Manager, Air Traffic Division, ASO-500
Federal Aviation Administration
Southern Region Headquarters
P.O. Box 20636
Atlanta, Georgia 30320
The Aircraft Owners and Pilots Association (AOPA), representing the interests of over 375,000 general aviation and professional pilots nationwide, respectfully requests that the Federal Aviation Administration (FAA) withdraw its NPRM for the proposed Class B airspace for Raleigh-Durham International Airport, NC (RDU). In light of recent events that have substantially impacted the air traffic system, AOPA believes a complete reassessment of the proposal is necessary. Considering the demise of RDU's most prominent air carrier in September of this year and the current economic recession, it is likely that RDU will not continue to meet the criteria necessary to warrant a reclassification to Class B airspace.
At informal airspace meetings held in early December 2001, the message from local pilots clearly indicated overwhelming opposition to the proposed airspace. Many of the attendees actively use the current RDU Class C airspace and voiced concern regarding the negative economic impact a reclassification of airspace would have on many airports underlying the proposed Class B airspace. Furthermore, the users asserted that the RDU air traffic control tower easily manages current traffic loads during the few heavy periods experienced during peak air travel hours.
Although the most recent design and development process was initiated in 1998, several factors used as a basis for justification at that time have now come into question. Both the termination of Midway Airlines, as well as the decline in business air travel due to the economic recession has contributed to the decline in operations at RDU.
With the shutdown of Midway Airlines in mid-September, RDU lost its most prominent air carrier service. Midway was responsible for over one third of Raleigh's operations and accounted for over 1.4 million enplanements in 2000. AOPA believes the termination of this air carrier service, and the corresponding decrease in air travel at RDU, justifies the need to reassess the Class B proposal to determine if RDU even meets the threshold criteria necessary to be considered for an airspace reclassification.
RDU operations have declined by nearly 33 percent in the wake of September 11, 2001. While the shutdown of the most prominent air carrier obviously has had a significant impact, business travel is down due to recession in the economy. The travel industry has also experienced declines since the September tragedies resulting in a major reduction in air travel overall. Although the country is recovering from the effects of the attacks, the impact to our air traffic system requires continuous reevaluation considering air travel, and load factors are not as they were prior to September 11, 2001. While some will argue that the Class B airspace is necessary to accommodate proposed future air service at RDU, historically airspace reclassifications have been implemented based upon current traffic counts rather than promises of pending operations, which may or may not come to fruition. Finally, air traffic numbers alone do not tell the entire story, nor should they be used as empirical evidence of the need for more restrictive airspace.
AOPA also encourages the FAA to revisit the airspace user group process in the course of its reevaluation of the airspace proposal. Many concerns were raised regarding the process followed during the initial user group meetings. Since the conclusion of those meetings, AOPA has developed additional guidance on the user group process with the input of several longstanding user groups and suggestions from FAA headquarters. We look forward to working with the FAA as they solicit the insights of the user group in the future.
We appreciate the opportunity to provide comments on the RDU proposed Class B airspace. We ask that the FAA continue to evaluate the need for airspace reclassifications as situations occur and our ever-changing airspace system evolves.
Heidi J. Williams
Air Traffic Services
Cc: Reginald Matthews, ATA-400
January 2, 2002