AOPA Sells-Out California Pilots in Military Airspace Grab?

[Larry Dighera]

Another attempted military airspace grab?

The USMC wants to convert the San Onofre High and Low MOAs, that lie
along the busy, aircraft-congested Pacific coastline, into a
Restricted Area: R-2503D. The USMC say they need 38% higher
Restricted Airspace to conduct live-fire artillery and aerial drone
operations that would pose a mortal danger to civil air commerce
flights along the coastline between 2,000 feet and 11,000 feet.

This proposed amendment would convert the San Onofre High and Low
MOAs (and the associated CFA) into Restricted Area R–2503D, which
would extend from 2,000 feet MSL up to 11,000 feet MSL, or 38% (3,000
feet) higher than the existing San Onofre MOAs it would replace.

Despite the fact that the military were originally denied the
exclusive airspace use provided by a restricted area that INCLUDES
VICTOR AIRWAYS, they are again requesting it. But this time they want
to include remotely operated aircraft INCAPABLE OF COMPLYING WITH
SEE-AND-AVOID REGULATIONS, and significantly increase its height above
the existing 8,000 foot MOA. (What is curious is how the live
artillery fire and drones will not affect air commerce below 2,000
feet.)

If this NPRM were adopted, the Oceanside VOR-A Approach, Carlsbad
(McClellan-Palomar) ILS Rwy 24 and VOR GPS-A approaches, the holding
function of Oceanside VORTAC (OCN), V-23 and V-208 would all be
negatively impacted.

Although R–2503D would be limited to a maximum use of 20 days per year
from 0600 to 2400 hours local time, and no more than 90 days per year
between 0001 and 0600 local time, during those times (up to 110-days
annually) (the way the NPRM is currently worded) civil aircraft would
be banned from use of Victor Airways V-23 and V-208 below 11,000 feet,
the Oceanside VOR-A Approach, and the holding function of Oceanside
VORTAC, thus negatively impacting air commerce.

The USMC has requested these changes because the existing special use
airspace does not permit essential large-scale amphibious assault
activities (including artillery live-fire, fixed-wing close air
support, and remotely operated aircraft operations).


AOPA supports this military airspace grab!:

http://www.aopa.org/whatsnew/newsitems/2004/04-1-161x.html
AOPA is backing the creation of one restricted area in California
and the modification of another in Georgia because, in each case,
the result would actually improve general aviation operations
around military training areas.

Near Camp Pendleton in southern California, close cooperation
between the U.S. Marine Corps, the Southern California Airspace
Working Group (of which AOPA is part), and local pilots, a new
restricted area proposed on Friday may actually ease operations
along the coastline.

"From the outset, the Marine Corps sought out the general aviation
community and worked with us to minimize the impact of their
proposal," said AOPA Manager of Air Traffic Heidi Williams. "As a
result, we've got a proposal that will let the Marines train they
way they fight while allowing GA pilots to use adjacent Victor
airways."

The Marines want to replace the San Onofre High and Low military
operations areas with a new restricted area, R-2503D, which will
directly overly R-2503A, extending up to 11,000 feet, and would
include a number of mitigation efforts.


I am unable to find any language from AOPA nor FAA that supports the
contention, that this new Restricted Area will permit civil flights to
use the Oceanside VOR-A Approach, Carlsbad (McClellan-Palomar) ILS Rwy
24 and VOR GPS-A approaches, the holding function of Oceanside VORTAC
(OCN), V-23 and V-208 when the proposed Restricted Area R-2503D is
"hot." Did AOPA and the FAA fail to disclose an explanation of their
mitigation efforts, or did I miss something?


The comment period for the notice of proposed rule making (NPRM)
closes on May 10, 2004.

Voice your comments to the FAA here: http://dmses.dot.gov/submit/

----------------------------------------------------------
Here's the NPRM:

http://dmses.dot.gov/docimages/p78/274726.pdf
http://dmses.dot.gov/docimages/pdf89/274726_web.pdf
Federal Register / Vol. 69, No. 59 /
Friday, March 26, 2004 / Proposed Rules

DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration
14 CFR Part 73
[Docket No. FAA–2003–16722; Airspace
Docket No. 03–AWP–19]
RIN 2120–AA66
Establishment of Restricted Area
2503D, Camp Pendleton; CA
ACTION: Notice of proposed rulemaking
(NPRM).
SUMMARY: This action proposes to
establish a restricted area (R–2503D)
over Camp Pendleton, CA. Specifically,
this action proposes to convert the
current San Onofre High and Low
Military Operations Areas (MOA) and
the associated Controlled Firing Area
(CFA) to R–2503D. The FAA is taking
this action to assist the Camp Pendleton
U.S. Marine Corps (USMC) Base, CA,
mission of providing realistic fleet
training requirements and to enhance
safety.
DATES: Comments must be received on
or before May 10, 2004.
ADDRESSES: Send comments on this
proposal to the Docket Management
System, U.S. Department of
Transportation, Room Plaza 401, 400
Seventh Street, SW., Washington, DC
20590–0001. You must identify FAA
Docket No. FAA–2003–16722, and
Airspace Docket No. 03–AWP–19, at the
beginning of your comments. You may
also submit comments on the Internet at
http://dms.dot.gov.
http://dmses.dot.gov/submit/

FOR FURTHER INFORMATION CONTACT: Ken
McElroy, Airspace and Rules, Office of
System Operations and Safety, ATOP–R,
Federal Aviation Administration, 800
03–AWP–19) and be submitted in
triplicate to the Docket Management
System (see ADDRESSES section for
address and phone number). You may
also submit comments through the
Internet at http://dms.dot.gov.
Commenters wishing the FAA to
acknowledge receipt of their comments
on this action must submit with those
comments a self-addressed, stamped
postcard on which the following
statement is made: ‘‘Comments to FAA
Docket No. FAA–2003–16722, and
Airspace Docket No. 03–AWP–19.’’ The
postcard will be date/time stamped and
returned to the commenter.
All communications received on or
before the specified closing date for
comments will be considered before
taking action on the proposed rule. The
proposal contained in this action may
be changed in light of comments
received. All comments submitted will
be available for examination in the
public docket both before and after the
closing date for comments. A report
summarizing each substantive public
contact with FAA personnel concerned
with this rulemaking will be filed in the
docket.
Availability of NPRM’s
An electronic copy of this document
may be downloaded through the
Internet at http://dms.dot.gov. Recently
published rulemaking documents can
also be accessed through the FAA’s Web
page at http://www.faa.gov, or the
Federal Register’s Web page at http://
www.gpoaccess.gov/fr/index.html.
You may review the public docket
containing the proposal, any comments
received and any final disposition in
person in the Dockets Office (see
ADDRESSES section for address and
phone number) between 9 a.m. and 5
p.m., Monday through Friday, except
Federal holidays. An informal docket
may also be examined during normal
business hours at the office of the
Regional Air Traffic Division, AWP–
520, 15000 Aviation Boulevard,
Lawndale, CA 90261.
Persons interested in being placed on
a mailing list for future NPRM’s should
contact the FAA’s Office of Rulemaking,
(202) 267–9677, for a copy of Advisory
Circular No. 11–2A, Notice of Proposed
Rulemaking Distribution System, which
describes the application procedure.
The Proposal
The FAA is proposing an amendment
to Title 14 Code of Federal Regulations
(14 CFR) part 73 (part 73) to revise and
expand the dimensions of the current
San Onofre MOAs over the Camp
Pendleton, CA, area. The USMC has
requested these changes because the
existing special use airspace does not
permit essential large-scale amphibious
assault activities (including artillery
live-fire, fixed-wing close air support,
and remotely operated aircraft
operations).
The existing restricted areas over
Camp Pendleton are R–2503A,
extending from the surface up to 2000
feet mean sea level (MSL); R–2503B,
extending from the surface up to 15,000
feet MSL; and R–2503C, extending from
15,000 feet MSL to FL 270. These areas
will not be changed. The San Onofre
High and Low MOAs lie adjacent to the
restricted areas from 2,000 feet MSL up
to, but not including 8,000 feet MSL.
This proposed amendment would
convert the San Onofre High and Low
MOAs, and the associated CFA to R–
2503D, which would extend from 2,000
feet MSL up to 11,000 feet MSL. The
San Onofre MOA and CFA designations
would be revoked.
The time of designation for R–2503D
would be intermittent by NOTAM 24
hours in advance, and limited to a
maximum use of 20 days per year from
0600 to 2400 hours local time, and no
more than 90 days per year between
0001 and 0600 local time. The restricted
area would be available for joint-use and
scheduled for training operations on an
as needed basis subject to the maximum
use limits.
The FAA has determined that this
proposed regulation only involves an
established body of technical
regulations for which frequent and
routine amendments are necessary to
keep them operationally current.
Therefore, this proposed regulation: (1)
Is not a ‘‘significant regulatory action’’
under Executive Order 12866; (2) is not
a ‘‘significant rule’’ under DOT
Regulatory Policies and Procedures (44
FR 11034; February 26, 1979); and (3)
does not warrant preparation of a
regulatory evaluation as the anticipated
impact is so minimal. Since this is a
routine matter that will only affect air
traffic procedures and air navigation, it
is certified that this rule, when
promulgated, will not have a significant
economic impact on a substantial
number of small entities under the
criteria of the Regulatory Flexibility Act.
Environmental Review
This proposal will be subject to the
appropriate environmental analysis in
accordance with FAA Order 1050.1D,
Policies and Procedures for Considering
Environmental Impacts, prior to any
FAA final regulatory action.
List of Subjects in 14 CFR Part 73
Airspace, Navigation (air).
The Proposed Amendment
In consideration of the foregoing, the
Federal Aviation Administration
proposes to amend 14 CFR part 73 as
follows:
PART 73—SPECIAL USE AIRSPACE
1. The authority citation for part 73
continues to read as follows:
Authority: 49 U.S.C. 106(g), 40103, 40113,
40120; E.O. 10854, 24 FR 9565, 3 CFR, 1959–
1963 Comp., p. 389.
§ 73.25 [Amended]
2. § 73.25 is amended as follows:
* * * * *
R–2503D Camp Pendleton, CA [Added]
Boundaries. Beginning at lat. 33°22'42? N.;
long. 117°36'45? W.; to lat. 33°27'13? N.;
long. 117°34'17? W.; to lat. 33°18'41? N.;
long. 117°23'58? W.; to lat. 33°17'30? N.;
long. 117°16'43? W.; to lat. 33°14'09?N.;
long. 117°26'38? W.; to the point of the
beginning by following a line 1 NM from
and parallel to the shoreline.
Designated altitudes. 2,000 feet MSL to
11,000 feet MSL.
Time of designation. Intermittent by
NOTAM 24 hours in advance not to exceed
20 days per year from 0600 to 2400 local time
and not more than 90 days per year between
0001 and 0600 local.
Controlling agency. FAA, Southern
California TRACON.
Using agency. U.S. Marine Corps,
Commanding General, MCB Camp Pendleton,
CA.
* * * * *
Issued in Washington, DC, March 18, 2004.
Reginald C. Matthews,
Manager, Airspace and Rules.
[FR Doc. 04–6747 Filed 3–25–04; 8:45 am]
BILLING CODE 4910–13–P


