A deluge of orders for new helicopters during HAI’s Heli-Expo, held in Las Vegas last month, surprised even seasoned industry watchers on the floor. By the end of the show’s second day, an estimated 110 airframes, conservatively worth $600 million, had been spoken for by domestic and international customers.
Last year’s sales total over three days had been a relatively small 50 rotorcraft, and 2002’s total was an even more miserly 20. Attendance figures were also up–the two-day total of 14,723 topped last year’s event in Dallas by almost 2,500 and surpassed even the figure recorded in Vegas in 2000, when the economy and the industry were both arguably in better shape.
Big news were the orders–worth $275 million–for 16 new Sikorsky S-92s, including three for North Sea operator CHC Scotia and others for an undisclosed raft of corporate and offshore customers, as well as scheduled passenger operators. It was an announcement that transforms the fortunes of the OEM after several years of failure in military skirmishes against the Anglo-Italian EH 101.
The first production S-92 was also handed over to offshore operator Petroleum Helicopters; a second is scheduled for delivery this summer. An ebullient senior marketing and commercial vice president, Jeff Pino, said it also made the S-92 launch “the most successful in the history of Sikorsky Aircraft,” and will take up production until the latter part of next year. S-76 orders continue to look good as well–Sikorsky’s current 13-month order book is for 59 aircraft with options on another 57.
Bell was a surprising runner-up in the order stakes, at least in terms of airframes sold. Firm orders for no fewer than 46 Bell helicopters put a spring in CEO Mike Redenbaugh’s step. His team secured a 10-ship order for its stalwart 412EP and, amazingly–within 48 hours of its launch on the eve of the convention–took deposit checks on no fewer than eleven 427IFRs. Other Bell sales–eleven 407s and four 427VFRs, as well as several 430s, 412s and 206Bs–totaled 46 airframes worth $150 million. Spokesman Mike Cox confirmed these were all firm orders with deposits taken. “If it were up to our sales force, they would be claiming a lot more,” he said.
The single-pilot 427IFR, to enter service in 2006, will feature more cabin space and a new avionics system with a three-axis autopilot. A “completely reworked” rotor system will reportedly deliver increased speed, higher altitude and decreased noise. A dedicated air-ambulance version will hold two patients, two attendants and equipment, in the rear cabin. Kits will be made available to enable existing 427 owners to upgrade, but Redenbaugh said sales of the VFR version were now improving, and he was confident they would not be affected. “I see a place for both variants,” he added.
Redenbaugh also announced plans to build the Bell 210–a major retrofit package for the UH-1H that includes many drive-train components from the Bell 412. Together with more than 200 unique items, the upgrade is expected to deliver startling performance improvements, including an 11-percent increase in internal mtow, an 18-percent increase in external mtow, 40-percent lower direct operating costs ($530 per hour compared with $880) and double or even triple TBO intervals on major components.
The amount of work required will vary from airframe to airframe, but Redenbaugh estimated the upgrade should not cost more than $3 million. Plans call for certification to be completed in the summer next year.
Bell’s much-heralded MAPL (modular affordable product line) will depend on key technologies, including the main rotor, drivetrain, autopilot and noise control. In addition, suppliers are working on engine technologies and avionics. Illustrations of a proposed single and twin featured an enclosed tail rotor, but Redenbaugh suggested that not too much should be read into that. “We are working on certification and first deliveries by the end of the decade,” he said.
The European Front
Eurocopter also announced significant orders during the show, including one for 12 helicopters (six EC 130s and six AS 350B2s) from California EMS and charter operator Helinet. Air Methods committed to 10 EC 135 air ambulances–the largest single order for the light twin in that role in North America. Vanderbilt Life Flight agreed to buy three EC 145s, France’s Heli-Union ordered two AS 365N3 Dauphins (hard on the heels of an order for two AS 332L1 Super Pumas in February) and execs from U.S. offshore operator Taylor Energy shook hands on a deal to buy three EC 130s. In addition, CJ Systems ordered six EC 135 air ambulances.
Eurocopter president and CEO Fabrice Bregier announced that, with the opening of its new manufacturing facility in Mississippi, his company has its eye on an even bigger slice of the American pie. For the past year, he said, the company had been focused on European EC 145 launch customers, including the French civil defense and emergency-planning organization, the French national police, REGA Swiss air rescue, other air rescue units and the Hessen police in Germany.
