CALPILOTS Response to FAA Order 5190.6B (FAA-2009-0924)

To read the California Pilots Association’s response to the FAA’s proposed Order 519006B (Airports Manual) click Read More.

Mr. Randy Fiertz
Director, Airport Compliance & Field Operations Branch
FAA, Airports Division
800 Independence Ave., SW
Washington, DC 20591

Subj: FAA Order 5190.6B (FAA-2009-0924)


Dear Mr. Fiertz:

This letter is in reference to the FAA Airports Division revised Airport Compliance Manual, FAA Order 5190.6B, issued this past year.

The California Pilots Association (CALPILOTS) is a statewide volunteer organization whose mission is to promote, preserve and protect the state’s general aviation airports. We believe this also to be part of the FAA’s mission for the United States as a whole, which is why we are writing regarding this Order.

We were stunned that the manual, which is the guide for FAA staff, has increased from a readable 96 pages, to an encyclopedic 691 pages, a staggering 700% increase. More importantly, these pages effectively create new rules, new regulations, and generate major changes that will, in our estimation, produce unneeded confusion at the typical general aviation airport; and may harm the already fragile general aviation industry.

Frankly, we question if anyone on your immediate staff has actually read Order 5190.6B. It would be an effort akin to trying to understand every page of Tolstoy’s “War and Peace”. Size indicates that this was a year’s long project in which those creating the guidance lost track of their goals. We question whether the top FAA officials have reviewed this order and its negative effect on general aviation.

Fortunately, for us, there is guidance from the Experimental Aircraft Association (EAA), which has taken on the task of digging through the 691 pages of your order. We expect that the Aircraft Owners and Pilots Association (AOPA) will also comment questioning the reason for these dramatic changes, if it hasn’t already.

We are in agreement with the EAA’s response, and herein comment on a number of problem areas that the EAA has identified which we believe will hurt California’s airports, and the ability to operate general aviation aircraft in our state. We would like to understand the FAA’s sudden change regarding the following subject matter.

Auto Gas
Why does the updated order ban auto gas? This is confusing because twenty years ago the FAA and the EAA worked together to develop an STC for the use of auto gas in airplanes. We assume that this was an error by a staff that was looking at 30-year old FAA policy. In addition, this change would negatively affect the FAA’s support of the Sport Pilot program in which a number of Light Sport Aircraft (LSA’s) have been designed specifically to use auto fuel.

Through-the-fence (TTF) Operations
TTF is another of the areas that the FAA has unexplainably changed. The question must be asked – Why? This change would have a severely negative effect on existing and previously approved future residential developments, as well others that are being planned. Such developments are always subject to close review to determine if they can exist with the safety and security that an airport requires. This had previously been the FAA viewpoint as well, i.e., a case-by-case review of such housing.

Additionally, the whole TTF issue can affect other aviation operations that use airports but are adjacent to, and not on, the airport proper. We have read reports that FAA officials have stated that this change is due to airport noise complaints from air park residents. We have also read the FAA has been unable to produce said complaints.

The TTF appears to ban Trailerable Light Sport Aircraft, Powered Parachutes, Weight-shift-control and Gyroplanes. We do not understand why you wrote these sections into the manual, but if the information is correct, it would appear to be an effort to achieve safety and security by destroying this aviation segment. Surely the goal of this new guidance is not to destroy this industry segment.

Camping,
Per your new order, camping would seem to be banned. “The term ‘campgrounds’ indicates a permanently based campground at an airport instead of a temporary parking situation, which one finds at Oshkosh and other fly-ins.” Here in California, the very popular Columbia Airport and its adjacent State Historical Park, benefit from a permanent campground at the airfield. There is no known problem and no one foresees a problem with the camping there. Is the new order providing a solution that is in search of a problem?

What is the problem?
For whatever reason, large government bureaucracies do not seem capable of emulating the private sector in common sense problem resolution by asking the simple question “What is the problem we are trying to solve?” This rewrite of an effective manual is an example of that.

There was a time in history when the government was writing specifications for the design of products that they needed. Most of that thinking has been replaced by the writing of specifications for the performance of products that are needed. By writing this tome of an order, the Airports Division has taken its guidance from a “what we want done” performance specification to a “how to do it” design specification telling us where to drill the holes and whether to use screws or bolts.

We believe that this approach is wrong and that the original Order would be a better product to accomplish airport guidance. Perhaps you could reissue the order 5190.6B as an Advisory Circular that would give advice on “suggested” ways of operating an airport.

In closing we have to ask the tough question “Is this over-reaction of an Order the result of the FAA running scared from the TSA and its recent unwarranted general aviation security proposals?”

We have written to the TSA and provided feedback that the TSA should be working with and through the FAA to resolve any aviation issues, because the FAA is better qualified to respond. We are concerned that the FAA is changing what has been working to appease the TSA and its one size fits all mentality. The last thing the general aviation industry needs is another TSA type approach to problem resolution.

Respectfully,

Edward Rosiak – President
California Pilots Association

cc:
Aircraft Owners and Pilots Association
Experimental Aircraft Association
California Division of Aeronautics
Randy Babbitt – FAA Administrator
www.calpilots.org

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