EAA 's E-GRAM: More Proposed Airspace Restrictions(long but important)
Question:
I think this is worth posting here. Please read it and respond to the FAA. Note: This is an official EAA correspondence. Your email address has been hidden so that others may not obtain it without your permission. IMPORTANT NOTICE FROM THE EAA GOVERNMENT OFFICE EAA headquarters needs your help with an important Airspace issue. This proposal, if accepted, will set a precedent making it easier for the government to ban general aviation traffic over all national parks. The current proposal deals with banning general aviation aircraft from overflying Grand Canyon National Park. This proposal, if accepted, will set a dangerous precedent for the government to more easily ban general aviation traffic over all national parks. It is important that we take a stand against this proposal. EAA will be filling comments, however the Department of Transportation needs to hear many voices. Your action can stop this ban. You can help by simply composing your own email message from the information below and sending it to the DOT. Action must be taken by September 7, 1999. Given the short period for your comment, it is fortunate that the U.S. Department of Transportation is allowing comments to be received via e-mail. EAA recommends using e-mail, if possible, to speed a response to the proper agencies. When responding to any proposal from the FAA or any government agency it is important that you compose your own message. Simply forwarding this message or if your message is an exact copy, it will not be considered by the DOT. Adding simple changes, however, such as a personalized opening paragraph with information on your occupation, what pilot credentials you hold, how long you have been flying, if you visit national parks and similar information will count your letter as a separate response. You may also consider copying any correspondence to your US Senators or Congressman’s office. Their e-mail address can be obtained at http://www.com/hpi/us50/index.html The full text of the proposal is available on the web at http://www.access.gpo.gov/su_docs/aces/aces140.html "click" proposed rules enter search on 07/09/99 then search the federal register for "page 37295" Thank you for being an EAA member and for taking the time to review this issue. Regardless of where you live, an airspace rule in one area sets a precedent that may affect your area in the future. It’s important that you take action. Earl Lawrence Executive Director EAA Government Programs Note: If your response is sent as an attachment the FAA uses Microsoft Word. or Mail your response to: U.S. Department of Transportation Dockets Docket No. FAA-99-5926 400 Seventh Street, SW. Washington DC, 20590 the Grand Canyon National Park Special Rules Area and Free Flight Zones Here are some of the issues EAA believes are important to the discussion: * Extending Special Rules Area and Flight-Free Zones outside of the current scope sets a dangerous precedent. The National Park Service may then use mitigation agreements to "give away" federally protected airspace anywhere in the country. * An attempt to raise the upper limit of the park’s Special Rules Area from 14,500 feet MSL to 18,000 feet MSL is proposed with no evidence that any noise impact exists. * The proposed southeastern border of the Special Rules Area would effectively eliminate all eastbound VFR routes and create a safety hazard with an adjoining military operations area. * The expanded northern and western boundaries of the Special Rules Area are unnecessary, as no evidence of noise issues has been presented. * The two established VFR transition corridors for use by general aviation pilots flying through the area should be maintained. In addition, non-commercial general aviation aircraft should be allowed to overfly the proposed Flight Free Zones at altitudes above 10,499 feet MSL. . Read on for an expanded version of EAA’s comments to the DOT. Below is a listing, in order, of EAA’s priorities for which we need to fight for. They are all important but if you have limited space, pick and choose starting at No. 1 Recommended Introduction Insert your own first paragraph stating personalized opinions with information on your occupation, what pilot credentials you hold, how long you have been flying, if you visit national parks and similar information. The following comments are filed in response to the Modification of the Dimensions of the Grand Canyon National Park (GCNP) Special Flight Rules Area (SFRA) and Free Flight Zones (FFZ). My objections to the proposed expanded SFRA and FFZ’s in the GCNP center on the following: I am concerned that the Federal Aviation Administration (FAA) and the National Park Service (NPS) have made no effort to determine the effect, if any, general aviation is having on the GCNP and it’s neighbors. The noise impact from commercial air tours is the only aviation activity addressed in this study. The FAA and the NPS have failed to present any evidence that indicated the need to restrict general aviation aircraft from flying in the vicinity of or over the GCNP. There is no evidence that general aviation has contributed to the loss of natural quiet within the GCNP. Therefore, I feel it is irresponsible for any government agency, especially the FAA, to restrict free passage of general aviation aircraft within the National Airspace System without showing due cause for such a restriction. Neither the National Park Service nor the Federal Aviation Administration has shown just cause for effectively banning general aviation from overflying the park. I propose the following changes to the proposed rule: EAA’s highest