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June 2nd, 2004
Federal Aviation Administration
Mr. Clay Hewitt
Regional Runway Safety Program Manager
1601 Lind Ave. SW
Renton, WA 98055
RE: Runway & Aircraft Safety Issues Concerning Notams
Dear Mr. Hewitt:
The Colorado Airport Operators Association (CAOA) Notam Committee met with
Ms. Lisa Rounsavell of the Denver AFSS on May 13th, 2004, followed by
a presentation she made to the members of our association during our Spring 2004
Conference in Grand Junction. As noted during our committee’s discussion, a
number of Colorado airports have been having a variety of problems concerning
Notam issuance, processing and dissemination. These include but are not limited
to:
- Inconsistencies with acceptance of Notam information by AFSS controllers.
On a regular basis, some controllers will not accept both routine and
non-routine Notam information issued by Colorado airports, while other
controllers will. Additionally, information is sometimes accepted by the AFSS,
only for the airport to receive a phone call later in the day by the AFSS
advising them that the Notam cannot be issued.
- Inflexible nature of the Notam system concerning airport operational
safety issues. As discussed in detail during the committee meeting, most
airports are required under their Airport Certification Manuals, through FAA
airspace reviews, or through their FAA approved construction safety and
phasing plans, to issue Notams on many circumstances which are not considered
Notam criteria by AFSS guidelines. This problem has been caused by conflicting
requirements between different branches or divisions of the FAA, which have
placed airports in a difficult position concerning being able to meet their
reporting requirements. Additionally, the current Notam criteria does not
allow for any flexibility whatsoever for an airport to issue a Notam on an
obvious airport operational safety issue which pilots need to know about, if
it is not considered Notam criteria under the current guidelines.
The differing Notam opinions by two different lines of business within the FAA
is of significant issue. The varying Notam requirements of each line of
business that airports must work with must be made consistent in order not to
continue causing the degradation of both runway and aircraft operational
safety which currently exists.
- Speed of processing Notams by AFSS. A common problem for most Colorado
airports is the time it normally takes to process a Notam and have it entered
into the system at the AFSS level. For example, during periods of inclement
weather, when airports are conducting snow removal operations, critical safety
information on airport operational areas tends to change often, requiring
updates to Notams frequently throughout the day. Notams on current field
conditions are often being issued to the AFSS before the prior field condition
Notams have even been processed into the Notam system by AFSS. It was reported
by several airports at the committee meeting that pilots are often phoning the
airport’s while in flight to obtain the most current field condition
information before landing, since Notam information obtained from AFSS is
often obsolete.
One solution discussed by our committee was the possibility of using existing
wireless technology to transmit Notams to the AFSS directly from the field.
Using a standardized Notam template to reduce terminology or contraction
errors, palm pilot type devices can be used to transmit the most up to date
Notam information to the AFSS, provided the AFSS is equipped with a receiving
device. The Colorado Airport Operators Association is willing to pursue
potential funding for such a system, including the receiving equipment needed
in the Denver AFSS, provided this program meets with the FAA’s approval.
In each of the above circumstances and examples, pilot safety and runway
safety are being jeopardized. This exposes our airports to additional liability,
despite efforts to notify pilots of current or hazardous conditions.
CAOA understands the substantial role that AFSS controllers play in the
operational safety of the Colorado Airport System, and recognizes the sometimes
overwhelming effort they invest in a system with greatly limited resources.
However, we also feel that the Federal Aviation Administration needs to evaluate
how these limited resources and the inflexible nature of the system are
affecting the dissemination of critical flight safety information to pilots, and
the potential results these are having on the aviation system. While our
committee will continue to meet and communicate with AFSS personnel regularly on
these and other issues, we urge the FAA to consider making policy changes within
its system which will improve the overall safety and efficiency of the Colorado,
and the National Airspace System.
Sincerely,
Rex Tippetts, A.A.E.
President
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