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Posted

I submitted the following to the docket:

I strongly object to the proposal to decommission in entirety the air-to-ground communications network used by pilots to contact Flight Service Stations (FSS). While it is undoubtedly true that the volume of calls has substantially decreased in the past decade, likely due to use of other technologies, the voice capability via Flight Service Remote Communications Outlets remains invaluable.
While raw weather data is available by datalink, assistance in interpretation of this data can be critical. One cannot overstate the value of having an experienced professional available to assist in weather-related decision making. This expertise must be accessible by radio.
Assistance in obtaining and interpreting Notices to Airman is another essential use of air-to-ground contact. This is so important if any changes need to be made to a planned flight after departure. Questions on temporary flight restrictions need ready answers.
Activating, closing and modifying flight plans often cannot be done on the ground using web sites or text messages, and sometimes phone service at remote airports is non-existent. The air-to-ground frequencies allow contact with FSS either shortly after departure or prior to landing for this purpose. If the time on a flight plan needs to be extended, the ability to contact FSS in a timely manner can save search and rescue efforts.
While it may be argued that FSS services to airborne aircraft could be provided by Air Traffic Control specialists, that does not fit with the way things work in the real world. Controllers--if they respond at all to a call from an unexpected aircraft--often tell the pilot to contact FSS with requests such as flight plan operations, pilot reports and practically everything else which is not their highest priority. These services will not be simply shifted to ATC; they will be de facto eliminated.
It would be reasonable to look at reduction in the total number of air-to-ground outlets by seeing where there is overlap of coverage. The complete dissolution of this network in the name of cost savings is ridiculous at best, dangerous or deadly at worst.
Thank you for your consideration.

I find it hard  to believe that any Mooney pilot would support elimination of ALL air-to-ground FSS frequencies.  It's pretty easy to submit a comment on this.

Go here: https://www.regulations.gov/docket/FAA-2025-0558   

 

Jon

 

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Posted

I was thinking today that the thing missing in getting in-flight data from ADS-B or XM or wherever else is the inability to communicate to FSS.    My usual interactions with them are to report ELTs, forest fires, etc., and many use them for PIREPs as well.   Putting those burdens on clogged ATC channels doesn't sound like a good idea.

Posted
  On 4/9/2025 at 6:17 PM, EricJ said:

I was thinking today that the thing missing in getting in-flight data from ADS-B or XM or wherever else is the inability to communicate to FSS.    My usual interactions with them are to report ELTs, forest fires, etc., and many use them for PIREPs as well.   Putting those burdens on clogged ATC channels doesn't sound like a good idea.

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Anymore, I just offer Pireps to whoever I'm talking to (Center or Approach; sometimes I'll give ceilings and tops if I'm talking to tower, but I usually fly to & from uncontrolled fields), they've always been thankful. 

Posted
  On 4/9/2025 at 2:33 AM, 4cornerflyer said:

...assistance in interpretation of this data can be critical. One cannot overstate the value of having an experienced professional available to assist in weather-related decision making...

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What would be an example of such interpretation that was beyond your abilities as properly trained PIC and affected your decision making? 

Disclaimer: Not trying to be a Richard; genuinely curious. 

Posted
  On 4/9/2025 at 10:05 PM, varlajo said:

What would be an example of such interpretation that was beyond your abilities as properly trained PIC and affected your decision making? 

Disclaimer: Not trying to be a Richard; genuinely curious. 

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“VFR flight not recommended”:D

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Posted
  On 4/9/2025 at 10:05 PM, varlajo said:
What would be an example of such interpretation that was beyond your abilities as properly trained PIC and affected your decision making? 
Disclaimer: Not trying to be a Richard; genuinely curious. 

Not trying to speak for Jon, but a pretty obvious one in my mind is TFRs. We all know we need to stay out of TFR’s but VIP TFR’s often allow exceptions when you read the small pint. Some allow flying in and through as long as we’re talking to ATC while squawking while others don’t. Some of the more complicated ones are divided into 2 areas with an outer ring that we can fly in if squawking and talking. Flight conditions and time constraints might make it challenging to read all the fine print while flying.

True these questions can be posed to ATC but if you’re aways out from their airspace FSS is the better one.

Then there are simpler ones like your a ways out planning an approach using a VOR and you see a NOTAM for your approach that the TACAN is out of service - i can see some pilots wondering does mean just DME or Azimuth as well? There are lots of NOTAMS that can be confusing that we could do a little research on the ground but when discovering them in the air we may need a little help.