Bregier said this group of “highly demanding customers” had put the EC 145 through its paces during missions ranging from mountain rescue, special-forces engagements, EMS and intensive-care transport missions–including a landing on Europe’s highest mountain, 15,770-foot Mont Blanc.
Celebrating a year as head of Eurocopter, Bregier said in that time the company had made sales resulting in revenues of $2.6 billion. The manufacturer’s current order book stands at $8.8 billion.
According to Marc Paganini, president and CEO of American Eurocopter, the OEM already supplies 33 percent of the EMS fleet; 27 percent, utility; 20 percent, parapublic; 15 percent, corporate; and 5 percent, offshore. It delivered 74 helicopters in the U.S. last year, and it expects to do even better this year. The first EC 145 for a North American customer was revealed at Heli-Expo. Florida-based Lee County’s EC 145 represents the first U.S. delivery of the latest upgrade of the Eurocopter BK 117.
Shreveport, La.-based Metro Aviation is tidying up the certification process before its 145 enters service as an aeromedical transport and search-and-rescue tool.
Next in the Heli-Expo order rankings came Bell/Agusta Aerospace (BAAC), which revealed orders for four AB139s. One was for New Zealand’s Helicopters (NZ) and another for Honeywell, which had plenty of time to evaluate the aircraft while test flying its Primus Epic avionics aboard the medium twin in Phoenix. A third will go to U.S. offshore utility operator Evergreen and the fourth to Canadian charter company London Air Services.
Bell/Agusta confirmed that a second production and final assembly line for the AB139 will be added to Bell’s Amarillo, Texas assembly center. The facility was previously announced as the manufacturing site for the BA609 civil tiltrotor and assembly and delivery center for the V-22 Osprey. The Amarillo production line will be in addition to the current line in Italy at Agusta’s Vergiate facility.
Keeping a relatively low profile, MD Helicopters still announced sales of four helicopters: an MD 600N to Brazilian utility operator Peña Aero Taxi, another one to its distributor, Helicentro Morumbi in São Paulo, and a 520N/902 Explorer combo to a newly appointed Russian distributor, GALS Helicopters of Moscow.
Alone among the turbine-engine airframe makers, AgustaWestland could not point to a single sale inked during the convention. Handovers, however, included the fourth of 10 A119 Koalas destined for offshore operator Tex-Air. AgustaWestland also announced that the company will move production of the increasingly popular single-engine Koala from Italy to Philadelphia. Construction is already under way on a manufacturing and final assembly plant at Northeast Philadelphia Airport, where about 20 helicopters will be built each year.
Pistons Took the Back Seat
The piston brigade fared less well than in recent years. Enstrom sold a 280FX, Schweizer one 300C and Robinson–in a poor showing by its own standards–just two R44 Raven IIs. However, Robinson earlier announced record sales last year, with production committed for the first half of this year. Robinson also said it now has 16 of its “free” rooftop helipads on order, for delivery to customers around the world. Three have already been delivered–one to an R44 owner in New Zealand, another to the Philippines and a third to a Honda dealer in Santa Ana, Calif.
A Robinson spokeswoman told AIN that, after a slow start, the company is now getting “weekly” letters of interest in the $6,000 extruded aluminum pads, which were launched at Heli-Expo three years ago and are free if ordered with a new R44. “Before we can deliver, though,” she said, “the customer has to get all federal, state and local permissions.”
French engine manufacturer Turbomeca overcame last-minute Honeywell objections to enter discussions with the U.S. Coast Guard for the contract to re-engine up to 96 USCG HH-65 Dolphins. Airframe maker Eurocopter will carry out the engineering work, which will involve nearly 200 engines, from the new base in Mississippi.
Margaret Mitchell Jones, a spokeswoman for procurement agency Integrated Coast Guard Systems, told AIN that the decision to opt for Turbomeca’s Arriel 2C2-CG engine was made just before Heli-Expo. “We put out a request for information from four highly qualified engine manufacturers in January, but stipulated that the chosen company would be able to start implementing the solution by mid-June,” she said. “Only Turbomeca was able to meet our time, cost and power requirements, so it and Eurocopter have been invited to go through to the next stage.”
