With the anticipated publication this month of an NPRM in the Federal Register, the FAA is laying the groundwork for implementation of domestic reduced vertical separation minimums (DRVSM) in U.S. airspace between FL 290 and FL 410 in December 2004. But as the rule’s start date draws nearer, many in aviation circles are complaining that the FAA’s plan for DRVSM is flawed and that significant concerns must be addressed before going forward.
The National Air Transportation Association (NATA), whose members include air-taxi and charter operators, FBOs and maintenance facilities, wants the FAA to come up with a longer phase-in period for DRVSM. Although most Part 135 on-demand air charter operators conducting international operations have already obtained the required approvals, there is a large population of turbine aircraft that are not RVSM-compliant, the association said. There is also the concern that insufficient repair station capacity exists to meet the demand in such a relatively short timeframe.
“In addition to these concerns, we worry that any FAA cost-benefit analyses employing pre-September 2001 traffic projections may no longer be appropriate,” said NATA v-p Joseph Burnside.
Avionics installation shops estimate RVSM modification costs for older turbine aircraft of $200,000 to $300,000. Upgrades required include new air-data computers and autopilots, which many operators argue are simply cost prohibitive for some aircraft. The result could be that scores of older business jets, for which RVSM compliance packages do not exist or are too expensive, could be forced to keep out of DRVSM airspace, meaning flying at less fuel-efficient altitudes below FL 290.
In a letter to FAA Administrator Jane Garvey last summer, NBAA and the General Aviation Manufacturers Association (GAMA) said both organizations support “a reasonably implemented DRVSM plan,” but added that the business aviation community needs at least until late 2006 to modify the turbine fleet. In the letter, signed by NBAA president Jack Olcott and GAMA president Ed Bolen, the trade groups made a strong case for delaying the rule’s effective date:
“Implementing DRVSM below FL 350 before December 2006 will unjustifiably exclude a significant number of operators. Many of these operators will incur a significant burden either by operating at lower altitudes and burning more fuel or by not being able to operate at all over certain routes due to the fact that the aircraft’s range is dramatically reduced at lower altitudes.”
NBAA and GAMA asked the FAA to consider initially implementing DRVSM from FL 290 to FL 350 and allowing non-compliant aircraft to transition through DRVSM airspace. It is expected that the associations will submit formal comments when the NPRM process gets under way, but it is not yet clear whether the FAA would be amenable to the suggestion. As the draft proposal for DRVSM is written, non-compliant aircraft will be allowed to transition through DRVSM airspace, but that means a climb above FL 410, which is not possible for many fully loaded business airplanes, particularly many older models for which an RVSM mod may be unavailable or cost prohibitive.
Another sticking point in the move to DRVSM could be coordination between the U.S. and Canada. Canada itself plans to implement RVSM on April 18 in the airspace between FL 290 and FL 410 above 57-deg north latitude, and extend it south in the years to come. Several meetings have been held between officials from the FAA and Nav Canada, the privatized air traffic control provider for Canada, to coordinate implementation along the border.
The National Air Traffic Controllers Association (Natca) last month issued an inflammatory statement chastising Nav Canada for moving at a far slower pace than the FAA on RVSM issues affecting flights to the U.S. from oceanic sectors. The complaints add fuel to an ongoing campaign aimed at discouraging U.S. lawmakers from privatizing ATC, but air traffic controllers at Boston Center claim their plight is far more than making political hay from nothing.
RVSM is already in use for North and Western Atlantic oceanic traffic controlled by Jackson Center, Miami Center, New York Center and Washington Center. But because three of six Boston Center sectors of airspace scheduled to use RVSM border Canadian sectors, Boston has been unable to assign RVSM altitudes to aircraft flying in its airspace, even though it was scheduled to begin doing so last November.
After Canada objected to Boston Center’s plan to assign RVSM altitudes in airspace along the border, Boston Center and Nav Canada controllers were scheduled to undergo RVSM training beginning March 20 and start using the program on April 18. However, Natca president John Carr has accused Nav Canada of dragging its feet in recent months.
Nav Canada has told Boston Center officials the training has yet to begin because
of lingering insurance liability issues, said Carr. But he contended that Nav Canada has yet even to perform an airspace impact study–something Nav Canada officials say is necessary–in the Canadian sectors that would handle RVSM traffic heading to Boston Center. The U.S. sectors affected roughly cover the state of Maine and affect mostly North Atlantic Track traffic.
“This is yet another example of the failures of a privatized air traffic control system,” said Carr. “If it’s not a financial crisis or government bailout like in Great Britain, it’s modernization on the Canadian model–waiting to see what the U.S. develops and then waiting to see if increased charges to passengers will help pay for it.”
Jim Roberts, president of Natca’s Boston chapter, said that as a solution Boston Center proposed that all flights handled by both U.S. and Canadian controllers would fly at non-RVSM “cardinal” altitudes between FL 290 and FL 410 in increments of 2,000 ft before being handed off to Canada. Nav Canada opposed the proposal citing safety concerns, and told Boston Center it would agree to allowing Boston to assign RVSM altitudes only in the sectors that do not border Canada. Nav Canada also said that it would be ready to proceed with training by October, after the needed airspace studies were completed. Boston Center officials complained to FAA headquarters in Washington, but to no avail, said Roberts. Soon afterward, the FAA sent a letter to Boston Center ordering it to give Nav Canada the extra time it said it needed.
“Moving forward with modernization is not optional, it’s mandatory,” said Roberts. “I can’t understand why the FAA would handcuff us this way.”
Industry trade groups believe this could be only the beginning of difficulties with Nav Canada and that DRVSM implementation could prove far thornier an issue. A final DRVSM rule is not expected to emerge before next June, at least giving business aircraft operators time to investigate what upgrades need to be performed to meet the rule’s more stringent height-keeping requirements. Soon after publication of the rule the FAA plans to approve the means by which operators may test individual airplanes in flight to gain the needed RVSM approvals.
This month the FAA is scheduled to present the first of five DRVSM airspace seminars to provide operators with specific guidance on what they need to do to comply with the requirements. The meeting is to be held on April 9 and 10 at the Hyatt Dulles Hotel at Dulles International Airport in Virginia. The remaining four DRVSM seminars will take place in the South, Southwest, Northwest and Central/Great Lakes regions at approximate six-month intervals.
The FAA plans to have completed all necessary ATC system modifications by July 2004 and, assuming all goes according to plan, the agency said it intends to implement DRVSM in U.S. airspace from FL 290 to FL 410 inclusive in December 2004. Considering the number of factors that could affect a go, no-go decision–not to mention the fact that comments from industry and operators have yet to be presented and considered–the late-2004 date is still being described as tentative. However, if RVSM implementation in other parts of the world serve as a barometer, it is unlikely the FAA’s schedule for DRVSM introduction would slip by much, if at all.