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probably air passenger transportation, and certainly air freight transportation, does not serve the public convenience and necessity. Thus, air fright amounts to only one-tenth of 1% of the total common carrier freight market. Fixed-wing air traffic amounts to only 4% of the total inter-city traffic and less than one-half of the 1% of the travelers going less than 200 miles. (NYA 602-3) Certainly the more reasonable standard is the total volume of traffic carried.

D. The Defense Department's Computation of Military Traffic Useage [[Usage]] Has No Validity.

The Defense Department concluded that it had no specific passenger requirement in the New York area. 22/ It reached this conclusion despite the following facts:

(1) New York generates an important volume of military traffic. The record shows that over 240,000 military passengers were either originated in or were destined for the New York area in 1964. (Adm.Ex. 307; Tr. 771)

(2) There are a large number of military installations clustered around the Newark airport. Helicopter service makes available the vastly superior schedules operating from Kennedy or LaGuardia. (Adm.Ex. 308)

(3) The Department fully recognized that just as it used air transportation to save time between airports, it is interested in saving time to the airports. (Tr. 771)

The Department based its conclusion solely on a study purporting to show that only 18 GTE's issued by the military used NYA in April 1965. This exhibit, however, was completely discredited at the hearing. Since it was based solely on passengers paying full local helicopter fares, it gave no recognition to the use of joint fares which permit helicopter transportation free or at rates below alternate surface transportation to the major military destinations.. The advantage of joint fares is shown by the table below:


22/ Testimony of Commander Rhodes, p. 2.