debra.e.Sullivan@faa.gov

Dear Ms. Sullivan:

The following comments are in response to the Department of Transportation, Federal Aviation Administration Notice to the Public on Proposed Cancellation of Non-Directional (NDB) Instrument Flight Procedures, published in the Federal Register/Volume 70, Number 41/Thursday, March 3, 2005/Notices.

Worcester Regional Airport strongly supports the installation of area navigation (RNAV), especially with the introduction of Wide Area Augmentation System (WAAS) capable RNAV instrument approach procedures that will provide for a near-precision vertical guidance at KORH.  Such equipment will serve the charter, corporate and high-end general aviation users of the airport, as well as air carriers, when scheduled airline service returns to Worcester.

In spite of these benefits, Worcester Regional Airport opposes the elimination of the NDB Approach to Runway 29 at KORH.  Furthermore, although not listed in the Federal Register Notice, FAA’s New England Regional Office personnel indicate that FAA is also contemplating the elimination of the NDB approach to Runway 11 and removal of the Outer Marker (OM), as part of the provision of the next phase of GPS derived instrument approach procedures.  While we are supportive of the development of such procedures, we are opposed to the elimination of the NDB’s and removal of the Runway 11 OM, for the following reasons:

1. The overwhelming majority of based aircraft at Worcester/KORH are not equipped with IFR certified GPS installations, thereby nullifying the advantage of the new procedures for those aircraft and pilots (estimate that 90 of 100 based aircraft/pilots are not IFR/GPS certified).
2. FAA still requires pilots with NDB's installed in their aircraft to demonstrate proficiency in flying those approaches when obtaining their Instrument Flight Rating or their Air Transport Rating.  Elimination of NDB’s at Worcester/KORH would mean that our pilots would have to fly to other airports to learn and practice NDB approaches.  This adds costs to an already expensive process.
3. Amity Flight School, based at Worcester/KORH will be put at a competitive disadvantage with flight schools based at other Massachusetts airports that still have NDB approaches.  Their students will be penalized with additional cost to fly to other airports to learn and practice NDB approaches.
4. Worcester/KORH will likely suffer a loss of aircraft operations due to the number of Instrument Flight and Air Transport based students that will now be required to go to other airports to learn and practice NDB approaches.
5. Worcester/KORH will likely suffer a loss of aircraft operations due to the number of Instrument Flight and Air Transport itinerant students that will now be required to go to other airports to learn and practice NDB approaches.
6. Operation counts, and especially, Instrument Approaches are significant factors in the FAA derived Cost Benefit Analysis conducted for those airports that are invited to join in the Air Traffic Control Tower Cost Sharing Program.  Loss of the operations noted in #’s 4 & 5, above, would have a direct effect on future Cost Benefit Analysis conducted by FAA to determine the community’s share of funding for its non-Federal Air Traffic Control Tower operation.
7. FAA New England Region suggests that VOR cross radials from Putnam VOR and Gardner VOR would likely be used to satisfy the needs of minimally equipped IFR aircraft; however, Gardner VOR is approximately 23 miles from KORH and Putnam VOR is approximately 18 miles from KORH.  Signal quality would need to be confirmed for both of these facilities before identifying a fix to replace the OM.  At least in the Gardner VOR case, its location is pushing the limits in terms of distance from a facility and signal degradation is a realistic concern.

Again, Worcester/KORH supports the development and installation of new RNAV systems; however, until such time as FAA formally eliminates the need for Instrument Pilot Rating and Air Transport Pilot Rating student candidates to demonstrate proficiency in flying NDB approaches as part of the practical tests to obtain those ratings, we are compelled to vehemently oppose the portion of the proposal listed in the Federal Register relating to the elimination of NDB approaches at KORH, as well as the one described by FAA New England Region personnel (as outlined herein), for all of the reasons listed above.

Sincerely,

Eric N. Waldron, A.A.E.
Director, Worcester Regional Airport