Page 8 Testimony of Mr. T. Coleman Andrews In no case can the Nation compromise the safety of our aircraft. Nor can we view protectionist actions which decrease U.S. charter carriers' ability to remain schedule and cost competitive in international markets as in the best interests of the Nation. We have seen the results of actions which underestimate the capability of worldwide competitors in other industries. The recently completed DOT study on international air cargo capability and this Nation's increasing dependance on foreign cargo airlift underscores the significance of maintaining an environment in which carriers such as ourselves can effectively -compete. The November 22, 1988 FAA ruling: 1. 2. 3. 4. 5. 6. Recognizes the global nature of the markets Permits us to remain competitive with Recognizes and accommodates the requirement stations. Contributes to both the peacetime and wartime While small relative to the majors, carriers such as World Airways and Key Airlines play a critical role in the Nation's peacetime military air transport mission. As major CRAF participants, we represent a substantial portion of the emergency airlift capacity available to the nation in the event of a national emergency. We provide tens of thousands of jobs throughout the economy and are often pioneers in exploiting new market opportunities and providing inroads to emerging economies throughout the world. We must not overlook the impact of legislation and rule changes on this important segment of the industry. Thank you. Mr. CLEMENT. Our next panel, if you will come forward immediately. Mr. Robeson; Mr. James Cudd; Mr. Jack Wires; Mr. W.E. Vanduyne; and Mr. John Alexander. Mr. INHOFE. Mr. Chairman, for those who are still here from the last panel, I am reading from the Congressional Record on January 3, 1989, a statement by Mr. Mineta, where he states that they would be able to use foreign-based subsidiaries of United Stateson U.S. aircraft without need for individual regulatory exemptions. I thought I would mention that, because I think that is a major misunderstanding that some of us, some of you folks are laboring under. Thank you, Mr. Chairman. Mr. CLEMENT. Mr. Robeson, we will start with you. TESTIMONY OF ROBERT E. ROBESON, VICE PRESIDENT, CIVIL AVIATION, AEROSPACE INDUSTRIES ASSOCIATION; JAMES CUDD, DIRECTOR OF PROGRAM AND BUSINESS MANAGEMENT, OVERHAUL AND REPAIR OPERATIONS, UNITED TECHNOLOGIES, PRATT & WHITNEY; JACK WIRES, VICE PRESIDENT, QUALITY ASSURANCE, BOEING COMMERCIAL AIRPLANE CO.; W.E. VANDUYNE, GENERAL MANAGER, AIRCRAFT ENGINE GROUP, FIELD SERVICE OPERATION, GENERAL ELECTRIC CO.; AND JOHN ALEXANDER, GENERAL MANAGER, SPECIAL PRODUCTS AND SERVICES, DOUGLAS AIRCRAFT CO. Mr. ROBESON. Thank you, Mr. Chairman. I am Bob Robeson, vice president of Civil Aviation for the Aerospace Industries Association. We represent the major manufacturers of commercial jet aircraft engines and related components. And I would like to summarize the rather lengthy statement I have represented, and I would like that just inserted in the record, if I may? Mr. CLEMENT. Yes, sir. All your testimony will be accepted into the record. Mr. ROBESON. Thank you. Over the last 2 years, the two main concerns that have been consistently expressed on this issue involve safety in jobs. We have heard it all again today. The industry addressed those concerns in testimony before this committee in 1987, but we want to point out in particular four de velopments that have taken place since that time, which we think make it even more imperative to maintain a part 145 in its current form. Those issues are, first, aging aircraft; second, a surge in orders for new aircraft; third, requirements for wind shear and TCAS installation on commercial aircraft; and fourth, the rise in the use of leasing as a form of aircraft ownership and operation. Let me turn briefly to the subject of safety. It has been addressed at length, but I think that AIA needs to be on record strongly with a few points. First, under the 1949 rule governing repairs, the FAA adopted a policy of issuing limited ratings for modification, repair of aircraft and overhaul of aircraft engines. This allowed foreignapproved stations to work on aircraft and components. But in 1985, as we know, there was a reinterpretation of the rule, which result ed in inconsistent application of rules and lack of consensus on policies regarding foreign repair stations. Through 1988, the FAA granted exemptions on a case-by-case basis. There is no evidence that the use of foreign repair stations degraded the safety, reliability or maintenance of aircraft, regardless of registry. After the change, safety was maintained, but the procurement, operation and maintenance of new and used aircraft should not be forced to rely on an uncertain, time-consuming and inefficient exemption process. Further, in our view, all foreign and domestic FAA repair stations are subject to FAA surveillance. We heard nothing to disabuse us of that notion today, and foreign repair stations also fall under the jurisdiction of the associated country's, foreign civil aviation authorities. And in our view, that constitutes a double-check, and we think the committee should recognize that fact. In summary, we believe that the use of foreign repair stations under the expressed intentions of FAA does not constitute an airworthiness problem, and that the FAA has stated that they will not certificate in a manner which outstrips their ability to perform required surveillance. We believe there is no question of safety, and we would not support the rule if we thought otherwise. Let me turn to the question of jobs. The crucial point which is often ignored in the debate is that hundreds of thousands of jobs in this industry depend directly on the health of the manufacturers. In 1988, we employed 239,000 directly in the manufacture of civil aircraft and components. In 1988, our sales resulted in a positive trade balance of from $17.9 billion. There is a chart on page 3 of my testimony which shows shipment orders and backlogs for 1986, 1987 and 1988. In 1988, exports of civil products, principally complete transports nd aircraft and engine parts amounted to 75 percent of U.S. aerospace exports, with a value of $20.3 billion. Any regulation that would restrict the free flow of trade in international airline markets would have a negative impact on the U.S. aerospace industry and on the Nation's overall trade balance. Internationalization of the industry has become so extensive that there does not exist today a single major civil aircraft program or aircraft or engine program which is developed by a single country. The magnitude of international trade among manufacturing firms has led to an increase in the number and variety of reciprocal