AOPA is urging the White House Office of Management and Budget (OMB) to reject a pending FAA rule that, as written, is extremely detrimental to operators of turbine general aviation aircraft. AOPA believes the proposed domestic reduced vertical separation minima (DRVSM) rule unrealistically compresses the implementation timeframe and could ground or severely restrict the practical usage of thousands of turboprop and jet GA aircraft.
The FAA's plan for DRVSM would reduce the vertical separation minima from 2,000 to 1,000 feet for aircraft operating between Flight Level 290 (29,000 feet) and FL410 (41,000 feet) in domestic airspace. OMB reviews proposed federal rules for their economic impact.
The FAA wants to implement DRVSM by December 2004. Even if the agency is able to publish a final rule by the end of September 2003, aircraft owners and the FAA would have only 15 months for equipment installation and certification in over 15,000 aircraft.
"The economic impact for GA operators is immense," said AOPA Vice President of Regulatory Affairs Melissa Bailey.
In AOPA's letter to OMB, Bailey points out that in many cases, the cost of equipage exceeds the value of the airframe. In addition, the rule will require turboprop aircraft to carry two RVSM-capable altimeters, solely so that the U.S. rule will be "harmonized" with international rules.
"While the percentage of turboprop aircraft currently operating in the flight levels 290-410 is not statistically large, domestic RVSM requirements should not be dictated by Canadian, Mexican, or other international civil aviation authorities or standards," she wrote. "Most U.S.-based turboprops are used for domestic travel, not international, and it is AOPA's position that operators should retain the ability to decide how their aircraft will be equipped, not the federal government."
In addition, Bailey notes that the FAA can only process a maximum of 3,000 field approvals in a year. "Even if the FAA conducted only DRVSM field approvals for the next year, (which is impractical) it would still leave thousands of airframes noncompliant," banned from the DRVSM flight levels, and unable to take advantage of the lower operating costs at those altitudes.
"AOPA is also concerned that this rule was issued without the support of several key industry participants," said Bailey. "In early 2001, the FAA had achieved industry-wide consensus for phased implementation. Now they're reneging on the consensus plan in favor of an unrealistic, virtually unattainable goal."
The phased implementation strategy (FL350-FL390 by December 2004 and full implementation no sooner than December 2006) favored by AOPA and agreed to by industry and the FAA will allow the FAA and operators the time needed to comply with the requirements of RVSM airspace.
Rep. Donald Manzullo (R-Ill.), chairman of the House Committee on Small Business, recently echoed AOPA's concerns about errors in the proposed DRVSM rule. He urged OMB to return the final rule to the FAA for reconsideration of small business impacts and alternatives to full DRVSM implementation in December 2004.
AOPA acknowledged that DRVSM is an important piece of the puzzle for increasing airspace capacity. But in AOPA's letter to OMB, Bailey said, "The FAA must consider all airspace users when implementing new programs or strategies.
"Because of DRVSM's importance to the user community, it is incumbent upon the FAA to do everything within its power to ensure its benefits are realized with a minimal impact. As a result, AOPA recommends that the FAA pursue a phased implementation strategy and extend the deadline for total compliance to at least December 2006."
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