have
a devastating impact on Miami, and its whole future as an
'E international trading city. In calendar year 1983, approx-
imately 48% of MIA's international cargo, valued at more
than 1.2 billion dollars (and representing 60,000 U.S. jobs),
was carried on MIA's B-707, CV-880, and DC-8 freighters,
all of which are non -FAR 36 compliant aircraft. The loss
of these vital services to 30 cities throughout the Caribbean
and Latin America could immediately impact over 6,000 jobs
in Miami.
I know you are aware of the importance of this issue
to the Miami community. I feel that if we can garner
support from Miami's international business and community
leaders it will help us in our effort to gain MIA's exemption
request.
I look forward to talking with you again soon and
greatly appreciate your assistance in this matter.
Sincerely,
ector Alcalde
HA: am
Enclosure
i
1901 N. FT. MYER DRIVE TWELFTH FLOOR RosSLYN. VIRGINIA 22209 PH. 703 841-0626 84-454
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LIN
DRAFT RESOLUTION - FAR 36
City of Miami
WHEREAS implementation of Federal Aviation Regulations
FAR 36.and 91E will, on January 1, 1985, prohibit all
Boeing 707, Boeing 727 - 100, Convair 880 and most DC8
aircraft from operating in the United States and at Miami
International Airport;
WHEREAS most of the airlines in the Caribbean and Latin
America use these aircraft exclusively, or almost exclu-
sively; and
WHEREAS 37 foreign airlines will be banned from Miami
International Airport - the gateway to the Caribbean
and Latin America; and
WHEREAS Miami International Airport and the Miami community
will impact 6,000 jobs; and 48% of its international cargo,
valued in 1983 at more than $1.2 billion; and
WHEREAS due to their present economic situation, most of
the affected Caribbean and Latin American countries can-
not afford FAR 36 - compliant new or reengined aircraft;
and
WHEREAS there is currently on the market no FAA certif-
icated quiet enl!i.ne nac:el_le. or "hush ],,it" to enable their
present: to coi;ipl y v,! t:h FAR 36; rand
WHEREAS such Bush }:it:s fall not be on the market in full
production until Somet:imc- in I985 at the earliest; and
WHEREAS it is therefore financially and technically im-
possible for these airlines' aircraft to comply with FAR
36 by January 1, 1985; and
WHEREAS the FAA has and has used on behalf of U.S. air
carriers its exemption authority with regard to FAR 36
to grant many U.S. airlines exemptions to FAR 36 until
January 1, 1988; and
WHEREAS the exemption sought by Miami International Airport
on behalf of the carriers operating international routes from
Miami is until January 1, 1988; and
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84-454t
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Page Two
WHEREAS the International Civil Aviation Organization, of
which the Ut S. is a signatory member, has recommended that
these or similar noise regulations should not be applied
to aircraft of foreign airlines until January 1, 1988; and
WHEREAS Great Britian and other EEC countries are utilizing
the January 1, 1988 date for compliance with similar noise
regulations relating to the aircraft of foreign airlines; and
WHEREAS implementation of FAR 36 and FAR 91E on January 1,
1985 will have a serious negative effect on trade and
tourism between the United States and the Caribbean and
Latin American countries; and
WHEREAS implementation of FAR 36 will reverse the potential
economic advances made possible by the Caribbean Basin
Initiative and other efforts;
Now, therefore BE IT RESOLVED that the City of Miami
supports the effort of Miami International Airport to
seek a three year exemption to FAR 36 and FAR 91E until
January 1, 1988; and
BE IT FURTHER RESOLVED that the FAA and other agencies
involved in the decision of whether to grant an exemption
relating to Miami International Airport should consider all
pertinent factors and should not pre -judge the issue; and
BE IT FURTHY"R RESOLVED that the FAA and the Department of
Transportation should grant the requested exemption to
FAR 36 and FAR 91E for international operations at Miami
International Airport until January 1, 1988.
84-454
Position of the Dade County Aviation Department on the impact of Federal Avia-
tion Regulations (FAR 361FAR 91E) effective December 31, 1984, on 47 Airlines
and five Aircraft Maintenance Bases at MIA
From: Richard H. Judy
Director, Dade County
Aviation Department
March 30, 1984
Miami International Airpcfrt (MIA) is the most vital infrastructure of Dade
County for the development of international business, and the continued eco-
nomic growth of all sectors of the gross product of South Florida. Miami is
served by 80 scheduled airlines, 45 of which are foreign airlines; with
scheduled flights to 97 North American cities and 91 international cities. Over
72,000 people arc directly and indirectly empioyed in South Florida's aviation
industry, and a recent University of Miami economic stud}- indicates that the
aviation industry today produce;; 25'L of the gross product of Dade County.
Through t.iiami' gcographic location, and the positive . yticrL_.ir=n-, betv,con 1„iatni
International Airport and the 1 irE;c international bu:.;ines�� cor;lmunity of. South
Florida, Miiami has become a ',vorld l atcway for- the:° U. 5. , Carib}:scan :nd Latin
American economies, and the U.S. and international air cargo industries.
Miami's large international business sector- comprises a wide range of companies
in the export, import, international banking, international accounting and
international insurance fields, and offices of over 100 multinational
corporations. Many of these corporations are located in Miami because of the
wide range of convenient air schedules to virtually every city in the Caribbean
and Latin America. The Department of Business Studies at Florida
International University reports that this extensive international business
sector presently employs directly and indirectly approximately 25 % of all the
citizens in Dade County.
Miami's dynamic and synergistic aviation and international business and
international trading economy is, however, now in grave danger as the result
of arbitrary and unilateral regulations published in November 1980 by the
Federal Aviation Administration (FAA) . These regulations will, on December
31, 1984 (nine months from today) , effectively ground the perfectly serviceable
aircraft of 37 foreign airlines and 10 U.S. airlines serving Miami. i his action
will virtually destroy most of these airlines. It will also seriously impact Miami
as .an international business and international trading city, unless exemptions
to these arbitrary regulations are granted, as provided for in Federal law.
