Read the California Pilots Association response to the FAA’s proposal to change Long Beach Airport to a Class C – we are against adding even more complexity to the world’s most complex airspace without the required justification.
July 12, 2010
Operations Support Group, AJV–W2
Western Service Area, Air Traffic Organization
Federal Aviation Administration
1601 Lind Avenue SW.
Renton, WA 98057.
Subject: Proposal to create Class C airspace at LGB and revise the SNA Class C airspace;
Federal Register Vol. 75, No. 64/Notices
April 5, 2010
The California Pilots Association (CALPILOTS) is a statewide non-profit volunteer organization – representing the state’s 70,000 pilots – whose mission is to promote, preserve, and protect airports in California. We are writing to you regarding the proposed Class C airspace change for Long Beach Airport (LGB). As proposed, we believe that the airport at LGB and the surrounding airports of TOA, HHR, CPM, and FUL will suffer a loss of revenue associated with the more restrictive airspace that Class C will bring to the region.
We assume that you are aware of the fact that the FAA’s notice in the Federal Register did not meet the guidelines set forth in FAA Order 7400.2 in which it is stated that “… notice shall describe the proposal in sufficient detail, including charts, if necessary, to enable interested persons to prepare comments prior to the meeting.” We respectfully suggest that this failure be corrected by extending the comment period beyond 31 July in that the “proposal and its chart” were not placed before the public until the first informal meeting on 22 June.
Regarding the Class C proposal itself, the concept of “safer” has to begin with identifying a hazard that demonstrates that something is unsafe. The need for increased safety in the LGB area, as explained at the informal meetings by ATO staff, would appear to have no justification beyond that to support its “being enhanced by containing the air carrier operations within airspace with greater control.”
We have many questions with this concept which we believe require answers.
- What is Safer? – Does the Long Beach Airport Class C proposal eliminate mid-air collisions? We are not aware of any collisions involving turbine-powered aircraft; nor can we find any Near Mid-Air Collisions (NMACs) in the FAA record system.
- What hazard is being eliminated? – We have found a small number of “NMAC” type of reports on the NASA ASRS web site. They seem to be between small aircraft and appear to have been submitted to criticize the ATC system near and on the airfield.
- Where is the data to justify imposing class C airspace on the airport which shows that such action will resolve the perceived threat to safe air operations at LGB airport?
- Are there written reports from air carrier captains expressing their concern about a dangerous airspace situation?
The creation of a more restrictive and controlling airspace requires justification. At the FAA’s informal meetings in Long Beach, there was no presentation of an air safety hazard at LGB. This proposal should not be implemented due to numbers of aircraft or passengers on those aircraft. Nor should the FAA state that it would increase safety simply because it “it would contain the jet traffic that is receiving TCAS alerts on their approaches and departures from LGB”.
It appears to us that the LGB Class C proposal is based on a perceived problem – a problem of trying to eliminate some number of airline TCAS alerts. In fact, it appears to be about one air carrier receiving more TCAS alerts than they would like to see happening. We believe the FAA should seek to control added traffic based on fact-based problems, not on a perceived problem.
It is our understanding that approximately five years ago, staff from Jet Blue airlines told the Southern California Airspace Users Working Group (SCAUWG) that they wanted to find a way to mitigate the number of TCAS alerts that their airline was experiencing in its LGB operations.
- The information that Jet Blue Airlines provided to the SCAUWG included a statement that the carrier was, at that time, receiving more TCAS alerts with its BUR operation than at LGB. As you know, BUR is already a class C airspace. Obviously, creating a more controlling airspace does not necessarily create an environment that eliminates TCAS alerts.
- The SCAUWG and the FAA proposed a number of ideas to reduce the TCAS issue at LGB. The FAA tested a different departure vector for the jets, the results of which showed no difference. The SCAUWG recommended routing the jets to the west near LAX, or southwest over the Palos Verdes community. The FAA responded that it couldn’t be done.
- The SCAUWG asked if jets climb could be expedited into the class B airspace. The FAA responded that it couldn’t be done. A SCAUWG member suggested that the carrier make a “heads up” radio transmission on the training area frequency; something that would get everyone to watch for the departing jet. The air carrier responded that such a transmission would be non-standard and couldn’t be done.
If the Class C at LGB proposal is allowed to proceed, what is expected to be accomplished? If there is no NMAC record, nor ASRS or airline reports to eliminate, what hazard do we eliminate?
We could consider possibilities. Could an air carrier collide with a small airplane? It has happened before; however, previous airline mid-air collisions that have occurred were mostly in the era before TCAS. Do we assume that due to a large number of TCAS alerts, a jet operator might miss one and have a collision? Has there been a study on this, or is there any valid data to verify it?
The Department of Homeland Security (DHS) and Transportation Security Administration (TSA) used the possibility argument when it wrote a Large Airplane Security Program (LASP) that was to impose serious security constraints on general aviation administrative and operating practices.
The Operators to which LASP was to be applied are vehemently against it. The reason – TSA reasoned it was possible that an aircraft over 12,500 pounds weight could be used as a weapon – unless the proposal was adopted. Yet the AG report stated that was unlikely.
Will matching the number of BUR TCAS alerts with an equal number at LGB mean that we will have a collision? It is possible, but is it likely? Are we to clear the airspace to eliminate TCAS alerts for the air carrier? It is unlikely that we could ever do that unless we make it so difficult for small GA aircraft to use the system that we arrive at that same end-point.
