FAA Proposes Class D Airspace at LAX

Proposed addition of class D airspace to the class B surface areas

As Andrew Jackson said during his farewell address to the country, “the price of liberty is eternal vigilance”. Nowhere is this more true than when dealing with our freedom to fly.

Thankfully we’ve got organizations like AOPA to help monitor the reams of NPRMs and documents issued by the federal government on a daily basis. I say thankfully because as connected as I am to the industry, there’s no way I could keep up with the blizzard of paperwork flying out of Washington. It’s hard to remember how we did it even half as well before the advent of the world wide web.

AOPA recently found a proposed change to the Los Angeles Class B airspace. This change isn’t a physically large one, and it won’t have much if any impact for most pilots. The reason it caught AOPA’s attention is that it telegraphs a significant shift in the way the FAA uses airspace.

The FAA defines the problem by noting that airplanes performing missed approach procedures at LAX sometimes stray outside of the lateral confines of the Class B airspace surface area. They do not explain exactly why this happens. Since published missed approach procedures keep pilots within the confines of protected airspace, one can only assume that controllers are providing radar vectors which take pilots out of the Class Bravo. The only other options I can conceive of would be repetitive faulty airmanship and/or a poorly designed approach procedure, neither of which is likely.

I have a feeling this might really be about the approximate 15 degree offset between the runways at LAX and the alignment of the Bravo surface area corridor which should — but for some reason does not — parallel it.

The solution proposed by the FAA? They want to add small Class D cutouts to the north and south of the surface Bravo airspace:

Proposed addition of class D airspace to the class B surface areas

If you’re confused, welcome to the club. Every pilot learns early on in primary flight training that Class D airspace is always centered around an airport with an operating air traffic control tower. Specifically, an airport too small to receive a Class B or C designation. These designations are based on the number of operations and passengers enplaned and deplaned in a given year. LAX is one of the busiest airports on the planet and is long established as a Class Bravo field. Class D airspace is not designed for the LAXs of the world.

Assuming the Notice of Proposed Rulemaking (NPRM) is not in error — and boy would this be a big one — the FAA’s proposal for LAX would establish one of several new precedents. It’s a testament to the confusion this NPRM creates that I cannot even determine which precedent would be set. Either this would mark the first tower-less Class D airspace I’ve ever heard of, or the first time a single air traffic control tower was responsible for two different classes of airspace (B and D) at the same time.

AOPA references to this proposal as a “quick-fix” are a generous assessment in my opinion. The reasons for the change aren’t clear. Why are aircraft leaving the protected airspace during missed approaches at LAX? And if that’s happening, shouldn’t fixing the approach, re-aligning the Bravo surface area or expanding the Class B airspace slightly be the common sense solution?

Even if the FAA is determined to add Class D airspace, they shouldn’t be attaching it to LAX. The LAX tower already coordinates closely with both Santa Monica and Hawthorne towers. Why not just extend the Santa Monica and Hawthorne airspace slightly?

Another head-scratcher from the NPRM:

This action is based on the results of a study conducted by the Los Angeles VFR Task Force, and the Los Angeles Class B Workgroup.

A Google search of those two organizations yielded nada, so I wonder if they’re referring to the Southern California Airspace Users Working Group. If so, it would add a new level of perplexity to the issue, because that organization is comprised of people who actually fly in this airspace and would be the first to see the oddity of the FAA’s proposal.

Again, the practical effect of the changes being proposed by the Feds at LAX are small. That’s not the real problem. The larger issue is the misuse of airspace classification and the confusing precedent it would set. As an long-time instructor, I don’t even know how one would teach something like that to a student. In my experience, students often learn best when they understand the reason behind rules and procedures. Unfortunately, in this case that clarity is sorely lacking.

Long Beach Class C Airspace Proposal

Well, here it is: the long-awaited details of the FAA’s proposed addition of Class C airspace to Long Beach:

I’m not sure this airspace addition will reduce the risk of a midair collision. In fact, I think it might do just the opposite. While ostensibly protecting airplanes on the instrument approaches to runway 30, it will force non-participating aircraft into a smaller chunk of sky.

I’ve heard they are expecting to implement this change without much, if any, increase in staffing at Socal Approach. Considering the volume of traffic in and around Long Beach, I can only assume Socal will be unable to provide services to aircraft in local practice areas. This will force them down below 2400 feet over the harbor, and below 1500 feet off the Huntington Beach coast. At that altitude, they will be mixing it up with banner towers and helicopters. In addition, lower altitudes equate decreased glide distance for single engine airplanes. So they will stick closer to the coast, causing further congestion.

Transiting aircraft will be forced upward and having to live in the airspace between 3500 and 4900 feet. Should training aircraft elect to fly above the Class C airspace, that will add to the logjam as well.

It’s also worth noting that these are the aircraft which are most likely to be flying without traffic detection equipment.

There are a few other odd things about this proposal. The Los Alamitos class D airspace appears to be reduced to a pie-shaped slice. I’ve not seen that before. The west side of the field will be class C while the east side remains class D.

