An establishment of restricted airspace (SUA) at Devil's Lake, ND is needed for viable National defense training, however, the petition lacks certain details that need to be addressed. The SUA should be limited to daylight hours only, and published times or times that can be obtained through a FSS or KZMP. The SUA needs operating altitudes and deconfliction with ATS routes and the NAS. This airspace should be ceaded back to civil control when not in use.
The USAF has failed to identify how their UAVs would transit civil airspace in order to fly in their SUA. The SUA, in addition, needs to be environmentally assessed for not only UAV aircraft, but for a broad array of military aircraft that could be flying in concert with UAVs in a theater of operation.
The military has failed to show how they would safely seperate UAV aircraft from civil aircraft and without any definiitive FAR (someday may be 14CFR107), what standards will be used for "See & Avoid"? Will the SUA involve a corridor from KRDR to Devil's Lake and if so, how will it be activated and what will be the block altitudes and width?
What is the plan for errant UAVs should they loose their TADL or programming?
Dale A. Smith
This is comment on Proposed Rule
Proposed Establishment of Restricted Areas R-5402, R-5403A, et al., Devils Lake, ND
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