Dupree, SD: Class E Conversion

The National Business Aviation Association (NBAA) fully supports this proposal to further reduce the choke points and areas in our National Airspace System (NAS) caused by these small to large areas of Class G airspace, whether they have a top of 14,500, msl, or some other fixed altitude higher than 1,200 feet, agl. These Class G choke points and areas create an undue burden on the expansion of terminal instrument procedures, particularly in the inter-mountain west. These Class G choke points and areas also cause ARTCC minimum instrument altitudes (MIAs) to be increased to be within controlled airspace. This creates significant barriers to efficient Next Generation en route and terminal area performance-based navigation. We urge you to continue this initiative until Class E airspace everywhere in the continental United States is not higher than 1,200 feet, agl.

This is in additional comment in support of the elimination of Class G airspace in the area around Dupree, South Dakota. NBAA notes that two very small areas of Class G airspace were not included within the boundaries proposed in the NPRM. These small areas are between V169 and V 55 northeast of BIS VOR and between V55 and V510 west of JMS VOR. These two small areas appear to be inadvertent omissions and should be included in the final rule.

See attached file(s) Attached is a graphic of the FAA IFR low altitude en route chart for the area of this NPRM. The area outlined by blue lines is the area encompassed by this NPRM. The two area contained in green circles to the north are two small areas of Class G airspace that should be included in the final rule.