September 22, 2003
Mr. Donald Smith Acting Manager, ASW-520 Department of Transportation Federal Aviation Administration Fort Worth, TX 76193-0520
RE: Airspace Study 2003-ASW-02-NR
Dear Mr. Smith:
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 Natchitoches, Louisiana, as referenced in airspace study 2003-ASW-02-NR. While AOPA supports the cancellation of R-3801A and conversion of that airspace into the Claiborne Military Operations Area (MOA), we are opposed to the southern boundary of the proposed Hackett MOA because of the impact it will have on Natchitoches Airport (IER). We are also opposed to the proposed use of the new MOA for night-vision "lights-out" training.
As proposed by the United States Air Force (USAF), the Hackett MOA, which combines and expands the existing Jones and Lady MOAs, would have a detrimental impact on the traffic pattern operations for nearby Natchitoches Airport (IER). The southernmost portion of the proposed boundary comes within 1 nm of both runways and has the potential to impact nearly 15,000 general aviation operations annually.
To mitigate this impact, AOPA recommends the southern boundary of the Hackett MOA be modified to ensure operations from all runways at IER remain uninterrupted. This could be accomplished by moving the southern boundary line to the north as follows: A line drawn from latitude 31°51'02" North, longitude 93°12'16" West to latitude 31°50'31" North, longitude 92°55'26" West.
This modification would give approximately 4 nautical miles additional space between IER and the proposed Hackett MOA south boundary and allow for normal pattern operations at the airport.
AOPA is opposed to the proposed night-vision goggle (NVG) training in this SUA. According to the documented list of SUA areas provided in the USAF petition request for exemption from § 91.209(a)(1) and (b) of Title 14, Code of Federal Regulations, the proposed Hackett and Claiborne MOAs are not included as designated airspace for NVG training. As a result, we do not believe the proposed MOAs should be used for such training under Exemption No. 7960, issued January 24, 2003.
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 the proposed Hackett and Claiborne MOAs on the Houston sectional chart.
AOPA appreciates the opportunity to comment on the proposed SUA modifications and looks forward to working with the FAA and the USAF to implement the recommended changes.
Brent Hart Government Analyst
September 22, 2003
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