Mr. Don Day
Airspace Branch, ASW-520
Department of Transportation
Federal Aviation Administration
Fort Worth, TX 76193-0520
RE: Lancer Military Operations Area
Dear Mr. Day:
The Aircraft Owners and Pilots Association (AOPA) submits these comments to Airspace Study #2000-ASW-01-NR: Proposed Establishment of the Lancer Military Operations Area (MOA), North-Central Texas. This is the United States Air Force proposal for the establishment of airspace to support a Realistic Bomber Training Initiative (RBTI) for B-1B and B-52H training. With this letter, AOPA is opposing the proposed Lancer MOA and providing comments on several areas of concern including the impact on the National Airspace System (NAS); "real-time" notification; and aeronautical charting.
Impact on the NAS
The proposed Lancer MOA could have a significant negative impact on air commerce, both VFR and IFR. The most troublesome aspect of this proposal is its size—the volume of navigable airspace that this proposal consumes is immense. Because the overall geographic area of the proposed MOA is similar to existing SUA, it is misleading to look at a two dimensional depiction on an aeronautical chart. Unlike the existing SUA, which is high enough to allow easy transit underneath (below 10,000 feet msl), the proposed MOA extends well into the altitudes used by general aviation traffic. The Lancer MOA will effectively compress general aviation traffic to altitudes below 3,000 feet agl, essentially eliminating access to the airspace when it is active.
AOPA is concerned that the proposed Lancer MOA will restrict access to Victor Route 563, between Lubbock International Airport and Big Spring Airport and Victor Route 62, between Lubbock International Airport and Abilene Regional Airport. Additionally, because the proposed airspace would be located in an area directly between Lubbock and Abilene, it would inhibit IFR arrivals and departures operating southeast. When the airspace is active, pilots will be forced to take a circuitous route around the airspace. AOPA requests that the FAA quantify the amount of traffic using Victor 563, Victor 62, and departing/arriving to the southeast. If the amount of traffic is significant, we believe that the FAA should disapprove the proposed Lancer MOA.
According to local users, pilots operating in the area southeast of Lubbock have expressed serious safety concerns about flying VFR through the proposed MOA. This information mirrors what AOPA has heard from other pilots around the country. It is no secret that the FAA does not do an adequate job of providing VFR pilots with scheduled and "real-time" SUA status information. Historically, most flight service stations (FSSs) do not receive actual SUA schedule information and they do not have access to "real-time" information. Most FSSs only have the charted 'Times of Use' for SUA.
Compounding this problem is the fact that the FAA is proposing to chart the Lancer MOA 'Times of Use' as continuous from 0900 until 0000L Monday through Friday and other times by notam. This listing is too broad to be of any relevance for flight planning purposes. Generally, "real-time" SUA status information can be determined by calling the controlling ARTCC, but this is problematic for VFR pilots. The FAA does not publish the ARTCC frequencies on VFR aeronautical charts, so VFR pilots do not have the information readily available in the cockpit. Furthermore, the ARTCC will only work with VFR requests on a "time available" basis, so there is no guarantee that VFR pilots will have consistent access to the resource. Lack of access to SUA schedule and status information forces prudent VFR pilots to fly around MOA airspace, which has the effect of restricting access and inhibiting air commerce.
Providing VFR pilots with SUA schedule and "real-time" status information is an essential element of SUA management that has never been adequately addressed. If the FAA decides to move forward with this proposal, despite our objections, it is imperative that they publish the controlling agency and appropriate military control frequencies on VFR aeronautical charts. The FAA should also consider posting SUA schedule information on their Internet site to provide pilots with this critical flight planning information.
There is a proliferation of SUA in the area of the proposed Lancer MOA. Because of this, the FAA should carefully evaluate the cumulative impact the proposed MOA would have on civil aviation. The FAA has the responsibility to efficiently manage the NAS and balance the needs of all users, both civil and military. The burgeoning SUA in Texas already skews the balance and the proposed Lancer MOA serves to further degrade general aviation access to the NAS.
As the NAS evolves there is increasing reliance on IFR and VFR RNAV operations. The FAA must evaluate and mitigate the adverse impact the Lancer MOA proposal would have on these operations. The significance of this point is illustrated by the fact that the FAA administrator tasked RTCA Special Committee 192—a government/industry committee, to develop guidelines and concepts for transitioning to Free Flight. One of the key performance outcomes that SC-192 identified is the need for increased user access to SUA and to SUA status information.
The FAA must take steps to increase civil aviation access and allow for optimum flight profiles for all users. If the FAA ultimately approves the Lancer MOA proposal, these steps should include (but not be limited to) the development of VFR and IFR corridors through the proposed Lancer MOA. The FAA should work with local users to define the optimum altitudes and flight paths.
The Aeronautical Information Manual (AIM), which is the FAA's official guide to basic flight information and ATC procedures, offers the following guidance concerning pilots operating VFR in and around MOAs:
AIM Section 4. 3-4-5 c. states "Pilots operating under VFR should exercise extreme caution while flying within a MOA when military activity is being conducted. The activity status (active/inactive) of MOAs may change frequently. Therefore, pilots should contact any Flight Service Station (FSS) within 100 miles of the area to obtain accurate real-time information concerning the MOA hours of operation. Prior to entering an active MOA, pilots should contact the controlling agency for traffic advisories."
As mentioned previously, the problem with this guidance is that FSS facilities do not have ready access to SUA "real-time" information. Furthermore, because the FAA does not publish the controlling agency frequency on VFR aeronautical charts, it is difficult for pilots to contact said controlling agency.
As stated above, the charted 'Times of Use' are too vague to be useful. If the FAA moves forward with the Lancer MOA proposal, despite the negative impact on civil aviation, they should develop a memorandum of understanding with the Air Force to establish procedures that support improved availability of SUA schedule and "real-time" information. For example, the FAA could require that the Air Force maintain an 800 line and Internet site for providing schedule information. The FAA could also require the publication (on VFR aeronautical charts) of a range control or other appropriate frequency for determining SUA status. All of these examples have been successfully implemented in other SUA areas around the country and they serve to greatly increase civil aviation access to SUA.
AOPA priorities for the charting of SUA are:
These items are high priority because of the safety and capacity benefits that will be realized with better information dissemination.
Finally, AOPA recognizes the importance of providing the military services sufficient SUA to maintain a high level of military preparedness. We realize that today's advanced military aircraft have outgrown some of the existing SUA areas. However, our airspace resources are limited, and the military and the FAA must look for ways to utilize the airspace more efficiently. The goal must be to provide for the fewest restrictions possible for all users. One way of accomplishing this is for the Air Force and the FAA to step up to the plate and implement new meaningful and innovative real-time notification and charting solutions.
For the reasons stated above, AOPA is opposed to the proposed Lancer MOA. Thank you for the opportunity to comment on this airspace proposal.
Melissa K. Bailey
Airspace and System Standards
July 7, 2000