AOPA calls proposed Pennsylvania restricted area 'excessive'

September 26, 2003

Docket Management System
U.S. Department of Transportation
Room Plaza 401
400 Seventh Street, S.W.
Washington, DC 20590-0001

Re: FAA-2003-13850/Airspace Docket No. 02-AEA-19

To Whom It May Concern:

The Aircraft Owners and Pilots Association (AOPA), representing over 400,000 general aviation pilots, submits the following comments to proposed changes to special-use airspace (SUA) in Fort Indiantown Gap, Pennsylvania, as referenced in Docket No. FAA-2003-13850/Airspace Docket No. 02-AEA-19. AOPA opposes the conversion of the Kiowa Military Operations Area (MOA) to R-5802C, as well as the establishment of R-5802 D & E. We also oppose the dramatic increase in activation periods of the SUA in Fort Indiantown Gap, considering utilization of the current airspace has diminished over the last recorded year. General aviation access in this area will be extremely limited with the implementation of additional restricted airspace in conjunction with increasing activation periods.

AOPA opposes the implementation of R-5802C to replace the current Kiowa MOA, as well as the establishment of R-5802D & E. With the increase in vertical dimensions of this SUA, general aviation overflights of this airspace would be eliminated. Currently, Fort Indiantown Gap SUA has a maximum altitude of 13,000 feet mean sea level (msl), thus allowing general aviation to overfly the current Kiowa MOA during active times of use. However, the establishment of R-5802D & E results in an increase of airspace up to Flight Level 250 (FL250) and will no longer allow overflights of the SUA without the continued use of oxygen. If the proposed activation times are implemented, general aviation access to the area will effectively be cut off.

In addition to the reclassification of Kiowa MOA to R-5802C, we oppose the proposed increase in times of use. Currently, the Kiowa MOA is scheduled approximately 180 days a year, allowing general aviation pilots access to that airspace at least 50 percent of the year. The proposed activation times from daily sunrise to 2200 local for R-5802C would eliminate any access to the SUA airspace. Representatives of the 193rd Special Operations Wing (SOW) stated there is no current need for this proposed time expansion for the proposed SUA in Fort Indiantown Gap.

According to memorandums from the Fort Indiantown Gap Training Site to the FAA Eastern and New England regions, R-5802A & B utilization from October 1, 2001, through September 31, 2002, has shown a widened gap between scheduled use of the restricted areas and actual utilization. Before September 11, 2001, and the ensuing large-scale deployments of military personnel and equipment, the current restricted areas for Fort Indiantown Gap were utilized at least 100 percent of the scheduled times. However, due to large deployments overseas, the percentages have dropped nearly in half. We strongly recommend that the current charted times remain unchanged for the proposed SUA since no justification has been provided for increased activation times.

Lastly, it is essential for pilots to obtain accurate, real-time information on SUA activation status. To facilitate the dissemination of this information, AOPA recommends the FAA chart SUA frequencies for Fort Indiantown Gap SUA on the New York sectional chart.

AOPA appreciates the opportunity to comment on the proposed SUA modifications. Should you have any additional questions on AOPA's recommendations, please contact Brent Hart at 301/695-2207.

Sincerely,

Brent Hart
Government Analyst

Cc: Reginald Matthews, ATA-400

September 26, 2003