An FAA proposal to create two areas of Class D airspace north and south of Los Angeles International Airport is not the right tool for the job of containing aircraft executing missed instrument approaches at the airport, AOPA said in formal comments on a proposed Los-Angeles-area airspace redesign.
Calling for a better solution, AOPA pointed out that the proposed Class D areas would not solve all containment issues at Los Angeles International, would not reduce pilot or controller workload, and amounts to a Band-Aid approach that should be deferred in favor of the broader overhaul that is needed in the complicated airspace of the Los Angeles basin.
The FAA has not presented data on any excursions from Class B airspace that would warrant the imposition of Class D airspace, nor has it discussed any efforts to modify existing published missed approach procedures—both steps which should precede any new rulemaking proposal, said Tom Kramer, AOPA manager of air traffic services, in formal comments filed July 19.
“The proposed Class D airspace is a temporary solution. AOPA questions the prudence in completing a rulemaking process that will be supplanted in a few short months or years by a full-scale Class B review and modification, which is already under way,” he said.
AOPA objects to the current proposal’s potential for setting a precedent allowing future circumvention of prescribed procedures for the FAA to follow when modifying other Class B airspace areas, he said.
The association urged that the notice of proposed rulemaking be withdrawn “in favor of non-rulemaking options,” until the Los Angeles Class B airspace is reviewed.
Members can submit comments by Aug. 1 online by referring to FAA Docket No. FAA-2011-0496, or by mail to John Warner, Manager, Operations Support Group, Western Service Center, U.S. Department of Transportation, Docket Operations, M-30, West Building Ground Floor, Room W12-140, 1200 New Jersey Avenue, SE., Washington, D.C. 20590.
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