* notice of proposed rulemaking:
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=44f9e0eeb3fb1b21f69a155444303098&rgn=div5&view=text&node=14:1.0.1.2.2&idno=14

[Aloft]

20 days a year/90 nights a year is not what I'd call an airspace "grab",
more like an improvement in safety for those few times a year when the
Marines want to do a full dress rehearsal.

Do you fly around that area much? If you did, you'd know what a hazard is
created whenever the Marines conduct a full-scale exercise, as they did this
last weekend. Despite NOTAMs and flyers on FBO bulletin boards, idiots
still continue to blunder into those hot areas, threatening not only their
own lives, but the lives of the military aircrews operating there. You know
the type I'm talking about; the 60-something pilot who's flown that
coastline a thousand times so he doesn't own a current terminal chart, never
bothers to check NOTAMs, doesn't feel comfortable talking to SoCal so he
doesn't, never bothers to check FBO bulletin boards, etc, etc. Basically
your airborne Sunday driver. Now, I'm sure you're saying, "well, that type
of pilot won't even know about the restricted area". He'll find out when
ATC asks him to jot down a telephone number.

And by-the-by, R-2503A already encompasses the airspace in question from the
surface to 2000 ft.

[[email protected]]

You're going to have a difficult time in these times to deny the Marine Corps what they need at Pendleton.

Without assessing the instrument approach procedures you cite, I can only speculate that they would be unaffected because that part of
Pendleton is all housing and other buildings, thus, their operations don't extend that far south.

As to the KCRQ ILS it would have minimal impact because no one ever uses the transition from OCN VOR except perhaps an occasional practice
flight, and those are often refused because of conflict with the normal flow onto the ILS.

Larry Dighera wrote:

