Federal Aviation Administration
Office of the Chief Counsel
Attn: Rules Docket (AGC-200)
Airspace Docket No. 93-AWA-5
800 Independence Avenue, SW
Washington, DC 20591
Gentlemen:
The Aircraft Owners and Pilots Association (AOPA), representing over 340,000 members of the general aviation community flying for business and personal transportation, submits the following comments to the notice of proposed rulemaking (NPRM) for the Establishment of Cincinnati/Northern Kentucky International Airport (CVG) Class B Airspace Area. With this letter, AOPA also requests that the Federal Aviation Administration (FAA) conduct another series of public meetings and a re-opening of the comment period.
AOPA has commented, on numerous occasions, that a single notification in the Federal Register with a 60-day comment period is not adequate for notifying the user public of a proposal. Few, if any, general aviation pilots have access to the Federal Register. Our members rely on AOPA and the aviation trade publications for dissemination of information and 60 days is not nearly enough lead time for AOPA and others to get the word out. At the very minimum, the FAA should publish a 90-day comment period and look at alternative methods for notifying the flying public.
In 1992, the FAA held informal airspace meetings and formed an ad hoc user group advisory committee to solicit user input in the development of this proposal. Six years have passed, and the FAA is only now issuing a NPRM for this airspace. Because so much time has elapsed since the informal airspace meetings, the FAA should hold another round of informal airspace meetings on the proposal. The comment period should be re-opened in conjunction with the meetings to allow pilots the opportunity to provide additional written comments.
While the current Cincinnati Class B proposal incorporates user recommendations such as establishing the ceiling at 8,000 feet msl and use of landmarks to delineate segment boundaries, it fails to adequately address many of the problems identified in 1992.
The proposed configuration appears to be inconsistent with the guidelines in Handbook 7400.2D, paragraph 25-21 with regard to the height of the floors of the areas between 10 and 20 nautical miles and beyond. Using the guidelines for height above the airport elevation, it looks like Areas C and D should be 3,700 feet to 3,900 feet msl, Areas E and F at 5,900 feet msl, and Area G at 6,900 feet msl. Also, the gradients for Areas C and D (Handbook guidelines between 10 and 20 nm) show a gradient of 100 nm, not the recommended 300 nm.
Another look at the merit of the proposed floors is warranted. This is necessary because of the hardship that these floors place on the general aviation airports caught underneath. For example, segment D over Lunken Airport is 3,500 feet msl, which does not allow a sufficient margin for operating safety for aircraft utilizing this vital general aviation airport. Investigation revealed that the FAA argument against raising the floor of this segment to 4,000 feet msl was based on the glideslope penetration of the segment D floor for the Runway 27 approach to CVG. The Runway 27 glideslope is based on a 3 percent angle. The users recommended changing the glideslope to 3.5 degrees to facilitate raising the floor of the segment D to 4,000 feet msl. This would alleviate the concerns of the Lunken users and provide adequate clearance.
To alleviate the burden this airspace places on satellite airports the FAA should provide cutouts and other mitigations to keep these general aviation airports economically viable. There does not seem to be any justifiable operational requirement for a 25-nm ring. One opportunity to mitigate the impact of this airspace on Clermont County Airport and Snyder Airport would be to change the lateral boundary of the outer ring to 20 nm from the current 25-nm distance. At the 20-nm limit, both of these airports would be completely excluded from the Class B airspace. At the very least, the FAA should provide these airports with airspace cutouts.
There are significant airspace problems relative to the proposed Class B airspace caused by the existence of military special-use airspace (SUA) to the east and west of the Cincinnati metroplex. This creates a funneling of a large quantity of north/south traffic between the outer ring of the proposed Class B airspace and the SUA.
Despite numerous recommendations for the establishment of VFR flyways to accommodate non-participating traffic, the current proposal does not offer any planned VFR flyways.
We have also received numerous inquires from Sporty’s and other area businesses who are concerned that no one from the FAA has contacted them concerning the economic impact of the airspace. These business owners feel that the proposal, as written, could be detrimental to their business interests. Additionally, the proposal does not address the negative economic and operational impact the Mode-C 30-mile veil would have on non-equipped aircraft.
AOPA has been notified that there are significant sailplane and glider operations that will be impacted by this proposal. To our knowledge there has been no attempt to mitigate the aeronautical impact that this airspace will place on these activities.
In addition to the above, user-identified issues, there are also several additional recommendations that should be incorporated into the proposal. These include the depiction of radials and distances from the vortac and waypoints to identify segment boundaries, and special helicopter route charts.
To assist with VFR navigation, radials and distances from the vortac, or latitude and longitude, or both should depict areas of the Class B that are not identified by landmarks. Radial and distance points could be useful even though the vortac is not located on the airport. The local user group committee should assist with the determination of the points to be depicted that would most benefit VFR navigation.
In consideration of the comments from the helicopter operators, the FAA should develop a helicopter route chart similar to those produced for other Class B areas.
AOPA applauds the FAA policy of working closely with the local user groups prior to a regulatory proposal. However, for this policy to be meaningful, the FAA must take action on recommendations in a timely manner. In the case of the Cincinnati Class B proposal, this has not happened. Therefore the FAA must solicit additional user input in order to provide the flying public with the safest and most efficient possible airspace design.
For the reasons stated above and because of the time that has elapsed since the initial informal airspace meetings, the FAA should hold a new round of public meeting on the proposal. Additionally, the comment period for the NPRM should be re-opened for user input during the informal meeting process.
Thank you for the opportunity to respond to this proposed airspace. We look forward to your positive response.
Sincerely,
Melissa K. Bailey
Director
Airspace and System Standards
Regulatory Policy
April 10, 1998
