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Mr. William H. Lawson, Director of Operations, Minnesota Business Aircraft <br />Association, objected for the following reasons: <br />1. The proposed site is below the TCA, and at 2,000' AMSL, he stated that <br />compliance with FAR requirements would leave only 1,000' for flight <br />between the floor of the TCA and the proposed structure. <br />2. He identified the site location as a prime student training area with <br />attendant diverse attention requirements to avoid other aircraft, <br />student performance, aircraft instruments, terrain clearance, TCA <br />avoidance, and the proposed 990' AGL tower. <br />3. He identified VFR traffic from Flying Cloud, Anoka County, Crystal, and <br />Gateway North Airports as routinely transitioning this area in no set <br />pattern. He said that low visibility and/or ceilings make VFR <br />navigation more difficult, and tower -structures more difficult to see <br />and avoid without hazard. <br />4. He said that raising minimum vector altitudes would increase air traffic <br />controller workload and increase traffic delays by reducing available <br />altitudes for ATC use. He points out that under certain weather <br />conditions, the higher vector altitudes would not allow early issuance <br />of contact/visual approaches at Flying Cloud and Crystal Airports, <br />resulting in further delays. <br />5. He said the proposal violates the "antenna farm" concept which he claims <br />was agreed to by the aviation community in the early 1970's. <br />Mr. Robert D. Powell, Attorney for the National Business Aircraft Association, <br />opposed the proposal on the basis of the VFR effects associated with High- <br />way 55, a student training area over the site, and future airport development. <br />Mr. Jerome F. Mann, Director of the Air Transport Association of America, <br />discussed raising the vector altitude and the resultant loss of 3,500', and <br />remaining clear of the TCA, as being lost to the IFR system. He claimed that <br />there would be a reduction in IFR transition capacity in the area by limiting <br />system capacity and increasing ATC workload. <br />Mr. C. Dennis Wright, Director, Airspace Technology Department, Aircraft Owners <br />and Pilot's Association, objected to the proposal because of its location in <br />relation to the Terminal Control Area, resulting in the compression of VFR <br />traffic into approximately 1,000' of airspace, in airspace also occupied by IFR <br />traffic. He discussed the heavy VFR student training which is conducted in the <br />area of the proposal. He said that the seven flight schools and the flying <br />clubs at Crystal and Flying Cloud Airports utilize the site as their <br />Page 3 of 8 Pages <br />Aeronautical Study No. 81-AGL-1556-OE <br />