> Another attempted military airspace grab?
>
> The USMC wants to convert the San Onofre High and Low MOAs, that lie
> along the busy, aircraft-congested Pacific coastline, into a
> Restricted Area: R-2503D. The USMC say they need 38% higher
> Restricted Airspace to conduct live-fire artillery and aerial drone
> operations that would pose a mortal danger to civil air commerce
> flights along the coastline between 2,000 feet and 11,000 feet.
>
> This proposed amendment would convert the San Onofre High and Low
> MOAs (and the associated CFA) into Restricted Area R–2503D, which
> would extend from 2,000 feet MSL up to 11,000 feet MSL, or 38% (3,000
> feet) higher than the existing San Onofre MOAs it would replace.
>
> Despite the fact that the military were originally denied the
> exclusive airspace use provided by a restricted area that INCLUDES
> VICTOR AIRWAYS, they are again requesting it. But this time they want
> to include remotely operated aircraft INCAPABLE OF COMPLYING WITH
> SEE-AND-AVOID REGULATIONS, and significantly increase its height above
> the existing 8,000 foot MOA. (What is curious is how the live
> artillery fire and drones will not affect air commerce below 2,000
> feet.)
>
> If this NPRM were adopted, the Oceanside VOR-A Approach, Carlsbad
> (McClellan-Palomar) ILS Rwy 24 and VOR GPS-A approaches, the holding
> function of Oceanside VORTAC (OCN), V-23 and V-208 would all be
> negatively impacted.
>
> Although R–2503D would be limited to a maximum use of 20 days per year
> from 0600 to 2400 hours local time, and no more than 90 days per year
> between 0001 and 0600 local time, during those times (up to 110-days
> annually) (the way the NPRM is currently worded) civil aircraft would
> be banned from use of Victor Airways V-23 and V-208 below 11,000 feet,
> the Oceanside VOR-A Approach, and the holding function of Oceanside
> VORTAC, thus negatively impacting air commerce.
>
> The USMC has requested these changes because the existing special use
> airspace does not permit essential large-scale amphibious assault
> activities (including artillery live-fire, fixed-wing close air
> support, and remotely operated aircraft operations).
>
> AOPA supports this military airspace grab!:
>
> http://www.aopa.org/whatsnew/newsitems/2004/04-1-161x.html
> AOPA is backing the creation of one restricted area in California
> and the modification of another in Georgia because, in each case,
> the result would actually improve general aviation operations
> around military training areas.
>
> Near Camp Pendleton in southern California, close cooperation
> between the U.S. Marine Corps, the Southern California Airspace
> Working Group (of which AOPA is part), and local pilots, a new
> restricted area proposed on Friday may actually ease operations
> along the coastline.
>
> "From the outset, the Marine Corps sought out the general aviation
> community and worked with us to minimize the impact of their
> proposal," said AOPA Manager of Air Traffic Heidi Williams. "As a
> result, we've got a proposal that will let the Marines train they
> way they fight while allowing GA pilots to use adjacent Victor
> airways."
>
> The Marines want to replace the San Onofre High and Low military
> operations areas with a new restricted area, R-2503D, which will
> directly overly R-2503A, extending up to 11,000 feet, and would
> include a number of mitigation efforts.
>
>
> I am unable to find any language from AOPA nor FAA that supports the
> contention, that this new Restricted Area will permit civil flights to
> use the Oceanside VOR-A Approach, Carlsbad (McClellan-Palomar) ILS Rwy
> 24 and VOR GPS-A approaches, the holding function of Oceanside VORTAC
> (OCN), V-23 and V-208 when the proposed Restricted Area R-2503D is
> "hot." Did AOPA and the FAA fail to disclose an explanation of their
> mitigation efforts, or did I miss something?
>
> The comment period for the notice of proposed rule making (NPRM)
> closes on May 10, 2004.
>
> Voice your comments to the FAA here: http://dmses.dot.gov/submit/
>
> ----------------------------------------------------------
> Here's the NPRM:
>
> http://dmses.dot.gov/docimages/p78/274726.pdf
> http://dmses.dot.gov/docimages/pdf89/274726_web.pdf
> Federal Register / Vol. 69, No. 59 /
> Friday, March 26, 2004 / Proposed Rules
>
> DEPARTMENT OF TRANSPORTATION
> Federal Aviation Administration
> 14 CFR Part 73
> [Docket No. FAA–2003–16722; Airspace
> Docket No. 03–AWP–19]
> RIN 2120–AA66
> Establishment of Restricted Area
> 2503D, Camp Pendleton; CA
> ACTION: Notice of proposed rulemaking
> (NPRM).
> SUMMARY: This action proposes to
> establish a restricted area (R–2503D)
> over Camp Pendleton, CA. Specifically,
> this action proposes to convert the
> current San Onofre High and Low
> Military Operations Areas (MOA) and
> the associated Controlled Firing Area
> (CFA) to R–2503D. The FAA is taking
> this action to assist the Camp Pendleton
> U.S. Marine Corps (USMC) Base, CA,
> mission of providing realistic fleet
> training requirements and to enhance
> safety.
> DATES: Comments must be received on
> or before May 10, 2004.
> ADDRESSES: Send comments on this
> proposal to the Docket Management
> System, U.S. Department of
> Transportation, Room Plaza 401, 400
> Seventh Street, SW., Washington, DC
> 20590–0001. You must identify FAA
> Docket No. FAA–2003–16722, and
> Airspace Docket No. 03–AWP–19, at the
> beginning of your comments. You may
> also submit comments on the Internet at
> http://dms.dot.gov.
> http://dmses.dot.gov/submit/
>
> FOR FURTHER INFORMATION CONTACT: Ken
> McElroy, Airspace and Rules, Office of
> System Operations and Safety, ATOP–R,
> Federal Aviation Administration, 800
> 03–AWP–19) and be submitted in
> triplicate to the Docket Management
> System (see ADDRESSES section for
> address and phone number). You may
> also submit comments through the
> Internet at http://dms.dot.gov.
> Commenters wishing the FAA to
> acknowledge receipt of their comments
> on this action must submit with those
> comments a self-addressed, stamped
> postcard on which the following
> statement is made: ‘‘Comments to FAA
> Docket No. FAA–2003–16722, and
> Airspace Docket No. 03–AWP–19.’’ The
> postcard will be date/time stamped and
> returned to the commenter.
> All communications received on or
> before the specified closing date for
> comments will be considered before
> taking action on the proposed rule. The
> proposal contained in this action may
> be changed in light of comments
> received. All comments submitted will
> be available for examination in the
> public docket both before and after the
> closing date for comments. A report
> summarizing each substantive public
> contact with FAA personnel concerned
> with this rulemaking will be filed in the
> docket.
> Availability of NPRM’s
> An electronic copy of this document
> may be downloaded through the
> Internet at http://dms.dot.gov. Recently
> published rulemaking documents can
> also be accessed through the FAA’s Web
> page at http://www.faa.gov, or the
> Federal Register’s Web page at http://
> www.gpoaccess.gov/fr/index.html.
> You may review the public docket
> containing the proposal, any comments
> received and any final disposition in
> person in the Dockets Office (see
> ADDRESSES section for address and
> phone number) between 9 a.m. and 5
> p.m., Monday through Friday, except
> Federal holidays. An informal docket
> may also be examined during normal
> business hours at the office of the
> Regional Air Traffic Division, AWP–
> 520, 15000 Aviation Boulevard,
> Lawndale, CA 90261.
> Persons interested in being placed on
> a mailing list for future NPRM’s should
> contact the FAA’s Office of Rulemaking,
> (202) 267–9677, for a copy of Advisory
> Circular No. 11–2A, Notice of Proposed
> Rulemaking Distribution System, which
> describes the application procedure.
> The Proposal
> The FAA is proposing an amendment
> to Title 14 Code of Federal Regulations
> (14 CFR) part 73 (part 73) to revise and
> expand the dimensions of the current
> San Onofre MOAs over the Camp
> Pendleton, CA, area. The USMC has
> requested these changes because the
> existing special use airspace does not
> permit essential large-scale amphibious
> assault activities (including artillery
> live-fire, fixed-wing close air support,
> and remotely operated aircraft
> operations).
> The existing restricted areas over
> Camp Pendleton are R–2503A,
> extending from the surface up to 2000
> feet mean sea level (MSL); R–2503B,
> extending from the surface up to 15,000
> feet MSL; and R–2503C, extending from
> 15,000 feet MSL to FL 270. These areas
> will not be changed. The San Onofre
> High and Low MOAs lie adjacent to the
> restricted areas from 2,000 feet MSL up
> to, but not including 8,000 feet MSL.
> This proposed amendment would
> convert the San Onofre High and Low
> MOAs, and the associated CFA to R–
> 2503D, which would extend from 2,000
> feet MSL up to 11,000 feet MSL. The
> San Onofre MOA and CFA designations
> would be revoked.
> The time of designation for R–2503D
> would be intermittent by NOTAM 24
> hours in advance, and limited to a
> maximum use of 20 days per year from
> 0600 to 2400 hours local time, and no
> more than 90 days per year between
> 0001 and 0600 local time. The restricted
> area would be available for joint-use and
> scheduled for training operations on an
> as needed basis subject to the maximum
> use limits.
> The FAA has determined that this
> proposed regulation only involves an
> established body of technical
> regulations for which frequent and
> routine amendments are necessary to
> keep them operationally current.
> Therefore, this proposed regulation: (1)
> Is not a ‘‘significant regulatory action’’
> under Executive Order 12866; (2) is not
> a ‘‘significant rule’’ under DOT
> Regulatory Policies and Procedures (44
> FR 11034; February 26, 1979); and (3)
> does not warrant preparation of a
> regulatory evaluation as the anticipated
> impact is so minimal. Since this is a
> routine matter that will only affect air
> traffic procedures and air navigation, it
> is certified that this rule, when
> promulgated, will not have a significant
> economic impact on a substantial
> number of small entities under the
> criteria of the Regulatory Flexibility Act.
> Environmental Review
> This proposal will be subject to the
> appropriate environmental analysis in
> accordance with FAA Order 1050.1D,
> Policies and Procedures for Considering
> Environmental Impacts, prior to any
> FAA final regulatory action.
> List of Subjects in 14 CFR Part 73
> Airspace, Navigation (air).
> The Proposed Amendment
> In consideration of the foregoing, the
> Federal Aviation Administration
> proposes to amend 14 CFR part 73 as
> follows:
> PART 73—SPECIAL USE AIRSPACE
> 1. The authority citation for part 73
> continues to read as follows:
> Authority: 49 U.S.C. 106(g), 40103, 40113,
> 40120; E.O. 10854, 24 FR 9565, 3 CFR, 1959–
> 1963 Comp., p. 389.
> § 73.25 [Amended]
> 2. § 73.25 is amended as follows:
> * * * * *
> R–2503D Camp Pendleton, CA [Added]
> Boundaries. Beginning at lat. 33°22'42? N.;
> long. 117°36'45? W.; to lat. 33°27'13? N.;
> long. 117°34'17? W.; to lat. 33°18'41? N.;
> long. 117°23'58? W.; to lat. 33°17'30? N.;
> long. 117°16'43? W.; to lat. 33°14'09?N.;
> long. 117°26'38? W.; to the point of the
> beginning by following a line 1 NM from
> and parallel to the shoreline.
> Designated altitudes. 2,000 feet MSL to
> 11,000 feet MSL.
> Time of designation. Intermittent by
> NOTAM 24 hours in advance not to exceed
> 20 days per year from 0600 to 2400 local time
> and not more than 90 days per year between
> 0001 and 0600 local.
> Controlling agency. FAA, Southern
> California TRACON.
> Using agency. U.S. Marine Corps,
> Commanding General, MCB Camp Pendleton,
> CA.
> * * * * *
> Issued in Washington, DC, March 18, 2004.
> Reginald C. Matthews,
> Manager, Airspace and Rules.
> [FR Doc. 04–6747 Filed 3–25–04; 8:45 am]
> BILLING CODE 4910–13–P
>
> * notice of proposed rulemaking:
> http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=44f9e0eeb3fb1b21f69a155444303098&rgn=div5&view=text&node=14:1.0.1.2.2&idno=14

[Dave Butler]

Aloft wrote:
> 20 days a year/90 nights a year is not what I'd call an airspace "grab",
> more like an improvement in safety for those few times a year when the
> Marines want to do a full dress rehearsal.
>
> Do you fly around that area much? If you did, you'd know what a hazard is
> created whenever the Marines conduct a full-scale exercise, as they did this
> last weekend. Despite NOTAMs and flyers on FBO bulletin boards, idiots
> still continue to blunder into those hot areas, threatening not only their
> own lives, but the lives of the military aircrews operating there. You know
> the type I'm talking about; the 60-something pilot who's flown that

What does the age of the pilot have to do with it?