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All Interested Parties
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BACKGROUND:
In December 1976, the FAA implemented aircraft noise control regulation FAR
36, which effectively began the process of phasing -out of operation by U.S.
domestic commercial airlines all of the then -existing Boeing 707, Boeing
727-100, Convair 880 and Douglas DC-8 aircraft by January 1, 1985. The
drafting of this regulation was carefully structured during the four year
period 1972 to 1976, by the FAA and the U.S. air carriers, to incorporate the
U.S. airlines' fleet reequipment programs. The FAR 36 regulation was then
implemented, in 1976, so as not to affect adversely, in any way, the economics
of the U.S. scheduled air carriers and the air services they provided.
In November 1980 this regulation was extended, through FAR 91E, to cover
these B707, 13727-100, CV880 and DC-8 aircraft when operated by forte
airlines from any U.S. airport; although the FAA paid no attention to the
potential economic impact of this regulation on the foreign airlines, as they had
done with the U.S. domestic airlines. By this action, the FAA had effectively
given U.S. airlines eit ht years to meet its ne", regulations (one could even
say 13 years, since 197Z), while giving the economically %,.eaker foreign airlines
only four Years. To the expressed concern of the U.S. Department of State,
the FAA by its unilateral action, effectively ignored the traditional Bilateral
Air Agreement process between the U.S. and every other nation in the world.
The FAA Administrator, however, in 1980, in a policy statement to the
International Civil Aviation Organization (ICAO) , of which the U.S. is a treaty
member, clearly stated to the aviation representatives of the world
that the FAA was legally permitted to issue exemptions to FAR 36/FAP. 91/E,
to minimize the potential economic hardships these regulations might cause to
foreign airlines. In June 1979 ICAO had already recommended, for very sound
international economic and political reasons, that all nations tale no noise
regulation actions against the aircraft of foreign airlines until January 1988.
This action was in response to requests from the U.S. that ICAO extensively
review the matter of aircraft noise throughout the airports and airlines of the
world, and then take a formal international position on aircraft noise. ICAO
had, therefore, made a careful study of the impact of aircraft noise on the
major airports in the world, and of the composition of the aircraft fleets of the
international airlines serving those airports. lCAO had also considered, as the
FAA had done for its domestic Air Transport Association (ATA) carriers, the
plans and capabilities of the foreign airlines of the world to progressively
change their equipn-ic-nt o,.,er the ne:�_t tell years, in a norm i] technical and
econotnic manner. ICAO had paid special attention to the airports and airlines
of the economically weaker member states, since in many cases the economic
imporU:nce of the air service of these nations far outweighed any airport noise
84-45C
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All Interested Parties
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problems which might, or might not, exist. The economic importance of the
perfectly serviceable aircraft of the airlines of some of the developing nations
(which these nations could not afford to replace), was also far more important
to many nations than any noise their aircraft might malce, if the alternative
was the total elimination of service by their national airline. ICAO had
recommended, therefore, that those nations (primarily western nations) whose
airports were located in noise -sensitive areas should not take any action
against foreign aircraft until January- 1, 1988. ICAO clearly considered that
this date would be a fair balance between the complex environmental, economic
and political issues involved. ICAO also left open the possibility for nations to
give extensions to this date, in specific cases of severe economic hardship to
developing countries or their airlines.
The imposition of FAR 36/FAR 91E by FAA at Miami International Airport (MIA)
on January 1, 1985, less than nine months from today, and the resultant
banning of all international B707's, B727-100's, CV880's and most DC-8's from
MIA, will have a devastating effect on the airlines of almost every developing
country in the Caribbean and Latin America, most of which use Miaini as their
international gateway to the U.S. Of the 37 foreign airlines affected, 30 will
be totally eliminated, since they own only non-FC�01 36 aircraft. This
tremendous loss of international airline service will hay e a revere: effect on the
intern ation.aI economy of South Florida. It will also have a s;ignific, nt effect on
the economics of many other parts of our nation (e.g. the U.S. oil,ai,ito, truck
and agricultural machinery industries), since many of these industries depend
on MIA's unique range of air cargo service to ship their specialized products
on the only available air freighter routes to our trading partners south of
Miami. Many of the passenger airlines of the Caribbean and Latin American
nations operating into Miami will be virtually eliminated. Almost every cargo
airline from these nations will be totally eliminated, since their well-being
depends upon the economics of their air routes to and from Miami, and they
own only non -FAR 36 B707's, CV880's and DC-81s. For example,
banned from Miami will be all of the aircraft presently operated by the
national passenger airlines of Guatem�jla, Guyana, Panama, Paraguay and Peru.
Also banned from !�':iami will be all of the aircraft presently operated by the
national cargo airlines of Barbados, Costa Rica, Ecuador, Haiti and Panama. A
listing of the 37 foreign airlines at MIA affected by these regulations is shown
in Exhibits 1, 2 and 3.
Miami's large international cargo industry, which serves the productive
processes both of our nation and the Caribbean/Latin American region, will be
severely damaged by the 90% reduction in available all -cargo (freighter) ser-
vice shown in Exhibit 2. In calendar year 1963 approximately 9E$ of MIA's
international cargo, valued at more than $1.2 billion (and representing
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All Interested Parties
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60,000 U.S. jobs), was carried on hIIA's international B707, CV880 and DC-8
freighters. Thirty-one cities in the Caribbean and Latin America receive
cargo service from NIIA by these aircraft. Only four cities, of the over 30
foreign destination cities in the whole region, are served by FAR 36-compliant
freighter aircraft.
More than 85 0 of the non -FAR 36 compliant aircraft flights from NIIA are by 37
foreign airlines, representing almost every friendly nation among our southern
neighbors. Nineteen of these foreign airlines are the national flag carries- of
their country. Nine of these foreign airlines own only non -FAR 36 passenger
aircraft. Twenty-five of these foreign airlines own only non -FAR 36 cargo
aircraft. All of these foreign airlines will no longer be able to operate the
majority (in most cases, any) of their aircraft into and out of. NIIA in foreign
commerce. None of these foreign airlines are in a financial position to replace
their non -FAR 36 compliant B707's and DC-8's with $18 million FAR 36-compliant
DC-8-73F's. In fact, MIA has already had to develop extended payment plans
for some of the foreign airlines shown in Exhibit 1, because of their critical
lack of U.S. dollars even to pay their ticket counter rentals and landing fees.
