link between the ground and aircraft and a series of computers on the ground to determine if there is any danger of a midair collision. This is the discrete address beacon system, and the automatic traffic advisory and resolution system, DABS/ATARS. We would suggest, Mr. Chairman, that this alternative is even more in the future and even more costly than the trimodal system. Furthermore, it lacks the independence of the primary surveillance system that is so essential to the backup role.

ALPA and many other aviation groups believe it is unwise to rely solely on a ground-based system, and even the FAA's DABS/ATARS system will work only in areas where the necessary ground equipment is installed. It cannot work over the ocean or in remote areas. Another objection to DABS/ATARS is that it would take years to develop an international standard so it could be used worldwide.

There are other serious reservations about DABS/ATARS. For example, we are concerned about possible interference with other civil and military communications and navigations systems.

Then there are questions about the DABS data link. How much capacity does it have? Can it provide information on traffic as well as auxiliary data, and, if so, how much?

There are questions concerning the availability of DABS/ATARS. When could DABS be available if the decision were made today to implement it? We have heard estimates ranging from 5 up to 15 years before the FAA will have a fully functioning system.

If these time estimates are correct, we wonder why the FAA is basing its full-capacity collision avoidance system on the availability of DABS, which is years away. We question the Agency's continued reliance on such an unproven communications link.

To date, we have had little more than verbal assurances that DABS will be able to do all the FAA says it will. More justification is needed to support continued development.

On the other hand, ALPA does have some positive ideas on how to deal with the midair collision threat. This is far from a new problem. We formed a collision avoidance committee in 1966 to represent our views to the industry. Mr. Chairman, all the original members of that committee have long since retired from airline flying. This is how long this has been going on.

Additionally, ALPA has developed a set of technical and operational criteria needed to make any collision avoidance system truly effective.

Mr. Albrecht was talking before about coming out with a national standard in, I believe, December of this year. That is his target date to come up with a proposed notice of rulemaking. We would like to suggest that this would be our technical and operational criteria for a BCAS:

Be as independent as possible from the ground-based systems; Offer maximum protection to the aircraft regardless of whether other aircraft are CAS equipped;

Be equally effective under visual and instrument conditions; Function properly in all geographic areas, regardless of whether radar coverage is available;

Provide the pilot with sufficient information to take corrective action in the event of a threat;

Impose no limitations on normal aircraft maneuvers;

Be compatible with the aircraft's full performance range; Display threat information so it is integrated with other cockpit data;

Work in cooperation with existing air traffic control systems;

Allow the pilot to monitor the integrity of the air traffic control system;

Offer reliability comparable to that of primary navigation systems; Generate a minimum of false warnings, and

Be able to operate with future as well as current traffic densities. ALPA also believes that the cockpit display of traffic information (CDTI) offers the best method of displaying collision-avoidance information in the cockpit. It also offers the potential to improve management of the increasingly heavy traffic in the terminal area by enabling the pilot to share the workload with controllers on the ground. The next-generation airline transports will offer cockpit displays that could be used for this purpose.

This cockpit display would offer greater flexibility in the use of limited airspace and would give the pilot an increased awareness of traffic and other conditions surrounding his flight, such as weather, terrain, and navigation data. Then a pilot would be better able to manage his aircraft to fly the safest and most efficient route.

Currently, the FAA has a joint program with the National Aeronautics and Space Administration to study CDTI. However, our impression is that this program is not receiving the attention and support it deserves within the FAA. Also, it could be tied in with the collision avoidance program to avoid potential duplication of effort.

For example, the FAA has already tested the airborne trimodal collision avoidance system that would enable traffic information to be displayed to the pilot. However, the agency suddenly canceled its contract last June with the developer of this system. ALPA has never received a valid explanation from the FAA as to why it canceled this contract, and that makes us wonder if the agency's real reason was to eliminate threats to its own ground-based system.

The FAA's deep attachment to a completely ground-based system of air traffic control is causing it to lag behind in development of a cockpit display of traffic information.

Even worse is the fact that the equipment developed under the FAA contract is now sitting on a shelf, and the agency refuses to let NASA run its own flight tests on this idle hardware.

Adding to the collision avoidance problem is the fact that the FAA has been slow in developing airports and their facilities.

As I have indicated already, one of the more serious problems in aviation today is the growing congestion at airports, particularly the major hubs. One underlying reason is the lack of adequately equipped reliever airports for general aviation around the hubs. Thus, general aviation aircraft are forced to use the larger hub airports, particularly in bad weather, because they have nowhere else to go.

ALPA has long supported faster development of a system of reliever airports. It is vital that these relievers have instrument landing systems (ILS) and other navigational aids such as visual approach slope indicators (VASI) and proper approach lights if they are to be useful to general aviation.