> coastline a thousand times so he doesn't own a current terminal chart, never
> bothers to check NOTAMs, doesn't feel comfortable talking to SoCal so he
> doesn't, never bothers to check FBO bulletin boards, etc, etc. Basically
> your airborne Sunday driver. Now, I'm sure you're saying, "well, that type
> of pilot won't even know about the restricted area". He'll find out when
> ATC asks him to jot down a telephone number.
>
> And by-the-by, R-2503A already encompasses the airspace in question from the
> surface to 2000 ft.

[[email protected]]

Aloft wrote:

> 20 days a year/90 nights a year is not what I'd call an airspace "grab",
> more like an improvement in safety for those few times a year when the
> Marines want to do a full dress rehearsal.

Agreed.

>
>
> Do you fly around that area much? If you did, you'd know what a hazard is
> created whenever the Marines conduct a full-scale exercise, as they did this
> last weekend. Despite NOTAMs and flyers on FBO bulletin boards, idiots
> still continue to blunder into those hot areas, threatening not only their
> own lives, but the lives of the military aircrews operating there. You know
> the type I'm talking about; the 60-something pilot who's flown that
> coastline a thousand times so he doesn't own a current terminal chart, never
> bothers to check NOTAMs, doesn't feel comfortable talking to SoCal so he
> doesn't, never bothers to check FBO bulletin boards, etc, etc. Basically
> your airborne Sunday driver. Now, I'm sure you're saying, "well, that type
> of pilot won't even know about the restricted area". He'll find out when
> ATC asks him to jot down a telephone number.

I live just to the north of the restricted area. It is violated constantly.
Alas, no one enforces it. SoCal doesn't even track aircraft in that area that
are that low.

>
>
> And by-the-by, R-2503A already encompasses the airspace in question from the
> surface to 2000 ft.

Well, the MOA goes further out to sea than does the present restricted airspace.

Keep in mind, too, there is a nuclear power plant in this mix that makes a lot
of folks nervous.

[[email protected]]

>
> > You know
> > the type I'm talking about; the 60-something pilot who's flown that
>
> What does the age of the pilot have to do with it?

I took that to mean total time.

[Lee Elson]