When they purchased their B707's and DC-8's over ten years ago (often as
used -aircraft from major U. S. airlines) , these foreign airlines bought
well -maintained aircraft which fully complied with all U. S. and inter -national
airworthiness standards. These aircraft have continued to be maintained,
and still comply with all relevant U. S. and international airworthiness
standards. P.lany of these aircraft are only at 60° of their normal economic
life, and have many years of useful service remaining. In spite of this fact,
by its announced policies the FAA is no«• going to unilaterally ground all of
these still perfectly serviceable aircraft, effective December 31, 1984, nine
months from today. The U.S. carefully avoided these adverse impacts on its
own domestic airline fleets, of the older BAC111, B737-100, B747-100 and
DC9-10 aircraft, to which it carefully gave exemptions until the ICAO date of
January 1988, when drafting the FAR 36 regulations.
We have not been able to locate any record that the U.S. officially advised
these foreign nations in November 1980, through proper bilateral diplomatic
channels, that they would only be given this sh_u-t period of four years to
attempt to find solutions to the adverse impacts that the implementation of FAR
36/FAR 91E would cause on their nations' air service zinc] their carriers. Nor
did the U.S., in a timely manner, warn these nations that the optimum
economic and technical solution ("hush -kits"), as FAA orip in.:ll`, promised to
Congress, would not be available on a time]), basis. Nor that the exemption
process Provided for by law would not be considered so far as the FAA was
concerned. The FAA has effective]), created a unique situation, where the
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All Interested Parties
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only solution acceptable to it, is for all these foreign airlines to ground their
aircraft. It seems unlikely that this was the intent of Congress.
The result of grounding the B707, CV880 and DC-8 freighters of. 25 foreign
airlines serving MIA will be a significant reduction in international cargo
service, through the 90% reduction in the number of freighters serving these
important foreign markets. We know of no alternative air service to replace
this extensive and critical air cargo service that will be eliminated on December
31, 1984. We suggest that the FAA, and the ATA airlines opposed to the
exemption process, should work with the U.S. State Department to propose an
extensive and economical alternate bilateral air cargo service program that will
be available to meet tht se critical lost air cargo services, should these
suggested exemptions to FAR 36/FAR 91E not be granted.
We believe it is essential that the State Department and the appropriate
Foreign Policy Sub -Committees of Congress concern themselves with the
significant foreign policy issues involved in the statements by the FAA that
they will not even consider granting exemptions to these regulations. The
exemption process was specifically provided for by Congress to deal with such
unforeseen, but delicate issues; in this case resulting from the lack of the
time]), avail ability of the economically cost-effective t.echnica] means
("hush -kits") 10 enable the existing aircraft of these airlines to comply by
January 1, 10,85. The severe economic recession being suffered by the
southern neighbors of our nation clearly makes it impossible for these a;.rlines
to pursue their only other alternative, the purchase of expensive replacement
aircraft.
We also believe that an appropriate committee of Congress should request the
General Accounting Office (GAO) to analyze and to report to Congress on the
economic impact which FAR 36/FAR 91E will have on all affected parties.
All of the 37 foreign airlines and 10 U.S. airlines affected have staffs at MIA
who will lose their jobs if exemptions to FAR 36/FAR 91E are not granted.
Extensive unemployment also will follox among the employees of the freight
forwarders, customs brokers, flower importers, etc. , since these companies
will have less reason to use Miami, if limited or no air service is available to
the countries they currently serve. Approximately 6,000 jobs would be
directly. irr;pacted in Dade County. Obviously there will be a far greater
�
economic impact on the present very fragile economies of the foreign nations
1 involved.
A further problem also will occur, since even if the foreign airlines could
operate their B707, B727-100, CV880 and DC-8 aircraft elsewhere within the
84-454
All Interested Parties
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only solution acceptable to it, is for all these foreign airlines to ground their
aircraft. It seems unlikely that this was the intent of Congress.
1 The result of grounding the B707, CV880 and DC-8 freighters of 25 foreign
airlines serving MIA will be a significant reduction in international cargo
service, through the 90 o reduction in the number of freighters serving these
j important foreign markets. We know of no alternative air service to replace
this extensive and critical air cargo service that will be eliminated on December
31, 1984. We suggest that the FAA, and the ATA airlines opposed to the
t
exemption process, should wort: with the U.S. State Department to propose an
extensive and economical alternate bilateral air cargo service program that will
be available to meet th�.se critical lost air cargo services, should these
suggested exemptions to FAR 36/FAR 91E not be granted.
We believe it is essential that the State Department and the appropriate
Foreign Policy Sub -Committees of Congress concern themselves with the
significant foreign policy issues involved in the statements by the FAA that
the), not even consider granting exemptions to these regulations. The
exemption proccs�-; specifically provided for by Congress to deal ;ith such
unforeseen, but. delicate issues; in this case resulting; from the lack of the
timely ava.il2 1)iIity of the economically cost_effective technical means
("hush -kits") to enable the existing aircraft of these airlines to comply by
January 1, 1985. The severe economic recession being suffered by the
southern neighbors of our nation clearly makes it impossible for these 'airlines
to pursue their only other alternative, the purchase of expensive replacement
aircraft.
We also believe that an appropriate committee of Congress should request the
General Accounting Office (GAO) to analyze and to report to Congress on the
economic impact which FAR 36/FAR 91E will have on all affected parties.
All of the 37 foreign airlines and 10 U.S. airlines affected have staffs at MIA
who will lose their jobs if exemptions
to FAIF.
36/FAR 91E are not granted.
Extensive unemployment also %,.ill follow among
the employees of the freight
forwarders, customs brokers, flov.,er
importers,
etc. , since these companies
will have less reason to use Miami, if
lii,iited or
no air service is available to
- the countries they currently serve.
Approximately
6,000 jobs would be
directly . in;pacted in Dade County.
Obviously
there will be a far greater
economic impact on the present very
fragile: economics of the foreign nations
involved.
A further problem also will occur, since
even
if the foreign airlines could
operate their B707, B727-100, CV880
and DC-8
aircraft elsewhere within the
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Caribbean /Latin American region, they could not continue to bring their air-
craft to Miami for maintenance by the large Miami -based aircraft maintenance
companies, such as Airtech, Airlift, Batchair, Commodore Aviation, Eastern
Airlines, General Air Service, etc. , as is now the practice. This will further
reduce aviation industry employment in Miami. The total economic impact on
both Dade County and our southern neighbors will be severe.
