| Admiral John E. Shkor Transportation Security Administration Floor 12, TSA-1 400 Seventh Street, SW Washington, DC 20590 | Robert Sturgell FAA 800 Independence Ave, S.W. Room 1010 Washington DC 20591 |
Gentlemen:
The Aircraft Owners and Pilots Association (AOPA), on behalf of its over 393,000 members, continues to be concerned with the new security reality that we all face since the tragic events of 9/11/01. This past weekend's ideal weather conditions provided the first significant "test" of the revised Washington, D.C., Air Defense Identification Zone (ADIZ). Unfortunately, as you are very aware, the air traffic system was unable to support the operational needs of the area's general aviation pilots. This was not the fault of the dedicated staff at the Baltimore or Potomac tracons who worked diligently to accommodate the influx of requests. However, it was a validation of concerns raised by AOPA in an FAA/TSA meeting before the ADIZ was implemented in February 2003.
At that time, AOPA expressed serious concerns regarding the air traffic control system limitations, pointing out that the FAA does not have the resources in place to effectively manage, for extended periods of time, the volume of general aviation traffic requiring access.
With this concern, and realizing the past weekend was the first in many weeks of good (VFR) weather, on Friday March 7, AOPA established a special e-mail address for pilots to report problems associated with operations in the ADIZ. Over 150 comments have been received from pilots thus far. These are real-world expressions of challenges and frustrations faced by pilots in their efforts to meet the requirements of notam 3/1850 to obtain a discrete transponder code and establish two-way communications prior to entering the ADIZ.
In literally hundreds of instances, the system failed pilots, they failed within this stressed system, or the interpretation of complex airspace terms of reference was misunderstood. The air traffic system's inability to properly handle the volume of general aviation traffic requesting access to the Washington, D.C., ADIZ resulted in confusion, frustration, and, in some locations, absolute gridlock as pilots waited on the ground with engines running and in the air circling for interminable periods of time waiting for transponder codes that, in some cases, were never issued. The problem was more pronounced in the Baltimore Tracon, which has fewer staff dedicated for this purpose and covers at least five general aviation airports that have a total of over 625 based aircraft and account for 319,000 annual operations.
Compounding the problem is the fact that the ADIZ requirements, as written, are not well understood by the air traffic controllers, and as a result pilots find themselves in scenarios where they are unfairly being counted as "violators." For example, some controllers mistakenly believe that a clearance is required to operate inside the ADIZ; it is not. Additionally, controller overload resulted in at least one pilot being vectored into the flight-free zone.
In recent meetings, TSA and security officials have repeatedly told AOPA that Washington, D.C., as the nation's capital, is unique and therefore warrants this kind of unprecedented airspace protection. Security officials also warn that with pending military action in Iraq, the threat of a terror attack in Washington increases. This may lead to the continuation of the ADIZ, or more drastic restrictions.
If the Washington ADIZ is to remain in place indefinitely, TSA and the FAA must work to address the communication, staffing, and technological challenges that are plaguing the system.
AOPA wants to work with both agencies to immediately develop alternatives to the current ADIZ requirements that reduce the burden on controllers and pilots, while maintaining the security intent of the ADIZ. Through our research of the airspace, airports, and member feedback, we have identified the key problem areas and generated solutions. AOPA's philosophy in addressing the operational problems is to reduce the burden on pilots AND CONTROLLERS, while maintaining the security paradigm that the original regulation provided, and KISS—keep it simple, stupid—so the incursion rate could be drastically reduced. Adopting AOPA's recommendations would provide short-term relief to strained air traffic resources, accommodates at least a minimal flow of general aviation traffic, reduces the number of incursions, and standardizes what has become an unpredictable flight environment.
AOPA recommends that the steps outlined in the attached document be taken immediately to address the ADIZ operational problems. The coming weekend promises to be warm, sunny, and clear—perfect VFR flying weather. Without immediate implementation of these solutions, the TSA, FAA, and area pilots will be faced with another weekend of confusion and frustration. AOPA offers these short-term interim solutions as a stopgap measure until TSA and FAA air traffic can get resources (manpower and automation) in place to handle the volume of general aviation traffic that requires access to the ADIZ.
If the TSA and FAA implement these important changes, AOPA will work diligently to distribute the information to pilots and publicize the simplified rules. We will do so by launching a prominent ADIZ "how-to" Web page, including a checklist for operating in the ADIZ and frequently asked questions and answers. We will launch an electronic outreach strategy including use of AOPA ePilot, the AOPA Airport Support Network, and a prominent ADIZ Web presence on our home page.
AOPA can even print and distribute posters, with an ADIZ checklist to key general aviation airports in the region. AOPA can do this immediately, before this weekend, but only IF the TSA and FAA act and adopt the operational changes.
We are prepared to discuss the problem areas and solutions that are contained in the attachment.
Sincerely,
Phil Boyer
March 12, 2003