In this competition, Turbomeca found itself head-to-head with Honeywell, whose LTS101 engine had, in the past, given the Coast Guard both maintenance and performance problems. Arguments over whether these problems were engine- or airframe-related had become almost vituperative in recent weeks. But in a last-ditch effort, via a press release distributed at Heli-Expo, the U.S. engine maker was keen to extol the current reliability rate of the unit. Honeywell invested more than $30 million in upgrading the engine, including installing FADEC. However, it could not commit to getting it certified until next year–well outside the Coast Guard’s extremely tight timeframe.
Precision Approaches Draw Closer
An air of cooperation between FAA officials and the helicopter operating community prevailed at an HAI Flight Operations Committee meeting, as the parties talked about how to achieve helicopter ILS approach capability to 100-foot minimums at Category I airports.
The FAA’s Ken Knopp said that low-visibility airport-approach capability was an intermediate step toward one of two mileposts on the agency’s helicopter technology “road map” of research and development initiatives mandated in the FAA reauthorization bill. “The ultimate goal is zero-ceiling, zero-visibility operations,” he said.
Knopp told AIN that the signal-integrity issue will eventually become moot as the national airspace system moves away from dependence on ground-sited navaids. He said the wide-area augmentation system (WAAS), which uses ground station-corrected GPS signals to deliver position accuracy to the order of ±three feet, will help in the transition, and that the long-delayed local-area augmentation system (LAAS) is the ultimate solution. WAAS, he predicted, will be the nearer-term basis for a helicopter-specific low-altitude route structure that will lessen pressure on the ATC system. Despite its recent problems, Knopp eventually anticipates resumed progress on LAAS.
Stephen Hickock, a pioneer in the development of helicopter instrument-approach criteria and procedures, has launched a new company to continue the work of creating and certifying IFR procedures for heliports.
After retiring from the FAA, Hickock became a founding member and principal manager of Satellite Technology Implementation–the first company authorized by
the U.S. government to develop and implement helicopter GPS approaches. He played a key role in the development of almost all helicopter Rnav/GPS procedures flown in the U.S. today.
His company’s launch customer is CareFlite, a Grand Prairie, Texas EMS provider with a mixed fleet of helicopters. Hickock & Associates will provide a turnkey solution for IFR approaches to 15 hospitals in the Dallas/Fort Worth area. Hickock’s work inside and outside government has led to privatization of helicopter instrument-approach development and certification. Given the FAA’s low priority for developing instrument procedures for helicopters itself, the private effort is likely to be the primary means for helicopter operators to achieve off-airport instrument-approach capabilities.
Hickock added that a critical first step in the process was FAA adoption of “point in space” criteria for instrument approaches to VFR heliports, which he helped to write. “We don’t have IFR heliports in this country,” he noted, explaining that while airports are surveyed for elevations and obstruction heights, heli- ports are not. Thus the GPS-based point-in-space concept is an essential part of the almost 200 industry-developed approaches now in effect.
Accomplishing that development requires people who “understand that one size does not fit all, and who can draw on knowledge of what the FAA expects. Every project and every site deserves the personal attention that only the most experienced and qualified people can provide.”
Continuing the approach theme, an FAA program manager was on hand at the FreeFlight booth to answer delegate questions on WAAS. In the U.S., the only country so far to have set up a system, 25 ground-based wide-area reference stations (WRS) continually monitor and collect data from GPS satellites. Each WRS uploads data to one of two wide-area master stations, where correctional data for specific geographical areas is computed. A correction message is prepared and uplinked, via ground stations, to geostationary satellites. Finally, the message is transmitted on the standard GPS frequency to GPS/WAAS receivers aboard aircraft flying within the coverage area.
FreeFlight designs and builds avionics hardware, including a 12-channel GPS sensor that can translate the corrected signals. (Such a system has already been selected for the FAA’s Capstone flight-safety program in Alaska). Company president Steve Williams told AIN that the FAA has already approved 750 WAAS approaches in the U.S., but the potential is “at least 4,500.” Japan is the only other country so far committed to the technology, but Williams said that by removing the requirement for hardware at individual airport sites, there are real savings to be made anywhere where aircraft need to make instrument approaches.
“The technology also removes the final technical obstacle to the goal of achieving precision helicopter approaches to the hover over a given point in space,” he said.
