December 9, 2020
Dear Thann, Welcome back after you time away. I am writing you regarding several issues with the SFO Class B airspace. Before I begin, allow me to introduce myself. My name is Douglas Rice – I am a recently retired Captain with American Airlines and have been flying in/out of the Bay Area for almost 50 years. In your arena, I was the designated airspace expert for both AOPA and ALPA on the SJC Class C design and was a member of the executive committee of the NorCal Airspace Users Working Group, which designed the first HITS routings around/under the Class B using the VP waypoints still in use today.
What I want to bring to you are several questions/issues I discovered during my recent review of the SFO Class B airspace – I will be the first to admit I haven’t used the Class B chart for a number of years due to my inactivity in General Aviation flying but will begin actively flying GA aircraft within the next couple of months.
1. Use of the VP Waypoint Designation in the design of the Class B: Originally, this designation was created for VFR navigation in/around Class B airspace to avoid penetration of the protected airspace either as a GPS coordinate or the co-location of a GPS waypoint and visually identifiable object. As an example, the VPDLR (my initials) and VPCRL (my mothers (ATP CFII MEI)) were designed specifically to provide clearance around the instrument approach corridor to SJC. Similarly, VPEMB was designed to assist navigation to the Embassy Suites in Milpitas as an entry fix to SJC. We also designed parallel routes into/out of SQL across the bay to provide navigation and avoid head-on traffc flows.
My point is that the VP designator was originally intended to be a navigate and avoid system rather than an airspace designation point. Since these points are not on instrument charts, they are not known or identifiable for use by pilots on instrument flight plans nor are they usable by pilots to monitor flight within or underneath Class B airspace. Further, if a VFR pilot uses the waypoints for navigation overflight of the waypoints within the designated altitude structure leads to an airspace violation rather than avoidance of the designated airspace, exactly counter to the reason these waypoints were designed.
I understand that the FAA has a limited number of usable Alpha designators, but the use of the VP designation in airspace design, while not limited under the standards of the AIM, is a miss-use and prone to degrade safety and cause confusion. There needs to be a designation developed that is easily identifiable to both VFR and IFR pilots – for reference, air carrier aircraft have the additional capability of simplified designation of abeam reference for a given waypoint that aids in identification of boundaries that most GA aircraft do not have.
2. Class B Design: In reviewing the Class B design, I noticed a number of “anomalies” that should be corrected:
- a. The designation of a single waypoint 28 nm southwest of OSI is not strange. Unless it is an IFR designator with a overflight altitude designated as above 10,000 ft. it is useless. There should be two waypoints as a gateway into the Class B brought closer to OSI.
- b. The departure corridor west of SFO is currently designed for NAV departures (that is, aircraft using either VOR or RNAV capability). This ignores 1) Missed approaches where heading is given, 2) Go-around where a heading is given, and 3) Engine out procedures utilizing a turn to the right after departure. All of these have the potential to exit the side or bottom of the Class B and conflict with traffic avoiding the airspace.
- c. SJC departures and arrivals and Oakland arrivals lack clear navigation points as to when they are underneath the Class B. Again, reference points with the ability to use abeam procedures will aid the pilot in positive position reference for speed control.
3. With reference to item C, I want to give specific attention to SJC arrivals from the North. It is virtually impossible to identify aircraft position relative to the Class B in order to not exceed the 200 knot limit for flight under the Class B. It either requires an overlay on the navigation display (not available on current generation air carrier aircraft), a specific bearing off one of the VP waypoints (if it is in the air carrier aircraft database) in order to create the depiction of a boundary of the Class B on the navigation display, or the designation of an IFR waypoint on the arrival that can be used to generate an abeam fix designating the airspace boundary.
Until one of these steps is accomplished, it would be advisable to notify the controllers working these sectors of these issues so as to ensure that either aircraft remain within the Class B airspace or that the pilots are advised that they will be flying under the Class B when operating to the non-primary airports.
I look forward to your response.
Regional Vice President – CalPilots
Thank you Doug for taking the time to share your concerns regarding the SFO Class B airspace.
1.VP Waypoints: The SFO Class Bravo airspace change was made in accordance with FAA directives 7400.11 and 7400.
2. The directives required that FAA coordinate with State Aviation department to lead an Ad Hoc Committee that made recommendations regarding the Class B Change. The Ad Hoc team was assembled in early 2016 and provided their final report in June of 2016. Early on in the airspace development the FAA received a request to develop VP waypoints to allow pilots to use current technology to chart routes around and through the Class B. You are correct that the VP designator was not originally intended to be an airspace identifier, however there was no prohibition against this use and the overwhelming opinion from the NPRM responses was that waypoints would be a useful alternative to the VOR radial DME system of past. I also concur with your suggestion that a new designator of waypoint should be developed for this use and I have forwarded that recommendation to the Service Area Operations Support Group/Flight Procedures Team.
- Waypoint 28nm southwest of OSI...: I believe the waypoint you are referring to is VPBBQ and it is the northwestern boundary of where the Bravo airspace goes from an 8000 ft floor to a 6000 ft floor. I agree as a standalone waypoint it is not very useful.
- The departure corridor west of SFO is currently designed for NAV departures…: The Airspace for five and a half miles west of SFO is a surface area. Multiple years of flight track data was evaluated during the design and missed approach aircraft were captured. I am unsure if engine out procedures utilizing a turn to the right after departure were considered in the design. Unfortunately it is not possible to make amendments to the SFO Class B airspace at this point, without once again following all of the legal requirements for controlled airspace.
- SJC departures and arrivals and Oakland arrivals lack clear navigation points…: This is a concern throughout the NAS, and the FAA has a workgroup currently working on possible solutions. One suggestion is to indicated on the approach/departure plates where class b airspace overlies a procedure. Other considerations are being discussed at the National level with the user groups.
- The Proposed Modification of SFO Class Bravo change was published in the NPRM in 2016. Public meetings were held in 2017 and the final proposal went out for comment in 2018. The FAA did receive a comment requesting the airspace be designed using radial DMEs off of the SFO VOR for the reasons you stated. This suggestions would have resulted in large amounts of regulated airspace that are not needed for SFO aircraft. General aviation users and user groups opposed this suggestion.
- I have probably not answered your questions to your satisfaction and I apologize that there is not much more I am able to do at this point. I will follow up on the waypoint naming standard you suggested and the status of the Class B airspace indicators in regards to other airport arrivals/departures and I will let you know if I get any further information
Manager, Airspace & Procedures
Manager, Planning & Requirements
Northern California TRACON
Oakland District (TWOA)