More steps must be taken to mitigate the impact on general aviation of proposed changes to the Cheyenne Military Operations Area (MOA) in western Kansas and eastern Colorado, AOPA said in formal comments on the proposal.
AOPA submitted the formal comments May 30 after receiving feedback from members. AOPA noted a variety of concerns about the impact on IFR and VFR GA operations, on several airports, of potential adverse economic effects, and on the accuracy of statements about civilian use of the airspace contained in the MOA proposal.
AOPA suggested an alternative to the proposed raising of the floor of the new Cougar Low MOA from 300 to 500 feet agl, which the association believes amounts to an airspace “giveback” with little practical value. AOPA urged more accurately aligning the charted times of MOA use with actual use, which added up to only about 923 hours for both the high and low MOA segments in fiscal 2010.
The proposed MOA changes would make Victor 17 southeast of the Goodland VOR and V216 northeast of the Lamar VOR unusable during times of MOA activation. AOPA urged that Air Force and Denver Air Route Traffic Control Center work collaboratively to allow transition through the airspace during times of activation.
The proposed new Cougar Low MOA would directly overlie Eads Municipal Airport. Tribune Municipal Airport would lie within two miles of the MOA’s southern boundary, and aircraft arriving from the north would have to transit the active MOA. Aircraft departing to the north would have to turn almost immediately after takeoff to avoid penetrating the MOA. Providing exclusion areas with lateral and vertical boundaries prescribed by the FAA would mitigate potential hazards, AOPA said.
AOPA pointed out that the FAA has recently completed an aeronautical survey aimed at developing instrument approach procedures for Tribune Municipal--a process that could be adversely impacted by the MOA proposal.
GA operators at area airports that lie beneath or close to the MOAs account for about $9.8 million in annual economic activity, the association said, urging better transparency of MOA operational information to minimize any adverse economic impact.
AOPA questioned an Air Force assertion that noise reductions would be accomplished by the airspace reconfiguration, and pointed out the inaccuracy of the draft proposal’s assertions that the airspace cannot be used by civil aircraft during active periods. An FAA order provides that MOAs are always “joint use” airspace, AOPA said.