We realize that this particular maintenance problem could be easily resolved by
the FAA granting permanent "maintenance exemptions", and it is not the
thrust of this position paper; however the lack of a solution being announced
by FAA at this late date certainly concerns the large Miami -based aircraft
maintenance industry. I
MIA does not have an aircraft noise problem comparable to many communities.
MIA, with the FAA and the airlines, has cooperatively developed a successful
aircraft sound management and facilitation program. In this program only about
15 (4 �) of the approximately 350 commercial jet aircraft departures a day are
by 13707's, Cl78S01s, or DC-S's taking off over populated areas, where there
would be sonn- noise impact. Most of these B707's, C VS80's a 'd DC- S's are also
at moderate talceoff %Weights when flying; to points on]). 500 miles to 1 , 500 miles
from Miami, ::since they are not flying; to their rr;a:.imun', rangtc (over 3,000
miles) , and therefore are not at their maximum fuel load and rna:%-imam takeoff
weight. Studies by Boeing indicate that, at these moderate takeoff weights,
the rate -of -climb of these B707/DC-8 aircraft is quite acceptable. The Boeing
studies also indicate that, under these conditions, the takeoff noise levels of
the moderate -weight B707's and DC-8's on MIA's surrounding communities are
quite comparable to, and often lower than, the takeoff noise levels of the many
maximum -weight FAR 36-compliant B727-200's flying over 1,000 miles from MIA
to Boston, Chicago or New York; or the man), maximum -weight FAR
36-compliant B747's or DC10-30's flying over 4,000 miles non-stop from MIA to
Europe, or Argentina, or Brazil. (Because of the manner in which FAR 36
was drafted, actual takeoff noise levels on surrounding communities in actual
flight operations are not a factor; only theoretical noise levels, with respect to
theoretical maximum takeoff weights.)
Miami has also used the FAA Integrated Noise Model to perform studies of the
community noise impacts of maximum -takeoff -weight FAR 36-compliant B727-200
aircraft, versus typical medium -takeoff -weight B707/DC-8 aircraft at 230,000
Ibs, 240,000 Ibs and 260.000 lbs. The FAA Inteerate•d Noise Model clearly
shows that the heavy B727's, which are deemed to be legal, make more noise
impact on the community than the n;ediurn-range B707's and DC-5's, xhich are
deemed to be illegal; raising serious questions as to the FAA's wording of the
regulation, as compared to Congressional intent of the regulation. This
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"noisy but legal", i'quieter but illegal" situation is confirmed by Aeromar, the
cargo airline of the Dominican Republic, who have been advised by the
extremely noise -sensitive Port Authority of New York and New Jersey, that
Aeromar's straight -pipe (non -fan) DC-8-331s, at takeoff weights up to 268,000
lbs. , make no more noise than the noisiest FAR 36-compliant aircraft already
using JFK. Under these conditions, Aeromar has been given an exemption to
the Port Authority's interim special noise rules. Under FAR 36/FAR 91E
Aeromar, however, will not be able to operate at JFK after December 31, 1984,
regardless of how light, or how quietly, their DC-8 aircraft is operated.
The balance of benefits to the Miami community of the international B707,
B727-100, CV880 and DC-13 operations at MIA is overwhelmingly positive. Most
importantly, only our community can weigh the importance of our aviation
industry, our international trade, and our associated international business
support industries. in accounting, banking, insurance, etc. , and our very
large scale employment in the international customs broker, freight forwarders
and international aviation industries, against this very limited aircraft noise
exposure (from 1955 thru 1987) . The Miami community, therefore, not the
Federal Government, should be able to make the cost -benefit decision on an
issue which is so vital to us, and which involves on))- our community. This is
consistent with the announced policy of the present U.S. Administration to
shift the responsibility of noise regulatory decisions to local communities.
During the Congressional Hearings on the FAR 36 legislation the FAA promised
to Congress that economically priced (5500,000) engine "hush -kits"
(accoustically-treated nacelles) would be available by 1980. Our community,
and many Congressmen, relied upon this statement, of the early availability of
economically -priced "hush -kits", in voting on the legislation. In fact, these
hush -kits are only now being developed; and the first B707 and DC-8
hush -kits are not expected to be certificated by FAA until the fall of 1984.
The new accoustic nacelles should then be in full production from early 1985,
for fitting during the scheduled down -time associated with major aircraft
maintenance checks during 1985 and 1986. FAR 36-compliant freighter conver-
sions of the 13727-100 passenger aircraft (converted by (Monarch Aviation at
MIA) also ",ill be available during 1985/86/87. By 1988 most of the problem
will have been resolved if the economies of our southern neighbors improve as
anticipated; hence our request for an exemption from FAR 36/FAR 91E until
the ICAO date of January 1988.
As an example of hour other nations are addressing this delicate issue, Great
Britain and the European . Economic Community (E. E. C. ) nations have set a
January l , 1986, or January 1, 1987 noise -compliance date for their own
domestic carriers, but will continue to allow other foreign carriers (eg. the
84-454
All Interested Parties
-8-
small airlines from the developing countries in Africa and Asia) to operate into
their primary British or European gateway airport until the ICAO Annex 16
compliance date of January 1.988. Great Britain and the E.E.C. nations have
clearly recognized that aviation relationships between sovereign foreign nations
are governed by bilateral air -route negotiations and bilateral air agreements.
Great Britain and the E.E.C. nations also recognize the serious foreign policy
issues involved in forcing the airlines of developing countries to comply with
regulations which are clearly technically and economically impossible for them
to comply with, without putting the affected airlines out of business. By
comparison, the arbitrary and unilateral action intended by FAA indirectly
abrogates the intent of all of the U.S. bilateral air agreements with the
Caribbean and Latin American nations. It also ignores the ICAO
recommendations on this vital issue, which were carefully and thoughtfully
followed by Great Britain and the E.E.C. nations.
FAA's action also sho«,s no concern whatsoever for the potentially very serious
effects of its action upon the foreign policy of the U.S. in this vital Caribbean
and Latin American region.
