May 3, 2001
The Honorable Jane Garvey
Administrator
Federal Aviation Administration
800 Independence Avenue, SW
Washington, DC 20591
Re: Operational Evolution Plan
Dear Administrator Garvey:
Let me personally, and on behalf of our more than 370,000 members, congratulate you on your leadership and the team of managers you assembled to put together the Federal Aviation Administration's (FAA) release of the Operational Evolution Plan (OEP).�While the plan is primarily focused on solutions to improve capacity at key air carrier airports, as you read in my March editorial in AOPA Pilot magazine, helping to solve the air carrier delay problem is in the best interest of all aviation system users, including general aviation.�When the airlines are happy, G.A. is happy, and when the airlines are under pressure (as they are now), small airplanes are often used as the scapegoat.
In my almost eleven years as president of the world's largest aviation organization, I have seen the Agency attempt many fixes, full programs, and address individual issues.�Never before have I seen the dedication of time and management skill, also employing the assets of MITRE/CAASD, to address a growing national concern with pragmatic solutions.� More importantly, the solutions were bound by realistic thinking.�All to often, in the past, the FAA and others have made unachievable assumptions that were critical to the success of a program ( Congress will pass legislation ...; the workforce will change rules ...; etc.).�The OEP has dealt with what is real, what can happen with little or no intervention, and assumes no new technological hurdles must be overcome to accomplish the goals.
This approach is an important step in managing the evolution of the National Airspace System (NAS) by identifying issues and developing solutions for immediate and near- term implementation, yet linking it with longer-term modernization efforts.� Because it is a living document, the OEP can be revised to accommodate system requirements based on changes in the aviation industry, effectiveness of the plan's strategies, new ideas and technologies.
The plan also re-emphasizes the basic business and management philosophy of establishing much-needed individual accountability within the FAA.� This has worked well in your Free Flight Phase I and Y2K initiatives, and now can work on a broader scale with the OEP.�Coupled with emphasis not only by Congress, but the American traveling public on capacity improvements, gives us reason for optimism that the OEP is a break from the past.
Following the business model for new concepts and strategic directions, the next step is stakeholder consensus.�Now that the version 2.0 of the OEP has been produced and exposed to the industry, the Agency has asked all segments of the aviation community for their support relative to the OEP.� Throughout the process MITRE and the FAA have solicited comments and while the document mainly focuses on air carrier issues, we have submitted general aviation input and questions throughout its development.
AOPA supports the Operational Evolution Plan in principle; reserving unconditional support based upon the outcome of key issues that have yet to be given enough specificity to understand how they would affect the interests of the general aviation community.�Let me amplify on those issues.
We were pleased to be among those who pointed out in the very first public meeting on the OEP that airports seemed to be missing from the equation.� Subsequently, the Agency has correctly identified that additional runway capacity is key to addressing current capacity constraints.� At the same time the focus and spotlight hits 31 major airports, AOPA believes consideration should be given to ensure general aviation access is accommodated at airports nearby to these key locations; in many cases these are the "reliever" facilities labeled as such by the Agency.
While properly constructed airspace redesign and RNAV implementation can result in more flexible and more accessible airspace, it is essential the current level of airspace access and the operational flexibility existing in both the VFR and the IFR flight environments continue.�Although we have indicated acceptance of the OEP recommendation that preferential treatment be given to aircraft RNAV equipped, this was with regard to the primary airport in Class B airspace only and with the assumption this would be phased in over time.� Obviously, we are most concerned with those airports not considered choke points containing a mix of air carrier and general aviation traffic.� Our recommended limitation of this equipage requirement provides the air carrier capacity gains sought by the OEP, but doesn't mandate expensive equipment for G.A. aircraft using the reliever facilities.�The best example of this in the highly congested NY airspace would be near-term implementation of RNAV equipage for IFR operations at LGA, EWR and JFK, without such a requirement at TEB, MMU, HPN, etc.
Although the OEP does not include a specific schedule for implementing RNAV procedures at the key airline airports, it must be benefits driven and phased in on a realistic timeline.�The FAA must also make allowances for a mixed equipage environment, especially at the airports currently serving a significant number of general aviation operations.� Likewise, access to general aviation airports in the area must not be adversely affected.�AOPA would oppose an equipment mandate that does not appropriately address these concerns.
It is encouraging that the OEP recommends the use of ADS-B infrastructure for monitoring airport surface movements.� However, to fully use the capabilities of this equipment and transition into the future planning for the air traffic control system, ongoing OEP versions should be expanded to encompass the further development of data link to provide weather and non-ADS-B traffic data in the cockpit.� This support is contingent on one data link that can support both traffic and graphical weather.� These concerns were raised at the last "Industry Day" meeting at MITRE.
An issue touched on by the OEP is the need for increased access to special use airspace (SUA) for improving capacity.�AOPA believes the FAA's management of SUA must be improved.� Specifically, there must be better coordination and more efficient utilization of this airspace when not in use by the military.�A solution AOPA has been advocating is improved availability of "real-time" SUA status information to pilots.�General aviation pilots must have access to Special Use Airspace Management data (SAMS) and we ask that you take steps to make this information available.
Once again, Jane, I truly commend the FAA for its efforts putting together the blueprint for the coming years.�The plan will evolve and change over time; just as air traffic requirements and technology have changed over the last decade.� I will personally work with the Agency, and pledge the support of our pilot membership and qualified staff to see that tactics of the OEP match its strategic goals.
Sincerely,
Phil Boyer
| cc: | Monte Belger Amr ElSawy Steve Brown Steve Zaidman Tom McSweeny Peter Challan Nick Lacey |