Federal Aviation Administration
Mr. Mark Ward
Acting Manager, ASO-530
1701 Columbia Avenue
College Park, GA 30337
RE: Proposal to Delete and Establish Military Operations Areas in Georgia
Dear Mr. Ward:
The Aircraft Owners and Pilots Association (AOPA), representing over 395,000 pilots nationwide, is opposed to the Proposal to Delete and Establish Military Operations Areas (MOA) near Townsend, Georgia. The proposal imposes a barrier to both VFR aircraft and IFR traffic transiting the airspace. The proposed special-use Airspace (SUA) also threatens the economic viability of the underlying general aviation airports.
AOPA objects to the proposed eastern boundary of Coastal 1 East and Coastal 2 MOAs. This boundary parallels Interstate 95, the major VFR flyway for north-south traffic. Large portions of the I-95 Flyway from 300 feet agl to 18,000 feet msl would be negatively impacted by the proposed airspace. This proposed SUA would have its greatest impact on safety during the hot, humid, hazy summer days when VFR traffic is greatly increased and visibility conditions are at or near the basic VFR minimums. The FAA encourages VFR pilots to navigate by flying routes that follow rivers, coastlines, similar types of natural landmarks or major highways, and other manmade objects and therefore should not approve the proposed MOA because of the impact that it would have on this major flyway.
The FAA must also consider this proposal's impact on the general aviation airports that are underneath or immediately adjacent to the MOAs. Itinerant operations are the lifeblood of these smaller airports. But, VFR pilots often fly around MOAs because of safety concerns; creating a valid concern that business at these airports will drop off significantly if the MOAs are implemented as currently proposed.
AOPA's 2003 Policy and Issue Survey of its members shows that a full 73 percent of the general aviation pilot population deviates around MOAs, in part because of the inability to get accurate "real-time" status information on that airspace. In fact, our members ranked the ability to receive "real-time" status of SUA as its second most important airspace issue facing general aviation. The AOPA policy survey is a statistically valid sampling with a plus/minus 2.6-percent accuracy rate.
Despite the above problems, the FAA and the military do not consider this proposal to have any impact on VFR operations. This lack of consideration is based on the fact that the federal aviation regulations (FARs) do not prohibit VFR aircraft from operating in activated MOA airspace. In the interest of safety, AOPA believes it is necessary to look beyond the "letter of the law" when establishing MOA airspace. It is not prudent for a VFR aircraft to transit the airspace without regard to activity status. Furthermore, as indicated above, most pilots plan around SUA when it is activated. Therefore, the Coastal MOA has a significant impact on VFR flight operations. There is also an impact to IFR traffic in this proposal.
Because the FAA does not clear IFR traffic through an active MOA, V179 from Dublin to Brunswick and V578 from Alma to Savannah will be unavailable for IFR traffic when the MOA is hot. This proposal would greatly reduce the efficiency and effectiveness of IFR travel in the region. This would also further hamper any general aviation growth in the southern Georgia region.
The FAA must also consider the impact this proposal would have on existing and planned future approaches. For example, Jesup-Wayne County Airport, which underlies the Coastal 1 West MOA, has completed the extension of their runway, and plans are under way to add a precision instrument approach. The state of Georgia and the city of Jesup have spent a combined $800,000 on the runway extension, and the airport has recently been given a $500,000 grant by the state of Georgia to build a terminal building to promote economic development. This airport is recognized by the Georgia Department of Aeronautics as a vital business airport, and its economic viability must be preserved. This is just one of the many airports that could be negatively impacted by the proposed SUA.
If this proposal is adopted, the existing temporary SUA would be deleted and the Coastal MOA would be charted as permanent SUA with significant increases in both times of use and altitude. The current temporary MOA complex is only activated to a maximum of 28 days per year. With the proposed changes, this airspace would be charted active 0700 to 2200 (L) Monday through Friday and other times by notam. The altitudes would be increased to 18,000 feet msl.
The proposed activation times creates a huge discrepancy between charted -v- actual usages of SUA. For example, in the 1995 Georgia ANG Final Environmental Impact Statement for the Coastal MOA Complex, Page 2-33, Table 2-10, projected the Coastal 1 MOA would be used 665 hours a year. This averages out to roughly 13 hours of use a week. Despite this limited use, the Coastal 1 MOA would be charted as active 0700-2200 (L) Monday through Friday, other times by notam. The proponent should provide reasons for this dramatic change and the most recent data to substantiate the reasons for the need.
While the FAA has released a revised environmental assessment (EA), the current Coastal MOA proposal is based upon environmental information that was completed in 1995. AOPA believes that the FAA has an obligation to conduct a new EA before moving forward with this new proposal. In addition, the user community should be provided an opportunity to provide comment on a new assessment.
Based on conversations with military contacts regarding justification for the proposal, there have been numerous comments referencing the fact that the impact of the proposal will be minimal considering real-time SUA information is available to users. Unfortunately, real-time information IS NOT readily available to users and should not be used as a mitigation strategy. Rather, real-time information is a conduit to disseminate information to users and does not justify increased activation times or the need for full-time MOAs.
AOPA recognizes the importance of providing the military services sufficient SUA to maintain a high level of military preparedness. However, our nation's airspace resources are finite, and the questions of civil aviation safety and access must be mitigated.
For the reasons stated above, AOPA opposes the proposal to establish the Coastal MOA.
Air Traffic, Regulatory and Certification Policy
April 23, 2003