At airports where it is necessary that airlines and general aviation coexist, ALPA encourages development of separate runways and approach aids so that slower general aviation aircraft and special performance ones such as helicopters are segregated from airliners in the interest of safety.

A collision between an airline transport and a general aviation aircraft always leads to demands that general aviation be banned from airline airports. ALPA does not support this proposal. We recognize the right of all users to have access to the airspace; we simply do not want to run into anyone. We see no sense in determining access to airspace by the weight of the aircraft or the number of seats. The avionics on the aircraft and the qualifications of the pilot should determine whether a particular aircraft is allowed in a crowded terminal area.

In conclusion, Mr. Chairman, we wish to offer four recommendations for your consideration as solutions to the longstanding problem of collision avoidance.

First, the FAA should be required to validate the already-developed airborne trimodal collision avoidance system and to issue promptly a national standard for it. Then, these systems should be required on all airline aircraft.

Second, Congress and the administration should set a higher priority on developing properly equipped reliever airports with money already in the aviation trust fund.

Third, the FAA should be directed to proceed as quickly as possible with testing of cockpit displays that would not only provide collision avoidance information but also give the pilot much more data about other factors affecting his flight.

Fourth, the Congress may wish to direct its agencies such as the GAO and the Office of Technology Assessment to examine the definite bias of the FAA in quietly promoting ground-based collision avoidance systems with their attendant delays and added costs.

I'd like to add one thing in here, two things really; that is, several of you have commented on the excess ADAP funds available. We don't want to get into a long discussion of that here. We're mainly concerned with midair collisions; but if you do have hearings on that, we are fully prepared to indicate the areas of critical safety that need these funds, the approach areas to the airport, ILS, VASI's the runways themselves, grooving, length, lighting systems, crash and fire equipment, capability to operate, and the same with the aircraft. We have a multitude of ways that that idle money should have been spent long ago for aviation safety.

Second, there's been a lot of discussion on system errors. We had a definition. I believe Mr. Ertel took exception to the FAA's definition of systems errors, but we're stuck with that definition of it. The definition is no matter what the cause, be it human, procedural, or equipment malfunction, if an aircraft gets out of the planned separation standard, it is a system error. As was indicated by Mr. Flener, they have no lack of system errors to investigate. Daily they do this. There are a lot of them. The ATC system is a good one, but it is subject to error. What we are talking about is when there errors occur, what recourse do we have? We say that we need an airborne collision avoidance system for the times when there are system errors in the ATC system.

When the last resort-when two aircraft are coming nose to nose, eyeball to eyeball, what do they have to help them? The FAA has nothing. "We had a system error, sorry, old boy, watch out." That is not enough. We think this available technology, a BCAS, a collision avoidance system, is the solution to this problem. We're not talking about a new ATC system. All we're talking about is something to overcome the errors that must be present, that are admittedly present in the present system. They're happening every day at the rate of about 1 a day, around 300 a year, if you look back through the last report. That's what you're having, one a day almost.

What happens? We think it's absolutely essential, long overdue that this collision avoidance system be available.

We commend both committees, Mr. Chairman, for holding this timely and needed hearing. We hope it will motivate the FAA to act quickly so a disaster such as happened here just a month ago will not occur again.

For many years, the Nation's airline pilots have joined in the call for an effective collision avoidance system. The tragic accident here last month underscores the need for such a system.

The record is clear. The duty of all of us in aviation to save lives by preventing aircraft accidents is manifest. The technology and the money to prevent midair collisions are at hand. Now it is up to the FAA.

We deeply hope, Mr. Chairman, that this is the last time we will have to testify after an accident about the need for collision avoidance systems.

We thank you for this opportunity to present our views on this truly vital subject, and we are ready to answer any questions. [The attachments referred to follow:]

ATTACHMENT 1

GENERAL ELECTRIC CF-6 ENGINE

This case involves insufficient testing of a new jet engine by the manufacturer and the Federal Aviation Administration and the failure of the FAA to apply adequate certification standards. These lapses led to at least three incidents of engine failure in passenger-carrying DC-10's. The FAA's response to this evidence of a weakness in the engine was half-hearted. Only after another engine failure-in which a DC-10 valued at about $30 million was destroyed-did the agency require changes to the engine itself to prevent future failures.

The CF-6 fan blades in the front of the engine rotate thousands of times each minute at near supersonic speed. They must be able to withstand ice, birds or other objects that are occasionally drawn into the engine. Otherwise, the blades will break and hurl metal fragments through the engine and into the wing or fuselage. Three important problems were revealed by the early service experience: Fan blades with holes drilled in the tips to save weight has a tendencey to break up into fragments when struck by birds, ice or other foreign objects. These blades are still allowed in service, but when used in the No. 2 (tail-mounted) engine of the DC-10, a special armor is required to protect fuel lines against damage from blade fragments.