Speaking of Los Alamitos, I can’t help but wonder how this will affect the Medfly operations in and out of that airfield. Our operations probably contribute to the perceived need for this airspace. We routinely fly in and out of Los Al to the south at 1000′ MSL. We have north/south regions over that area which we fly at 1000′ and/or 2100′. These are standard procedures for us, all of which were designed with ATC’s input and which we fly while talking to them and with their full assent. It may give the airliners an occasional RA (resolution advisory) or two, but I’ve never felt it was in any way unsafe.

There are certainly times when adding airspace is necessary. For example, I wouldn’t mind seeing a class D tower added at Corona. But I’m not sure this Long Beach thing is such a good idea.

I’d be interested to hear from other Socal pilots. What’s your take on this proposal?

MOA Flying

There are many types of “special use” airspace out there. One of the most prevalent is a Military Operations Area, or MOA. According to the Aeronautical Information Manual (Sec. 3-4-5):

a. MOAs consist of airspace of defined vertical and lateral limits established for the purpose of separating certain military training activities from IFR traffic. Whenever a MOA is being used, nonparticipating IFR traffic may be cleared through a MOA if IFR separation can be provided by ATC. Otherwise, ATC will reroute or restrict nonparticipating IFR traffic.

b. Examples of activities conducted in MOAs include, but are not limited to: air combat tactics, air intercepts, aerobatics, formation training, and low-altitude tactics. Military pilots flying in an active MOA are exempted from the provisions of 14 CFR Section 91.303(c) and (d) which prohibits aerobatic flight within Class D and Class E surface areas, and within Federal airways. Additionally, the Department of Defense has been issued an authorization to operate aircraft at indicated airspeeds in excess of 250 knots below 10,000 feet MSL within active MOAs.

c. Pilots operating under VFR should exercise extreme caution while flying within a MOA when military activity is being conducted. The activity status (active/inactive) of MOAs may change frequently. Therefore, pilots should contact any FSS within 100 miles of the area to obtain accurate real-time information concerning the MOA hours of operation. Prior to entering an active MOA, pilots should contact the controlling agency for traffic advisories.

d. MOAs are depicted on sectional, VFR Terminal Area, and Enroute Low Altitude charts.

One of my pet peeves is a misunderstanding about Military Operations Areas which leads many pilots and air traffic controllers to believe that any VFR aircraft flying inside one must be a “knucklehead” (a controller’s description!). From an ATC or military pilot perspective, perhaps this is the case. After all, what possible justification could a non-military pilot have for going into one of these MOAs when it’s active? Just go around it! Right?

Wrong.

“Look left!” The Extra 300 flying an upline.

As I said in a reply to this Jetwhine article, I fly a lot of high performance aerobatics in a south Orange County (Calif.) area known as the Blockhouse. There is no protective MOA on the chart for us, and we often have climb and descent rates which exceed 15,000 fpm. Consider: an Extra 300 pulling into a vertical upline at 180 knots TAS is traveling straight up at 18,228 fpm.

We’re out there with minimal fuel flying very high performance maneuvers while trying to teach students. I’ve seen as much as +10G on the accelerometer, and as low as -6G. Inverted flat spins. Tumbles. Rolling turns. And I’ve given and received formation and aerial interception training. So I’m quite familiar with the sort of high performance maneuvers which make it hard to watch for other traffic.

Those who say non-military pilots should simply “always stay well clear” of an active MOA irk me because it ignores many practical matters regarding this special use airspace.

First, what if I’m trying to get to Inyokern, Tehachapi, or Kern Vally airports, all of which lie in the middle of the Isabella MOA? You literally cannot get there without flying through a MOA.

Half the high desert airports around my neck of the woods are in the middle of MOAs. Pull out a sectional and look at them.

Second, what if weather dictates a deviation which takes me through a MOA? I’ve encountered this scenario several times. I’m ferrying a Pitts S-2B which has a 23 gallon fuel tank and burns ~13 gph. Should I deviate another 75 nm out of the way to go around it? Many of these MOAs are in hot, high desert areas here in the southwest, and often thunderstorms, terrain, fuel, turbulence, wind, or other factors come into play, depending on the aircraft in question.

Finally, if the activity is dangerous enough to non-participating aircraft (a gunnery range, etc.), it should be a restricted area. Now that’s an airspace I wouldn’t want to fly into if it was hot, even if I legally could. I’ve seen active restricted areas at night and the tracers were bright enough to light up the sky. The sound of the artillery could be heard even above the noise of the aircraft’s engines! But MOAs are not restricted areas. And there’s a reason for that.

Having said that, I don’t take flying into a MOA lightly. I know there are high performance military aircraft out there doing their thing. I know budgets are tight, their flying time is minimal, and I don’t want to be the cause of their having to break off some training exercise simply because I was in the way. But keep in mind, the airspace is JOINT-USE. We do have a right to be there, and there might be a darn good reason for our presence as well.