November 11, 2010
By Dan Namowitz
AOPA has submitted formal comments to the Air Force’s draft environmental impact statement (DEIS) on a proposal that would create the nation’s largest block of special-use airspace by quadrupling the size of the Powder River Military Training Complex (PRTC). AOPA disputes the need for the expansion, which would pose operational risks and economic hardship for general aviation in the affected region that includes parts of Montana, Wyoming, North Dakota, and South Dakota. The Air Force also has not provided sufficient justification for year-round use of the expanded airspace, AOPA said.
The DEIS was the subject of a series of public hearings that concluded Oct. 26. AOPA’s regional representative, Mike Ferguson, attended the Oct. 22 hearing in Hardin, Mont., sharing AOPA’s concerns and engaging with the local community about the proposal’s impact.
As AOPA reported on Sept. 8, the Air Force has proposed conducting B-1 and B-52 bomber training missions in the complex that would include deploying flares and metallic chaff—a hazard to non-participating VFR aircraft operating legally in the airspace. The proposal also raises major economic concerns for GA operations and businesses at 39 directly affected airports with 285 based aircraft and many transient flights. Detouring around the airspace to avoid hazards could add 100-plus miles to a flight. Total airspace in the complex would increase from 7,000 square miles to about 28,000 square miles—a block roughly the size of South Carolina.
Citing data from the 2007-2008 Montana Economic Impact of Airports Study, AOPA has pointed out that the complex could jeopardize 95 jobs that generate $1,539,000 in annual payrolls, and $3.8 million in economic activity in the surrounding communities all directly attributable to the underlying public-use airports. FBOs would stand to lose revenue from a decrease in transient operations. Locally based pilots might opt to move their aircraft to an airport outside the PRTC. Student pilots would face hour-long commutes to reach airspace outside the complex, doubling the cost of earning a private pilot certificate, or possibly more.
AOPA’s formal comments on the DEIS highlighted the “substantial negatives” for general aviation ranging from the economic impact and potential flight delays to “multiple safety issues” raised by the planned training missions, “including high speed/low-altitude maneuvering, deployment of chaff and flares, and limited radio communications and radar coverage.”
“The PRTC will destroy the flight training industry at 39 airports underlying the proposed airspace. In the DEIS, the USAF explained that one of the key drivers of the PRTC was avoiding expensive, unproductive commutes to distant ranges. The same can be said for general aviation pilots, who are paying for flight training as well. Flight instructors would be forced to choose between conducting a flight in an active MOA with low altitude military aircraft operating at speeds in excess of 500 knots, or commute as much as 50 minutes to conduct the flight training outside of the SUA,” wrote Tom Kramer, AOPA manager of air traffic services in the Nov. 12 letter to the Air Force.
“AOPA understands and respects the military’s need to train. However, the massive scale of this airspace will have devastating impacts on the general aviation industry,” he added, pointing out such inconsistencies in the proposal as the Air Force publishing up to 44.5 hours of airspace use per week when only 15 hours are planned.
A more interactive training airspace design process would produce less controversial results, he said. “Based on the economic impacts and safety concerns with the proposed expansion of the PRTC, we strongly recommend the USAF go back to the drawing board and involve users in a meaningful dialog to ensure that any considered airspace expansion includes input from the user community.”
AOPA has been actively engaged on the Powder River proposal for several years, seeking input from members in the area. The proposal has garnered concern from several diverse groups including the National Business Aviation Association, airlines, several cities, and county commissions. AOPA continues to press the FAA for real-time status updates on special-use airspace through participation in the National Special Activity Airspace Program. The Powder River proposal demonstrates that with more accurate and timely airspace status updates, the negative impact to GA could be limited. Elected officials have also criticized the expansion plan as unjustified.
The deadline for commenting to the Air Force on the DEIS is Nov. 15. Send comments to Ms. Linda DeVine Program Manager ACC/A7PS, 129 Andrews St., Suite 337, Langley AFB, VA 23665.
The FAA also seeks comments on the aeronautical impact of the proposal by Nov. 30. Comments can be mailed to: Manager, Operations Support Group, ATO Central Service Center, AJV-C2; Airspace Study 10-AGL-6NR; Department of Transportation; Federal Aviation Administration; 2601 Fort Meacham Blvd; Fort Worth, TX 76137.
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