DRVSM proposed rule published, AOPA opposes 'single-phase' implementation

On Friday, the FAA published a proposed rule that, if implemented, will bring domestic reduced vertical separation minimum (DRVSM) to U.S. airspace in December 2004 [see AOPA's issue brief]. Intended to increase airspace capacity, DRVSM will implement a 1,000-foot vertical separation standard between FL290 and FL410. Currently, the vertical separation minimum at these strata is 2,000 feet due to limitations in aircraft instrumentation and altitude-keeping capabilities. Although not typically considered a general aviation issue, RVSM will impact many high-end operators throughout the country.

"AOPA has long advocated a phased implementation schedule that would introduce DRVSM airspace between FL350 and FL410 initially, to be followed by full implementation down to a FL290 floor at a later date," said AOPA President Phil Boyer. "AOPA's plan would give many high-end GA and business aircraft owners the time needed to absorb the cost of equipage and give the FAA enough time to process the influx of aircraft requiring certification. AOPA is deeply concerned about the FAA's ability to meet demand with the aggressive timetable outlined in the proposed rule and believes it will lead to delays for many owners, even those able to absorb the costs at an earlier date. The FAA has a responsibility to general aviation to follow a phased DRVSM implementation plan."

Operators who need to fly within the DRVSM altitude strata will be required to equip their aircraft with approved avionics and submit the aircraft to a lengthy certification process that includes flight testing by an FAA-approved avionics shop, as outlined by the proposed rule. (See the FAA's Web site for additional details). While modification costs are a concern, AOPA is even more troubled by the single-phase implementation schedule and doubts the ability of the FAA to meet the aircraft certification and flight-testing demand that a single-phase implementation will bring.

It is naïve of the FAA to think that DRVSM can be implemented by 2004. The comment period on this proposal closes in August, and realistically, it will take the FAA six months to a year to publish a final rule, which means the earliest a rule could be published is January 2003. This leaves less than a year for the thousands of GA aircraft impacted to be certified. It is unlikely that operators will begin the certification process prior to publication of a final rule.

In its comments to this proposal, AOPA will continue to push for a phased implementation because of its concerns over the FAA's and industry's ability to meet the certification demands of DRVSM over the limited timeframe.

As a traffic management tool, RVSM is an internationally established practice. The North Atlantic RVSM program was implemented in 1997 and, based on its success, premiered in the Asian-Pacific theater in February 2000. With the West Atlantic Route System (WATRS) RVSM program scheduled for full implementation by November of this year, followed by the realization of RVSM airspace throughout Europe by January 2002, it is clear this will be the standard for traffic management in the upper flight levels for the foreseeable future.

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