Separate Surveys Predict Buoyant Market
According to Honeywell’s latest market forecast, operator demand for more power and useful load, improved safety/crashworthiness, attractive pricing and lower direct operating costs will be the strongest drivers for sales of new helicopters over the next five years.
Between now and 2008, sales are expected to be 6.8 percent higher than in the five-year period from 1999 to 2003, with corporate, EMS and law-enforcement helicopters leading the way.
Honeywell’s sixth Turbine-Powered Civil Helicopter Purchase Outlook projected deliveries of approx- imately 2,350 new civil-use helicopters during the period, driven in part by increased demand for light single and intermediate twin models.
Buyer interest remains healthy overall, Honeywell reports, and there is no indication that a decline in demand is likely in the near future. The findings were based on inputs from more than 900 flight departments across the world.
Regulatory initiatives and proposals continue to stimulate significant interest in twin-engine heli- copters in some regions. In Europe, almost two-thirds of all survey expectations are for twins, while in North America, where regulations covering their use are less restrictive, 62 percent of planned purchases will be singles. Asia, the Middle East, Africa and Oceania are also potential strong growth areas.
According to Lynn Brubaker, v-p of Honeywell Commercial Aerospace, “survey data also indicates that the decision to acquire new heli- copters is driven primarily by age of current aircraft and an operator’s desire for newer technology, bigger cabins and more payload. Along with new model introductions, these continue to be important factors supporting demand. We are optimistic about the long-range prospects for helicopters in this diverse global economy.”
In North America, according to the survey, law enforcement received 30 percent of all mentions this year. Although this represented a decline over last year, it remained the most popular market sector. One possible reason for this was that expected funds to purchase new helicopters for increased homeland defense and border-patrol requirements never materialized. EMS applications held steady at almost 30 percent of planned new purchases, while planned corporate purchases fell again to 18.4 percent of the total.
Honeywell said the latest worldwide survey indicates a strengthening of demand for new helicopters over the next five years, despite the fact that expectations fell compared with last year’s survey. Last year’s survey results were affected by a spike in European expectations for new twin-engine helicopter requirements, mandated by laws now in effect.
North America continues to have the greatest demand for new helicopters, accounting for almost 46 percent of expected future purchases. Expectations fell modestly in this year’s survey compared with last year, with most of the decline blamed on reduced expectations for law-enforcement aircraft to support homeland defense and border-patrol missions.
Responses suggest that about 23 percent of all new turbine-powered helicopter sales will be in Europe. European operators continue to cite evolving regulatory requirements regarding the types of equipment that can be flown within populated areas as a significant factor in replacement demand. Accordingly, close to two-thirds of future European demand for new turbine helicopters is still expected to be twins.
About 60 percent of future demand in other regions–Asia, Africa and Oceania–is expected to be for multi-engine helicopters. However, unlike in Europe, the demand is expected to be skewed much more toward larger machines, which are predicted to account for more than 40 percent of expected demand in the region. Although the reasons for buying closely follow those in Europe, nearly 32 percent of expected purchases will be for offshore oil applications, dramatically higher than any other region. Corporate applications were also mentioned frequently by respondents in this region.
Latin American expectations increased noticeably in this year’s survey after falling sharply last year. However, the region still has the lowest fleet replacement and expansion percentage of all world regions and also represents the smallest number of purchases for new helicopters.
This region is expected to account for only around 9 percent of expected demand for new helicopters. More than 80 percent of expected rotorcraft demand in Latin America is for single-engine helicopters. Aircraft age is the dominant reason for expecting to replace current aircraft with new ones, accounting for 88.5 percent of comments. The next most frequently mentioned reason was improved technology, but it accounted for only 10 percent of the responses.
Latin American operators expressed deep concern over poor economic conditions and taxes or threats of new aviation-targeted taxes. Although some currencies have gained against the U.S. dollar, others are negatively affected by the dollar’s decline. Latin American operators said their flight department budgets are tight, which is affecting the use of their current aircraft and potential purchases.
Rolls-Royce, in association with the Teal Group, also released its annual 10-year forecast of worldwide turbine helicopter deliveries. Stuart Mullan, the company’s president for helicopters, said that in the next decade some 10,724 turbine helicopter deliveries are forecast worldwide, with an associated airframe value of $95.6 billion and an installed engine value of $8.8 billion. The figure represents 3-percent growth over last year’s forecast, reflecting the transition of some major military programs into production during the period offset by some rescheduling of demand.
