Comments Requested on a Notice of Proposed Rule Making for the Modification of Class D Airspace & Establishment of Class E Airspace at San Bernardino International Airport (SBD)
Comments Are Due by November 25th
Comments can be provided electronically via the link in the federal register, or by US mail, or FAX. See instructions in the federal register for this NPRM. When you comment, please point out the issues with the proposal. It is okay to express disapproval and the reasons why. However, the FAA responds more favorably if instead of just saying “no”, commenters provide alternative or compromise suggestions where possible.
___________________________________________________
Background- Summary of Airspace Change Proposal - FAA’s July 2, 2024, Memorandum, Subject: Revised Airspace Review – SBD
Class D airspace findings:
- The current vertical limit of the Class D airspace is 3,200 feet. The vertical limit should be increased to 3,700 feet to better accommodate turboprop and turbojet aircraft in a high-density area. IFR arrivals to Ontario International Airport, CA (KONT), currently transition above the proposed ceiling of 3,700 feet. A lower transition for KONT arrivals could be accommodated via a letter of agreement.
- The current eastern lateral boundary of the Class D airspace does not fully contain IFR departure operations between the surface and the base of adjacent controlled airspace. A Class D shelf should be added to the northeast portion of the airspace from 2,600 to 3,700 feet, inclusive, extending 5.5 miles to the east. This proposed shelf would provide sufficient lateral distance to allow aircraft departing on either the JADKO ONE DEPARTURE (Area Navigation [RNAV]) Runway (RWY) 6 or the RWY 6 obstacle departure procedure (ODP) to reach the base of adjacent airspace within the lateral boundaries of the Class D airspace. The shelf would also allow for continued operations at Redlands Municipal Airport (KREI) at their current pattern altitude of 1,000 feet above the surface—while still allowing for northbound VFR transitions underneath the shelf and glider operations east of the airport in the foothills of the San Bernardino National Forest.
- The current western boundary of the Class D airspace does not fully contain the IFR departure operations of the RWY 24 ODP while between the surface and the base of adjacent controlled airspace, nor would it fully contain RNAV (Required Navigation Performance [RNP]) X RWY 6 IFR arrival operations while between the surface and 1,000 feet above the surface. A 4.2-mile-wide extension centered on the airport’s 250° bearing extending a half mile west of its 4.5-mile radius should be added to the existing boundary to sufficiently contain these operations.
- The current northern lateral boundary of the Class D airspace would not fully contain IFR departure operations while between the surface and the base of adjacent controlled airspace when utilizing the JADKO ONE DEPARTURE (RNAV) procedure. The northern border of the Class D airspace should be extended .29 miles north of its current position to sufficiently contain departures on that procedure. The modification would also more appropriately align the northern border of the proposed Class D surface area with the northern border of the proposed Class D shelf.
Class E airspace findings:
- The current eastern lateral boundary of the Class D airspace would not fully contain IFR arrival operations for the RNAV (RNP) RWY 24 approach while between the surface and 1,000 feet above the surface. An eastward-then-southward extension to the surface area should be established to contain those operations. Because the needed extension is greater than two miles, the extension should be Class E4 airspace. The roughly 7x5-mile area would extend from the surface and would impose a 500-foot clearance-from-clouds requirement on VFR aircraft operating within the airspace area to support flight safety at KSBD without imposing 2-way radio communication. • Class E airspace beginning at both 700 feet (Riverside Class E5) and 1,200 feet (Los Angeles Class E6) above the surface exists in the area and provides all other required transitional containment.
Background -Existing and Proposed SBD and REI Airspace
Existing Airspace @ SBD & REI
SBD Class D During Tower Operating Hours
REI Class G to 699’ AGL, Class E starting at 700’
Proposed SBD Class D Expansion and Class D Shelf
The proposed expanded Class D surface area is depicted in green, and the proposed Class D shelf is depicted in orange. The class D shelf overlays the fixed wing and helicopter traffic patterns at REI.
Proposed SBD Class E4 Extension to the Class D
The proposed Class E4 airspace area designated as an extension to the Class D surface area is depicted in red. It will replace the existing Class G airspace, where depicted and begin at the surface and go to overlying Class E5 airspace at 700’. Class G airspace surface to 700’ exists outside of the depicted Class E4 airspace.
The new E4 surface airspace would impose a 3-mile visibility and 500 below 1,000 above and 2,000 horizontal foot clearance-from-clouds requirement on VFR aircraft as compared to 1 mile (day) and clear of clouds requirement for Class G airspace.
