Mr. Denis C. Burke
Manager, Airspace Branch, AGL-520
Federal Aviation Administration
2300 East Devon Avenue
Des Plaines, IL 60018
Dear Mr. Burke:
The Aircraft Owners and Pilots Association (AOPA), representing the interests of over 380,000 aviation enthusiasts and professionals nationwide, submits the following comments to Airspace Case 02-AGL-16-NR. In this proposal, the United States Air Force is requesting changes to the Chippewa Military Operations Area (MOA). While the volume of airspace consumed by this modification is relatively small, the impact to general aviation pilots is increased. Based on this, AOPA requests that the Federal Aviation Administration (FAA) adopt a mitigation strategy consistent with maximizing the safe and efficient use of airspace enjoyed by pilots throughout this region.
While pilots may legally operate within a MOA under visual flight rules (VFR), it is important to note that having both military and non-participating aircraft sharing the same airspace places additional demands on pilots. For many within the general aviation community, the concerns raised serve as a de facto restriction, thus limiting the safe and efficient use of airspace. The best strategy for mitigating this impact is to provide both scheduling and real-time airspace information to civil aviators. This will not only aid pilots during their preflight planning, it will also allow them to make educated in-flight decisions concerning the conduct of their flight. AOPA's proposed mitigation strategy includes the following:
While changes such as the one proposed will not profoundly impact users of the National Airspace System, the FAA must be mindful that no impact to general aviation can be considered trivial. With the enlargement of the MOA's footprint and the lowering of its floor, both VFR and IFR traffic lose a very valuable 2,000 feet of altitude strata. As a result, the need for accurate, easily accessible airspace information only increases. With this in mind, AOPA asks for the FAA's help in ensuring the needs of the general aviation community are met through the implementation of the cited strategy.
Michael W. Brown
Air Traffic, Regulatory, and Certification Policy
May 22, 2002