August 8, 2002
Docket Management System U.S. Department of Transportation Room Plaza 401 400 Seventh Street, SW. Washington, DC 20590-0001
RE: Docket No. FAA-2002-12261; Notice No. 02-09, DRVSM
The Aircraft Owners and Pilots Association (AOPA), representing the interests of over 385,000 aircraft owners and pilots nationwide, opposes the implementation strategy outlined in the Federal Aviation Administration's (FAA) Domestic Reduced Vertical Separation Minima (DRVSM) Notice of Proposed Rulemaking. As proposed, DRVSM would reduce the vertical separation minima applied to aircraft operating between Flight Level (FL) 290 and FL410 from 2,000 to 1,000 feet over the United States by December 2004. This means that even if the FAA takes quick action and publishes a final rule by June 2003, the industry and FAA will have a mere 16 months to complete the equipment installation and certification of over 15,000 turbine-powered aircraft. AOPA does not believe that the FAA or the industry have the resources to meet this aggressive timeframe. Instead, AOPA favors a phased implementation strategy that allows the FAA and operators time to meet the regulatory requirements of the rule.
The aggressive implementation schedule outlined in this rulemaking action will likely result in economic and operational hardships for many within the aviation community. AOPA recognizes that the federal government and airlines will realize system-wide advantages through the utilization of DRVSM, in the form of fuel and time savings and increased system capacity. Unfortunately, the benefits to non-airline, turbine-powered aircraft are not nearly as significant and do not offset the cost of equipage. However, the penalty for not equipping is significant for these operators in that they will be excluded from this airspace.
AOPA does not believe that the FAA can meet the certification demand that its proposed implementation schedule creates. Therefore, AOPA favors a phased implementation strategy (FL350-FL390 by December 2004) as agreed on early in 2001, and an extension of at least than two years making the full implementation date December 2006. Doing so will allow the FAA and operators the time needed to comply with the requirements of RVSM airspace.
Many of AOPA's concerns are centered on the time and cost needed to equip and certify existing airframes, as well as the FAA's ability to meet the proposed implementation schedule.
AOPA does not dispute the long-term capacity-enhancing potential of DRVSM. The addition of six flight levels offers increased flexibility to the National Airspace System (NAS). However, any advantages gained in the en route environment will not be fully realized until systemic "choke-point" issues in the terminal environment are resolved. The infrastructure necessary to do this is addressed in the FAA's Operational Evolutionary Plan (OEP), of which DRVSM is a component. Many of these OEP initiatives so critical to improving capacity in the NAS, such as expanding the number of runways throughout the country, are long-term solutions. As a result, the ability to leverage the full potential of DRVSM in the short term is questionable, thus AOPA questions the need for full implementation by the end of 2004.
In short, AOPA is mindful of the need to take full advantage of all available capacity-enhancing tools. However, the FAA must consider all airspace users when implementing new programs or strategies.
Because of DRVSM's importance to the user community, it is incumbent upon the FAA to do everything within its power to ensure its benefits are realized with a minimal impact. As a result, AOPA recommends that the FAA pursue a phased implementation strategy and extend the deadline for total compliance to at least December 2006.
Melissa K. Bailey Vice President Air Traffic, Regulatory, and Certification Policy
August 7, 2002
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