The fan blades seemed susceptible to damage from bird ingestion. No remedy has been applied to the problem and proposals for modifying the bird ingestion testing requirements of FAR 33 are included in the FAA's Engine Regulatory Review Program.

The epoxy material used for shrouding the blades could be abraded into particles fine enough to explode in the engines. The remedy was to require replacement of the epoxy material with aluminum honeycomb.

Evidence accumulated by a special investigations subcommittee of the House Interstate and Foreign Commerce Committee revealed a critical breakdown in the airworthiness certification process as administered by the FAA.

37-810-79-8

In January of 1970, the FAA certificated the CF-6 engine as "safe." Despite the fact the engine had new technology that advanced the state-of-the-art by several stages, a five-year-old and, as it turned out-unsatisfactory-certification standard was applied to the engine under the "special conditions" authority vested in the FAA. Special conditions basically allow manufacturers to set their own certification standards if they can provide to FAA a satisfactory design and engineering basis for an exception to existing rules.

This was done for the CF-6 engine.

The company sought special conditions for certification of its new engine with drilled-tip blades, which had never been used before, based on the FAA's earlier certification of the Pratt & Whitney JT9D engine, which powers most Boeing 747s. The JT9D was the first high-bypass-ratio engine to enter commercial service. It and the CF-6 engine use advanced technology to produce about three times more power than earlier engines on such aircraft as the 727 and DC-9.

The JT9D was gaining service experience during the time period of the CF-6 certification program. Service difficulties on the new engine were known to FAA engineers; however, it is not known whether, or to what extent, that information was used to modify or add emphasis to parts of the CF-6 testing.

When certification of the JT9D was requested, the FAA did not have certification standards for high-bypass-ratio engines. Therefore, the JT9D was certificated in accordance with Advisory Circulars (ACs) covering older, less-powerful engines. A new AC for high-bypass-ratio engine testing was being written when General Electric requested certification of the CF-6. The company argued successfully that it would be an economic hardship if the FAA were to apply the new AC to its engine when it had not been applied to the earlier JT9D. Of course, the certification criteria in the new AC could not have been applied to the JT9D because they had not yet been formulated.

Thus, the FAA bowed to the manufacturer's economic arguments and did not employ the most current and stringent technical standards when it certificated the CF-6.

The House subcommittee report noted three accidents over a 14-month span of CF-6 operation during which ample evidence of difficulties with drilled-tip compressor blades was gathered. Despite these findings, however, the FAA declined to issue an Airworthiness Directive (AD) to replace drilled-tip blades with those of more conventional manufacture.

General Electric switched to solid-tip compressor blades in all its production engines, including the CF-6, in December, 1973. This did not, of course, solve the problem of several hundred CF-6 engines with drilled tips already in service. The Air Transport Association, an airline trade association, according to the subcommittee report, estimated that it would cost $47,000,000 to convert drilledtip CF-6's to solid tips, and opposed an Airworthiness Directive which would have mandated the conversion.

The House subcommittee investigation also disclosed that icing tests made by the Great Lakes Region of the FAA were nowhere near what could be described as exhaustive. In fact, the subcommittee report declared that test aircraft did not penetrate known icing conditions for any length of time at all in certification tests. Even at lesser icing conditions, test engines suffered damage. Nevertheless, certification proceeded.

FAA did issue an Airworthiness Directive (AD) on the CF-6. The AD, however, did not call for a fix of the engine. Rather, it called for protection of fuel lines and other control conduits on the DC-10, particularly to the No. 2, or tail-mounted engine.

That AD, issued August 23, 1974, provided only that the main fuel line to the tail engine of the DC-10 be shielded on GE-powered aircraft. Less than two months later, on October 15, the original AD was amended to provide special shielding was necessary only on GE-powered DC-10's with drilled-tip compressor blades.

On November 12, 1975, an Overseas National Airways DC-10 began its takeoff roll at John F. Kennedy Airport. Midway down the runway, the DC-10 encountered a flock of gulls feeding from a nearby garbage dump. One of the plane's wing-mounted engines-not the high, tail-mounted engine that was the subject of the FAA's two airworthiness directives-ingested some of the flock. Its drilledtip blades disintegrated into shrapnel that blasted through the engine shroud and into the wing and fuselage. Portions of the disintegrating engine ripped through fuel lines causing jet fuel to ignite. The pilot ultimately fought the blazing aircraft to a halt off the end of the runway. His actions allowed the 139 passengers to escape, but the DC-10 was consumed by fire.