Federal Aviation Administration
Office of the Chief Counsel
AGC-200
Rules Docket 28537
800 Independence Avenue, S.W.
Washington, DC 20591
RE: Petition for reconsideration of the Special Flight Rules in the Vicinity of Grand Canyon National Park.
Dear Counsel:
With this letter, the Aircraft Owners and Pilots Association (AOPA) is petitioning the Federal Aviation Administration (FAA) for reconsideration of the special flight rules (SFR) in the vicinity of the Grand Canyon, published in the Federal Register on December 31, 1996.
Despite the elimination of the proposed Marble Canyon no-fly zone, general aviation overflying the Grand Canyon have lost significant airspace access in this area. The new Marble Canyon Sector raises the floor from 6,000 feet msl to 8,000 feet msl. The expanded Marble Canyon Sector also increased the floor of the previous North Canyon Sector from 5,000 feet msl to 8,000 feet msl. General aviation overflights are penalized when it is clear that they do not contribute to commercial sightseeing tour issues at the Grand Canyon. The sector altitudes for general aviation overflights should be restored to the original altitudes of 6,000 feet msl and 5,000 feet msl, respectively.
The Grand Canyon SFR also eliminates the former Fossil Canyon Corridor and the proposed Tuckup Corridor. AOPA believes that these corridors should remain open to general aviation overflight. There is absolutely no data to support maintaining these areas as no-fly zones for general aviation. The Fossil Canyon Corridor and the Tuckup Corridor should be reestablished for general aviation overflights.
The conditions at Grand Canyon that prompted SFR 50-2 are unique. Because of the Grand Canyons’ combination of unusual terrain and a high volume of air tour traffic, AOPA accepted SFR 50-2 even through it was inherently discriminatory. The new Grand Canyon SFR significantly compounds this discrimination because it unfairly penalizes general aviation, non-commercial operations by restricting access, imposing aircraft performance penalties, and increasing the costs associated with overflights.
AOPA recognizes that this rule is intended to regulate air tour operators only, but the SFR has a significant negative impact on private aircraft. The Grand Canyon SFR also has national significance because the threat that this airspace model will be instituted at other national parks nationwide is likely.
For the reasons stated above AOPA is petitioning the FAA under Federal Aviation Regulation 11.73, Petitions for Rehearing or Reconsideration of Rules or Order, for the following:
- Restore the floor of the North Canyon Sector to 5,000 feet msl for general aviation overflight.
- Restore the floor of the Marble Creek Canyon Sector to 6,000 feet msl for general aviation overflight.
- Reestablish the Fossil Canyon Corridor for general aviation overflight.
- Establish the purposed Tuckup Corridor for general aviation overflight.
AOPA understands the responsibility placed upon the government with respect to Public Law 100-91. However, AOPA believes that the Grand Canyon SFR violates the congressional intent of this law. The law’s scope should be limited to addressing commercial sightseeing issues at the Grand Canyon. AOPA actively opposes this and further efforts to unreasonably restrict general aviation overflight above national park lands.
Sincerely,
Phil Boyer
President
January 15, 1997
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