Incidentally, i have to add a “Properly trained PIC” is non-sensical. Even on the day of our checkride we don’t know everything. The adage that the certificate is nothing more than a license to learn is right attitude IMO.


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Posted (edited)

Isn't "basic FSS coverage" required as per ICAO? at least for international flights (radio contact and flight following), search and rescue, triggered elt/plb, military-civilian coordination, as well as being aware of zones or events outside controlled airspace (NOTAM, TFR, ADIZ, Restricted Areas, Drones, Pireps, SoS...)

I imagine there is not much international flights low level VFR flight plans to/from Alaska? or the majority of these are now talking to ATC who manage controlled airspace and instrument routes...

While ago, I spoke to one Area FIS (FSS in Europe) about his mandate? the main ones are opening flight plans, coordination of search and rescue, however, he mentioned that he handled few UFOs reports by flight crew in the last years :D

Edited by Ibra
Posted
  On 4/11/2025 at 1:49 PM, Ibra said:

Isn't "basic FSS coverage" required as per ICAO? at least for international flights (radio contact and flight following), search and rescue, triggered elt/plb, military-civilian coordination, as well as being aware of zones or events outside controlled airspace (NOTAM, TFR, ADIZ, Restricted Areas, Drones, Pireps, SoS...)

I imagine there is not much international flights low level VFR flight plans to/from Alaska? or the majority of these are now talking to ATC who manage controlled airspace and instrument routes...

While ago, I spoke to one Area FIS (FSS in Europe) about his mandate? the main ones are opening flight plans, coordination of search and rescue, however, he mentioned that he handled few UFOs reports by flight crew in the last years :D

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I can't speak to ICAO requirements, but with the possible exception of search and rescue, the services mentioned in your first paragraph are all functions handled by ATC. in the US. Alaska is excepted in the notice because it is different in that respect.  Large and remote areas where ATC communication may be sporadic. FSS has zero involvement with radio contact and flight following except in areas without ATC communication coverage. 

In your second group - opening VFR flight plans is purely an FSS issue and  I am concerned about that in a few areas other than Alaska, but the reality is that VFR flight plans in the lower 48 are the exception rather than a rule. On the search and rescue end, there is no need for pilot-FSS air-to-ground or ground-to-ground radio communication required. With a VFR flight plan, automatic search and rescue is based on being overdue. Manual initiation is a communication to FSS by ATC that they've lost contact with no explanation or a phone call. 

UFOs reports by flight crew would definitely be to ATC in the US.

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Posted (edited)
  On 4/11/2025 at 4:59 PM, midlifeflyer said:

but with the possible exception of search and rescue, the services mentioned in your first paragraph are all functions handled by ATC

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Indeed, the functions are usually  performed by ATC rather than non-ATC. Usually, ATC are associated with controlled airspace (Alphat to Delta and including Echo), while "ICAO FIS/FSS" tend to cover pure Golf uncontrolled airspaces (sometimes not necessarily on air-to-air radio).

In the lower states, I beleive Echo airspace is everywhere starting at 1200ft agl? so, it's as you mentioned the case of Echo ATC providing these services to VFR (in addition to controlling IFR). Maybe Alaska had different layout of Golf vs Echo airspace? 

Maybe this is also related,

https://www.federalregister.gov/documents/2024/11/25/2024-27377/modification-of-class-e-airspace-alaska-ak

On UFOs, my kid told his teacher "the air traffic controller told us they see them" (something was lost in translation)

Edited by Ibra
Posted
  On 4/11/2025 at 7:46 PM, Ibra said:

Indeed, the functions are usually  performed by ATC rather than non-ATC. Usually, ATC are associated with controlled airspace (Alphat to Delta and including Echo), while "ICAO FIS/FSS" tend to cover pure Golf uncontrolled airspaces (sometimes not necessarily on air-to-air radio).

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One of the big differences is what I bolded. For all practical purposes there isn’t any navigable Golf airspace in the US lower 48. You are correct. Except for some small pockets in the mountain west, Class E begins at 1200 AGL, but even that is declining because airports which have instrument approaches start at 700. AGL or at the surface. Head over to SkyVector and pull up a US VOR chart and you can see that. All those magenta vignettes around airport represent Class E beginning at 700 AGL. The rest of the area, 1200 AGL. Higher Class G is relegated to places like this

image.png.a84f97e455ab5385a70f0f41bd5c6c2f.png

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