Although substantial growth in the military helicopter market is still expected, the timing has been shifted to the future due to program delays and redirected near-term funding to operational expenditures associated with the war on terror. The civil helicopter market forecast has also seen a very slight near-term softening associated with the prolonging of the current economic downturn, among other things.
The split between civil and military unit sales is forecast to remain at around 50/50. In addition to underscoring the relatively larger size of most military rotorcraft as a cost accelerator, the difference is also reflected in the higher cost of mission avionics, for example.
The 10-year projected deliveries of civil helicopters remained unchanged from last year’s 5,165 units. These will account for $13.9 billion in airframes and $1.9 billion in installed engines. The consistency reflects the long-term health of the civil helicopter market, bolstered by paramilitary sales and the expectation of new product introduction toward the end of the decade.
Fifty-seven percent of the deliveries will be turbine singles, 22 percent are projected to be light twins and the intermediate class is anticipated to account for 17 percent. Deliveries are expected to increase slowly over the period from a low of 480 units this year to a peak of 531 at the end of the period.
Although civilian turbine helicopter delivery volume was marginally down from 2002 to last year, deliveries did remain robust when viewed in the context of the protracted economic downturn and global political instability. Last year also saw a substantial rebound in piston-engine helicopter sales, which reached approximately 470 aircraft, thanks to a 50-percent increase in Robinson deliveries.
While an influx of funding for additional paramilitary rotorcraft has yet to appear, the heightened focus on domestic security has benefited existing airborne law-enforcement fleets through increased operational funding and fleet replenishment.
The tourism market has continued its two-year recovery, and the offshore market has remained stable with some regional increases in flight activity. Despite suffering a substantial fall last March, the pricing trend for crude oil has continued to recover over the past 12 months, and the future outlook for hydrocarbon exploration remains positive.
Resale Values Split
Meanwhile, compilers of the rotorcraft industry’s resale bible, the Official Helicopter Blue Book, identified a split in resale pricing trends they had not seen in 25 years of editing the guide. Helivalue$ president Barry Desfor said the good news for operators of larger twins is that their ships have increased in value, in some cases by as much as 20 percent. The bad news is that owners of smaller turbine singles have seen their fleet values slump anywhere from 20 to 40 percent.
“The problem is exacerbated for older airframes,” said Desfor. “The tremendous hits that some of the types are taking are not the fault of the aircraft themselves,
but the result of external pressure within the secondary market, specifically insurance.”
The fall in value of helicopters such as the Bell 206B and MD 500, and to a lesser extent the AS 350 series, is directly attributable to the high cost and lack of availability of insurance coverage in North America, said Desfor. The smaller mom-and-pop operators, who typically operate between one and four helicopters, are finding it extremely difficult to get coverage at all–let alone coverage at a reasonable cost.
“The upshot is that some charter operators now find it uneconomical to fly their machines,” he said. “When customers require helicopters to have public-liability coverage of $2 million dollars per seat [equivalent to $10 million for a Bell 206], insurers will typically cover only half that.”
As a result, smaller operators find themselves shut out of the market. Desfor said one Canadian operator told him it is cheaper to continue payments on two financed JetRangers and put them into long-term storage in a heated hangar than it would be to insure them properly and put them to work.
“Right now, more than 10 percent of the installed Bell 206 fleet–around 500 helicopters–is up for sale,” said Desfor. “We are seeing a devastating effect on the market.”
A Sleeping Dragon Stirs
During a China rotorcraft forum, representatives from the China World Helicopter Association (CWHA) and HAI updated a group of about 60 people on the state of helicopter operations in that populous nation. According to panel remarks, the Chinese government has approved Eurocopter, Bell and Sikorsky/Schweizer helicopter man- ufacturing on a relatively small scale, but it is still not ready to open its skies to wide-scale helicopter operations.
“The Chinese government is pondering whether or not to open the domestic market to helicopters,” said Tomoo Nakayama, president and CEO of Tokyo-based ITC-Aerospace and a CWHA representative. “It has no experience in helicopter operations. For the past 50 years, HAI members have experienced lots of development while the Chinese government has maintained a closed door.”
