August 8, 2003
Mr. Charles Keegan Associate Administrator Research and Acquisitions (ARA-1) Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20015
Re: Operational Evolution Plan Version 5.1
On behalf of the Aircraft Owners and Pilots Association's (AOPA) more than 400,000 members, we offer the following response to the recent Operational Evolution Plan (OEP). As I stated at the Industry Day meeting held at Mitre on July 21st, it is disappointing that the OEP has not addressed issues AOPA presented at last year's OEP meeting, and subsequently presented to you in written form on February 24, 2003. We have repeatedly expressed the need for including implementation of GPS and WAAS procedures, addressing general aviation access to airspace and airports surrounding "OEP" airports, and improving reliever airport infrastructure.
AOPA was alarmed when its review of OEP version 5.1 revealed a dramatic change in FAA policy, in that it has eliminated the commitment for developing and charting GPS and WAAS instrument approaches. As a result, it is unclear if any new instrument approaches will be created for general aviation between now and 2013. Without a commitment for publishing approaches for a minimum of 500 runways per year (as was expected for GPS-based procedures), general aviation will lack any incentive to equip with GPS suitable for instrument flight rules operations. AOPA has stated this repeatedly for over ten (10) years. Slow equipage rates will likely delay user transition to RNAV (or RNP) and the need for a very high frequency omni-range (VOR) will be extended.
Unfortunately, the most recent version of the plan continues to ignore the importance of general aviation airports that provide important air transportation infrastructure around the OEP airports. If general aviation airports in these areas are access restricted due to the absence of navigational aids, local community restrictions or lack of adequate runway/taxiways to accommodate a spectrum of general aviation users, the OEP airports and associated airspace will be impacted. Airport infrastructure improvements should include the following items, which provide better all-weather access:
The FAA has not adequately addressed the airspace and air traffic requirements for supporting general aviation operations into the satellite and outlying airports around the "OEP airports." While general aviation operations do not directly impact the operations at "OEP airports," without proper planning, general aviation will have but little option to utilize the OEP airport. Supporting these satellite airports means that the FAA must include in the OEP a plan to improved VFR access. Proper design of the airspace must ensure predictable access for pilots operating in these airspace areas. This should include the design and charting of performance-based RNAV routes through the terminal airspace areas. AOPA requests that, by the end of the long term, the FAA publish several routes through each of the 30 Class B airspace areas. This requires immediate planning and execution. In fact, to be on target, 50 percent of these routes would likely need to be implemented by the end of the near term.
A good example of increased general aviation pressure on an OEP airport is occurring at Dulles International Airport (IAD) in Virginia. You have personally witnessed this increased traffic volume when you visited the general aviation ramp at Dulles on two different occasions recently. With Reagan National Airport closed to general aviation, operations have migrated to IAD, where sufficient infrastructure is prepared to support their operational needs. The only other airports within 50 miles of Washington, D.C., with all-weather access (ILS approach) are Frederick, Md., and Manassas, Va. Neither airport has flight support services open around the clock, and only one (Manassas) is currently capable of handling all sizes of business aircraft. However, the ILS at Manassas directly impacts the operations at IAD, often creating delays for pilots attempting to land at Manassas. Ignoring these challenges leaves general aviation with few options but to continue using this key OEP airport at a time when air carrier operations are expected to return to pre-9/11 levels. The solution to this problem is to preserve existing capacity by protecting general aviation airports from closure or inappropriate limitations on operations. Inadequate infrastructure, restrictions, or even closure of these airports remove capacity from the system. AOPA urges the FAA to develop and support satellite airports.
AOPA also recommends that new instrument approach procedures based on the Global Positioning System (GPS) and the Wide Area Augmentation System (WAAS) be provided at these airports. While many of the airports may have first-generation GPS procedures (with higher published minimums), AOPA is currently working with FAA Flight Standards to improve the design standards for these approaches, which would result in lower minimums. The re-publication of these GPS procedures (along with LPV procedures where ILS is not available) could improve the capacity of these airports and the pilots' ability to consistently use these airports instead of the OEP airports.
Again, AOPA strongly encourages the FAA to address these important concerns in the next version of the OEP.
Andrew V. Cebula Senior Vice President Government and Technical Affairs
August 8, 2003
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