AOPA COMMENTS TO THE FAA STRATEGIC PLAN; FLIGHT PLAN FOR 2004-2008
AOPA organizes its comments under the major objectives of the strategic plan as follows:
There are two elements missing from the FAA's Greater Capacity goal:
- Security Strategy—The FAA should include a security strategy under Objective 3. Increase or improve airspace capacity in the eight major metropolitan areas and corridors that most affect total system delay.
Since the attacks of 9/11, security related flight restrictions have become the new general aviation capacity constraint, causing congestion and delays, especially in the area of the Washington, D.C., Air Defense Identification Zone (ADIZ). The FAA must establish measurable goals, tied directly to the FAA budget, that address security related capacity constraints and improve general aviation access to airspace. This strategy should include the development of policies and procedures to mitigate the constraints and implementation of equipment, procedures, and training to support general aviation access.
- Accessibility and Flexibility of the NAS—The FAA's strategic plan identifies capacity as the "exclusive" measure of efficiency in the NAS. This does not provide a complete picture of NAS efficiency, especially as it relates to general aviation. For general aviation, the quality of service for the FAA's customers is reflected in its ability to provide services requested by users, and the FAA should implement a better strategy for accommodating diverse, flexible general aviation operations.
To make the strategic plan Greater Capacity objective meaningful for general aviation, AOPA recommends that the FAA add a strategy to measure accessibility and flexibility of the NAS as indicators that air traffic control services meet the requirements of general aviation. The accessibility strategy should measure the frequency in which VFR services are provided upon request, including requests to operate in Class B airspace. To address flexibility, the strategic plan should contain a strategy that measures the FAA's capability of demonstrating an increased responsiveness to changes in airspace users' needs. For example, the airspace system should meet a goal of supporting non-airway instrument flight rules routing (when the aircraft are equipped with GPS) 99 percent of the time.
In addition to the above missing elements, AOPA provides the following comments on the objectives related to the Greater Capacity objective:
- Page 23, fourth bullet under first group of initiatives: AOPA recommends that the airports included in the FAA initiative include the reliever airports around the top 35 OEP airports.
- Page 23, third bullet under second group of initiatives: The Plan should commit the FAA to having airways and routes charted for use in all metropolitan areas complete by 2008.
- Page 24, first bullet at top of page: The FAA should also provide instrument approach lighting systems when possible to maximize the use of the WAAS system for low visibility minimums.
- Page 26, first bullet under first list of initiatives: With regards to airspace redesign for eight major metropolitan areas, the FAA should clearly state that all airspace users requirements are addressed, including general aviation.
- Page 26, second bullet under first list of initiatives: The FAA should specifically identify the new equipment and technology they intend to use to reduce en route congestion.
- Page 26, second bullet under second list of initiatives: AOPA recommends that the FAA include the development of a strategy to disseminate the SUA information via World Wide Web and ADS-B datalink (page 13, second bullet of first list of initiatives).
The FAA should develop an International Leadership strategy that ensures that harmonization efforts do not saddle domestic general aviation with costly equipment requirements and burdensome regulations and standards, driven almost exclusively by commercial air carrier interests. The FAA should revise its objectives in the strategic plan, to include a strategy for protecting the domestic general aviation industry from unnecessary regulation and equipage requirements.
With the above thought in mind, AOPA provides the following comments on the objectives related to International Leadership:
- Page 32, Objective 1. The FAA should ensure that any such "promotion" by FAA staff should include advocating for a robust, diverse aviation system as is currently found in the United States. Such a system supports vibrant and healthy general aviation industry.
- Page 36, second bullet of performance targets. It is unclear to AOPA how the FAA plans to reduce separation standards in such a short amount of time. Lateral separation is a complex subject that must take into account ground infrastructure and on-board avionics. The FAA should better define its reduced separation standards (except for DRVSM) and the avionics baseline envisioned for such reductions.
There are several elements missing from the FAA's Increased Safety goal:
- Pireps—The FAA's Increased Safety objective should include a strategy for improving the collection and dissemination of pireps, especially from IFR pilots through ATC, as identified as a key element in the Weather JSAT/JSIT. The draft plan talks about this via datalink, but it will be a long time before there is much fleet equipage especially at the low end of GA where this information is critically needed.
- Notices to Airmen—Notam system deficiencies have sufficient safety implications for general aviation, but this is not addressed in the plan. The FAA must include a strategy for fixing the system, especially in light of all the airspace security issues that have emerged since 9/11.
- Runway safety—all the initiatives are controller-centric. The plan should include continued development of low-cost, simple technology that brings pilots into the safety equation such as flashing vertical guidance systems that have been tested and shown to be effective at LGB. There is no mention of anything else in the plan other than very expensive ASDE and AMASS systems.
- The FAA Increased Safety initiatives should include a provision for ensuring commonality and intuitiveness of avionics through the aircraft certification process.
In addition to the above missing elements, AOPA provides the following comments on the objectives related to Increased Safety:
- Page 8, last paragraph. AOPA questions the purpose of the new safety index that combines GA and air carriers' accident data together in the same category. We believe that the data could be too broad to be used in addressing risk and guiding decision-making and ask that the FAA provide an explanation of how the data will be used to meet the objective of Increased Safety.
- Page 13, first bullet for reducing the number of fatal accidents in general aviation. The FAA needs to better explain the initiative to provide VFR pilots with "an IFR-like environment" and clarify that its intent is not to impose IFR regulatory requirements on VFR operations. AOPA believes that this item should capture, among other things, the effort to expand Safe Flight 21 information dissemination via UAT ADS-B datalink. We recommended the FAA also add language to clarify its intent to provide VFR pilots with improved weather data, notam/TFR data, and airborne traffic data as information.
- Page 13, last bullet in second set of initiatives. AOPA is also concerned about the implications of the FAA/Industry Training Standards (FITS) initiative listed under the objective aimed at reducing the number of fatal accidents in general aviation. It is not the concept of FITS that concerns AOPA, but rather how it will be applied. While FITS is touted as a "non-regulatory" initiative, it will likely result in changes to the Practical Test Standards (PTS), which denies the users any opportunity to provide input on standards that directly impact them. Additionally, if underwriters and manufacturers begin to require (and charge for) FITS training, it will have the same effect as making it regulatory. AOPA is concerned about this "defacto" requirement and the ultimate cost and availability of the training. This initiative should clearly spell out how the FAA intends to include users in the development of FITS.
- Page 13, second bullet under second group of initiatives: While AOPA strongly supports this initiative, the AOPA requests that the FAA also commit to publishing approaches to 500 general aviation runway ends per year.
- Page 17, third strategy discussed: AOPA recommends that the FAA commit to installing new runway incursion technologies at general aviation airports by 2008.
August 8, 2003