AOPA told the FAA its draft strategic plan, Flight Plan for 2004-2008, falls short of its mark and insisted the agency adequately address the needs of general aviation.
In its most glaring omission, the FAA's draft plan does not deal with the effects of aviation security requirements on GA traffic, which accounts for most of the flight hours in this country. In a letter and accompanying comments to FAA Administrator Marion Blakey, AOPA President Phil Boyer stressed that the FAA must develop a new strategy that mitigates the impact of security-related flight restrictions. Those restrictions effectively constrain GA capacity, causing congestion and delays around the country, especially in the area of the Baltimore-Washington Air Defense Identification Zone (ADIZ) and the presidential-movement temporary flight restrictions (TFRs).
"The FAA should not ignore its responsibility for an efficient air traffic control system that should serve the needs of the aviation users as it implements security-driven restrictions," Boyer wrote. "As the FAA notes in its introduction of the draft plan, '...the challenges facing aviation demand nothing less than a transformation of the system itself.' We couldn't agree more." The letter calls on the FAA to establish measurable goals tied to the FAA's budget to address security-related capacity constraints and improve GA access to airspace.
AOPA also voiced concern about a new safety improvement initiative, known as the FAA/Industry Training Standards program, or FITS.
FITS is an attempt by the FAA to recognize that aviation technology, in both airframes and especially avionics, is evolving so rapidly that the old training regimen that has stood for decades may no longer be enough. The program is a non-regulatory voluntary "add-on" that would train pilots in the use of specific equipment or aircraft.
AOPA has no problem with the goals of the program but is worried about implementation issues. For one thing, FITS may well lead to changes in the Practical Test Standards, which the FAA can make without public input. Further, AOPA is concerned that aircraft manufacturers and insurers may make passing a FITS program mandatory for buying an aircraft or receiving a policy. Such a requirement by industry would make the initiative a de facto regulation and, were industry to charge for the training, turn the initiative into a profit center.
In his letter, Boyer also told Blakey that while AOPA respects the FAA's efforts to reassert U.S. leadership in the international aviation community, all-out efforts to "harmonize" U.S. regulations with other nations' could hurt general aviation in America, where GA is more vibrant and of greater utility than anywhere else in the world.
Boyer warned, "If the FAA does not revise its objectives in the International Leadership section to include protection of domestic general aviation, it will end up pursuing global regulatory and policy-making initiatives that are not in 'America's best interest.'"
"I ask that you take AOPA's concerns to heart and incorporate our recommendations to address the areas affecting general aviation," he concluded.