Docket Management System
U.S. Department of Transportation
Room Plaza 401
400 Seventh Street, SW
Washington, DC 20590-0001
RE: FAA-2001-10912/Airspace Docket No. 00-AWA-6
The Aircraft Owners and Pilots Association (AOPA), representing over 380,000 members nationwide, respectfully submits the following comments in response to the notice of proposed rulemaking (NPRM) to modify the Cincinnati/Northern Kentucky International Airport (CVG) Class B airspace area. AOPA strongly supports the proposed revisions to the lateral boundaries of the airspace providing a cutout for Clermont County, Ohio (I69). However, this positive modification is accompanied by an unjustified proposal to raise the vertical limits of the Class B airspace from 8,000 to 10,000 feet mean sea level (msl).
AOPA commends the Federal Aviation Administration (FAA) for restoring airspace over Clermont County since the airspace was not necessary to support approaches and departures from CVG. In the multi-year effort to modify the final Class B airspace rule that was originally published in November 1998, the proposed return of airspace in the east and west quadrants echoes previously voiced user recommendations to reduce the outer ring from 25 nm to 20 nm to accommodate general aviation. The association is pleased that the FAA followed the suggestions of the users and reassessed the need for inclusion of this portion of airspace within the Class B airspace boundary.
While we strongly support the airspace return over I69, the proposal to raise the ceiling of the Class B airspace from 8,000 to 10,000 feet msl is unjustified. Class B airspace should be established only when there are significant numbers and mix of controlled and uncontrolled flights within the same airspace. The survey of VFR flight tracks does not support a need to raise the upper limit of the CVG Class B airspace. Seventy overflight VFR tracks over a 60-day period do not appear to pose a safety problem for the CVG traffic between 8,000 and 10,000 feet msl.
The survey information lacks significant detail about the number of VFR flights per day as well as the occurrences during CVG peak arrival and departure periods. In addition, to provide a complete picture of the airspace use between 8,000 and 10,000 feet, the survey should have recorded the number of VFR overflights that received radar services from CVG.
The discussion portion of the proposal mentions a benefit to be gained through the reduction of coordination requirements with adjacent air traffic control (ATC) facilities and frequency changes for CVG departures. Again, there are no details on the number of these occurrences. If this coordination has been a significant problem, it would seem feasible that the issue would already have been addressed through letters of agreement or airspace re-sectorization rather than changing the airspace vertical boundary through a lengthy rulemaking process.
Furthermore, it is unclear based upon the discussion how raising the ceiling of the Class B airspace will eliminate the need to level off departing aircraft. Without implementation of new arrival and departure procedures, it appears ATC will still find it necessary to level off departures until the required lateral separation from inbound aircraft is established. The discussion addresses concerns about the distance that arriving aircraft must travel above the existing Class B airspace but does not mention any procedural changes to resolve the obvious "level off" situation. Although justification for the vertical expansion centers on the economic benefit for aircraft departing without having to level off, it does not appear that a vertical expansion of the airspace boundary alone will provide the infrastructure to allow continuous climbout for aircraft departing CVG.
For the reasons stated above, AOPA recommends that the FAA implement its proposed modifications to the lateral boundary of the existing Cincinnati Class B airspace. Based on the lack of sufficient justification, AOPA recommends that the FAA retain the current 8,000-foot vertical boundary.
Thank you for the opportunity to provide comments on the proposed modifications to the CVG Class B airspace area. AOPA anxiously anticipates publication of the final rule.
Sincerely,
Heidi J. Williams
Associate Director
Air Traffic Services
Cc: Reginald C. Matthews, ATA-400
February 13, 2002
