Lawrence Berger

As a member of the Deer Valley Pilots Association I fully agree with their thoughtfuly worded comments that I have appended below. I have been a pilot in the Phoenix area for 25 years. I can see no benefit to safety by squeezing GA traffic into smaller and smaller spaces. Before Luke's request for onerous restrictions be considered all other options that Luke could do should be done and disclosed. At the least I would like to see a report on all the recent near missses (last 3 years) before any consideration be given to any air space changes. The following now from DVPA: As an overall consensus, the opposition is not because pilots do not want to talk to Luke RAPCON or are not concerned about safety. It is a case that there are alternatives yet to be investigated plus many unanswered questions from pilots. A restriction that satisfies Luke needs and does not address General Aviation (GA) needs is not acceptable. I am sure there is a better and more efficient compromise if the military and civilian entities could work together toward a mutual solution. That has not been the experience to date. Following are many of the concerns reported by the pilot community. Complex and chopped up airspace- Six sectors with varying floors and ceilings going from the surface to 7k’. Why such complex chopped up airspace in such a small area? Can it be made more pilot friendly? It is impractical to fly under because of high terrain and obstacles. Summertime will pose other problems for DVT westbound traffic with the high climb gradients required for loaded aircraft on a hot day. Airspace administration overly complex-Luke proposes to have it active during weekdays and daylight hours or by NOTAM. The question is what happens to the airspace during holidays - -- it sits there unused. On weekends it will be NOTAMed, but with a military NOTAM which aren’t easily accessed by the GA pilot. How about all the night flights Luke conducts, don’t they have the same GA conflict problem at night that Luke is trying to solve during the day. The next step will be to activate for 24hr. It will become so complex for GA to determine when the airspace is active that GA will be discouraged from using it- - -essentially achieving the same objective as restricting the airspace to GA pilots. Other unanswered GA pilot questions– - What does it mean to “talk to RAPCON?” This is a reference in the NPRM and Luke avoids a definition. AOPA is investigating this question. - Can Luke communicate airspace status on ATIS and inform adjacent airport control towers and assign squawk codes before departure at adjacent airports. This would reduce the increased pilot workload of quickly changing control agencies before violating airspace on departure. Again Luke is silent. This was asked in 2004. - Complexity and onerous rules will discourage GA airspace use and force the transfer of this density to other valley locations. That is a lot of traffic to concentrate elsewhere. Luke reports 200k operations annually, while DVT, GEU & GYR account for about 800k. That is about 4x the traffic of Luke. Pilots are already avoiding MOAs because of discouragement by the military. In the Phoenix area there are multiple Class D underlying a Class B which was recently restructured with lower floors compressing the growing traffic into less vertical airspace. With the addition of the SATR restrictions, the airspace will be again concentrated into a more dense traffic area, all the time doing it for the sake of safety. How about the safety of GA that is forced to fly in the Class E airspace without the benefit of radar. - Can Luke share their high traffic times with adjacent airports so pilots could more easily schedule departure times to avoid Luke peak traffic periods. Currently it is a case of depart and take your chances on Luke traffic. There must be a better compromise to the growing airspace complexity. The solution must include improved communication and procedures between the military and civilian control authorities. The idea that each has its own procedures and the two don’t mix may be an antiquated concept and a paradigm shift to mutually coordinated shared airspace a required objective. Airspace is not unlike many of our other natural resources in that there is a fixed amount. Unless it is judiciously conserved and managed, everybody will eventually suffer the consequence. The proposed SATR airspace has yet to be well thought out and is presented more as a concept with the request to the public to approve it and then work out the details later. The details are what make it attractive or unworkable. Please take more time to work out the details with workable solutions. The GA public is given little consideration in airspace matters. As taxpayers GA shares all expense that results from these actions, be it increased fuel consumption or the additional taxes to support the increased regulation.