Proposed Charting of Expanded Class D and E Airspace
This drawing was included in the FAA’s July 2, 2024 , Memorandum, Subject: Revised Airspace Review – San Bernardino International Airport. It illustrates how the proposed Class D expansion (depicted in green) and the Class E airspace area designated as an extension to the Class D surface area (depicted in red) would appear on a VFR terminal area chart.
Edited 10/16/2024
________________________________________________________________________________________________
Redlands Airport Association Assessment of the Airspace Change:
-Currently SBD does not have any surveillance equipment (Radar/ADS-B)to detect traffic within their existing class D airspace. Traffic is detected visually. SBD tower personnel have shared they are already challenged to see traffic within their existing airspace. SBD is supposed to get surveillance equipment within two years as stipulated in the FAA’s Reauthorization Act of 2024. The airspace modification proposal does not require the installation of surveillance equipment in the SBD tower as a prerequisite for this airspace change.
-The published TPA at REI is 2503’. That provides less than 100’ separation from the floor of the newly proposed Class D shelf. This may lead to airspace incursions or REI traffic flying at a lower pattern altitude.
-The new E4 surface airspace designated as an extension of the Class D will be off limits to ultralight aircraft and paragliders. (See 14 CFR 103.17). There are at least a ½ dozen ultralight aircraft based at REI. Although they can take off and turn southbound to remain in Class G airspace it would be difficult for them to fly a left-hand traffic pattern to land on runway 26 with the E4 Airspace abutting the northeast corner of REI’s runway. It’s not clear how and if REI could obtain a waiver to allow the continued operation of 103 aircraft based at REI.
- The new E4 surface airspace would impose a 3-mile visibility and 500 below 1,000 above and 2,000 horizontal foot clearance-from-clouds requirement on VFR aircraft as compared to 1 mile (day) and clear of clouds requirement for Class G airspace. The loss of the class G airspace to the north and east of REI’s runway does create some operating restrictions for REI operators that may have had need to use the Class G (day) VFR visibility and cloud clearance requirements. REI does not have an FAA approved weather source , so will operators at REI need to use reported SBD weather to determine VFR visibility in the Class E4 airspace? Visibility between both airports can vary due to elevation differences. During marine layer conditions REI will become VFR prior to SBD. This condition may lead to pilots operating at REI prior to SBD reporting VFR.
- The proposed charting of the expanded Class D and E airspace does depict the location of the E4 airspace under the new Class D shelf. Standard charting symbology depicts Class E surface area with a magenta dashed line. The magenta line should replace the dashed red line in this drawing and extend under the class D shelf. To the eastern boundary of the new Class D surface area.
- There has been discussion between the REI waiver holder and the FAA to raise the floor and ceiling of the aerobatic practice area 300’ to keep aerobatic aircraft out of the Class D shelf. This modification was acceptable to the APA waiver holder. No further changes to the APA are anticipated.
Questions? Email: Redlands.airport.association@gmail.com
About the Airport:
*Firefighting:
This crew, normally based at Fox Field (WJF) in Lancaster, arrived at REI Thursday evening. A US Forest Service employee who accompanied the crew shared on Friday 9-6, This crew dumped almost 119,000 gallons of water on the fire. The Skycrane can carry 2,650 gallons of water, so they flew at least 45 sorties that day over 7.9 hours. They are limited to flying 8-hour shifts. This Siller crew was probably responsible for saving the
East Highlands neighborhood at the foot of the mountains that we see just north of REI. Many of the helicopters were limited to about 3 hours of flying before needing to refuel. Numerous water sources around REI were used by crews. REI’s huge west ramp and its proximity to the fire were reasons for it to be used as a base.
The Good
• The airport received great press about its value to local communities.
• The firefighting helicopters and ground crews saved many homes.
• The airport is going to get compensated for its use. Initially AJ shared the city would get $200 /day and $.06
per gallon flowage fees, but then later said fees were being negotiated.
• Most tenants we talked with understood the need for the closure.
The Bad
• Communication from the city was not adequate and led to concerns about the need to close the airport.
There should have been some information about why tenants were not given any advance notice of the closure, why some helicopters were not flying in daytime hours, and city responsibilities when government agencies request to use the airport for an emergency.
• CalFire should have allowed more than one opportunity for aircraft to be moved from REI. It appeared there
were times when it was possible to do this.
