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FAA to extend comment period on North Carolina SUA proposal at AOPA's requestFAA to extend comment period on North Carolina SUA proposal at AOPA's request

FAA to extend comment period on North Carolina SUA proposal at AOPA's request

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The FAA is once again seeking formal comments on the proposed expanded military operations areas (MOAs) near Cherry Point over the Outer Banks in North Carolina. AOPA requested the 60-day extension for comments on the proposal to create the Core and Gunny (previously called Mattamuskeet) MOAs because the FAA did not properly notify airspace users the first time around.

In addition to AOPA and local pilots, Rep. G.K. Butterfield (D-N.C.) added congressional pressure in October to AOPA's request to extend the comment period.

"The proposed airspace creates an operational hazard for general aviation, and AOPA is pleased that the FAA has reopened the comment period until February 14," said Heidi Williams, director of air traffic services. "Those who already have submitted comments do not need to resubmit them - the agency will consider all previously received comments."

Few airspace users were notified about the comment period before it officially ended August 18. AOPA was not formally notified, and the North Carolina Department of Transportation received notice just two days before the end of the comment period. Several local airport managers weren't notified either.

AOPA contends that the establishment of the Core and Gunny MOAs along and just inland from the Outer Banks, from 3,000 feet to 17,999 feet agl, would create safety hazards and operational difficulties for general aviation pilots.

The U.S. Marines say they'll be flying in the MOAs most of the time, which effectively puts them "off limits" to GA pilots. Some 73 percent of AOPA members say they avoid flying through MOAs because of difficulty in determining when they are "hot."

IFR aircraft under Cherry Point approach control could transit the area while it is active. ATC would provide standard IFR separation from participating military users.

The FAA circular states that the military will be flying non-hazardous missions in the area. Even though the military will not be firing live ammunition, the operations themselves could be hazardous to GA aircraft. Missions in the Gunny MOA would include military air combat maneuvers, flight training aerobatics, formation flying, low altitude training, close air support, and air-to-air intercept. About 25 percent of the missions would be flown between 3,000 and 10,000 feet msl, and the remaining 75 percent would be above 10,000 feet msl.

To avoid these hazards, GA pilots could choose to fly below 3,000 feet to stay underneath the MOAs. But bird strikes are most likely below 3,000 feet. And both MOAs overlie areas where waterfowl abound, including several national wildlife areas.

The Core MOA, which would be used for high-speed tactical ingress and egress flights, also overlies the Cape Lookout National Seashore. Pilots are requested to fly at least 2,000 feet above the surface of national parks, monuments, seashores, and wildlife areas. The MOA would compress all VFR traffic in the area into a 1,000-foot section of altitude, creating congestion and leaving very little room to see and avoid other aircraft.

The military would conduct 35 percent of its missions between 3,000 and 5,000 feet msl in the Core MOA, with the remaining 65 percent above 5,000 feet msl.

Comments on the effect of the MOAs on aeronautical activity should be sent to:

Federal Aviation Administration
Air Traffic Division
Manager, Operations Branch (ASO-530.8)
P.O. Box 20636
Atlanta, Georgia 30320

December 28, 2004

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