Proposed Marine Corps MOAs Would Send Civilians In Harm's
Way
The US Marine Corps has
filed paperwork for two proposed military operations areas (MOAs)
that, if established, would compress civilian general aviation
pilots flying near North Carolina's Outer Banks into an area that
the military considers unsafe for its own pilots.
"If the FAA permits these two MOAs, they will have an
unavoidable adverse effect on civil aviation in the Outer Banks
area," said AOPA Manager of Air Traffic Heidi Williams. "Besides
some obvious safety issues, MOAs that are in constant use, as the
Marines envision these, become de facto airspace restrictions for
many GA pilots."
The Environmental Assessment filed on behalf of the Marine
Corps' Second Marine Aircraft Wing proposes creating the Core and
Mattamuskeet MOAs along and just inland from the Outer Banks, from
3,000 feet to 17,999 feet. The Safety and Hazardous Materials
Management section of the document notes, "Bird/aircraft strike
hazards are a serious concern for military aircraft operations. In
rare circumstances, aircraft may encounter birds at high altitudes.
However, data from the U.S. Air Force Aviation Safety Division
indicates that bird/aircraft strike mishaps, for which altitude is
known, occur predominately (98.4 percent of the time) below 3,000
ft." — precisely the area GA will be forced to fly in.
In addition, the proposed Core MOA, which overlies much of the
Cape Lookout National Seashore, either forces GA aircraft into
Class A airspace or compresses both northeast- and southwest-bound
traffic into a 1,000-foot-high corridor below the MOA floor.
Paragraph 7-4-6-(b) of the Aeronautical Information Manual states
in part, "Pilots are requested to maintain a minimum altitude of
2,000' above the surface of the following: National Parks,
Monuments, Seashores...."
The Mattamuskeet MOA overlies several national wildlife areas,
creating the same compressed airspace problem for aircraft
operating below its floor. In addition, the low floor deprives
eastbound pilots of a steady, efficient climb to a safe altitude
for an overwater flight to the Outer Banks. And westbound pilots
would have to make a premature descent or make an extended circling
descent once safely over the mainland.
"If pilots fly friendly and observe the National Park Service
request not to fly less than 2,000 feet above the National
Seashore," said Williams, "then the floor of the Core MOA at 3,000
feet leaves only 1,000 feet to see and avoid head-on traffic.
That's an uncomfortably thin margin of error."
In formal comments
filed last year, AOPA concluded, "When you combine the effects of
proposed and existing SUA, increased military flight operations,
and limitations in radar coverage that preclude real-time airspace
management throughout the region, it becomes clear that the
proposed action alternatives are not in the best interest of
general aviation pilots. As a result, AOPA strongly asserts that
the 'no action' alternative serves the best interest of airspace
users in North Carolina."
The Marine Corps has yet to submit its formal request to
establish the MOAs. Once it does, the FAA will have the final
authority to create Core and Mattamuskeet. Establishing MOAs is a
non-regulatory function, but the FAA is required to provide a
public comment period that will again allow users to weigh in on
the proposed airspace changes.
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