“We believe implementation of such a requirement would be extremely difficult given the high cost and continuing low availability of COVID-19 testing in the United States. Furthermore, such a proposal would disproportionately impact aviation vis-à-vis rail, bus and public transit, all of which have similar passenger seating environments, because travelers may be unwilling or unable to get testing before flying. In addition, a domestic testing requirement for air travel will inevitably result in potential air travelers electing to drive to their destinations, which is statistically more dangerous than flying and could lead to higher rates of COVID-19 transmission, as road trips typically include indoor food and rest stops..."
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