We should all be aware that the history of U.S. bilateral aviation negotiations
has often been very difficult, particularly with many of the South American
nations, often due to the past enforcement of unilateral U.S. positions
concerning air scrvice between the U.S. and these nations. Such unilateral
practices by the U.S. are now vigorously opposed by these nations; often by
the respective foreign nation retaliating against the service of the designated
bilateral U.S. flag carrier (for example, reduction in frequencies permitted,
canccllatiens of fifth -freedom rights, up to total renunciation of the Bilateral
Air Agreement) . Such retaliatory actions by many of the foreign governments
concerned in this bilateral issue could severely damage Air Florida, Eastern,
Flying Tiger and Pan Am, the respective U.S. bilateral carriers to many of
these nations.
The worldwide economic recession of the past two years has hit the Caribbean
and Latin American nations with particular force, and has caused severe
economic problems to every nation in the region. The dramatic drop in
worlchvide demand for their primary exports during this extended recession
resulted in larg%z trading deficits and rapid devaluation of their currencies.
Their low foreign currency earnings and the tremendous strength of the U.S.
dollar, together %%,ith the very High U.S. interest rates, thee, nr,,de it virtually
impossible for must of these nations to repay their loans from the U.S. and
international banks. As the U.S. and world econor.iies recover over the next
three years it is believed that these nations' exports, and their Bard -currency
export earnings, will recover. The U.S., through the Caribbean Basin
84-454
All Interested Parties
-9-
Initiative and similar progressive programs, is trying to assist the whole
Caribbean and Latin American region in this respect. All of these nations, in
response to the specific instructions of the International Monetary Fund
(I.M.F.), have had to impose strict import controls, budgetary restraints, and
severe limitations on the export of their limited amounts of hard currency
(particularly U.S, dollars). This is already causing problems for U.S.
companies and U.S. airlines, who cannot repatriate their dollar earnings from
these countries, due to the strict instructions of the IMF that virtually all of
the hard -currency earnings from each country are to be used to meet their
critical economic survival needs, and to repay the interest on their
restructured foreign debt programs. As mentioned earlier, MIA has already
had to develop extended epayment plans for many of these airlines, because of
their critical lack of U.S.- dollars even to pay their ticket counter rental and
landing fees. Obviously, under these severe economic conditions, the IMF
would not at this time permit these countries to reverse their policies, for the
very questionable purpose of replacing perfectable serviceable capital
investments, represented by their existing aircraft.
Miami International Airport (MIA) is actively seeking, on behalf of all of the
airlines presently serving MIA on international routes, and affected by FAR
36/FAR 91E, an administrative solution to their problems, as provided for
by Congress. MIIA, at this time, is asking only that an exemption to FAR
/FAR 91E be granted until January 1, 1988, the date recommended by the
.ernational Civil Aviation Organization (ICAO) , of which the U.S. is a treaty
member.
This exemption to FAR 36/FAR 91E %,,,ould only be applicable to international
operations at MIA, through December 31, 1987, by:
a) foreign all -cargo airlines serving MIA during
1984, with the aircraft types and numbers used
during 1984.
b) U.S. all -cargo airlines serving MIA during 1984,
with the aircraft types and numbers used during
19S4.
e) foreign passenger/combination airlines serving
MIA during 1984, with the aircraft types and
numbers used during 1984.
No other U.S. airport or region would be affected.
Ile believe that this exemption could be and should be
suggested, so as not to impact the competitive positions
implemented, as
of Air Florida,
All Interested Parties
-10-
Eastern, Flying Tiger, and Pan American, the respective U.S. bilateral
scheduled carriers on some of the affected air routes. The great majority of
the affected routes, however, particularly the all -cargo routes to the
Caribbean and Latin America, have never been served by any of the major
U.S. ATA carriers. This is because of the U.S. A.T.A. carriers lack of
economically and technically suitable equipment and resultant operational
economics to serve these small markets, which tend to be low yield, but
absolutely vital to the economic survival and day-to-day functioning of the
countries concerned.
As we are all aware, this matter (of exemptions for these foreign airlines'
aircraft) is being intensely* opposed by the ATA; but with no alternative solu-
tions proposed by the ATA to meet the vital economic and air transportation
needs of our southern neighbors. Nor have those opposed shown any concern
to the related, and extremely important, U.S. foreign policy issues in this
vital area of the world.
An exemption for foreign airlines until January 1988 «•ould be consistent 4:ith
the previously stated U.S. position on the issue. In comments on U.S. air-
craft noise legislation before the 23rd meeting of the ICAO Assembly, October
1, 1980, the FAA Administrator stated: "...1 would hke to point out to those
gathered here that my agency, as a matter of domestic lav:,, also h _s v,,hat we
call exemption authority. In cases of legitimate need, hard cases, we are
legally permitted to issue exemptions «•here they deserve to be issued. We
intend to consult with the member states of ICAO, a?ith the affected airlines,
to do our best to make sure that we can minimize the impact of this rule, if
any there might be, on those airlines that fall under it. V"'e will try to be as
sympathetic as we can, . . ." The FAA Administrator clearly saw that there
were technical and economic problems in the international area, which would
need to be balanced with social and foreign policy needs depending on the
international airlines and the U.S. airports involved.
There is already a U.S. precedent for an exemption to FAR 36 for certain
aircraft. For example, the non -noise compliant models of the BAC111 , B737
and DC9 aircraft are operated by many U.S. airlines into the smaller U.S.
cities; and the services provided by these non -compliant aircraft are vital to
those small cities. No other suitable aircraft exist to provide these services.
Congress, therefore, has granted an exemption to FAR 30, until the ICAO date
of January ME, to approximately 360 of the older non -compliant L'AC111, B737
and DC9 aircraft operated by U.S, airlines. (Althouph the B11CI l l has the
reputation of producing a far greater perceived noise impact on most U.S.
communities than the B707 or DC-8. )
84-454
All Interested Parties
-11- .
Had the small countries of the developing nations in the Caribbean and Latin
America received the same consideration as the small U.S. cities, at the time
that the FAR 36IFAR 91E regulations were being prepared, then Congress
undoubtedly would have granted "small -country," or "developing country,"
exemptions similar to the "small U.S. city" exemptions. The developing
countries of the Caribbean and Latin America, however, had no organization in
Washington such as the Air Transport Association (ATA) , which is so skilled
politically in assisting in the preparation of any federal regulations which
might affect their U.S. airline members.
