AOPA has submitted formal comments noting concerns about the impact on general aviation of a proposed expansion of military operations areas in the Joint Pacific Alaska Range Complex (JPARC).
Melissa Rudinger, AOPA vice president of government affairs, filed comments requesting modifications based on general aviation’s use of the area between Anchorage and Fairbanks, where concerns about safety of flight and communications infrastructure have been raised by the proposal.
AOPA worked with the Alaska Airmen Association and other aviation groups to identify concerns about the MOA expansion that would lower the floor of the existing Fox 3 MOA from 5,000 feet agl to 500 feet agl, and create a new Paxon MOA, also with a floor of 500 feet agl. The Paxon MOA’s creation would affect flights using Isabel Pass, an important VFR route through the Alaska Range between interior and south-central Alaska.
Combined, the MOAs would span about 10,000 square miles of airspace.
Although the Paxon MOA would only be activated during major flying exercises, AOPA sees potential conflicts in the mix of traffic that would be caused by lowering MOA floors over popular recreation and hunting territory. The lowered floors would also complicate pilots' access to lakes and backcountry locations along the Denali Highway, said Tom George, AOPA's Alaska regional manager.
AOPA requested expansion of a radio communication network to allow civilian pilots to communicate directly with military range controllers, giving the pilots "essential" real-time information on military activities. The network, called the Special Use Airspace Information Service, has been an effective tool in other parts of JPARC, but the service would require expansion to adequately provide the additional coverage needed.
Rudinger questioned the imposition of a proposed VFR corridor across the complex’s floor which would concentrate civil traffic unnecessarily in a confined airspace area at low altitude rather than encourage flight at safer levels, with greater separation. The corridor "is not needed, and represents a potential safety hazard as opposed to a benefit," she wrote.
AOPA also requested that the military ranges not be used for large exercises during hunting season, which, Rudinger said, represents a "Major Flying Exercise" for general aviation pilots and air-taxi operators. GA flights support other activities in the area including fishing, camping, and business transportation.
A previous expansion of the airspace in the 1990s took into account the seasonal uses of the underlying area, causing major military flight exercises to be avoided during those times, she noted, but needs to be extended based on the areas included in this proposal.
Operations in MOAs typically share airspace with VFR aircraft, but result in airway and route restrictions for IFR traffic, AOPA pointed out, calling for the development of procedures to allow civil aircraft "routine" IFR access to the airspace complex, which is “too large to have to fly around.”
Following the end of the public-comment period on May 10, AOPA awaits the FAA’s response to its comments and those received from others in the aviation community.