wrote in message >...
> You're going to have a difficult time in these times to deny the Marine Corps what they need at Pendleton.
That's true of any military base anywhere. Should we just give up and
smile while they take away our airspace?
>
> Without assessing the instrument approach procedures you cite, I can only speculate that they would be unaffected because that part of
> Pendleton is all housing and other buildings, thus, their operations don't extend that far south.
>
> As to the KCRQ ILS it would have minimal impact because no one ever uses the transition from OCN VOR except perhaps an occasional practice
> flight, and those are often refused because of conflict with the normal flow onto the ILS.
Not true. Every (VFR or IMC) ILS I've done from the north has *always*
used the OCN VOR transition. I've never been "refused" this
transition.
>
> Larry Dighera wrote:
>
> > Another attempted military airspace grab?
> >
> > The USMC wants to convert the San Onofre High and Low MOAs, that lie
> > along the busy, aircraft-congested Pacific coastline, into a
> > Restricted Area: R-2503D. The USMC say they need 38% higher
> > Restricted Airspace to conduct live-fire artillery and aerial drone
> > operations that would pose a mortal danger to civil air commerce
> > flights along the coastline between 2,000 feet and 11,000 feet.
> >
> > This proposed amendment would convert the San Onofre High and Low
> > MOAs (and the associated CFA) into Restricted Area R?2503D, which
> > would extend from 2,000 feet MSL up to 11,000 feet MSL, or 38% (3,000
> > feet) higher than the existing San Onofre MOAs it would replace.
> >
> > Despite the fact that the military were originally denied the
> > exclusive airspace use provided by a restricted area that INCLUDES
> > VICTOR AIRWAYS, they are again requesting it. But this time they want
> > to include remotely operated aircraft INCAPABLE OF COMPLYING WITH
> > SEE-AND-AVOID REGULATIONS, and significantly increase its height above
> > the existing 8,000 foot MOA. (What is curious is how the live
> > artillery fire and drones will not affect air commerce below 2,000
> > feet.)
> >
> > If this NPRM were adopted, the Oceanside VOR-A Approach, Carlsbad
> > (McClellan-Palomar) ILS Rwy 24 and VOR GPS-A approaches, the holding
> > function of Oceanside VORTAC (OCN), V-23 and V-208 would all be
> > negatively impacted.
> >
> > Although R?2503D would be limited to a maximum use of 20 days per year
> > from 0600 to 2400 hours local time, and no more than 90 days per year
> > between 0001 and 0600 local time, during those times (up to 110-days
> > annually) (the way the NPRM is currently worded) civil aircraft would
> > be banned from use of Victor Airways V-23 and V-208 below 11,000 feet,
> > the Oceanside VOR-A Approach, and the holding function of Oceanside
> > VORTAC, thus negatively impacting air commerce.
> >
> > The USMC has requested these changes because the existing special use
> > airspace does not permit essential large-scale amphibious assault
> > activities (including artillery live-fire, fixed-wing close air
> > support, and remotely operated aircraft operations).
> >
> > AOPA supports this military airspace grab!:
> >
> > http://www.aopa.org/whatsnew/newsitems/2004/04-1-161x.html
> > AOPA is backing the creation of one restricted area in California
> > and the modification of another in Georgia because, in each case,
> > the result would actually improve general aviation operations
> > around military training areas.
> >
> > Near Camp Pendleton in southern California, close cooperation
> > between the U.S. Marine Corps, the Southern California Airspace
> > Working Group (of which AOPA is part), and local pilots, a new
> > restricted area proposed on Friday may actually ease operations
> > along the coastline.
> >
> > "From the outset, the Marine Corps sought out the general aviation
> > community and worked with us to minimize the impact of their
> > proposal," said AOPA Manager of Air Traffic Heidi Williams. "As a
> > result, we've got a proposal that will let the Marines train they
> > way they fight while allowing GA pilots to use adjacent Victor
> > airways."
> >
> > The Marines want to replace the San Onofre High and Low military
> > operations areas with a new restricted area, R-2503D, which will
> > directly overly R-2503A, extending up to 11,000 feet, and would
> > include a number of mitigation efforts.
> >
> >
> > I am unable to find any language from AOPA nor FAA that supports the
> > contention, that this new Restricted Area will permit civil flights to
> > use the Oceanside VOR-A Approach, Carlsbad (McClellan-Palomar) ILS Rwy
> > 24 and VOR GPS-A approaches, the holding function of Oceanside VORTAC
> > (OCN), V-23 and V-208 when the proposed Restricted Area R-2503D is
> > "hot." Did AOPA and the FAA fail to disclose an explanation of their
> > mitigation efforts, or did I miss something?
> >
> > The comment period for the notice of proposed rule making (NPRM)
> > closes on May 10, 2004.
> >
> > Voice your comments to the FAA here: http://dmses.dot.gov/submit/
> >
> > ----------------------------------------------------------
> > Here's the NPRM:
> >
> > http://dmses.dot.gov/docimages/p78/274726.pdf
> > http://dmses.dot.gov/docimages/pdf89/274726_web.pdf
> > Federal Register / Vol. 69, No. 59 /
> > Friday, March 26, 2004 / Proposed Rules
> >
> > DEPARTMENT OF TRANSPORTATION
> > Federal Aviation Administration
> > 14 CFR Part 73
> > [Docket No. FAA?2003?16722; Airspace
> > Docket No. 03?AWP?19]
> > RIN 2120?AA66
> > Establishment of Restricted Area
> > 2503D, Camp Pendleton; CA
> > ACTION: Notice of proposed rulemaking
> > (NPRM).
> > SUMMARY: This action proposes to
> > establish a restricted area (R?2503D)
> > over Camp Pendleton, CA. Specifically,
> > this action proposes to convert the
> > current San Onofre High and Low
> > Military Operations Areas (MOA) and
> > the associated Controlled Firing Area
> > (CFA) to R?2503D. The FAA is taking
> > this action to assist the Camp Pendleton
> > U.S. Marine Corps (USMC) Base, CA,
> > mission of providing realistic fleet
> > training requirements and to enhance
> > safety.
> > DATES: Comments must be received on
> > or before May 10, 2004.
> > ADDRESSES: Send comments on this
> > proposal to the Docket Management
> > System, U.S. Department of
> > Transportation, Room Plaza 401, 400
> > Seventh Street, SW., Washington, DC
> > 20590?0001. You must identify FAA
> > Docket No. FAA?2003?16722, and
> > Airspace Docket No. 03?AWP?19, at the
> > beginning of your comments. You may
> > also submit comments on the Internet at
> > http://dms.dot.gov.
> > http://dmses.dot.gov/submit/
> >
> > FOR FURTHER INFORMATION CONTACT: Ken
> > McElroy, Airspace and Rules, Office of
> > System Operations and Safety, ATOP?R,
> > Federal Aviation Administration, 800
> > 03?AWP?19) and be submitted in
> > triplicate to the Docket Management
> > System (see ADDRESSES section for
> > address and phone number). You may
> > also submit comments through the
> > Internet at http://dms.dot.gov.
> > Commenters wishing the FAA to
> > acknowledge receipt of their comments
> > on this action must submit with those
> > comments a self-addressed, stamped
> > postcard on which the following
> > statement is made: ??Comments to FAA
> > Docket No. FAA?2003?16722, and
> > Airspace Docket No. 03?AWP?19.?? The
> > postcard will be date/time stamped and
> > returned to the commenter.
> > All communications received on or
> > before the specified closing date for
> > comments will be considered before
> > taking action on the proposed rule. The
> > proposal contained in this action may
> > be changed in light of comments
> > received. All comments submitted will
> > be available for examination in the
> > public docket both before and after the
> > closing date for comments. A report
> > summarizing each substantive public
> > contact with FAA personnel concerned
> > with this rulemaking will be filed in the
> > docket.
> > Availability of NPRM?s
> > An electronic copy of this document
> > may be downloaded through the
> > Internet at http://dms.dot.gov. Recently
> > published rulemaking documents can
> > also be accessed through the FAA?s Web
> > page at http://www.faa.gov, or the
> > Federal Register?s Web page at http://
> > www.gpoaccess.gov/fr/index.html.
> > You may review the public docket
> > containing the proposal, any comments
> > received and any final disposition in
> > person in the Dockets Office (see
> > ADDRESSES section for address and
> > phone number) between 9 a.m. and 5
> > p.m., Monday through Friday, except
> > Federal holidays. An informal docket
> > may also be examined during normal
> > business hours at the office of the
> > Regional Air Traffic Division, AWP?
> > 520, 15000 Aviation Boulevard,
> > Lawndale, CA 90261.
> > Persons interested in being placed on
> > a mailing list for future NPRM?s should
> > contact the FAA?s Office of Rulemaking,
> > (202) 267?9677, for a copy of Advisory
> > Circular No. 11?2A, Notice of Proposed
> > Rulemaking Distribution System, which
> > describes the application procedure.
> > The Proposal
> > The FAA is proposing an amendment
> > to Title 14 Code of Federal Regulations
> > (14 CFR) part 73 (part 73) to revise and
> > expand the dimensions of the current
> > San Onofre MOAs over the Camp
> > Pendleton, CA, area. The USMC has
> > requested these changes because the
> > existing special use airspace does not
> > permit essential large-scale amphibious
> > assault activities (including artillery
> > live-fire, fixed-wing close air support,
> > and remotely operated aircraft
> > operations).
> > The existing restricted areas over
> > Camp Pendleton are R?2503A,
> > extending from the surface up to 2000
> > feet mean sea level (MSL); R?2503B,
> > extending from the surface up to 15,000
> > feet MSL; and R?2503C, extending from
> > 15,000 feet MSL to FL 270. These areas
> > will not be changed. The San Onofre
> > High and Low MOAs lie adjacent to the
> > restricted areas from 2,000 feet MSL up
> > to, but not including 8,000 feet MSL.
> > This proposed amendment would
> > convert the San Onofre High and Low
> > MOAs, and the associated CFA to R?
> > 2503D, which would extend from 2,000
> > feet MSL up to 11,000 feet MSL. The
> > San Onofre MOA and CFA designations
> > would be revoked.
> > The time of designation for R?2503D
> > would be intermittent by NOTAM 24
> > hours in advance, and limited to a
> > maximum use of 20 days per year from
> > 0600 to 2400 hours local time, and no
> > more than 90 days per year between
> > 0001 and 0600 local time. The restricted
> > area would be available for joint-use and
> > scheduled for training operations on an
> > as needed basis subject to the maximum
> > use limits.
> > The FAA has determined that this
> > proposed regulation only involves an
> > established body of technical
> > regulations for which frequent and
> > routine amendments are necessary to
> > keep them operationally current.
> > Therefore, this proposed regulation: (1)
> > Is not a ??significant regulatory action??
> > under Executive Order 12866; (2) is not
> > a ??significant rule?? under DOT
> > Regulatory Policies and Procedures (44
> > FR 11034; February 26, 1979); and (3)
> > does not warrant preparation of a
> > regulatory evaluation as the anticipated
> > impact is so minimal. Since this is a
> > routine matter that will only affect air
> > traffic procedures and air navigation, it
> > is certified that this rule, when
> > promulgated, will not have a significant
> > economic impact on a substantial
> > number of small entities under the
> > criteria of the Regulatory Flexibility Act.
> > Environmental Review
> > This proposal will be subject to the
> > appropriate environmental analysis in
> > accordance with FAA Order 1050.1D,
> > Policies and Procedures for Considering
> > Environmental Impacts, prior to any
> > FAA final regulatory action.
> > List of Subjects in 14 CFR Part 73
> > Airspace, Navigation (air).
> > The Proposed Amendment
> > In consideration of the foregoing, the
> > Federal Aviation Administration
> > proposes to amend 14 CFR part 73 as
> > follows:
> > PART 73?SPECIAL USE AIRSPACE
> > 1. The authority citation for part 73
> > continues to read as follows:
> > Authority: 49 U.S.C. 106(g), 40103, 40113,
> > 40120; E.O. 10854, 24 FR 9565, 3 CFR, 1959?
> > 1963 Comp., p. 389.
> > § 73.25 [Amended]
> > 2. § 73.25 is amended as follows:
> > * * * * *
> > R?2503D Camp Pendleton, CA [Added]
> > Boundaries. Beginning at lat. 33°22'42? N.;
> > long. 117°36'45? W.; to lat. 33°27'13? N.;
> > long. 117°34'17? W.; to lat. 33°18'41? N.;
> > long. 117°23'58? W.; to lat. 33°17'30? N.;
> > long. 117°16'43? W.; to lat. 33°14'09?N.;
> > long. 117°26'38? W.; to the point of the
> > beginning by following a line 1 NM from
> > and parallel to the shoreline.
> > Designated altitudes. 2,000 feet MSL to
> > 11,000 feet MSL.
> > Time of designation. Intermittent by
> > NOTAM 24 hours in advance not to exceed
> > 20 days per year from 0600 to 2400 local time
> > and not more than 90 days per year between
> > 0001 and 0600 local.
> > Controlling agency. FAA, Southern
> > California TRACON.
> > Using agency. U.S. Marine Corps,
> > Commanding General, MCB Camp Pendleton,
> > CA.
> > * * * * *
> > Issued in Washington, DC, March 18, 2004.
> > Reginald C. Matthews,
> > Manager, Airspace and Rules.
> > [FR Doc. 04?6747 Filed 3?25?04; 8:45 am]
> > BILLING CODE 4910?13?P
> >
> > * notice of proposed rulemaking:
> > http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=44f9e0eeb3fb1b21f69a155444303098&rgn=div5&view=text&node=14:1.0.1.2.2&idno=14
>
> --

[[email protected]]

Lee Elson wrote:

> Not true. Every (VFR or IMC) ILS I've done from the north has *always*
> used the OCN VOR transition. I've never been "refused" this
> transition.

Better make sure you're over-water survival gear is in good shape then, because your north arrivals will be further out to sea.~

My experience has been different than your's. Then again, I've haven't arrived via V-23; rather from the east or on transition routing from
off-shore.

[Larry Dighera]

Thank you for your input on this issue.

On Tue, 06 Apr 2004 01:37:36 GMT, "Aloft" > wrote in Message-Id:
>:

>20 days a year/90 nights a year is not what I'd call an airspace "grab",

What would it take for you consider it an airspace grab? The military
already "owns" <50% of the area of the CONUS.