There is a further precedent for exemptions to FAR 36, namely the Concorde.
FAA granted exemptions sto the Concorde aircraft of Air France and British
Airways, because these aircraft had been constructed before 1980 (that is,
before FAR 91E) , and because of our close economic and political relationships
with 'France and Great Britain.
Miami International Airport, which normally tries to closely follow any federal
aviation action which might affect our tenant airlines (both U.S. and foreign)
and our community, took no early political action against the specific wording
of FAR 36/1'AR 91E, because we believed in the sincerity of the U.S.
Secretary Of Transportation, when, in z'esponse to a chrect. question at a
Senate hearing on this matter: "i . . . do you contemplate that 1herc will be a
grounding of the present aircraft?..." the Secretary replied: "...certainly
there is no thought on our part, given the present state of technology, of
grounding existing aircraft because of noise. However, we do feel that based
on advances in technology, the state of the art, if we are able to come up
%ti:th some retrofit program which has measurable benefits and which is
economically as well as technologically feasible, then we would expect the
operators of the aircraft to retrofit within a reasonable period of time..."
What has actually occurred to date, is that the new $15 million FAR
36-compliant retrofit engines cannot technically be fitted to the B 707-320 or the
DC-8-50 series aircraft, which 35 of these airlines own. The new engines can
only be fitted to the DC-8-60 series aircraft, which only four of these airlines
0•:11. The cost-effective 52.5 million "hush -kit" nacelles for the B707-320 and
DC-8-50 will not be certificated by FAA at the earliest until late 1984, and
probably will not be available for retrofit during scheduled major maintenance
checks until 1985. This lack of an-,, technical means of meeting the regulations
by December 31, 1984, is, by itself, sound and fair reason for the FAA to
grant exemptions to our foreign airlines, as requested herein. These foreign
airlines have traditionally bought U.S. aircraft, often used -aircraft from the
major U.S. airlines, and have the right to depend on the U.S. to provide, on
a timely basis, the hush -kits which were originally promised to Congress by
84-454
•
All Interested Parties
-17.-
the FAA, as a reasonable solution to the adverse impact of the implementation
of FAR 36/FAR 91E.
We should point out that the FAA is required by Congress to deal with these
realities in properly considering exemption requests. The preamble to Public
Law 90-411, under- which FAR 36 was issued, specifically states: "... the
Administrator is required to consider whether any retrofit rule is economically
reasonable, technologically practicable and appropriate for the particular type
of aircraft to which it will apply..."
On the subject of exemptions, we believed the sincerity of the FAA
Administrator, when, in October 1980, he told the ICAO Assembly: "... we
are legally permitted to issue exemptions where they deserve to be issued. We
intend to consult with the member states of ICAO, with the affected airlines,
to do our best to make sure that we can minimize the impact of this role ... on
those airlines that fall under it. We will try to be as sympathetic as we
can..." Had we not believed in the sincerity of DOT and FAA, we would have
drawn to the attention of Congress the potentially devastating effect these
regulations could have on the many foreign airlines of the developing nations
which use h,;IA as their U.S. gateway; and on the vital need for a
"small.-country/developing.-country" excmrption, until. January 1, 19S8, similar to
the "small -city" exemption granted to U.S. airlines. 1%le must also believe that
the affected foreign airlines, their government representatives, and
the U.S. Department of State heard these official statements by DOT and FAA,
and believed them to be a fair and reasonable position on a very delicate issue
affecting U.S. foreign policy. Obviously, in his public statements to ICAO,
the FAA Administrator recognized his responsibilities under Public Law 90-411,
and the bilateral aviation policies involved.
During 1984, however, the FAA, rather than consult with. -Lhe affected foreign
airlines, has clearly reversed its previous reasonable position. In a telegram
sent January 1964, through the communications system of the State
Department, to every foreign nation, the FAA stated that there would be no
exemptions to FAR. 36/FAR 91E. The same negative position \,.,as also communi-
cated, in February 1984, to citizens of the United States and their
representatives, by the FAA Associate Administrator for Policy and
International Aviation. One wonders how, and under what fairness doctrine,
the agency that is given responsibility by Congress to consider and grant
exemptions, for econotnic and technical reasons, can so negatively pre -judge
any exemption recyuest that has not yet even been received for official
consideration, and action. To further complicate their handling of this natter,
in March 1984, the FAA notified all carriers and interested parties that they
must submit their exemption requests by April 1, 1984. FAA's notification at
84-454
t
vi
All Interested Parties
-13-
the same time strongly emphasized that FAA was "firmly committed" to the
January 1, 1985 compliance deadline, and clearly* indicated that FAA did not
intend to really- consider any economic, technical, bilateral or constitutional
issues, which certainly would be presented in any exemption request.
In a similar manner to the services provided to small U.S. cities by domestic
airlines' BAC111, B737 and DC9 aircraft, the services provided at MIA by the
international B707, B727-100, CV880 and DC-8 aircraft are absolutely vital to
our community. These services are also critical to our presently friendly
southern neighbors, and no other suitable aircraft exist to provide these
services. Not;,,ever, unlike the many small U.S. communities which would have
been affected, if a waiver until January 1, 1988 had not been granted for
BACI11, B737 and DC9 type aircraft, Miami stands alone in our international
airline situation. No other U.S. city shares our unique geographical location,
our international business economy, and our resultant type and volume of
international airline service so heavily impacted by FAR 36. 'No other groups
of countries so friendly to the U.S. would also be hit so hard by these
regulations.
Ile can also point out that no other U.S. community, as early as 1972, began
a progressive and comprehensive aircraft sound management program, of
increased glide slope angles, runway extensions, displaced thresholds, pre-
ferential runway -use procedures, etc. , costing well over $50 million. This
program has already achieved for the Miami community 95 % of the aircraft noise
reductions promised by FAR 36. Miami International Airport also must be the
only major airport in the nation, v ith 1,000 aircraft operations a day, which
receives very fey noise complaints (less than two per month); and whose
business, political and media leadership in the community know their airport
and their aviation industry to be the economic keystone of the gross product
of their community. This is evidenced by the tremendous positive interest we
have received throughout the community on recently inaugurating Concorde
services to Miami; and the tremendous support we have received from our
%%,hole community on our position to request an exemption to the FAR 36/FAR
91E regulations.
