May 13, 2003

Mark McCumber, Acting Manager
Airspace Branch, AEA-520
Non-Rule Case No. 03-AEA-002-NR
FAA Eastern Region
1 Aviation Plaza
Jamaica, NY 11434-4809

Re: Airspace Case Number 03-AEA-002-NR; Philadelphia Class B Modification

Dear Mr. McCumber:

The Aircraft Owners and Pilots Association (AOPA), representing the interests of close to 400,000 general aviation pilots, including 26,000 members in the Philadelphia area, strongly opposes the Federal Aviation Administration's (FAA) strawman design to expand the vertical and lateral limits of the existing Philadelphia International Airport (PHL) Class B airspace area as outlined in 03-AEA-002-NR. AOPA requests that before the FAA moves forward with any airspace changes in Philadelphia, that an ad-hoc working group convene to review the air traffic justification and develop an airspace recommendation.

The proposed changes would effectively eliminate the ability for general aviation aircraft to transition past the Philadelphia Class B airspace to the east of the airport. The current Class B configuration allows for transitions outside the Class B footprint while remaining clear of Alert Area A-220 and R-5002C. Eliminating this transition airspace has a significant impact because, according to a recent AOPA survey, 73% of general aviation pilots said they deviate around Special Use Airspace (SUAs) because of the lack of real-time information about military flight activity.

Laterally expanding the Class B footprint would not only make transitions to the east of the airport difficult, but also creates an unsafe condition by compressing traffic into a narrow VFR corridor between PHL Class B airspace and Atlantic City International Airport (ACY). In addition, the proposed plan would encroach upon McGuire AFB C-141, KC-10 operations, and R-5001 operations by driving general aviation traffic over or in close proximity to McGuire AFB airspace.

As proposed, the lateral expansion would impact well over 337,944 general aviation local and itinerant operations. In addition, nearly 800-based aircraft would be impacted by the east-west expansions and lowering the shelf in those associated sectors.

Expansion of the current airspace also creates a significant potential for aviation businesses to be economically impacted. The plan would eliminate all parachute operations out of Cross Key Airport (17N), thereby potentially closing down businesses at the airport or forcing operations to relocate. The plan would also negatively impact glider operations out of New Garden Airport (N57), currently located within PHL Mode C veil. Again, this operation would potentially have to relocate or suffer financial hardships unless provisions are made to accommodate the current activity. Pilots circumnavigating the Class B airspace will be forced to travel an additional 10-20 nm. The increased travel times will result in general aviation pilots incurring additional operating costs.

In addition to the economic burden placed on these underlying airports, there is the increased risk of safety implications as traffic is compressed in the east and west quadrants where traffic congestion already exists.

Lastly, AOPA strongly opposes raising the ceiling of the PHL Class B airspace area from 7,000 feet msl to 10,000 feet msl as there is no justification provided that necessitates such a significant change. Class B airspace should be established only when there are significant numbers and mix of controlled and uncontrolled flights within the same airspace.

AOPA appreciates the opportunity to comment on the strawman design and strongly encourages the formation of an ad hoc working group to assist the FAA if they choose to move forward with this rulemaking process.

Respectfully,

Heidi J. Williams
Manager
Air Traffic, Regulatory and Certification Policy