• There are better ways to address airport problems other than sending nasty texts after hours to our airport
supervisor. Unfortunately, this created more ill feelings between the tenants and the city than existed previously.
• The city needs to be transparent about fees collected from agencies that used the airport for two weeks. It
will soften the impact of the closure.
*CHALLENGES:
Update on Installation of the Surveillance Display in the SBD Tower As mentioned in the RAA June 2034 Newsletter, the FAA Reauthorization Act of 2024 included language requiring the FAA Administrator to quickly certify if towers in the FAA’s contract tower program have a Standard Terminal Automation Replacement System (STARS) display. Under the bill, the FAA must install any needed displays into FAA contract towers within two years of the bill’s enactment. The FAA is now on the clock to install surveillance display systems in contract towers like SBD. We understood that STARS displays included both terminal radar and ADS-B data to help controllers see traffic.
But recently, Mark Gibbs, Director of Aviation at SBD, shared the FAA is planning to install a STAR’S terminal in the tower that will only receive ADS-B data. FAA officials are telling him that there are security concerns about providing radar data to new Federal Contract towers. Of course, aircraft in the airspace around Redlands and SBD are not required to have ADS-B. Consequently, many GA aircraft at REI and other neighboring general aviation airports are not ADS-B equipped. These aircraft will not be displayed in the SBD tower if the STARS display terminal does not have a radar feed. Mark Gibbs is disappointed and is engaging his lobbying contacts. He also welcomed any assistance the RAA can provide through our own contacts. So once again, we contacted Congressman Aguilars’ aides to review the latest news about the STARS terminal installation at SBD. They did confirm they are already in communication with Mark Gibbs and aware of this latest wrinkle concerning the installation of the SBD STARS display.
The congressman’s aides said they would reach out to their Washington DC FAA contacts. We have also notified AOPA’s Director of Airspace Jim McClay. He too is reaching out to AOPA’s FAA contacts in Washington DC. We will keep all advised as to the progress being made to get SBD tower the required, and hopefully, full-function STARS display.
The FAA Reschedules the SBD Airspace Change Safety Risk Management Panel Meeting The SBD Airspace Change Safety Risk Management Panel (SRMP) Zoom call has been scheduled by the FAA. It will be held on September 25th and 26th. Airport supervisor AJ, RAA member Tom Jones, RAA President Ted Gablin, AOPA Director Airspace, Air Traffic & Security Jim McClay, and about 65 other attendees (mostly FAA) have been invited.
The SRMP is an FAA process designed to conduct a safety analysis of a proposed National Airspace System (NAS) change. The FAA used this process to analyze the UPS RNAV Visual Approach to SBD Rwy 24.
The FAA is not soliciting user input for the change. Airport Supervisor AJ, REI Pilots Tom Jones, and Ted Gablin are listed as invitees on the airspace SRMP as Subject Matter Experts (SME’s) for REIs. They don’t get to vote on the change as do “panel members.” Their role is limited to providing technical guidance relating to REI and pointing out potential safety-related issues that may have been missed. Participants involved in the SRMP are not supposed to debate the change, just the risks associated with the change. - ... eventually, there will be a Notice of Proposed Rule Making (NPRM) on the airspace change with a comment period. Please be ready to comment when that occurs.
Request from the Riverside FSDO Regarding SBD & REI Traffic Conflicts
FAA Inspector Nelson Sanches has reached out to airport Supervisor AJ and the RAA to share he has collected data from two pilots reporting near midair collisions (NMAC’s) between SBD aircraft and other traffic. He says one of the incidents involved a hang glider. The other involved a fixed-wing plane and a tanker. He said that there were tapes of tower communications that supported one of the NMAC’s and the tower has filed two Mandatory Occurrence Reports. Nelson says he is leveraging the data to get the proper surveillance equipment installed in the tower. Nelson
has asked for Redlands pilots to continue reporting any NMAC or wake turbulence encounter to him. Preferably in an email. The RAA can help those who are unsure how to do this. He also asked anyone involved to call the incident to the SBD tower controllers’ attention by radio or by phone.
*Airport Data:
Redlands Airport Lighting Repairs are in the Works Airport Supervisor AJ has acknowledged repairs will soon begin on the PAPI, REILS, and a runway signage light. At the August Airport Advisor Board meeting, AJ said the only thing they are waiting on to initiate repairs was a completed
IRS W-9 form from the contractor. The repairs will cost $12K. AJ also committed to sharing information about the schedule for repairs and its impact on the airport.
