Ms. Caroline Carey
George Bush/Intercontinental Airport
2700 West Terminal Rd.
Houston, TX 77032
RE: Proposed Modifications Presented at Ad hoc Working Group Meeting
Dear Ms. Carey:
The Aircraft Owners and Pilots Association (AOPA) appreciates the opportunity to participate on the ad hoc working group to review the proposed changes to the Houston Class Bravo airspace. While the modifications presented to the working group appear to capture only the airspace necessary for containment of forecasted growth and airport expansion in progress within the Houston airspace system, we offer the following comments in response to the proposal.
- The staff study indicates there is no data available to document the number of VFR aircraft circumnavigating the present terminal airspace configuration. However, we are concerned with the compression of VFR traffic circumnavigating the Class B airspace that would be caused by lowering the shelves of several areas within the current configuration.
- Current VFR flyway altitudes depicted on the back of the terminal area chart would need to be lowered in order to maintain positive separation in light of the proposal to lower the floor of several areas within the 20-nm airspace area. The staff study references appendices G, H, and I showing proposed changes to the VFR flyway altitudes, but there is no graphical depiction or description of those changes.
- Although a new tracon is discussed as part of Phase III of Houston Gulf Coast Airspace Project (HGCAP), the Class B modifications are slated to take place during Phase II of the project. In several other airspace projects across the country currently undergoing a new or consolidated tracon, airspace modifications are part of the final phase of changes. Considering the many benefits and efficiencies gained with a new or consolidated facility, AOPA recommends the Class B modifications be part of the final stages of the HGCAP in the likely event that it may present additional opportunities for redefining the Houston Class B airspace.
- There are several general aviation airports that are impacted by the proposed changes, and AOPA recommends that representatives from Weiser Air Park (EYQ) and West Houston (IWS) be included in the ad hoc working group. Although IWS remains outside the impacted shelf area, the noise-sensitive area to the north and northwest as well as the noise abatement operations would be impacted.
- In addition, based on the reference to the SUA modifications during Phase II, a military representative on the working group is essential to a positive outcome.
AOPA appreciates the work that has been put forward on the HGCAP and encourages the FAA to continue their efforts to incorporate the airspace users throughout this process. We look forward to additional dialogue with the FAA and other users discussing the Class B modifications.
Heidi J. Williams
Air Traffic, Regulatory and Certification Policy
Cc: Joe Yadouga, FAA SW Region
June 26, 2002