Regarding extending class b where the floor of the class b is the ground from 6 to 8 miles.
The stated goal of the proposed change is to reduce the chance of a midair. Keeping airliners in class b airspace until touch down once they enter class b is one way to do that. A slide showed 2 aircraft (a rare occurance) going below class b between 6 and 11 miles to the east of phl. Another slide from the same time period showed numerous vfr aircraft transiting below class b between 6 & 11 miles (between phl class b and pne's control zone). We don't know why those 2 aircraft went below 1500 ft (possibly they requested lower to get below a cloud deck), but we can assume they could do it safely with all aircraft in the area required to have a transponder. We do know that, if the class b ground floor is extended to 8 miles, all of the vfr aircraft will be forced to fly in a much smaller airspace, increasing the chance of a midair between small civil aircraft over a very populated area.
In my opinion, increasing the class b from 6 to 8 miles, while it would prevent airliners from decending below the class b, would not change the potential for a midair for them, but would greatly increase the potential for a midair for those of us who fly below the class b by forcing more aircraft into a smaller area.
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James H. Naphas Public SubmissionPosted: 04/01/2011
ID: FAA-2010-1281-0002
James H. Naphas
This is comment on Rule
Meetings: Proposed Modification of the Philadelphia, PA, Class B Airspace Area; Correction
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Public Submission Posted: 04/01/2011 ID: FAA-2010-1281-0002