priority issue is: (delete this when you write your letter) 93.305 Flight-free Zones and Flight Corridors. Desert View Flight Free Zone I strongly oppose extending the Desert View FFZ outside the boundaries of the GCNP solely for the purpose of reaching a mitigation agreement with the Traditional Cultural Properties (TCP). Reason: The purpose of Public Law 100-91 is to provide a means to restore the natural quiet within the GCNP. It was not intended to be used as a bargaining tool by the NPS in reaching agreements with it neighbors. I strongly disagree with the FAA and the NPS in extending this mandate as a leveraging tool to meet mitigation agreements concerning impacts on TCP. Extending the SFRA and the FFZ’s outside of the intended scope of the 1987 Public Law 100-91 (e.g., outside the GCNP) sets a very dangerous precedent. Will future NPS mitigation agreements (USA wide) involve giving special airspace protection to any Federal, Public, or Private group? Once set, this NPS precedent of rewarding mitigation agreement signers with Federally protected airspace could have a devastating effect on the NAS. EAA’s second highest priority issue is: (delete this when you write your letter) 93.301 Applicability Reduce the proposed ceiling of the airspace from "up to but not including 18,000 feet MSL," to "up to but not including 14,500 feet MSL." Reason: It appears the FAA and the NPS are attempting to circumnavigate all the public and inter-agency agreements made during the 1996 GCNP SFRA public and congressional meetings. In 1996, the FAA and the NPS proposed the upper limit of the GCNP SFRA be increased from 14,500′ MSL to "up to but not including 18,000′ MSL". Public and Congressional meetings determined the requested increase placed an unnecessary burden on the public and per agreement, the upper altitude was left unchanged at 14,500′ MSL. In the 1999 Federal Register document, the FAA and the NPS are again trying to raise the upper limit to "up to but not including 18,000′ MSL." As in 1996, not one shred of evidence has been presented to justify the increase in altitude. Further, the environmental assessment did not address the noise impact, if any, of aircraft operating at these altitudes above the park. The upper limit of the GCNP SFRA needs to remain 14,500′ MSL. EAA’s third highest priority issue is: (delete this when you write your letter) 93.301 Applicability I recommend the following adjustment to the Southeastern border of the GCNP SFRA: Lat. 35*57′00" N., Long. 112*03′30" W.; East to Lat. 36*00′24" N., Long. 111*39′34" W.; North to Lat. 36*12′35" N., Long. 111*39′33" W.; Northwest to Lat. 36*24′49" N., Long. 111*47′45" W. Reason: The proposed Southeastern border of the GCNP SFRA, Southern point of Lat. 35*55′38" N., Long. 111*36′03" W., effectively eliminates all Eastern VFR routes around the GCNP. By placing this point one nautical mile (nm) from the Sunny Military Operations Area (MOA) border, the proposal effectively places a road block in the sky, making it impossible to fly from any airport South or West of the GCNP to Tuba City Airport (T03) or any points to the East or Northeast. If adopted, this roadblock will force VFR pilots to deviate up to 300 nm in order to fly around the GCNP to the West and North. This action will result in a greater environmental impact (fuel burned, aircraft noise) to those areas under these newly forced VFR flight routes. The Sunny MOA is a very active military jet fighter training area used by F16, F15, and F18 aircraft for basic fighter maneuver (BFM) training, fighter intercept training, fighter transition training and fighter formation flight training. With these fighters operating at a maximum airspeed just short of the speed of sound, no reasonable VFR pilot flying a small aircraft will enter the Sunny MOA hoping that they will be able to "see and avoid" these fighters in time to avoid a mid-air collision. Thus it is not reasonable for the FAA and the NPS to force slow flying VFR pilots into this "hornets" nest.
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Response:
I think this is worth posting here. Please read it and respond to the FAA.
thanks for posting this latest airspace grab. It cheeses me off, as I enjoy outdoor recreation but would like to know how in hell it’s supposed to be enhanced by this retarded proposal. Forcing traffic up into the Class A? Sorry, fellow hikers, but the airplane is not going to be appreciably quieter if it’s a half mile higher anyway. …also, pushing traffic laterally into the MOA is going to have the OTHER unintended consequence of degrading the value of the MOA for the military, and in the long run freezing THEM out too. ‘You can’t train because the civil airliners are here now. They have to fly here now because a bunch of lobbyists who live in the filth and din of Washington and New York want to see peace and quiet in the Park when they see a documentary about it on PBS.’ The amazing thing is that these Luddites who push for this kind of thing are the same ones that stumble through the parks in noisy crowds of thirty or more, throwing stuff everywhere. You could get rich off teh recycling of the plastic water bottles they leave behind. Frankly I’d rather have the drone of an aero engine two miles overhead than have to listen to a gaggle of ill-bred collegiates shouting at each other. With every second word beginning with ‘F’ – not because they have mastered the intricacies of profanity -usage, but rather because their vocabulary is otherwise impoverished. Wilderness policy is being made by couch potatos whose entire worldview is formed by the greatest of all barren wildernesses — television. Christ help us. cheers -=K=-
