Domestic RVSM

May 17, 2001

Attn: Mr. Roy Grimes, AFS-400
Federal Aviation Administration
800 Independence Ave., SW
Washington, DC 20591

Dear Mr. Grimes:

The Aircraft Owners and Pilots Association (AOPA), representing the interests of over 370,000 aviation enthusiasts and professionals nationwide, respectfully submits its objection to the proposal circulated by your office earlier this month. In that document, the Federal Aviation Administration (FAA) solicited feedback from users concerning an amended Phase 1 Domestic Reduced Vertical Separation Minima (RVSM) implementation to include flight levels (FL) 290-390 by the close of 2004. This is contrary to the FL350-390 stratum discussed earlier this year for Phase 1 completion. Although AOPA recognizes that Domestic RVSM is needed to address system-wide capacity issues, the implementation of a procedural floor at FL290 during Phase 1 is cause for major concern. Such a change would encompass the operational envelops of numerous additional aircraft types, creating a significantly negative impact to many of our constituents.

In the request for comments, the FAA cited difficulties revealed during a recent visit with Eurocontrol as a primary driver for the aforementioned changes. This causes us concern for several reasons, chief among them are the differences that exist between the Eurocontrol and U.S. national airspace systems. As with most nations outside of the United States, Eurocontrol countries lack a significant general aviation presence, thus they are not a major consideration in the development of airspace policies and procedures. However, the FAA does not have the luxury of casting aside the needs of a major population segment in order to accelerate its long-term goals. As the finest and most sophisticated air traffic control system in the world, we should not succumb to the limitations of our neighbors, rather we should be pioneers in the development of a system that will effectively accommodate all users.

While AOPA is very pleased with the FAA's cautious approach to date, we are concerned that this most recent change in implementation strategy is contrary to the overall good of established workgroup processes. The general aviation industry, your customer, should not face economic hardship or operational limitations simply because it eases the burden placed on the FAA. Domestic RVSM is a partial, solution to the capacity issues of the foreseeable future. To that end, we should endeavor, collaboratively, to develop an implementation strategy that will not create an undo burden to a significant number of airspace users.

AOPA thanks you for the opportunity to comment, and we look forward to the upcoming meeting on May 31st.

Respectfully,

Melissa K. Bailey
Vice President, Air Traffic Services
Aircraft Owners and Pilots Association