This vv-hole matter also raises certain constitutional issues, which, we will not
address here, but which the U.S. Government will have an obligation to
consider, both from the standpoint of its own citizens and its international
commitments.
In closing,
we
would like to bring to
your attention the advice of the U.S.
Department
of
State, to Congress, on
this matter of unilaterally regulating
noise levels
of
the aircraft of foreign
nations: "...We indicated that we were
84-454
e
All Interested Parties
-14-
concerned that unilateral action by the United States regarding aircraft noise
which affected foreign aircraft might have a disruptive effect on international
cooperation in aviation to our future disadvantage and could provoke retaliation
against our aviation interests. We stated our preference that the Congress not
mandate a 1985 compliance deadline for aircraft in foreign air transportation
and our belief that the Executive Branch should have been given sufficient
flexibility to negotiate an internationally acceptable solution reasonably
compatible with our own domestic standards..."
I enclose a listing of the 47 airlines and the five major aircraft service com-
panies at MIA which will be seriously affected by FAR 36/FAR 91E, unless a
vital three-year exemptidn to these arbitrary and unilateral regulations is
granted, as permitted under Federal law.
Exhibit 1 of 3
MIAMI INTERNATI.ONAI1 AIRPORT
37 FOREIGN AIRLINES AFTEGTED BY FAR 36
* = Flag Carrier of Country
AIRLINE
COUNTRY
AIRCRAFT
AECA
Ecuador
DC-8F-54
Aerolineas Argentinas
Argentina
B707-320C
Aeromar
Dominican Republic
B720F, DC-8-33F, DC-8F-54
Aeromexico
*
Mexico
DC-8-51
Aeronaves del Peru
Peru
DC-8-61AF, DC-8F-55
Aeronica
*
Nicaragua
B720B, B727-100
Aero Peru
*
Peru
DC-8-62
Air France
*
French West Indies
DC-BF-54, B727-200 (pre-1973)
Air Haiti
Haiti
DC-8-51F
Air Panama
*
Panama
B727-100
AN -DES
Ecuador
DC-8F-55
APA
Dominican Republic
B707-320C
ARCA
Colombia
DC-8-51F/53F
Avianca
*
Colombia
B707-320B
Aviateca
*
Guatemala
B727-100
Caribbean Air Cargo
) arbados
B707-320C
Dominicana
*
Dominican Republic
B727-100
Ecuatoriana
*
Ecuador
B707-320C
Fast -Air
Chile
B707-320C
Fawcett
Peru
DC-8-6.1AF
Guyana Airways
*
Guyana
B707-320B
INAIR
Panama
CV880F, DC-8F-55
LAB
*
Bolivia
B707-320C
LAC
Colombia
DC-8F-54
LACSA
*
Costa Rica
DC-8-51F, DC-8F-55
LADECO
Chile
B727-100
LAN Chile
Chile
B707-320C
LAP
*
Paraguay
B707-320B
SAM
Colombia
DC-SF-55
Seagreen
Antigua
CV880F
SERCA
Costa Rica
CV880F
Surinam Airways
*
Suriname
DC-8F-55
TA,MPA
Colombia
B707-320C
TAN
*
Honduras
B727-100
TAR
Argentina
B707-320C
Varig
*
Brazil
B707-320C
VIASA
*
Venezuela
DC-8-63CF
AIRLINE
Airlift International
Arrow Air
10 U.S. AIRLINES AFFECTED BY FAR 36
BASE CITY
Challenge Air Transport
Fair Air
Florida l',est Airlines
Flying Tiger
Global international
Jet Charter Service
Rich International
Miami
Miami/New York
Miami
Miami
Tampa
Los Angeles
Kansas City
Miami
Miami
ATRCRAPT
DC-8-63CF,
DC-8-61,
DC-SF-54
DC-8-63CF,
DC-8-F54
DC-8-62, B707-320C
DC-8-F55
CV88OF
B707-320C
DC-8-61CF,
DC-8-63CF
B707-320C
B707-320C
DC-817-55,
DC-8-33F,
DC-8-62
5 AIRLINE MAINTENANCE BASES AT MIA AFFECTED BY FAR 36
Airteeh Commodore Aviation
Airlift General Air Service
Batch -Air
Exhibit 1 of 3
84--4544
4
Exhibit 2 of 3
MIAMI INTERNNATIONAL AIRPORT
SCHEDULED INTERNATIONAL, FI'•_EIGHTER AIRCRAFT DFPARTURES
BY U.S. Al":D 11-1- -7 AITTT' T'S,
a = Flag Carrier of Country
AIRLINE
AIRCRAFT TYPE
DESTINATION
V,7ZEKLY
FLIGHTS
Jan. 1984
Jan. 1285
Aerolineas Argentinas
*
B 707-320C
Buenos Aires
1
0
Aerolineas Argentinas
*
B707-320C
Sao Paulo
1
0
Aeromar (Dom. Rep.)
B72 OF, DC-8-33F,
DC-8F-54
Santo Domingo
3
0
Aeronaves del Peru
DC-8-61AF, DC-SF-55 Lima
4
0
Aeronaves del Peru
DC-8-61AF, DC-8F-55 Talara, Iquitos, Lima
1
0
Air France
*
DC-8F-54 (chartered)
Port-au-Prince,
1
0
Pointe-a-Pitre
Air Haiti
*
DC-8-51F
Port-au-Prince
3
0
ANDES(Ecuador)
DC-8-F-55
Quito, Guayaquil
3
0
A::I)1 S
DC-8-F-55
Guayaquil
2
0
ANDES
DC-8-F-55
Panama City, Quito
1
0
APA (Dom. Rep.)