A delegation of helicopter operators, led by HAI president Roy Resavage, visited China in late 2002 and met with “top leadership” of the communist party and civil aviation administration of China (CAAC) officials to discuss opening the skies to rotorcraft as previously proposed for fixed-wing aircraft. Although China has since allowed limited fixed-wing operations, the country remains closed to helicopter operations. The few exceptions allow their use for offshore operations and powerline inspections.
However, even these are highly regulated, requiring the submission of a flight plan a week before the flight and no assurance that the flight will be permitted. Nakayama related a story of a wealthy individual who obtained permission to purchase a helicopter and a license from the CAAC to fly one, but, upon approaching a major city from the air, was forced to land because the municipal government had no regulations covering rotorcraft.
There are some signs that the closed door may be cracking open slightly, mainly because of upcoming events that will have the world focus on China. According to Luo You Zhen, a high-ranking official overseeing industry and commerce, the government has already been seeking advice from CWHA and HAI on how to arrange helicopter operations for the World Exposition to be held in Shanghai in 2010. Also, with a Formula One motor racing Grand Prix coming to Shanghai this September, municipal officials have requested permission for two EMS-configured helicopters to operate during the race. The city of Nanjing has also requested permission to use helicopters in firefighting roles.
A conference between CWHA members and government officials in Shanghai last September led to a proposal for a helicopter center in that city, with 51-percent government ownership and 49 percent divided among six to 10 private operators.
“The Shanghai government is considering acceptance of the helicopter center as a special economic development area,” Luo said. “For the Chinese government, the helicopter center is a way to be successful in helicopter operations, and success in Shanghai could result in similar centers being developed in other cities. With the big market in China, we are confident that the international financial institutions will join us to bring in the capitalization.”
Establishment of the helicopter center is still far into the future. The proposal is being worked by CWHA members and will not likely be submitted to the Chinese government until next year.
“It’s clear that this is a very big marble,” said Tim Biddle, a consultant to HAI who attended last year’s Shanghai conference, “and it’s going to be hard to crack. But it is crackable, if the Chinese government allows it to be.”
European trade show Helitech will set up a companion event in China. Organizer Spearhead Exhibitions is testing the water with a show in Hong Kong, scheduled for April next year. Said project manager Sue Bradshaw, “We will use that to finalize plans for a Helitech in Shanghai in 2006.”
Helos in Homeland Defense
HAI’s Resavage admitted he loses sleep over the fact that there is no firm plan in place on how to integrate commercial helicopters into a homeland-defense role.
The Transportation Security Administration (TSA), which took over aviation security from the FAA, is responsible for all modes of transportation, including aviation. “It is being asked to do a lot of things in a lot of different areas–aviation is only one of them,” Resavage said. “Its primary focus is quite rightly on commercial air transportation. It has worked on that problem very diligently, and everything else has kind of fallen off the radar screen. We’re trying to get it to rethink that.”
Resavage admitted that it’s a slow process, but he added that HAI is working very closely with the government. The association has submitted several different proposals–possible remedies and things to consider–about how to integrate commercial helicopters into emergency response.
He said that in the event of another airspace lockdown such as the one on 9/11, emergency planners would not know where to call and there would be no guarantee that non-government aircraft could even get into the air and fly.
According to Resavage, there is no mechanism available for an emergency responder, an individual or police department to summon airborne assistance for rescue, medical assistance or perhaps heavy-lift capabilities.
“One, we don’t know whether we can ever get airborne, because we’ve seen in the past that you can’t do that,” Resavage said. “Two, we don’t know who’s in control to start to make that call. We don’t know who’s in charge and who is authorized” to give commercial helicopter operators permission to respond during a national emergency.
Other unanswered questions are who would pay for it and who would insure it? Resavage said he met recently with top TSA officials, but he conceded that the agency may not be the best to approach, saying that possibly another agency within the Department of Homeland Security might be better qualified.
“It’s a work in progress. It’s been a work in progress, unfortunately, for about the last year,” he said. “We are starting to make a lot more progress than we have in the past, so it’s accelerating in the movement and acceptance of the concept.”
Briefly giving a rundown on some other HAI activities, Resavage said the organization is very proud of “a lot of work” that has been done on the infrastructure in the Gulf of Mexico. “For years, operators of more than 600 aircraft there have felt like second-class citizens,” he said. “They don’t have satisfactory communications, weather reporting or surveillance.”
He said HAI submitted unsolicited proposals to the FAA suggesting ways to solve a majority of the problems.