August 8, 2003
The Honorable Marion C. Blakey Administrator, Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591
Re: FAA Strategic Plan
Dear Administrator Blakey:
On behalf of the more than 400,000 members, the Aircraft Owners and Pilots Association (AOPA) appreciates the opportunity to comment on the Federal Aviation Administration's (FAA) strategic plan, Flight Plan for 2004-2008. While the initiative to develop a strategic plan is commendable, we believe that important revisions should be made to the Greater Capacity, International Leadership, and Improved Safety objectives in the draft plan. We have some specific recommendations in the attached document that I want to highlight in this letter.
It is essential that the FAA strategic plan address the new reality of aviation security in the post-9/11 flight environment. Since the attacks of 9/11, security-related flight restrictions have become the new general aviation capacity constraint, causing congestion and delays, especially in the area of the Washington, D.C., Air Defense Identification Zone (ADIZ) and with the presidential-movement temporary flight restrictions (TFRs). The FAA should not ignore its responsibility for an efficient air traffic control system that should serve the needs of the aviation users as it implements security-driven restrictions. As the FAA notes in its introduction of the draft plan, "...the challenges facing aviation demand nothing less than a transformation of the system itself."
We couldn't agree more. We ask the FAA to establish measurable goals, tied directly to the FAA budget, that address security-related capacity constraints and improves general aviation access to airspace.
Another area that AOPA believes needs revising is the FAA/Industry Training Standards (FITS) program in the draft safety objective. AOPA has repeatedly expressed concerns to the FAA about the potential regulatory and non-regulatory implications associated with FITS implementation. FITS is essentially a flight training standard for technically advanced avionics in general aviation aircraft. To date, AOPA has not received any indication that the FAA takes our concerns seriously. While FITS is touted as a "non-regulatory" initiative, it will likely result in changes to the Practical Test Standards (PTS), which denies the users any opportunity to provide input on standards that directly impact them, resulting in a "defacto" requirement and the ultimate cost and availability of the training. It is not the idea or principle but the implementation that generates our response.
Finally, we continue to be troubled that the FAA's International Harmonization goals have been adversely affecting general aviation in the United States. The agency's desire to reassert its international leadership primarily through international harmonization is commendable; these efforts must recognize the uniqueness of U.S. domestic general aviation operations. For example, the FAA's supplemental notice of proposed rulemaking for domestic reduced vertical separation (DRVSM) adds an expensive dual altimeter equipage requirement for turboprop aircraft that is based exclusively on an international standard. If the FAA does not revise its objectives in the International Leadership section to include protection of domestic general aviation, it will end up pursuing global regulatory and policy-making initiatives that are not in "America's best interest."
Again, thank you for your leadership in developing the strategic plan. I ask that you take AOPA's concerns to heart and incorporate our recommendations to address the areas affecting general aviation.
August 8, 2003
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