Redlands Airport FAA Grant Activity
FAA grant updates were included in the airport supervisor’s quarterly newsletter and as part of his updates at the August and September Airport Advisory Board (AAB) meeting. He shared that a contractor for the runway and west ramp pavement rehab project was selected. The project involves applying an approved slurry coat to the pavement and pavement marking. The bid was awarded to the contractor at the September 17th Redlands City Council meeting. C.R. Contracting LLC was determined to be the lowest bidder. Their bid for the project was $616,499. With a 10% contingency added, the council approved the $678,094 project. The contract for this project stipulates it will be completed within sixty (60) calendar days after the city issues a Notice to Proceed to the Contractor. At the same meeting, the city council approved FAA grant paperwork for receiving up to $750,000 toward this project. A 5% matching grant from CalTrans was also processed by the city for this project. There will be a mobilization meeting
between the city and the contractor to determine the work schedule which does involve periodic runway and west ramp closures. AJ has committed to communicating the timeline to his airport email distribution list as soon as it is available.
AJ has also shared that the city obtained bids for Airport Planning/Environmental and Architectural/Engineering consultants in July. These consultants will handle the environmental, engineering, and architectural needs for some future grant projects. The bid awards are pending city council approval. The city is awaiting approvals from the FAA’s LAX Airport District Office for using REI’s discretionary grant funds for a wash rack project and FAA approval of the airport layout plan and preliminary wildlife hazard assessment. Future Information pertaining to grants and capital
improvements at REI will eventually be posted to the airport webpage https://redlandsairport.com .
Redlands Airport Advisory Board (AAB) Activity
The AAB held meetings this quarter in August and September. The July meeting was cancelled due to lack of a quorum. At the August meeting the AAB elected Jason Golembeski as chair and Michael Allen as vice chair. They also discussed reducing the number of meetings they conduct. A suggestion to meet every other month was not approved. The board ultimately voted 7-0 to cancel future December, March, and July meetings. The board did not take action on any airport matters during this quarter. The AAB acts in an advisory role to the Redlands City Council on all things related to the airport. Board members volunteer for a 4-year term. They are selected by Redlands City Councilmember tasked with that duty. Most board members have some aviation experience. Some are RAA members as well. The meetings are a public forum for airport tenants to learn about airport issues and administration. Airport tenants can make the city aware of airport issues at the meetings with their public comments. Meetings are held on the third Thursday of the month at 6 pm usually in the Redlands City Council chambers. Members of the public who desire to comment on the agenda or any other airport issue can attend, complete a speaker form, and give a three-minute comment at the podium. REI tenants are encouraged to reach out to board members to discuss airport issues and to make suggestions. Feedback from tenants helps board members to be effective in their advisory role. Some board members attend RAA meetings for that very purpose. Here are the names and some emails of the current
AAB members:
Robert Pearce rpearce898@aol.com - Jason Golembeski Jasongolembeski@gmail.com = Dennis Nodine dennis.nodine@gmail.com - Val Dotchkov - Amber Harrison Michael Allen michaelallen41@att.net - Richard Jones
* Author Ted Gablin edited 10/8/2024
For additional information, you are invited to visit the Redlands Airport Association Website Here
You Can View the Association's memorialized NEWSLETTER Page Here
**Additional Information:
Airport Website: https://redlandsairport.com
Noise Abatement Information: https://redlandsairport.com/pilot-center/flight-maps/
Hotel List:
Ayres Hotel Redlands | Official Site 6 miles southwest,
Comfort Suites Redlands ® Official Site 6 miles southwest,
Home2 Suites by Hilton 6 miles southwest
FBOs: FBO- Redlands Aviation, 909-794-5642
Repair Facility: GAS-PPS https://www.groveaero.com/ Heavy maintenance, avionics pitot static and more
Local Attractions: San Bernardino mountain resorts, camping hiking and skiing. numerous bars and restaurants in downtown Redlands, San Bernardino County Museum, Hangar 24 Brewery across the street from REI
Car Rental: Car rental not available at REI. Call Enterprise car rental in Redlands for pickup at Redlands Airport. +1 909-793-0035. Deliver car to Redlands Airport Lobby 1755 Sessums Drive Redlands
Flight Schools: Learn to Fly Redlands (NextGen Flight Academy), https://flyhere.aero/
Aerotech Flight Academy, https://aerotechflightacademy.com/
** Compiled by Gary Palmer - edited 10/08/2024