Get extra lift from AOPA. Start your free membership trial today! Click here
Advocacy Advocacy Briefs Air Traffic Services Brief -- Proposed Modification of Circling TERPS Criteria

Air Traffic Services Brief -- Proposed Modification of Circling TERPS Criteria

May 4, 2001

Attn: Mr. Robert A. Wright, AFS-400
Federal Aviation Administration
800 Independence Ave., SW
Washington, DC 20591

Dear Mr. Wright:

The Aircraft Owners and Pilots Association (AOPA), representing the interests of over 370,000 aviation enthusiasts and professionals nationwide, wishes to express its concerns over the proposed Change 20 to FAA Order 8260.3, Terminal instrument Procedures (TERPS). During the most recent meeting of the Aeronautical Charting Forum, Instrument Procedures Subgroup, the FAA made clear its intention to move forward with increasing the protected circling areas for category A-D aircraft. Although the intent of this revision is to increase the margin of safety afforded all operators, AOPA is deeply troubled with the impact of this change to its members. The potential increase to approach minimums at airports throughout the country will have a profound and negative effect on the safe and efficient use of airspace by many general aviation (GA) pilots. In the absence of any compelling safety data to support such a wholesale change, AOPA strongly urges the FAA to retain the existing parameters for category-A aircraft.

AOPA is willing to defer to the operational expertise of other industry representatives in evaluating the stated need for an increase in category-C and D protection criteria. For category-B aircraft, AOPA would like to see additional testing to include flight-path variations resulting from changes in density altitude. A study of this type is instrumental in validating the need for increasing the category-B protection criteria. However, the FAA has failed to make a case for increasing the protected area for category-A aircraft. The following highlights our concern in this matter:

  • The computerized modeling data presented by Flight Standards fails to demonstrate a need for the proposed change.
  • Flight Standards has failed to show due diligence by not conducting the "real world" testing necessary to validate the need for change.
  • No assessment has been done to determine the operational impact to category-A operators.
  • No compelling accident data has been offered to demonstrate value.
  • The FAA's obstruction evaluation process has proven adequate in protecting instrument approaches. An increase in the protected area without a subsequent change to the obstruction standards of Title 14 CFR Part 77 would penalize the GA community both in terms of protection and lower approach minima.
  • Resources committed to re-assessing existing approaches would be better spent developing new approaches, which would offer improved overall system safety (and access).
  • The proposed circling area is larger than a visual flight rules (VFR) traffic pattern. Operational experience has shown that a protected area of that size is simply unnecessary to contain category-A aircraft.
  • The resulting penalty in terms of approach minimums appears contrary to other initiatives put forth by the FAA to encourage the GA community to increase their usage of the instrument flight rules (IFR) system.

In short, while AOPA has an abiding interest in the safety of its members, years of operational experience have demonstrated no need for an increase in the protected circling area for category-A aircraft. A search of both the FAA's Incident Data System and the National Transportation Safety Boards Accident/ Incident Data covering a 20-year period revealed no cases in which inadequate terrain protection was cited as a primary or causal factor. This is not to suggest that an accident should be necessary to trigger a safety enhancement. However, given the number of circling approaches conducted and the conspicuous absence of any catastrophic events related to protection criteria, it is clear that the current guidelines provide pilots of category-A aircraft with an acceptable level of safety.

Although there is an increased risk associated with circling approaches, especially under certain meteorological conditions, there is simply no evidence to support the FAA's contention that larger circling area criteria will mitigate any of the associated hazards. It is recognized that the greatest danger inherent to circling approaches is associated with human factors such as disorientation, poor technique, and lack of judgment. AOPA would respectfully remind the FAA that the role of TERPS is to provide a safe operating environment for pilots, not eliminate risks associated with a lack of adherence to sound operational practices. For these reasons, AOPA strongly urges the FAA to avoid a "cookie-cutter" approach to circling TERPS by retaining the existing protected area criteria for category-A aircraft.

Respectfully,

Randy Kenagy
Director, Advanced Technology
Aircraft Owners and Pilots Association