Mr. Richard Day
Manager, Air Traffic Division, ASO-500
Federal Aviation Administration
Southern Region Headquarters
P.O. Box 20636
Atlanta, GA 30320
RE: Proposed Establishment of Sanford Class C Airspace/Modification of the Orlando International Airport Class B Airspace Area
Dear Mr. Day:
The Aircraft Owners and Pilots Association (AOPA), on behalf of more than 400,000 pilots and aircraft owners nationwide, has concerns with the planned establishment of the Sanford Airport (SFB) Class C airspace area, Sanford, Florida, and the modification of the Orlando International Airport (MCO) Class B airspace area, Orlando, Florida. AOPA attended the recent scoping meetings held by the Federal Aviation Administration (FAA) to solicit input from the local user community on the proposed airspace changes. Airspace and safety issues were raised that lead the association to believe the FAA and users would be best served by revisiting the airspace user group process to work through the multitude of concerns raised by local airspace users. Therefore, AOPA requested the FAA delay final action and re-evaluate the airspace changes through the user group process.
Based on the issues discussed at the recent public meetings, it is clear that local users have not been adequately consulted during the development of the SFB Class C airspace or modifications to the MCO Class B airspace. Early involvement of the local airspace users is a critical element in the development of successful airspace changes that work for both air traffic control and users of the airspace. AOPA has developed guidance on the user group process with the input of several longstanding user groups and suggestions from FAA headquarters that can be found on our Web site.
The user group process allows local airspace representatives from surrounding impacted airports to review and develop recommendations to the airspace proposal. When dealing with a complex airspace area like Orlando Class B airspace, typically users would meet on multiple occasions and work through the issues they have with the proposal and develop recommendations before moving forward with public meetings. AOPA did participate in the one meeting that was held to discuss the proposed changes but to our knowledge, the airspace user group did not have the opportunity to submit recommendations or modifications to the proposal.
Although the airspace working group did not have the opportunity to provide formal written comments on the proposal, AOPA has analyzed the proposed changes and has several areas of concern based on our analysis and input from members:
- The Orlando Terminal Radar Approach Control (Tracon) staffing resources need to be carefully analyzed to ensure there is no degradation of safety or service to the VFR or IFR pilot if the FAA moves forward with the proposed changes.
- The practice of allowing pilots on the ground at Orlando Executive Airport (ORL) to obtain a discreet beacon code for a VFR departure should continue to be available as an option, regardless of proposed airspace changes.
- Based on the modifications, the corridor running east to west between ORL and SFB creates compression of VFR traffic over several tall towers to the east side and funnels traffic to a common VFR practice area on the west side over Lake Apopka.
- VFR waypoints should be considered as an alternative for pilots circumnavigating this complex airspace or for entry and exit points on VFR corridors.
- Considering the close proximity of the three busy airports within Orlando's Class B airspace area, there may be a need to redefine the airspace areas handled by the ATC facilities to allow for minimal frequency hand-offs for pilots in this busy terminal environment.
AOPA strongly encourages the FAA to revisit the airspace user group process in the course of its reevaluation of the airspace proposal. And we look forward to working with the FAA as they solicit the insights of the user group in the future.
Sincerely,
Heidi J. Williams
Manager
Air Traffic, Regulatory & Certification Policy
Cc: Mr. Reginald Matthews, ATA-400
December 3, 2003
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