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Geoff Fairless
24th Nov 2023, 00:11
Unfortunately, CASA has taken an FAA airspace designation and re-purposed it into a Restricted Area by any other name. Below is my response to the CASA consultation on AVSEF.

Attn - Eric Dallwitz

Dear Sir,

I have waited five years for action on the subject of the illegal declaration of Restricted Areas outside of Australian territorial waters (the 12 NM limit).

I am disappointed that CASA has chosen to use the term Military Operating Area (MOA), when the original definition by the FAA is so different. <https://www.faa.gov/air_traffic/publications/atpubs/pham_html/chap25_section_1.html>

Note: They cannot be created outside of US territorial waters and VFR aircraft do not have to seek approval to fly in them. Additionally IFR aircraft in the US are always in controlled Class E airspace above 1200 feet AGL so entry to an MOA would be coordinated by ATC.

CASA has essentially taken another Authorities naming convention, but then re-defined it in a manner that mirrors Restricted Area rules (in Australia).

This will clearly create confusion amongst visiting pilots, but particularly affect the training of foreign pilots in Australia.

I hope that this re-purposing of the FAA created MOAs will be treated a little more seriously than is current in the AIP "differences" document:

Australia also designates some danger areas as
'military operating areas'. Flight within
military operating areas may be subject to
conditions.

Kind Regards

Geoff Fairless

Geoff Fairless
24th Nov 2023, 23:29
OFFICIAL

Hi Geoff

Thanks for you email. There was a lot of discussion about the points you have raised.

CASA did not make any decision about the usage of the term MOA unilaterally as there has been long running consultation with affected parties. The consensus reached between Airservices Australia, the Department of Defence and CASA resulted in the term MOA being applied.

Both New Zealand and Papua New Guinea use the term MOA, and these MOAs operate like the Australian model. I’ve provided some info from the NZ CAA below:

Ultimately, regional consistency was considered more important by CASA and other stakeholders than alignment with the US.

Regards