Wally Roberts

The FAA proposal is insufficient to enhance the safety and management of IFR operations proposed for Panguitch Airport, because the pending LPV approach to Runway 18 will have a Decision Altitude (DA) of 200 feet, height above runway threshold. That is a very low DA, which can only be provided adequate safety with a Class E Surface Area. Otherwise, the most critical phase of this LPV approach (from 700 feet to 200 feet) will be flown in uncontrolled (Class G) airspace. Small aircraft often fly the traffic pattern at small Class G airports when the weather is less than 700 foot ceiling or visibility of far less than 3 miles. A Class E Surface Area will eliminate that safety risk posed by a low-DA LPV approach and Class G airspace near, and at, the airport.