March 13, 2003
Issue 1: Pilots are experiencing extensive delays in obtaining discrete transponder codes. Contacting ATC via landlines from airports without a clearance delivery frequency has led to delays that ranged from 10 minutes to over two hours. Part of this problem stems from the fact that there are only two designated lines at the Baltimore Tracon approach facility to handle all landline calls, and there is not a sufficient controller workforce to process calls if more lines were available. Pilots attempting to obtain discrete codes via clearance delivery on the ground also experienced delays of up to 45 minutes, while holding at the runway threshold, with the engine running. Larger corporate aircraft, requiring IFR release clearances at nontowered airports, were subject to delays imposed by the new requirement for all VFR traffic to use the limited facilities. Airborne pilots attempting to obtain a beacon code prior to entering the ADIZ faced lengthy hold times, and in many cases were denied service. Once again, IFR traffic attempting to cancel a flight plan in VFR conditions, an accepted practice to free up the airspace for other IFR traffic, could not contact the busy controller, who was working VFR traffic. Finally, all pilots calling flight service faced lengthy hold times and abandoned calls.
The air traffic control infrastructure is not equipped to handle the volume of traffic requiring codes, and there are not enough discrete transponder codes to allow the normal volume of VFR operations that typically take place within this 30-nm ADIZ area. Alternative methods for assigning codes must be implemented.
AOPA recommendation 1: To reduce delays in receiving transponder codes and to reduce the workload on pilots and air traffic controllers (ATC), AOPA recommends that each airport within the ADIZ be allocated a specific list of well publicized, discrete codes, exclusive to that airport. Those allocated codes would be categorized as follows:
This approach identifies the "intent" of aircraft that are operating within the ADIZ, provides surveillance operations with tracking information, reduces the workload on pilots and controllers, and addresses the problem with running out of discrete transponder codes.
Issue 2: There is continued confusion and conflicting guidance from various ATC facilities as to whether or not pilots need to receive an ADIZ clearance prior to operating in the ADIZ. There is also confusion and conflicting information regarding flight following by air traffic and the ability to ingress and egress to and from a specific location.
AOPA recommendation 2: To accompany the discrete codes and expedite ingress and egress procedures, AOPA recommends specific VFR corridors be established that would allow direct routing to and from the airports located within the ADIZ boundaries. These routes and procedures would be made available graphically to pilots prior to operations within the ADIZ. AOPA also recommends that the TSA and FAA to adopt a requirement that VFR aircraft operating in the ADIZ " monitor" a similarly well-publicized specific communication frequency and only communicate with air traffic control upon request.
This "monitor" procedure is the model used for general aviation events that draw unusually large concentrations of VFR traffic. The monitor concept is used for AOPA's annual Fly-In and Open House. It is used for the annual Oshkosh aviation event and the annual Sun and Fun Fly-In at Lakeland, Florida. It gives air traffic control the ability to manage a high volume of VFR operations safely with minimal communication and a significant reduction in workload.
Providing graphically depicted routes prior to flight adds a much needed element of predictability and order and gives pilots the opportunity to better prepare before operating in the ADIZ. Charted routes would also enable surveillance authorities and air traffic control to monitor operations and provide minimal guidance while dramatically reducing the communication workload on both pilot and controller. Requiring that pilots monitor the appropriate frequency in combination with a discrete beacon code and predictable route of flight provides an equivalent level of safety and security for operation within the ADIZ.
Issue 3: Located on the very outer edge of the current Washington ADIZ, this airport is home to more than 74 based aircraft. These based aircraft are currently able to depart the airport and clear the ADIZ airspace within moments of departure. However, the delays in obtaining a discrete code prior to departure to simply exit the ADIZ are extensive.
AOPA recommendation 3: An ADIZ "cutout" should be provided for Bay Bridge airport. This would allow the airport to remain outside the ADIZ area, free up additional beacon codes, and help to reduce the workload on the currently constrained system.
SFAR 94 allowed for a similar cutout for Freeway Airport, which is just on the fringe of the SFAR airspace. This action drastically reduced the economic burden that the restrictions would have placed on the airport had this common-sense approach not been taken. As we enter the upcoming spring and summer season, VFR operations will inevitably increase. Bay Bridge continues to be a popular seasonal destination that could easily remain outside the ADIZ area and be accessed by pilots transiting around the confined ADIZ area. We ask the TSA and FAA to once again embrace a common-sense approach and alleviate a portion of the burden on the current system by providing this much needed cutout for Bay Bridge Airport.
Issue 4: The strain of the ADIZ requirements on the air traffic system is compounded by the requests of pilots who are operating through the ADIZ airspace. While this is permitted, it adds to the workload being placed on the system.
AOPA recommendation 4: While there are valid reasons for general aviation aircraft to transit the ADIZ airspace, AOPA will STRONGLY RECOMMEND that our pilots NOT transition the ADIZ. This voluntary recommended practice would serve to eliminate the frustration that pilots, controllers, and security officials have experienced and reduce chances for inadvertent incursions.
Issue: Many pilots in the area do not understand the operational implementation of the ADIZ, the retention of the SFAR, and the procedures within Class B. This is causing inadvertent non-compliance with the operational elements of the notam.
AOPA recommendation: If the TSA and FAA implement the important changes listed above, AOPA and the pilot community will work diligently to distribute the information to pilots and publicize the simplified rules.
March 13, 2003
A new FAA policy on obstructive sleep apnea that addresses many of the concerns raised by AOPA is scheduled to take effect March 2.
AOPA and the National Business Aviation Association have jointly filed an amicus, or friend of the court, brief in the Ninth Circuit Court of Appeals as part of the ongoing legal battle over the future of Santa Monica Municipal Airport.
AOPA worked with the flight training industry and FAA to quickly resolve a problem that suddenly put many rating applications on hold.
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