Unfortunately, the Restricted Area doesn't go away when it's not in
use; it's there 24/7.

>more like an improvement in safety for those few times a year when the
>Marines want to do a full dress rehearsal.

This begs the question, why was the USMC denied a Restricted Area when
the MOAs were implemented? Didn't they want to conduct "full dress
rehearsals" then? There were good reasons for implementing the MOAs
and not Restricted Areas at that time. I'd venture there has been no
significant change in the criteria that prevented the RA in the past.

>Do you fly around that area much?

No.

>If you did, you'd know what a hazard is created whenever the Marines
>conduct a full-scale exercise, as they did this last weekend.

I would expect MOAs to be hazardous when hot. Isn't it interesting
that no Restricted Area to 11,000 feet was required for those
exercises? But then, the USMC wasn't flying their UAVs and lobbing
live artillery shells, were they?

>Despite NOTAMs and flyers on FBO bulletin boards, idiots
>still continue to blunder into those hot areas, threatening not only their
>own lives, but the lives of the military aircrews operating there. You know
>the type I'm talking about; the 60-something pilot who's flown that
>coastline a thousand times so he doesn't own a current terminal chart, never
>bothers to check NOTAMs, doesn't feel comfortable talking to SoCal so he
>doesn't, never bothers to check FBO bulletin boards, etc, etc. Basically
>your airborne Sunday driver.

I fail to understand how a new Restricted Area will mitigate the
hazard of the type of pilot you mention.

>Now, I'm sure you're saying, "well, that type
>of pilot won't even know about the restricted area". He'll find out when
>ATC asks him to jot down a telephone number.

So you feel that the new 24/7 RA will get pilot's attention after the
fact? Perhaps it would be significantly less intrusive to let
Darwinism take its course.

>And by-the-by, R-2503A already encompasses the airspace in question from the
>surface to 2000 ft.

Not exactly. The San Onofre Low MOA extends about 3 nm farther
offshore from the R-2503A Restricted Area.

[Larry Dighera]

On Tue, 06 Apr 2004 05:07:24 -0700, wrote in
Message-Id: >:

>You're going to have a difficult time in these times to deny the
>Marine Corps what they need at Pendleton.

I agree, that the USMC seems to be attempting to take advantage of
Baby Bush's invasion of Iraq to bolster their request. However, I'm
not aware of any plans the USMC may have to storm foreign beaches in
the immediate future.

>Without assessing the instrument approach procedures you cite, I
>can only speculate that they would be unaffected because that part of
>Pendleton is all housing and other buildings, thus, their operations
>don't extend that far south.

While the southern boundaries of the current MOAs and Restricted Areas
end just short of enveloping the Oceanside VORTAC, the proposed
R-2503D Restricted Area would further hamper civil air commerce due to
its increased height and size; the San Onofre High MOA currently ends
about 1/2 mile onshore not 1 mile offshore.

>As to the KCRQ ILS it would have minimal impact because no one ever
>uses the transition from OCN VOR except perhaps an occasional practice
>flight, and those are often refused because of conflict with the
>normal flow onto the ILS.

I received this e-mail CC explaination/clarification from AOPA:

Date: Thu, 08 Apr 2004 12:01:07 -0400
From: "Williams, Heidi" >
Subject: FW: Cal. Airspace issue
X-Originating-IP: [208.27.40.67]
To: '" >
Cc: '" >
Message-id: <1140FCAD8F8E9A41B5234D738B6398B702EA3784@AOPAMAIL>

> Lee,
>
> Thanks for your inquiry on AOPA's position regarding the Notice of
> Proposed Rulemaking for restricted airspace at Camp Pendleton. I
> would like to take this opportunity to give you some additional
> background on the issue.
>
> The proposed restricted airspace would replace two existing MOA's,
> but the overall impact of the restricted area is actually less
> severe. Although the San Onofre High and Low MOA's only extend
> upward to 7,999, there is a Controlled Firing Area stacked on top
> of the MOA's that extends upward to 10,000 msl.

[not 11,000 feet as proposed]

> In addition, the
> current MOA's extend to three miles offshore

[The San Onofre High MOA does not extend offshore, and the height of
the 'Low MOA is below 4,000 feet.]

> thus pushing traffic
> beyond the limits of what most GA aircraft are comfortable flying
> over water. The proposal moves the boundary to 1nm offshore.
> This allows unimpeded use of the shoreline route for aircraft
> transiting north/south around the airspace.

[While Victor-23 currently does not pass through Restricted Area nor
MOA, that would not be the case if this NPRM were enacted. I fail to
understand how the proposed change would constitute "unimpeded use."]

> AOPA pilot surveys
> indicated that over 70% of pilots fly around a MOA rather than
> flying through it, so we view this as a positive change.

[As currently charted, aircraft above 4,000 feet on V-23 do not need
to fly around the MOAs, but they will need to fly around the proposed
R-2503D restricted area.]

> Most important though is that the Marines will be limited to no
> more than 20 days of use per year from 0600-2400 - this remains
> unchanged from the current MOA usage. Most of the year (345 days),
> there is no impact on general aviation and the Victor routes
> because the restricted area is not in use.

[That statement is bogus. While it is currently possible to transit
the area along the coast above 4,000 feet without requesting
permission, if the NPRM is adopted it will not be possible to remain
on V-23 without requesting permission from ZIA Center.]

> As for impacts to the Oceanside VOR-A Approach, Carlsbad
> (McClellan-Palomar) ILS Rwy 24 and VOR GPS-A approaches, the
> holding function of Oceanside VORTAC (OCN), V-23 and V-208 would
> all be LESS impacted than they are today. The Marines and SOCAL
> TRACON have operated under a Letter of Agreement(LOA) since
> implementation of the MOA's in 1994 to allow all of these
> instrument operations to occur even when the MOA's
> are active through real-time coordination between the FAA and
> Marine ATC facilities. This is in fact transparent to the pilot
> and will continue should the restricted airspace be implemented.



> Despite the proposed airspace designation changes, the Marines and
> FAA (SOCAL TRACON) have agreed that the LOA will continue to be in
> effect and thus eliminate the burden on pilots. Again, this LOA
> means pilots will continue to operate using these instrument
> procedures as they do today.
> In fact, the boundary change lessens the impacts considering it
> moves the airspace boundary further from the Oceanside VOR.

[The NPRM does not seem to support that contention. The southern most
point of the propose R-2503D Restricted Area appears to be: lat.
33°14'09?N.; long. 117°26'38? W. Oceanside VORTAC lies at lat
33°14.44'N.; long. 117"25.06' W.]

> The Marines have attempted to reach out to the pilot community
> over the past two years through participation in FAA safety
> seminars and holding meetings at multiple local airports and with
> several aviation groups. During those meetings pilots asked for
> the frequency for the range to be included on the charts. Both
> the Marines and FAA agreed with that request and the frequency
> will be charted to allow pilots to interact directly with the
> Marines should they wish to coordinate transition through the
> airspace.


[i]
> While we certainly understand the concern over what appears to be
> a loss of airspace and access to an important Victor Airway, the
> Marines and FAA are willing to accommodate the users through their
> coordination to allow the same operations and accessibility that
> occur today.

[Personally, I would feel much more comfortable if that language were
added to the NPRM.]

> And in many ways, we believe the changes will allow
> additional opportunity for users to gain access to a shoreline
> route that has not been an option since 1994.


[i]
> As we move forward in crafting AOPA's comments on the NPRM, we
> will certainly relay the concerns of our members and appreciate
> your willingness to share the impacts from your local perspective.
>
> Sincerely,
>
Heidi J. Williams
Manager
Air Traffic, Regulatory & Certification Policy



If, as Ms. Williams states, "Most of the year (345 days), there is no
impact on general aviation and the Victor routes because the
restricted area is not in use." then perhaps removing the existing
MOAs and Restricted Areas and issuing Temporary Flight Restrictions
would be more appropriate than instituting a full time Restricted
Area.



