The U.S. Marine Corps has filed paperwork for two proposed military operations areas (MOAs) that, if established, would compress civilian general aviation pilots flying near North Carolina's Outer Banks into an area that the military considers unsafe for its own pilots.
"If the FAA permits these two MOAs, they will have an unavoidable adverse effect on civil aviation in the Outer Banks area," said AOPA Manager of Air Traffic Heidi Williams. "Besides some obvious safety issues, MOAs that are in constant use, as the Marines envision these, become de facto airspace restrictions for many GA pilots."
The Environmental Assessment filed on behalf of the Marine Corps' Second Marine Aircraft Wing proposes creating the Core and Mattamuskeet MOAs along and just inland from the Outer Banks, from 3,000 feet to 17,999 feet. The Safety and Hazardous Materials Management section of the document notes, "Bird/aircraft strike hazards are a serious concern for military aircraft operations. In rare circumstances, aircraft may encounter birds at high altitudes. However, data from the U.S. Air Force Aviation Safety Division indicates that bird/aircraft strike mishaps, for which altitude is known, occur predominately (98.4 percent of the time) below 3,000 ft."—precisely the area GA will be forced to fly in.
In addition, the proposed Core MOA, which overlies much of the Cape Lookout National Seashore, either forces GA aircraft into Class A airspace or compresses both northeast- and southwest-bound traffic into a 1,000-foot-high corridor below the MOA floor. Paragraph 7-4-6-(b) of the Aeronautical Information Manual states in part, "Pilots are requested to maintain a minimum altitude of 2,000' above the surface of the following: National Parks, Monuments, Seashores...."
The Mattamuskeet MOA overlies several national wildlife areas, creating the same compressed airspace problem for aircraft operating below its floor. In addition, the low floor deprives eastbound pilots of a steady, efficient climb to a safe altitude for an overwater flight to the Outer Banks. And westbound pilots would have to make a premature descent or make an extended circling descent once safely over the mainland.
"If pilots fly friendly and observe the National Park Service request not to fly less than 2,000 feet above the National Seashore," said Williams, "then the floor of the Core MOA at 3,000 feet leaves only 1,000 feet to see and avoid head-on traffic. That's an uncomfortably thin margin of error."
In formal comments filed last year, AOPA concluded, "When you combine the effects of proposed and existing SUA, increased military flight operations, and limitations in radar coverage that preclude real-time airspace management throughout the region, it becomes clear that the proposed action alternatives are not in the best interest of general aviation pilots. As a result, AOPA strongly asserts that the 'no action' alternative serves the best interest of airspace users in North Carolina."
The Marine Corps has yet to submit its formal request to establish the MOAs. Once it does, the FAA will have the final authority to create Core and Mattamuskeet. Establishing MOAs is a non-regulatory function, but the FAA is required to provide a public comment period that will again allow users to weigh in on the proposed airspace changes.