Air Traffic Services and Technology

June 5, 2000

Mr. Ron Morgan
Director, Air Traffic Services
Federal Aviation Administration
800 Independence Avenue SW
Washington, DC 20591

Dear Mr. Morgan:

On behalf of over 360,000 members, the Aircraft Owners and Pilots Association (AOPA) objects to the recent Federal Aviation Administration (FAA) decision to use the International Civil Aviation Organization (ICAO) flight plan format for all operations.

Since 1997, AOPA has worked with the FAA to resolve this issue, including increased efforts through the Multi-Agency Air Traffic Services Procedures Co-Ordination Group Technical Working Group (MAPCOG TWG). The MAPCOG TWG developed a consensus recommendation that brings the FAA into compliance with ICAO with minimal affect on general aviation. There are several reasons AOPA is opposed to the FAA's decision not to accept that recommendation:

• AOPA has not identified any service enhancements to pilots when using the ICAO flight plan for flights within the National Airspace System.
• The largest pilot population in the world will need to learn a new flight plan. Clearly this creates a major re-education effort.
• Forcing pilots to use the ICAO flight plan is a disincentive when filing flight plans for flights conducted under Visual Flight Rules (VFR). This is in direct contrast to a consensus recommendation from the recent FAA Flight Service Renaissance Summit.

Based on the concerns above, AOPA objects to using the ICAO flight plan for NAS operations. A mandate to change procedures without user benefit will meet strong resistance, especially in light of the fact that the majority of general aviation operations worldwide are conducted in the NAS. We ask for your assurance that changes will not occur without consensus from the industry.

Sincerely,

Melissa Bailey
Director, Air Traffic Services