B707-320C
Santo Domingo,
1
0
Puerto Plata
APA
B707-3?OC
Puerto Plata,
1
0
Santo Domingo
ARCA(Colombia)
DC-8-51F, DC-8-53F
Bogota
3
0
ARCA
DC-8-51F, DC-8-53F
Cali
2
0
ARCA
DC-8-51F, DC-8-53F
Medellin
1
0
Avianca (Colombia)
*
B747-1OOF
Cartagena, Bogota
1
1
Avianca
*
B747-IOOF
Bogota
1
1
Avianca
*
B7u7-100F
Barranquilla, Bogota
2
2
Avianca
*
B747-IOOF
Cali, Bogota
2
2
Challenge
DC-8-F-55
Iquitos, Lima
2
0
rcuatc:•iana (Ecuador)
*
B 707-320C
Guayaquil, Quito
1
0
u-toriana
*
B707-320C
Quito
2
0
r as-, Air (Chile)
B707-320C
Santiago
1
0
Fast Air
B707-320C
Panama City, Santiago
1
0
Faucet; (Peru)
DC-8-61AF
Lima
3
0
Flying 5.iger (U.S.
DC-8-63-CF
Manaus, Buenos Aires
1
1(a)
Flying Tiger
DC-6-63-CF
Manaus, Sao Paulo
1
1(a)
Flyinc Tiger
DC-8-63-CF
Rio De Janeiro, Sao
1
1(a)
Paulo
INAIR ('anama)
CV880-F, DC-SF-55
Panama City
4
0
LAB (Bolivia)
*
B707-320C
Santa Cruz
2
0
LAC (Colombia)
DC-8F-54
Barranquilla
3
0
LAC
DC-8F-54
Medellin, Bogota
1
0
LAC
DC-8r'-54
Cali, Bogota
1
0
-!
LAC
DC-SF-54
Cartagena, Bogota
1
0
-$
LAC
DC-8F-54
Bogota
2
0
LACS A ( Costa Rica)
*
DC-8-51F, DC-BF-55
San Jose
5
0
TA1.4PA(Colombia)
8707-320C
Medellin
5
0
-y
TAMPA
B707-320C
Bogota
6
0
_
VAR'G (Brazil)
B707-320C
Manaus
1
0
VIASr. (Venezuela)
DC-8-63CF,
Caracas
5
0
TOTAL 1';eekly Flights
83
9
-1
(a) As�:ur,es Flying Tigers operate DC-8-73CFIB747-100F, for service also at JFK and LAX.
nl:Gt•LAR ChARTER FOREIGN FREIGHTER AIRCRAFT DEP:1RTURES
..'RLINE L COUNTRY OF ORIGIN
AER
AECA (l.:cuador)
:fir Cargo (Trinidad)
Cargolux (Luxei:,burg)
S:':I.1 (Cuiur.;his i
SEkRica)
S1:rin
TAR
AIRCRAFT
B7U7-320C
DC-SF-54
B707-320C
B747-ROOF
DC-BF-55
CV880-1,
CA 8fi0-F
DC-SF-55
13707-320C
DESTINATION Vk'EF.KLY FLIGI3TS
Jan. 1964 Jan. 1965
Buenos Aires
Guayaquil, Quito
Irinivad, 13' rbados,
Antigua, Greneda
Average
Luxembourg
20
San Andr•L's
Flights
.�"nticua
Per
Say: .lose
Itieek
Par:,maribo
But -nos AirL'S
Total Flights `,;c•�k!•,
20
84-°° 454 LN I-Ijbit 2 of 3
Exhibit 3 of 3
MIANII INTERNATIONAL AIRPORT
FOREIGN AIRLINES OPERATING ONLY NON -FAR 36 PASSENGER AIRCRAFT ON
INTERNATIONAL ROUTES FROM MIA 11I INTERNATIONAL AIRPORT
* = National Flag Carrier
Aircraft
Airline Type
Aeronica (Nicaragua)
*
B727-100,
B720B
Aero Peru
*
DC-8-62
Acro Peru
*
DC-8-62
Aero Peru
*
DC-8-62
Air Panama
*
B7�0-100
Aviateca
*
B727-100
Dominicana
*
B727-100
Dominicana
*
B727-100
Ecuatoriana (Ecuador)
* B707-320B
B720B
Ecuatoriana "
* B707-320B
B72013
Faucett ( Peru)
DC-8-52 / 53
Faucet, 11
DC-8-52/53
Guy�-.na Airy, ays
* B707-320B
LADECO (Chile)
B727-100
LAP Waraguay)
* B707-320B
Destinations WEEKLY FLIGHTS
Jan. 1984 Jan. 1985
Managua
Guayaquil, Lima
Panama City, Lima
Lima
Panama City
Guatemala City
Santo Domingo
Puerto Plata
Santo Domingo
Quito,
Guayaquil
Guayaquil,
Quito
Iquitos, Lima
Lima
Georgetown
Bogota, Santiago
Asuncion
Total Weekly Departures
(a) See Notes Below
4
2
2
2
7
7
7
2 ?
2 ?
1
1
2
2
3
2
46
TOTAL INTERNATIONAL -RANGE FLEET OF EACH AIRLINE
Aeronica (Nicaragua)
Aero Peru
Air Panama
Aviateca (Guatemala)
Dominicana (Dom. Rep.)
Ecuatoriana (Ecuador)
Faucett (Peru)
Guvar,a
LADECO (Chile)
LAP
1 B720B, 1 B727-100
4 DC-8-62
3 B727-100
2 B727-100
1 B707-320B, 1 B727-200, 2 B727-100
2 B707-320B, 3 B720B
3 DC-8-52/53
1 B707-320B
2 B727-100
3 B707-320B
(a) Prissible actions to resume service in the 1985/86 time period.
? (a)
. , r.' 7 -i 00 aircraft passenger services, depending upon the range required, could possibly
placec b} purchased or lzssed FAIL 36-compliant B727-200's, many of which will be
;ring onto the used -aircraft market in 1985/80, as the major U.S. airlines tale delivery
of increasing numbers of nev,- 13757's and 13767's.
The B707 zind'DC-8 aircraft passenger services, because of range and load require-
ments, and Lt:cause of the_ economics involved on these "long -thin" routes, will have to
rely on accoustic-nLcelle "hush -kit" technology, which will not be available
until
It should btu pointed out that scheduled U.S. flag carrier service .will still be
availL,b1c orl trust of these foreign airline B727-l00/L'707/DC-6 passenger aircraft routes,
effective Ianuary 1, 1985. Ho%vever, very serious hil«teral treaty issues will be involved
if the FAA unilaterally mandates that only U.S. carriers can serve all these routes.
Exhibit 3 of 3
84-454