service arrangements. A number of foreign manufacturers have established repair facilities for the United States, and a continuation of free flow of aeronautical products and maintenance services will create an impetus for foreign original equipment manufactuers to expand this practice. U.S. airline and manufacturers' maintenance bases have performed maintenance for foreign aircraft, and it not only results in more American jobs, but also benefits the economy as a whole. Any proposal to infringe upon the international trade in maintenance could be interpreted as a violation of U.S. trade obligations, and we do believe that this could result in retaliation or the other R word, "reciprocity." Let me turn to the issue of capacity, which is directly related to jobs. The first three changes in the environment in the last 4 years relate to this issue, and those are aging aircraft, surge of new orders, and TCAS and wind shear requirements. There is a serious capacity problem in the United States, as we have heard from the previous panel, and for that matter there is a serious capacity problem abroad. It is aggravated by the three elements I mentioned above. On aging aircraft, the industry is well along in a program to identify and correct potential problem areas on so-called aging aircraft. And as a result of this effort, we will put into place new typespecific programs, including more vigorous inspection of aircraft and replacement of specified structural components on the basis of service life. Carrying out these modifications which are required to keep the fleet airworthy will further tax a system which is running at capacity and which had expansions planned, but basically not on the basis of the first two items. The one that people could see coming was new orders. On the issue of new orders, however, what people did not see coming was the dramatic increase in new orders. If you look back at the chart, you can see that the orders for aircraft have surged from 1986 to 1988. That surge in new orders has continued in 1989, and the order books for the air frame producers are virtually sold out through 1993. The same thing can be said of the producers of everything from avionics to galleys. There are two effects from this surge. The first is that there is going to be a dramatic increase in deliveries, and these aircraft will have to be maintained. We have seen the effect. American Airlines testified what that meant for them. They have had to turn down other work which was contracted, in order to take care of their own maintenance requirements. The second thing that has come up is that we do not expect a significant number of retirements of older aircraft. Most of these new orders will add increased lift to the system, so that will further strain the maintenance system. The same thing is going to happen with TCAS and wind shear. I don't want to belabor the point, but we have, just to give you an idea of how much work is involved here, ATA estimates that installation of TCAS will require about 777 manhours per aircraft, and wind shear, about 500 manhours. Those are required to be installed on all the U.S. commercial fleet, and there are 4,274 jet aircraft in the commercial inventory in the United States alone as of the year-end of 1988. So, it is a lot of work we are talking about. Now, these three items, aging aircraft and new additions and TCAS, as we mentioned, are going to require significant capacity. The question has come up, why aren't people rushing to meet that capacity? We heard one response from the previous panel, but we would propose to you that there is an additional problem on capacity, and that basically is a problem of where we will find qualified mechanics to staff our facilities. Our experience is that the industry's demand for qualified maintenance personnel outstrips the supply on a national basis. There may be isolated pockets of redundancies here and there, but generally speaking, we are having a difficult time finding airframe and powerplant people who are certificated and qualified to work on our aircraft. In addition, we found it extremely interesting that the IAM has apparently identified this problem themselves. On March 6 of this year, Charlie Bryan, chairman of the Eastern Air Lines Machinists Union, was interviewed by Robert MacNeil on the MacNeil-Lehrer Newshour, and referring to the salaries, Mr. MacNeil raised the question of whether the striking members of the IAM at Eastern were going to, as he put it, put themselves out of jobs, period, by this strike. And Mr. Bryan replied, and I also quote, "Well, about half our employees that we are representing are mechanics, a certified airplane powerplant and air frame mechanic, which is quite a skilled group, and there is a shortage of those right now. In fact, Eastern has lost a lot of these to the airlines that don't have these kinds of problems." We are struck in the industry by this statement on national television of a senior IAM official recognizing the shortage of skilled mechanics. Make no mistake, this is a skilled group, and it is essential to the well-being of our industry. It seems that their importance to us has been lost in the debate that centered solely on the carriers. As quality manufacturers, we set standards and specifications for maintenance, repair and overhaul of our products. We work closely with the FAA, and we work with the United States and foreign airlines to establish the maintenance requirements, and that was alluded to earlier as well. Let me cut my testimony short, and just say that what we see Mr. CLEMENT. We have the-all your statements are in the record. We will have a vote at 6, and a number of us have a number of questions to ask. Mr. ROBESON. I will cut it off. May I make two points? One is that we do believe that the foreclosure of the use of foreign repair stations will degrade our ability to provide the services which are required to make the sales, and the people who are with me on the panel will go further into that point. The second thing is that the rise in leasing is going to cost us jobs, if the use of foreign repair stations is foreclosed, and you don't need foreign retaliation on a government level will not be needed to do that. It is laid out in the testimony as to why we believe that is the case. In short, by increasing the maintenance pool available to those who source overseas for equipment, it will make it to their economic advantage to do so, and that will be to the disadvantage of U.S. producers. And with that, I will yield the floor. Mr. CLEMENT. Thank you, Mr. Robeson. Mr. Cudd. Mr. CUDD. Thank you, Mr. Chairman. With ill-founded optimism, the first words I penned were "good morning." So, if you will bear with me, I will try to make this fairly brief. |