Ms. Naomi Saunders
Airports Division Manager, ASW-600
Federal Aviation Administration
2601 Meacham Blvd.
Fort Worth, TX 76137-4298
Dear Ms. Saunders:
The Aircraft Owners and Pilots Association (AOPA) represents over 347,000 individual pilots and aircraft owners nationwide, more than 23,000 of whom reside in the state of Texas, many in the Austin area. We continue to be extremely concerned with the imminent closure of Austin-Mueller Airport and the opening of its replacement airport, Bergstrom International Airport. Despite extensive efforts by the general aviation community, the city of Austin continues to ignore the needs of this vital and growing segment of the national transportation system.
The association has always been a strong supporter of converting closed military airport facilities to civil aviation use. We fully recognize that new airport development at Bergstrom will go forward and that a new civil airport at the redeveloped Bergstrom site will offer significantly more air carrier capacity.
However, the current situation has become extremely critical. General aviation will not be properly accommodated at Bergstrom at the time of the closure of Austin-Mueller. Airport and service providers at Bergstrom are not accepting any additional general aviation aircraft. This will effectively leave over 200 general aviation aircraft currently at Mueller with no alternatives.
In early 1992, AOPA expressed the association’s serious concern about the complete absence of general aviation facilities in the draft master plan for Bergstrom. Since then, many other attempts to resolve this obvious planning exclusion have gone unanswered.
A 1997 letter to the Federal Aviation Administration (FAA) associate administrator for airports (ARP-1), in which AOPA expressed concerns and asked for assistance, was ignored. All attempts made by AOPA to mitigate the general aviation problems and find adequate solutions were simply disregarded by both the sponsor and the FAA. The FAA’s failure to address the general aviation problem at Bergstrom is unfortunate as the agency holds funding (Airport Improvement Program [AIP]/Surplus Property), planning (National Plan of Integrated Airport Systems [NPIAS]/Demand/Capacity), and, foremost, airport compliance responsibilities.
We continue to believe that the city of Austin lacks the will and resolution necessary to totally accommodate the full spectrum of general aviation at the new Bergstrom airport. The number of public airports in the Austin area is quite limited. For the general aviation users of Mueller Airport, the closure will cause the majority of both the 280 based aircraft and the 62,000 annual general aviation flight operations to disperse to non-existing area airports. The general aviation facilities currently contemplated for Bergstrom are totally incapable to accommodate a sufficient number of general aviation aircraft in terms of tiedowns and hangar space.
This is not a supply and demand issue where general aviation has other options in terms of airports. There are no other options. With the closure of Austin Executive, the small size and limited space at Bird Nest and the far-away location and limited space at both Taylor and Georgetown airports leave general aviation with no other options but Bergstrom.
In 1992, officials of the city’s airport department and Mayor Todd indicated that they intended to acquire Austin Executive Airport (3R3) as “the” reliever airport to Bergstrom. This close-in facility would then meet the needs of general aviation operators in the local Austin area. The city of Austin failed to seriously consider the acquisition of a reliever airport. In addition, the FAA failed to consider this basic planning requirement in terms of the definition of and the need for a reliever airport as well as the associated priority and eligibility guidelines.
The city of Austin admitted in a recent letter dated May 1999 that “the closure of Executive Airport has placed a strain on general aviation capacity.” Having admitted the general aviation problem, the city went on to say in that same letter that they “will make every effort after the opening of the new airport to address this problem.” Waiting for Austin Muller to close before addressing the general aviation needs illustrates a serious lack of planning ability, especially if the aircraft still at Mueller have no place to go. This completely inadequate planning is not new nor it is resident with the city alone. In 1984, when the FAA and the city of Austin were studying the possibility of a new airport in the area, the FAA clarified the city’s obligations by stating that “Any plan must adequately address and accommodate all segments of aviation presently being served by Robert Mueller Airport.” Apparently this guidance, which is current and valid FAA policy, has been forgotten.
AOPA believes there must be a reliever airport in the Austin area! Recent state legislative initiatives supporting the acquisition of the Mueller facilities by the state of Texas for continued operation as a reliever airport shows very clearly the state’s recognition that the city of Austin failed to adequately consider general aviation needs at Bergstrom. A scaled down Austin-Mueller Airport configuration should continue to support general aviation activity as a “reliever airport.” AOPA has supported and will continue to support such legislative initiatives.
The lack of general aviation facilities at Bergstrom today results from ignoring the appropriate FAA procedures and policies that govern release, modification, reformation, or amendment of airport agreements under FAA Order 5190.6A, specifically, the guidelines that govern “Replacement Airport” procedures. The FAA’s own procedures state that “the availability for public use of new and better airport is the basis for determining that the old airport (Austin-Mueller) is no longer needed....” It is obvious that both the city and FAA have ignored general aviation in the process.
Furthermore, through this process, by failing to consider and plan for the impact the move would have on general aviation, the FAA failed to properly ensure that the move to Bergstrom would “protect, advance, or benefit the public interest in civil aviation.” The public benefit is not assured merely by keeping the runways open to all users. At Bergstrom, the city of Austin accommodated air carriers, cargo operations, military operations, land-side facilities, and non-aviation services such as parking and light rail. In addition, hotels, golf courses, and unrelated waste storage facilities were also provided. In the case of the waste storage facility, prime aviation ramp space was used. The city of Austin failed to provide adequate general aviation facilities while dedicating time, space, and resources, including funding, to accommodate a golf course and a waste storage facility!
It is imperative that the FAA take immediate action to expedite the city’s accommodation of general aviation preparations at Bergstrom and consider delaying the closure of Austin-Mueller in order to provide services to general aviation. There is a clear need for a transitional period. General aviation aircraft must be able to move to Bergstrom prior to the closure of Austin-Mueller. This means that Austin-Mueller airport should be kept open for at least 120 days so that the city of Austin has the time to prepare for handling the existing general aviation demand of over 300 aircraft with adequate services, including enough tiedowns and hangars.
The FAA has the authority to delay the closure of Austin-Mueller until such time Bergstrom is ready to accommodate general aviation. After all, the FAA has historically allowed delays in opening multi-million-dollar airport facilities, with serious implication in terms of cost overruns because the airport was not ready to serve the users. Today, Bergstrom is not ready to accommodate general aviation.
We urge you to take appropriate action so that the opening of Bergstrom International Airport can be called a real success for the Military Airport Program.
The Honorable George W. Bush
The Honorable Rick Perry
The Honorable James E. Laney
Mr. David L. Bennett
Mr. Barry Molar
Mr. Charles Griffith
May 20, 1999