>Larry Dighera wrote:
>[i]
>> Another attempted military airspace grab?
>>
>> The USMC wants to convert the San Onofre High and Low MOAs, that lie
>> along the busy, aircraft-congested Pacific coastline, into a
>> Restricted Area: R-2503D. The USMC say they need 38% higher
>> Restricted Airspace to conduct live-fire artillery and aerial drone
>> operations that would pose a mortal danger to civil air commerce
>> flights along the coastline between 2,000 feet and 11,000 feet.
>>
>> This proposed amendment would convert the San Onofre High and Low
>> MOAs (and the associated CFA) into Restricted Area R–2503D, which
>> would extend from 2,000 feet MSL up to 11,000 feet MSL, or 38% (3,000
>> feet) higher than the existing San Onofre MOAs it would replace.
>>
>> Despite the fact that the military were originally denied the
>> exclusive airspace use provided by a restricted area that INCLUDES
>> VICTOR AIRWAYS, they are again requesting it. But this time they want
>> to include remotely operated aircraft INCAPABLE OF COMPLYING WITH
>> SEE-AND-AVOID REGULATIONS, and significantly increase its height above
>> the existing 8,000 foot MOA. (What is curious is how the live
>> artillery fire and drones will not affect air commerce below 2,000
>> feet.)
>>
>> If this NPRM were adopted, the Oceanside VOR-A Approach, Carlsbad
>> (McClellan-Palomar) ILS Rwy 24 and VOR GPS-A approaches, the holding
>> function of Oceanside VORTAC (OCN), V-23 and V-208 would all be
>> negatively impacted.
>>
>> Although R–2503D would be limited to a maximum use of 20 days per year
>> from 0600 to 2400 hours local time, and no more than 90 days per year
>> between 0001 and 0600 local time, during those times (up to 110-days
>> annually) (the way the NPRM is currently worded) civil aircraft would
>> be banned from use of Victor Airways V-23 and V-208 below 11,000 feet,
>> the Oceanside VOR-A Approach, and the holding function of Oceanside
>> VORTAC, thus negatively impacting air commerce.
>>
>> The USMC has requested these changes because the existing special use
>> airspace does not permit essential large-scale amphibious assault
>> activities (including artillery live-fire, fixed-wing close air
>> support, and remotely operated aircraft operations).
>>
>> AOPA supports this military airspace grab!:
>>
>> http://www.aopa.org/whatsnew/newsitems/2004/04-1-161x.html
>> AOPA is backing the creation of one restricted area in California
>> and the modification of another in Georgia because, in each case,
>> the result would actually improve general aviation operations
>> around military training areas.
>>
>> Near Camp Pendleton in southern California, close cooperation
>> between the U.S. Marine Corps, the Southern California Airspace
>> Working Group (of which AOPA is part), and local pilots, a new
>> restricted area proposed on Friday may actually ease operations
>> along the coastline.
>>
>> "From the outset, the Marine Corps sought out the general aviation
>> community and worked with us to minimize the impact of their
>> proposal," said AOPA Manager of Air Traffic Heidi Williams. "As a
>> result, we've got a proposal that will let the Marines train they
>> way they fight while allowing GA pilots to use adjacent Victor
>> airways."
>>
>> The Marines want to replace the San Onofre High and Low military
>> operations areas with a new restricted area, R-2503D, which will
>> directly overly R-2503A, extending up to 11,000 feet, and would
>> include a number of mitigation efforts.
>>
>>
>> I am unable to find any language from AOPA nor FAA that supports the
>> contention, that this new Restricted Area will permit civil flights to
>> use the Oceanside VOR-A Approach, Carlsbad (McClellan-Palomar) ILS Rwy
>> 24 and VOR GPS-A approaches, the holding function of Oceanside VORTAC
>> (OCN), V-23 and V-208 when the proposed Restricted Area R-2503D is
>> "hot." Did AOPA and the FAA fail to disclose an explanation of their
>> mitigation efforts, or did I miss something?
>>
>> The comment period for the notice of proposed rule making (NPRM)
>> closes on May 10, 2004.
>>
>> Voice your comments to the FAA here: http://dmses.dot.gov/submit/
>>
>> ----------------------------------------------------------
>> Here's the NPRM:
>>
>> http://dmses.dot.gov/docimages/p78/274726.pdf
>> http://dmses.dot.gov/docimages/pdf89/274726_web.pdf
>> Federal Register / Vol. 69, No. 59 /
>> Friday, March 26, 2004 / Proposed Rules
>>
>> DEPARTMENT OF TRANSPORTATION
>> Federal Aviation Administration
>> 14 CFR Part 73
>> [Docket No. FAA–2003–16722; Airspace
>> Docket No. 03–AWP–19]
>> RIN 2120–AA66
>> Establishment of Restricted Area
>> 2503D, Camp Pendleton; CA
>> ACTION: Notice of proposed rulemaking
>> (NPRM).
>> SUMMARY: This action proposes to
>> establish a restricted area (R–2503D)
>> over Camp Pendleton, CA. Specifically,
>> this action proposes to convert the
>> current San Onofre High and Low
>> Military Operations Areas (MOA) and
>> the associated Controlled Firing Area
>> (CFA) to R–2503D. The FAA is taking
>> this action to assist the Camp Pendleton
>> U.S. Marine Corps (USMC) Base, CA,
>> mission of providing realistic fleet
>> training requirements and to enhance
>> safety.
>> DATES: Comments must be received on
>> or before May 10, 2004.
>> ADDRESSES: Send comments on this
>> proposal to the Docket Management
>> System, U.S. Department of
>> Transportation, Room Plaza 401, 400
>> Seventh Street, SW., Washington, DC
>> 20590–0001. You must identify FAA
>> Docket No. FAA–2003–16722, and
>> Airspace Docket No. 03–AWP–19, at the
>> beginning of your comments. You may
>> also submit comments on the Internet at
>> http://dms.dot.gov.
>> http://dmses.dot.gov/submit/
>>
>> FOR FURTHER INFORMATION CONTACT: Ken
>> McElroy, Airspace and Rules, Office of
>> System Operations and Safety, ATOP–R,
>> Federal Aviation Administration, 800
>> 03–AWP–19) and be submitted in
>> triplicate to the Docket Management
>> System (see ADDRESSES section for
>> address and phone number). You may
>> also submit comments through the
>> Internet at http://dms.dot.gov.
>> Commenters wishing the FAA to
>> acknowledge receipt of their comments
>> on this action must submit with those
>> comments a self-addressed, stamped
>> postcard on which the following
>> statement is made: ‘‘Comments to FAA
>> Docket No. FAA–2003–16722, and
>> Airspace Docket No. 03–AWP–19.’’ The
>> postcard will be date/time stamped and
>> returned to the commenter.
>> All communications received on or
>> before the specified closing date for
>> comments will be considered before
>> taking action on the proposed rule. The
>> proposal contained in this action may
>> be changed in light of comments
>> received. All comments submitted will
>> be available for examination in the
>> public docket both before and after the
>> closing date for comments. A report
>> summarizing each substantive public
>> contact with FAA personnel concerned
>> with this rulemaking will be filed in the
>> docket.
>> Availability of NPRM’s
>> An electronic copy of this document
>> may be downloaded through the
>> Internet at http://dms.dot.gov. Recently
>> published rulemaking documents can
>> also be accessed through the FAA’s Web
>> page at http://www.faa.gov, or the
>> Federal Register’s Web page at http://
>> www.gpoaccess.gov/fr/index.html.
>> You may review the public docket
>> containing the proposal, any comments
>> received and any final disposition in
>> person in the Dockets Office (see
>> ADDRESSES section for address and
>> phone number) between 9 a.m. and 5
>> p.m., Monday through Friday, except
>> Federal holidays. An informal docket
>> may also be examined during normal
>> business hours at the office of the
>> Regional Air Traffic Division, AWP–
>> 520, 15000 Aviation Boulevard,
>> Lawndale, CA 90261.
>> Persons interested in being placed on
>> a mailing list for future NPRM’s should
>> contact the FAA’s Office of Rulemaking,
>> (202) 267–9677, for a copy of Advisory
>> Circular No. 11–2A, Notice of Proposed
>> Rulemaking Distribution System, which
>> describes the application procedure.
>> The Proposal
>> The FAA is proposing an amendment
>> to Title 14 Code of Federal Regulations
>> (14 CFR) part 73 (part 73) to revise and
>> expand the dimensions of the current
>> San Onofre MOAs over the Camp
>> Pendleton, CA, area. The USMC has
>> requested these changes because the
>> existing special use airspace does not
>> permit essential large-scale amphibious
>> assault activities (including artillery
>> live-fire, fixed-wing close air support,
>> and remotely operated aircraft
>> operations).
>> The existing restricted areas over
>> Camp Pendleton are R–2503A,
>> extending from the surface up to 2000
>> feet mean sea level (MSL); R–2503B,
>> extending from the surface up to 15,000
>> feet MSL; and R–2503C, extending from
>> 15,000 feet MSL to FL 270. These areas
>> will not be changed. The San Onofre
>> High and Low MOAs lie adjacent to the
>> restricted areas from 2,000 feet MSL up
>> to, but not including 8,000 feet MSL.
>> This proposed amendment would
>> convert the San Onofre High and Low
>> MOAs, and the associated CFA to R–
>> 2503D, which would extend from 2,000
>> feet MSL up to 11,000 feet MSL. The
>> San Onofre MOA and CFA designations
>> would be revoked.
>> The time of designation for R–2503D
>> would be intermittent by NOTAM 24
>> hours in advance, and limited to a
>> maximum use of 20 days per year from
>> 0600 to 2400 hours local time, and no
>> more than 90 days per year between
>> 0001 and 0600 local time. The restricted
>> area would be available for joint-use and
>> scheduled for training operations on an
>> as needed basis subject to the maximum
>> use limits.
>> The FAA has determined that this
>> proposed regulation only involves an
>> established body of technical
>> regulations for which frequent and
>> routine amendments are necessary to
>> keep them operationally current.
>> Therefore, this proposed regulation: (1)
>> Is not a ‘‘significant regulatory action’’
>> under Executive Order 12866; (2) is not
>> a ‘‘significant rule’’ under DOT
>> Regulatory Policies and Procedures (44
>> FR 11034; February 26, 1979); and (3)
>> does not warrant preparation of a
>> regulatory evaluation as the anticipated
>> impact is so minimal. Since this is a
>> routine matter that will only affect air
>> traffic procedures and air navigation, it
>> is certified that this rule, when
>> promulgated, will not have a significant
>> economic impact on a substantial
>> number of small entities under the
>> criteria of the Regulatory Flexibility Act.
>> Environmental Review
>> This proposal will be subject to the
>> appropriate environmental analysis in
>> accordance with FAA Order 1050.1D,
>> Policies and Procedures for Considering
>> Environmental Impacts, prior to any
>> FAA final regulatory action.
>> List of Subjects in 14 CFR Part 73
>> Airspace, Navigation (air).
>> The Proposed Amendment
>> In consideration of the foregoing, the
>> Federal Aviation Administration
>> proposes to amend 14 CFR part 73 as
>> follows:
>> PART 73—SPECIAL USE AIRSPACE
>> 1. The authority citation for part 73
>> continues to read as follows:
>> Authority: 49 U.S.C. 106(g), 40103, 40113,
>> 40120; E.O. 10854, 24 FR 9565, 3 CFR, 1959–
>> 1963 Comp., p. 389.
>> § 73.25 [Amended]
>> 2. § 73.25 is amended as follows:
>> * * * * *
>> R–2503D Camp Pendleton, CA [Added]
>> Boundaries. Beginning at lat. 33°22'42? N.;
>> long. 117°36'45? W.; to lat. 33°27'13? N.;
>> long. 117°34'17? W.; to lat. 33°18'41? N.;
>> long. 117°23'58? W.; to lat. 33°17'30? N.;
>> long. 117°16'43? W.; to lat. 33°14'09?N.;
>> long. 117°26'38? W.; to the point of the
>> beginning by following a line 1 NM from
>> and parallel to the shoreline.
>> Designated altitudes. 2,000 feet MSL to
>> 11,000 feet MSL.
>> Time of designation. Intermittent by
>> NOTAM 24 hours in advance not to exceed
>> 20 days per year from 0600 to 2400 local time
>> and not more than 90 days per year between
>> 0001 and 0600 local.
>> Controlling agency. FAA, Southern
>> California TRACON.
>> Using agency. U.S. Marine Corps,
>> Commanding General, MCB Camp Pendleton,
>> CA.
>> * * * * *
>> Issued in Washington, DC, March 18, 2004.
>> Reginald C. Matthews,
>> Manager, Airspace and Rules.
>> [FR Doc. 04–6747 Filed 3–25–04; 8:45 am]
>> BILLING CODE 4910–13–P
>>
>> * notice of proposed rulemaking:
>> http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=44f9e0eeb3fb1b21f69a155444303098&rgn=div5&view=text&node=14:1.0.1.2.2&idno=14

