Daniel N. Owen

Mar 29, 2009 Comments from a Part 135 operator regarding the FAA's T-route proposal and the Prince William Sound: The Prince William Sound region has not been helped in the FAA's T-route plan. The only change proposed is to add a new airway, T-269, generally along the route of the current V319 from the Anchorage VOR (ANC) to the Johnstone Point VOR (JOH). This new route is likely not an improvement, because it will probably require a higher MEA than the GPS MEA on V319, due to higher underlying terrain. Therefore, it is a less desirable route in many cases where a lower altitude is needed to remain clear of icing. And, it does not create any convenient IFR access or intra- Prince William Sound IFR infrastructure. The Prince William Sound region has two thriving small villages, Tatitlek (7KA) and Chenega Bay (PFCB), which account for a combined total of more than six hundred annual on-demand charters of our company's nine-passenger aircraft. These communities have no road access, and depend on air transportation for all of their essential needs, including emergency medical care. This region is known for rapidly changing weather, including blizzards, rain and snow squalls, fog, and enroute icing conditions, all of which can occur nearly year round. There have been two VFR into IMC weather related accidents in the region since the fall of 2006, including the loss of a medevac helo with all crew and a patient. Yet, these communities have no dedicated IFR access, either to connect with Anchorage, where most residents obtain essential services, or to transit between them. In addition to the Anchorage hub access, there is a need for between village travel, mainly to serve the health agencies and school district who move personnel from village to village. In addition to the communities? needs, there are compelling strategic justifications for an IFR infrastructure?s improved service reliability and safety: Oil tankers and cruise ships transit the area, creating a need for reliable disaster response. In fact, the Exxon Valdez tanker spill occurred about five miles from Tatitlek village. Disaster response could be enhanced during poor weather with the addition of IFR access to these communities' airports. I was the only commercial operator to attend all of the T and Q route working group meetings hosted by ZAN. Through the working group process, our company proposed establishing an overwater T-route with low MEA?s tying the Prince William Sound villages with Anchorage and with each other. It is roughly in the form of a triangle, with one corner near the present WILER fix on V319 east of the Anchorage VOR, a second corner near the current BLIGH fix adjacent 7KA, and a third corner underlying V440 about 15 NM northwest of MODDS, which is adjacent to PFCB. Our company, though small, has self equipped with WAAS GPS, and has equipped one aircraft with ADS-B. We are hoping that the FAA will do it's part to enhance the safety of operations in the region by improving its IFR infrastructure so that we may fully utilize our capabilities. This distills down to the definition of need based on real safety improvement, versus a capacity driven definition of need. Daniel Owen Owner/ operator