May 14, 2015

NBAA has identified three areas of concern related to the proposed expansion and modification of the vast Joint Pacific Alaska Range Complex (JPARC), citing the potential impact on business aviation in Alaska.

The proposal would add nearly 7,000 square miles to the Fox 3 military operation area and attach to its eastern perimeter the approximately 3,200-square-mile Paxon Military Operations Area (MOA), which would encompass the airspace from 500 feet above ground level up to Flight Level 180. The proposal also calls for the lowering of Fox 3 from 5,000 feet to 500 feet, and anticipates that the MOAs would be active 240 days a year for an average of 12 hours a day.

Given the size of these MOAs when active, avoiding them is impractical, said Bob Lamond, NBAA’s director of air traffic services and infrastructure. Concerned that lowering the MOA floor to 500 feet would reduce safety by compressing VFR traffic, NBAA urged the FAA to consider this in its final decision.

To maintain safety and access, NBAA requested that the Special Use Airspace Information Service (SUAIS) be expanded to include all of the proposed MOAs, and that SUAIS coverage be a condition for activating the MOAs’ lower altitudes. Operated by the military, the SUAIS provides real-time status information for 65,000 square miles of JPARC’s interior airspace, but does not cover the 42,000-square- nautical miles of training airspace over Gulf of Alaska. Covering the proposed MOA expansion would require additional communication equipment.

When active, the Paxon MOA directly affects two Victor airways, a T-Route, as well as all flights following direct routes through the MOA, said Lamond. Given the anticipated activity of 240 12-hour days, NBAA has requested that non-participating IFR traffic be given priority for transit through the MOAs, as the Air Force has done recently at the Powder River Training Complex, a 28,000-square-mile block of airspace over the Dakotas, Montana and Wyoming.

Read NBAA’s full comments on the proposed expansion of JPARC. (PDF)