[JYO] Fwd: Navy/Marines Propose New Military Operating Areas (MOAs) in already-satu...

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Hello to Aviation Supporters regionwide:
 
I write today to advise of the pending proposal by the Navy to establish
new MOA airspace in Eastern NC, a part of our state which already has a
disproportionate share of Special Use Airspace (SUA) in the region.  SUA
is an important part of our national defense aviation programs and it is
of course necessary that some airspace be set aside for high-performance
and other aircraft to practice what they do in combat and in the process
of supplying and supporting our troops.  At the same time, some regions
and states have traditionally carried more than their own weight in the
allocation of SUA.  Eastern NC happens to be among those regions.  There
is, thankfully, an appropriate process providing the average citizen
and/or aviator the opportunity to comment on the effects and viability
of new proposed SUA prior to its implementation and use.   
 
The proposed Gunny and Core MOAs are to be established across and North
of the Pamlico River and along the Core Banks between Cape Lookout and
Ocracoke I.  In my opinion, it warrants your concern.  If you foresee
this proposed airspace affecting you or your flight operations in the
region, please comment to FAA at:  
 
Federal Aviation Administration
Mr.Mark Ward
Manager, Operations Branch ASO-530.8
PO Box 20636
Atlanta, GA 30320
 
You should refer to North Carolina MOA Proposal NC-04-ASO-006-NR.
 
The formal comment period ran September 30, but FAA's Southern Region
has assured us that they will be accepting them "as long as there are
comments coming in".  If you would like more data on the proposal, our
material is at www.aopa.org/whatsnew/newsitems/2004/041012nc.html
<http://www.aopa.org/whatsnew/newsitems/2004/041012nc.html> .  Also
please note the attached copy of AOPA's comments on this proposal.  
 
AOPA's concerns fall in several areas:
 
1) FAA failed to notify AOPA and pilots of this proposal via Fed
Register publication or mail.  AOPA and other alphabet groups got word
of the plan only through users who provided feedback as to their
concerns.    
 
2) Radically increasing the SUA above 3000' as proposed would compress
civil traffic into the airspace (below 3000') in which 98.4% of known
aircraft birdstrikes occur;
 
2)  The Core MOA as drawn would require extended operations below 3000'
IF the pilot wished to avoid the airspace while simultaneously
maintaining 2000' or greater as recommended over the Cape Lookout
National Seashore, compressing much of the N/S Outer Banks traffic into
a 1000' stratum;
 
3)  The Gunny MOA (formerly called "Mattamuskeet") would create similar
compression, overlying significant national wildlife area acreage and
forcing traffic avoiding the SUA floor at 3000' into the narrow band
between 2000' and 3000'.  It would further cause pilots to fly overwater
for extended periods to operate east- or westbound under that 3000'
floor.    
 
4)  Radar coverage for flights in this region below 4000' has been
abysmal for years, and Navy and Air Force management have known this; it
is into that airspace stratum that traffic seeking to avoid the airspace
would be funneled, increasing the chances of traffic conflicts and
collisions.  If such new airspace WERE implemented, the using entities
should be required to fund the cost of new radar equipment and the
ongoing ATC and maintenance staffing needed to operate it.
 
5)   The economic and cumulative impact of the new airspace would add
unnecessary burden to a region which has accepted more than its share of
SUA over many years.  Multiple airports and their communities would
experience a drop in GA transient traffic and the corollary negative
financial impact as more pilots made the conscious decision to bypass
the military-use airspace.   
 
If there are questions on the issue, please advise by email and I will
be happy to try and answer or point you to someone better able to do so.

 
With thanks for your strong support for general aviation in this region
and kindest regards,
 
Chris Hudson
Mid-Atlantic Regional Representative
Aircraft Owners & Pilots Association
PO Box 33877
Charlotte, NC 28233-3877
(704)338-9161
Fax  376-0455
chris.hudson@xxxxxxxx <mailto:chris.hudson@xxxxxxxx> 


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