Proposed Modification of Class D Airspace at Mt. Clemens, MI

April 7, 2004 Docket Management System U.S. Department of Transportation Room Plaza 401 400 Seventh Street, SW. Washington, Dc 20590-0001 Dear Sirs: Reference: Docket Number FAA-2003-16705, Proposed Modification of Class D Airspace; Mount Clemens, MI; Selfridge Air National Guard Base. EAA (Experimental Aircraft Association) is the world leader in recreational aviation. With an international membership of 170,000 people in more than 100 nations, EAA brings together aviation enthusiasts, pilots and aircraft owners who are dedicated to the continued growth of aviation, the preservation of its history and a commitment to aviation's future. EAA programs, activities and events are known throughout the world for supporting aviation safety and promoting personal enjoyment and responsibility within an aviation lifestyle. These efforts are made possible through massive volunteer involvement in support of the organization, as well as EAA's special interest Divisions, and a global network of nearly 1,000 local Chapters and the affiliated National Association of Flight Instructors (NAFI). EAA objects to the proposed FAA action to increase the size of the Selfridge Air National Guard Base Class D airspace for the following reasons: 1.All the current IFR approach plates for the airport contain the following statement: "***Circling not authorized W of Rwy 1-19." Increasing the Class D to the west of the airport will not eliminate this noise restriction related to the densely populated areas, thus there is no managerial or IFR support reasons to extend the Class D area to the west of the airport. 2.EAA does not understand the operational need to reduce the circling minimums for these reasons: a.ILS Rwy 19 approach – the S-LOC 19 (straight-in non-precision approach) minimum are 960' for all categories of aircraft. And the current circling (non-precision approach) minimums for this approach are 1140' (Cat D). EAA feels the current difference in approach minimums of 180' is sufficient and attempting to reduce the difference even greater will have an adverse effect on IFR safety of flight. In addition, the circling minimums are currently lower than the S-ASR 19 (straight-in non-precision approach) approach minimums for Cat A-C approaches. b.ILS Rwy 1 approach - the S-LOC 1 (straight-in non-precision approach) minimum are 900' for all categories of aircraft. And the current circling (non-precision approach) minimums for this approach are between 1000' and 1140'. EAA feels the current difference in approach minimums of 100' to 240' is sufficient and attempting to reduce the difference even greater will have an adverse effect on IFR safety of flight. c.Pilots of all categories of aircraft approaching this airport may select from three (3) separate straight-in approaches – ILS, LOC, and ASR. The circling approach should be the last choice and EAA feels that the established circling minimums are sufficient. d.With the current demands placed on all Reserve, National Guard and Active Duty Air Force pilots and units, EAA does not feel unit or base commanders would allow precious flight time, fuel, and maintenance support assets to be "wasted" performing non-precision circling approaches. Especially since such instrument related flight-training maneuvers may be accomplished in modern flight simulators that do not place demands on other aircraft related unit personnel. 3.VFR pilots flying over Lake St. Clair between Selfridge ANGB (outside the existing Class D airspace) and the Canadian border currently have a 5-mile corridor in which to navigate. The change in Class D airspace from the current radius of 4.3 miles to the proposed 6.6 miles would only leave VFR pilots a corridor of 2.7 miles in which to navigate this area. This in itself would create a safety of flight hazard by condensing VFR traffic into a very small corridor, thus increasing the risk of mid-air collisions – especially when flying in weather at basic VFR mi…