[Greg Copeland]

On Sat, 10 Apr 2004 17:45:04 +0000, Larry Dighera wrote:

> I received this e-mail CC explaination/clarification from AOPA:

I seriously doubt that she is happy that you just posted her email address
so publically. Chances are high, her spam count is going to go through
the roof in the coming months.

If you must post letters, please be respectful of others and hide their
email address. Not doing so is considered to be very rude, especially if
you did it without their permission.

[Matt Johnson]

Larry, you've convinced me you're an idiot. The proposed rule gives back
more than it takes. With the proposed new restricted area limited to 20
days of use per year, ZLA/SoCal or LONGRIFLE will undoubtedly honor all
requests to transit the area. For those pilots with such disdain for
talking to ATC to obtain clearance through the airspace, go the inland route
or better yet, stay home--you're a hazard to the rest of us.

As for your suggestion that the MOAs and proposed restricted area be
replaced with TFRs, that'd be great, but the reality is that the area around
Pendleton is almost always busy with military traffic of all types, where
keeping on one's toes is a good idea for all concerned. Taking away the
MOAs and restricted area might tend to lull one into complacency, precisely
where complacency should be avoided.

I support the rule change.

Matt Johnson
KMYF

[[email protected]]

On Sun, 25 Apr 2004 20:43:03 GMT, "Matt Johnson"
> wrote:

>Larry, you've convinced me you're an idiot.

How did you arrive at that conclusion? Was there a flaw in the
_facts_ I presented as there appeared to be in those presented by
AOPA's Heidi Williams? Or are you just incapable of separating your
emotional nature from rational discourse?

>The proposed rule gives back more than it takes.

We disagree.

The NPRM contains language that replaces two MOAs with an even larger
(in terms of cubic area) Restricted Area. That seems to contradict
your assertion above. Please state how you arrived at the erroneous
belief you espouse above?

>With the proposed new restricted area limited to 20
>days of use per year, ZLA/SoCal or LONGRIFLE will undoubtedly honor all
>requests to transit the area.

All requests? How did you arrive at that conclusion? Won't ATC deny
Restricted Area transit requests during those 20 days? What of the
other 90 days of planned military activity?

If ATC were to grant _all_ transit requests through the proposed new
Restricted Area, what useful purpose would it serve?

>For those pilots with such disdain for talking to ATC to obtain clearance through
>the airspace, go the inland route or better yet, stay home--you're a hazard to
>the rest of us.

If talking to ATC were all that will be required to transit the
proposed Restricted Area, that would be fine. But that is not the
case. The area above 4,000' along the coast will require all VFR
flights to obtain ATC permission to transit; currently that is not the
case. Currently one can over fly Camp Pendleton at 8,000' without ATC
contact. If the proposed new Restricted Area is established as
published, it raises that floor to 11,000'.

It's another military airspace grab. Let the military relinquish some
of the 50% of NAS they currently "own."

>As for your suggestion that the MOAs and proposed restricted area be
>replaced with TFRs, that'd be great, but the reality is that the area around
>Pendleton is almost always busy with military traffic of all types, where
>keeping on one's toes is a good idea for all concerned.

First you reassure me that the military will only be using the
proposed new Restricted Area 20 days a year. Then you tell me the
area is "almost always busy with military traffic of all types." You
seem to contradict yourself, and you definitely fail to mention the
other 90 nighttime periods of proposed military activity. That leads
me to believe you may have some vested interest in seeing the proposed
Restricted Area established. What is the source of your bias?

>Taking away the MOAs and restricted area might tend to lull one into
>complacency, precisely where complacency should be avoided.

Are you able to cite any past incidents regarding the San Onofre MOAs
in which a Restricted Area would have enhanced flight safety? Do you
have any factual _information_ regarding complacent pilots causing a
hazard in the MOAs? Please provide some evidence that supports your
contention, or risk having your argument appear to be a straw man.

>I support the rule change.

Why? Do you have any _rational_ reason for supporting the proposed
new Restricted Area on California's coast? How will the proposed new
Restricted Area positively impact the high volume of flights daily on
V-23? How have the military managed to operate without the proposed
new Restricted Area for so many decades?

>Matt Johnson
>KMYF

While I welcome your input on this issue, it seems a little short of
_accurate_ facts, and long on emotional opinion.

PS:
As a friendly aside from one airman to another, name calling is often
the last desperate resort of a debater who lacks reasonable support
for his views.