Commissioner John D. Bruhn
St. Lucie Board of County Commissioners
2300 Virginia Ave.
Fort Pierce, FL 34982
Dear Commissioner Bruhn:
The Aircraft Owners and Pilots Association (AOPA) is a nonprofit membership association consisting of over 370,000 pilots and aircraft owners nationwide, 27,700 of whom reside in the state of Florida. AOPA is committed to ensuring the continued viability, growth, and development of aviation and airports in Florida and the United States.
It has recently been brought to AOPA's attention that the St. Lucie Board of County Commissioners has recently passed a policy to impose restriction on flight training activities at the St. Lucie County International Airport (FPR). It is our belief through this restriction the county is attempting to regulate aircraft operations that are within the exclusive province of the federal government.
As the sponsor of an airport that has accepted over $9.4 million in federal Airport Improvement Program (AIP) aid since 1990, St. Lucie County must adhere to certain assurances specified by the federal government in grant agreements.
Grant Assurance #22 Economic Nondiscrimination states in part:
St. Lucie County International Airport has a noise compatibility plan (NCP) approved by the FAA under 14 CFR Part 150 "Airport Noise Compatibility Planning." A notice of approval for the NCP was published in the Federal Register on August 31, 1994, approving six elements of the noise compatibility program.
In regards to the most recent restrictions at the airport, the association would like pose the following questions:
General aviation pilots and the entire aviation community willingly take voluntary and proactive steps to fly friendly and reduce airport noise whenever it is possible. AOPA has long been an advocate of "flying friendly" in order to reduce the impact of our members' aircraft operations on the local community. However, a touch and go is a necessary and legal flight operation. In the training environment a touch and go reduces taxi time and allows an instructor to concentrate more instructional time on the most complicated phase of a flight, the takeoff and landing phase. This restriction will add additional flight time to accomplish the same tasks, creating an additional unnecessary financial burden for aircraft rental and aircraft operating cost on the pilot. It will also increase airport congestion.
Consequently, we urge you to repeal this restriction until such time these concerns can be addressed. We request that this measure be fully examined to determine its true impact on noise contours, airport safety, and air traffic control tower procedures. Implementation of a restriction should only be done in accordance with existing federal law and regulations. We strongly encourage you to work with the Orlando Airport District Office in determining if this restriction is permissible with federal grant obligations. Additionally, we believe that all mitigation measures already approved by the FAA in the 1994 NCP should be implemented prior to moving on to mandatory access restrictions at St. Lucie County International Airport.
We respectfully request a response to our inquiry within 30 days. If you have any questions or if we can be of any assistance, feel free to contact me at 301/695-2204.
Keith W. Holt
|Cc:||Commissioner Doug Coward |
Commissioner Paula A. Lewis
Commissioner Frannie Hutchinson
Commissioner Cliff Barnes
St. Lucie County International Airport Manager
FAA Orlando Airport District Office
December 17, 2001