Imposing Class C airspace and blocking off the piece of class E airspace over Los Angeles County’s beach cities could result in fewer aircraft flying there. This Class C proposal could be a worst case scenario and cause a large number of general aviation pilots to give up flying. With fewer planes in the air, we would reduce the potential for TCAS events. Surely this is not the solution you are after.
Anecdotal reports state that when Santa Ana Airport became Class C, flight schools found that their operational cost rose because their students spent more time dealing with clearances and less time with learning to fly. Some closed their Santa Ana operation.
The proposed LGB Class C would compress the class E airspace that pilots might use if they choose to fly around LGB.
- When the LAX “corridor” was closed, following the Cerritos accident in 1986, a number of “near-midair collisions” (NMACs) began to appear as the pilots flew around the circumference of the LAX airspace while staying as close to it as possible (to minimize the travel distance) to get to the opposite side. This was an example of airspace compression.
- In a similar manner, with airspace at LGB requiring radio contact and with LAX requiring a clearance, it is likely that there will be an increase in the number of small aircraft flying in the small Class E airspace immediately north of LGB – across the CPM airport while remaining south of the LAX airspace.
- An example of airspace compression exists in the Los Angeles basin near Corona Airport. We believe that it was a factor in a midair collision that occurred there some ten years ago. It was all about a pilot flying along the I-90 freeway, avoiding mountains to the south, and class C airspace to the north, and hitting another aircraft that was also flying over that airport.
- Airspace compression will happen with implementation of the proposed LGB airspace. Many GA aircraft will use the narrow class E airspace north of LGB, and over the top of the Compton Airport. We must remember that typically these aircraft do not have the TCAS systems. They will not have the benefit of today’s high-end technology for collision avoidance.
- Safety will also be affected as more complicated airspace can mean more heads-down time while pilots check their charts.
- Pilot training is a major industry in the LGB area. Flight training over a metropolitan area is not desirable when one can fly in the over-water training areas south of LGB.
Unfortunately the Long Beach Harbor area has had a history of two mid-air collisions in the last decade. The collisions involved small aircraft; aircraft not having TCAS and most of whose pilots were concentrating on training. To mitigate collision hazards, the SCAUWG received FCC authorization for use of a radio frequency that they use as a self-announcing collision avoidance tool. It enables aircraft in the training area to be alert to other aircraft training in the area.
- If a LGB Class C is created, radio requirements will add to the workload of a CFI who is trying to instruct and keep track of radio communications with local traffic, and with the SOCAL TRACON. Many training aircraft may be unable to monitor more than a single frequency and would therefore have to ignore the self-announcement to others and depend on SOCAL for collision avoidance.
- There will be training airspace which allows operating without the SOCAL contact, once clear of the Class C, but the aircraft would then have to reestablish that contact to return through or into the Class C. The pilots would probably depend on the SOCAL TRACON rather than switch back and forth on their radio.
- Training aircraft will become compressed into the small area below the Class C as they seek efficient use of time and aircraft instruction in the nearby harbor area. Relative levels of safety will decrease because of additional aircraft which will be flying closer to the surface, due to overlying Class C.
- This lowered operational altitude is a factor in most quadrants of the proposed airspace change. Lower altitudes mean a marginalized opportunity for successful recovery in the event of an aircraft emergency.
There are alternatives to the Class C proposal that might mitigate the TCAS alerts being received by the jets. The following ideas have been previously suggested and ignored:
- Although previously rejected, the pilots of departure aircraft, or their agents, could re-examine the possibility of broadcasting on the existing “self-announcement” frequency to the training area traffic so as to have everyone looking.
- On arrivals, two options might be considered.
- One option would be to have the FAA Flight Standards staff consider establishing LGB as a “Special Airport” with its attendant training and, as TCAS alerts with training pattern aircraft seem to be an issue, have the airline operation set the TCAS to “Alert Only” as the aircraft descends below 1500′ MSL on the ILS.
- The second option would both involve Flight Standards and the operator, and would be based on making a change to the air carrier’s operating manual so that a pilot on the ILS could have the option to disregard a TCAS “RA” when he is able to visually identify the alerting/conflict aircraft. Such an airliner would be expected to be communicating with the control tower at this point, therefore it would be expected that the FAA tower controllers would be able to safely control the various aircraft in their patterns without undue hazard.
The Long Beach Airport Class C proposal will also be detrimental to the area economy, not only the Long Beach Airport (LGB) but the neighboring airports, resulting in reduction of flight hours due to its layers of restrictions.
In closing we would like to remind you that in 1991 the Long Beach airspace was the subject of an NPRM for creating an ARSA. That NPRM was withdrawn by the FAA using the (appropriate) reasoning that the airspace in the entire L.A. Basin should be the subject of study and redesign – not just the airspace at LGB. Unfortunately, that study never happened.
If this piecemeal redesign, creating LGB as a Class C airport is put in place, it would make it even more difficult to perform the long overdue total Los Angeles basin airspace redesign.
Another factor in considering the effort to redesign the airspace is the decision of the FAA to move forward with its NextGen Airspace concept and its directive that aircraft will need to be equipped with ADS-B by the year 2020. The NextGen effort might make the LGB Class C proposal to be impractical.
We understand the complexity of this issue; however, as a result of the above considerations, the California Pilots Association believes that the proposal to convert the Long Beach airspace to Class C should be withdrawn. We fail to understand how the plan creates safer airspace when it produces even more complexity to the already difficult to navigate SOCAL airspace, and it is sure to confuse and hinder both familiar and unfamiliar pilots with LA’s multifaceted airspace.
We are hopeful that you are able to seriously consider all input as you move toward the decision of changes to the complex airspace that already exists in the Los Angeles basin.
President, California Pilots Association