Mr. Robert M. Vosburgh
Air Traffic Manager
Cape Terminal Radar Approach Control
Federal Aviation Administration
Otis ANGB, MA 02452
RE: Preliminary Nantucket Class C Staff Study
Dear Mr. Vosburgh:
The Aircraft Owners and Pilots Association submits these recommendations in response to your August 15, 2000, request for comments on a preliminary Nantucket Class C Airspace Staff Study. AOPA is concerned that the establishment of Class C airspace could inappropriately reduce general aviation access to the airspace and reduce operating utility for all users, and might well cause some new safety problems. We believe that a full user input process should be conducted to evaluate the problems and identify the optimum solutions. In addition, while a study is under way we should immediately alleviate current potential safety concerns by charting the lateral limits and altitudes for radar services and promote the use of theses services by local and transient pilots.
The amount and mix of air traffic at Nantucket Memorial Airport varies tremendously over the course of a year, and the primary driver behind the push for Class C airspace is the peak traffic level during the summer season. We are concerned that the Class C airspace "solution" is overreactionary and unnecessary, given during most of the year the traffic count appears to be much lower. We are concerned that the imposition of Class C airspace will unnecessarily restrict general aviation access to the airspace.
As you may know, some years ago the FAA was criticized for developing solutions "in a closet," and that the FAA often not only failed to find optimum solutions, but also found that many users rejected the solutions that were instituted, not having been a part of the process that created them.
In recent years the FAA has recognized the importance of user input. In most regions, the FAA welcomes the involvement of appropriate user working groups to help identify and discuss possible solutions. We are pleased that your letter might be seen as the first step in beginning such a process for Nantucket, where a variety of unusual conditions exist and argue for careful study.
We request that the FAA find an appropriate neutral entity to host a user working group and then identify and contact all appropriate user constituencies and ask them to provide representatives to participate in the process. Representatives of airport management, local aviation businesses, user groups, and the working controllers must be a part of this process, since it is their interaction with pilots and others that is central to this discussion.
We suggest that an organization such as the Massachusetts Aeronautics Commission, which enjoys good relations with all segments of the user community, be asked to act as host. This would ensure that any one group that might have a particular interest in any specific outcome does not dominate the process. The working group then could act as an informal advisory group to the FAA, as has proven so successful in other parts of the country.
Implicit in your letter, however, is the idea that Class C airspace and its controls and restrictions would definitely lead to safer, more efficient operations. However, from the user point of view there are also other considerations, such as potential delays and a reduction in flexibility for handling the widely varying types of aircraft that make use of the airport. In addition there are safety issues to be considered when aircraft not equipped to fly in Mode C airspace might be forced to maneuver at low altitude, in possibly poor conditions of visibility, under and around the edges of Class C airspace in order to circumnavigate it to reach their destinations.
For these and many other reasons full discussion is warranted. For instance, at Islip on Long Island such a process led to a redesign of the Class C airspace boundaries to follow natural landmarks, improving safety and utility for VFR users and reducing controller workload.
In the meantime, we suggest that there is a solution that can be implemented within one charting cycle that would probably achieve much of what Class C designation is supposed to do: increase participation in the radar services that are provided by your facility. This solution would not require potential inconvenience, cost, or safety considerations for any users.
We believe the vast majority of itinerant VFR pilots flying aircraft equipped with Mode C transponders that do not seek radar services do so because it is not obvious from the VFR charts they use that such services are available at Nantucket. Anecdotally we understand that such users are one of the major matters for concern by those who have suggested implementing Class C.
We urge the FAA to immediately chart the lateral limits and altitudes for radar services provided by Cape Tracon directly on the VFR sectional and WAC charts, as is already being done for many other airports. Appropriate frequencies for use should be printed in boxes adjacent to those radar service areas. It is likely this simple and easily accomplished task, plus a campaign of education and training conducted by the airport and user groups, would yield near-universal participation in radar services now, without any delay, while we begin the process of a full user dialogue.
We have been assured that depicting the radar service areas can be accomplished by the FAA in very short order if the user community indicates that is desirable. Since we can do this now, while your study is conducted, we urge you to bring this possibility to the attention of all user groups, airport management, airport businesses, and others so they can indicate their desire to make this happen. At the same time, we can begin a process leading to the identification of the most appropriate solutions for the long term in improving the safety, utility, and efficiency of aviation operations serving Nantucket Island.
Melissa K. Bailey
Air Traffic Services
Robert Mallard, Executive Director, Massachusetts Aeronautics Commission
September 18, 2000