"Let's be blunt and call it what it is: the Next Generation AIRLINE Transportation System," said AOPA President Phil Boyer, "as opposed to what NGATS is supposed to stand for: the Next Generation AIR Transportation System. This largely NASA/FAA vision of the future leaves general aviation out in the cold."
The "Concept of Operations for the Next Generation Air Transportation System" is supposed to be the "common vision" of how air traffic control, airports, and airspace will be operated within 20 years.
"But in this nightmare of the future, GA would lose access to airspace, experience increased security requirements, and operate from fewer airports," said Boyer, " even if we equipped with all the expensive technologies envisioned."
Boyer detailed AOPA's critical review in a letter commenting on the 105-page draft document [warning: 1.3 MB file] prepared by the Joint Planning and Development Office (JPDO), a multi-agency planning group that includes the FAA, NASA, the White House Science and Technology Office, and the Departments of Defense, Transportation, Homeland Security, and Commerce.
"Certainly the overwhelming cost-drivers for ATC design, development, and equipment are the needs of the commercial airlines," Boyer wrote. "General aviation is a relatively small user of the system of services provided by the FAA."
Nevertheless, 600,000 GA pilots fly some 210,000 GA aircraft from more than 5,400 public-use airports - the majority of those airports used exclusively by general aviation. GA pilots fly more than 28 million hours a year, compared to 19 million hours for the airlines.
"How can the JPDO ignore the size, scope, and magnitude of the general aviation industry in the United States?" Boyer asked.
In the JPDO Concept of Operations (CONOPS) vision, GA would experience increased barriers, particularly for VFR flight. Highly controlled airspace (Class B, for example) and restricted areas would be expanded.
Airspace would be "flexible," with boundaries shifting in real time for weather, traffic, defense, and security reasons. Airspace would be restricted for "higher performance operations" when necessary to "manage demand."
Even VFR aircraft would be required to equip with expensive avionics to provide information for the "four dimensional trajectory (4DT) management" system, which would require every aircraft to supply a flight plan and continuously update current location and altitude, speed, direction and altitude vectors, and arrival time, even if not participating in the IFR environment. (It's worth restating that 90 percent of GA flights today take place in VFR conditions and require contact with ATC only when in congested, terminal airspace.)
Non-equipped aircraft would be limited to shrinking areas of "classic airspace."
The CONOPS also envisions "virtual towers," with computers, rather than controllers, directing aircraft. But that would also require expensive avionics for GA aircraft to land at GA airports.
"The CONOPS would require VFR aircraft to invest in significant and expensive avionics upgrades and comply with rigid operational rules, without any direct tangible benefits to the GA pilot or aircraft owner," said Boyer.
It's not that AOPA is against ATC modernization.
"For nearly two decades, AOPA has been a staunch supporter of using technology to reduce FAA costs while improving the airspace system for all airspace users," said Boyer. He cited AOPA support for loran, then GPS, and now ADS-B (automatic dependent surveillance-broadcast) as examples of the association's forward thinking.
"Our steadfast commitment has resulted in successful modernization that not only improves general aviation safety and increases airspace system access, but also reduces federal investment costs significantly," Boyer said.
He noted that AOPA would continue to serve on the JPDO teams and committees developing the NGATS, and that "we stand ready to take this current CONOPS and assist in the necessary revisions so that we can return to what was originally intend - the Next Generation AIR Transportation System to serve the needs of all users, not just the airlines."
September 14, 2006