AOPA has filed formal comments on the proposed Powder River Training Complex, a group of four primary military operations areas connected by Gap MOAs, which would cover some 28,000 square miles across North Dakota, South Dakota, Montana, and Wyoming.
In the May 1 comments, AOPA stressed the importance of minimizing the impact of the Powder River Training Complex on airspace users and the 39 public- and private-use airports situated beneath the MOAs. Taken together, the 19 public-use airports in the area provide 95 jobs, $1.5 million in annual payroll, and $3.8 million in economic impact to the surrounding communities, AOPA said. But those dollars are likely to dry up if pilots cannot safely transit the area around the airports, and flight training and other operations are restricted as a result of the MOAs.
In its comments, AOPA said the economic impacts of the proposed Powder River Training Complex are excessive and the association requested a number of specific mitigations to accommodate both the needs of military aircraft and those of civilian pilots. Those mitigations include reducing the charted hours of use, making proposed Gap MOAs temporary, establishing a special-use airspace communications plan, providing real-time access to IFR flights, and establishing radar coverage to ground level for the Powder River 3 Low MOA.
“We respect the military’s need to train, but we also recognize that many businesses, communities, and individuals in this area depend on aviation every day,” said Melissa McCaffrey, AOPA senior government analyst for air traffic services. “There are ways that civil and military aviation can co-exist, and we want to make sure the final airspace plan incorporates those factors.”
As proposed, the MOAs in the PRTC would be charted as active for 44.5 hours each week, although the Air Force has said it expects to use most of the airspace only 15 hours each week. In addition, the Gap MOAs are expected to be used only about 10 days per year. In light of those factors AOPA is asking that charted times for the primary MOAs be reduced to more accurately reflect their actual use and that the airspace included in the proposed Gap MOAs be turned into temporary or TMOAs to make it available for civilian use during the 98 percent of the year when it is not needed by the military.
AOPA is also asking for the addition of a Special-Use Airspace Information Service, which would provide civilian pilots with real-time information regarding military flight operations 24 hours a day. A similar system has been in use in Alaska since 1990, greatly improving situational awareness for both civilian and military pilots. In its comments AOPA notes that the infrastructure for such a system would need to be in place before final approval of the Powder River Training Complex proposal.
Other requests would provide for real-time access to airspace for IFR flights, saving untold time and expense for aircraft that would otherwise be routed around the enormous complex, and adding to-the-ground radar coverage for the Powder River Low 3 MOA, where the military anticipates flying at speeds up to 540 knots as low as 500 feet from the ground. Such speeds make see-and-avoid impractical, and radar would provide a level of safety for civilian aircraft operating in the area of the MOA.