September 6, 2005
Statement of Andrew V. Cebula Senior Vice President Government and Technical Affairs
On behalf of the
Aircraft Owners and Pilots Association
Senate Committee on Commerce, Science, and Transportation
Senator Ted Stevens, Chairman Senator Daniel Inouye, Ranking Member
General Aviation Security
June 9, 2005
Good morning, my name is Andy Cebula, senior vice president Government and Technical Affairs, of the Aircraft Owners and Pilots Association (AOPA). AOPA represents over 400,000 pilots and aircraft owners - more than two-thirds of all the pilots in the United States.
The individuals that we represent are your constituents and I want to share with you their anxiety about congressional action related to general aviation security. In a recent survey, over 90 percent expressed their concern that issues related to homeland security threatened general aviation operations in the national airspace. Likewise, 84 percent expressed concern that security measures mandated by Congress would adversely affect their ability to fly. My purpose today is to explain what has been done to enhance general aviation security since 9-11 and some of the current challenges being faced by AOPA members. General aviation is an essential part of the air transportation system, serving over 18,000 private and public airports in communities across the country, carrying over 166 million passengers per year. There are 5,400 public-use airports.
General aviation security is a responsibility taken seriously by AOPA and its members. Before 9/11, general aviation security focused primarily on preventing aircraft theft, and airspace regulations were typically safety related. However, in the last three and a half years that has changed dramatically; the general aviation community and the government have responded with programs to enhance the security of pilots, aircraft and airports, and airspace. Security, previously not often considered by the general aviation community, has become a top priority.
While the average airline passenger has seen little change in the basic security process since 2001, the typical general aviation pilot has witnessed tremendous changes with numerous new security requirements. Pilots are vetted, their names are cross-checked against terrorist watch lists, new security procedures have been implemented and equipment installed at general aviation airports, and the airspace can at anytime and anyplace in the country be closed or limited to pilots.
Given the relative low speed and small size of the majority of general aviation aircraft, AOPA has advocated improving general aviation security, but doing so recognizing the low threat general aviation poses to the nation. As we begin to look at the improvements to general aviation security, it is helpful to establish some comparative benchmarks.
The typical AOPA member operates an aircraft like a Cessna 172 Skyhawk. There are more than 25,000 Cessna 172 Skyhawks registered in the United States, making it the most popular general aviation airplane. This four-seat airplane operates at about twice the speed of a car (120 mph), has an average maximum weight of 2,300 pounds, carries 40 gallons of fuel, and has a useful load (after full fuel) for people and baggage of around 500 pounds. A Cessna 172 is less in size and weight than a typical compact car like the Honda Civic, which weighs around 2,600 pounds.
The number of general aviation aircraft stolen is down sharply since the general aviation community took steps to enhance security since the late 1980s to discourage aircraft thefts that were used mostly for drug smuggling. According to the most recent statistics available from the Aviation Crime Prevention Institute, in 2003, there were only six aircraft stolen nationwide.
The combination of these factors and security enhancements put into place since 9-11 limits the desirability of general aviation for illicit uses. Independent analysis by government agencies concurs with this assessment. A November 2004 Government Accountability Office (GAO) report on General Aviation Security concurred, noting that "the small size, lack of fuel capacity, and minimal destructive power of most general aviation aircraft make them unattractive to terrorists and, thereby, reduce the possibility of threat associated with their misuse."
The report found that most of the airports GAO visited had, on their own initiative, established a number of security enhancements, using either airport revenue or state or federal grant money to fund some of the enhancements. The report concludes that continued partnerships between the general aviation industry and the government, such as AOPA's Airport Watch program, are vital to the long-term success of efforts to enhance security at the nation's general aviation landing facilities.
With this information as a prelude, let us examine the improvements in general aviation security and current challenges.
With over 18,000 public and private general aviation-landing facilities, the government cannot, nor is it necessary to, regulate or directly oversee airport security at these facilities. Recognizing that general aviation airports are similar to small communities, AOPA worked with the Department of Homeland Security to develop and implement the Airport Watch program. Much like a neighborhood watch program, this Airport Watch enlists the support of some 550,000 general aviation pilots to watch for and report suspicious activities that might have security implications.
Since December 2002, TSA receives reports of suspicious activities through the general aviation hotline 866/GA-SECURE (1-866/427-3287). The Airport Watch program and the general aviation hotline are critical elements of general aviation security. The program serves as a centralized reporting system for general aviation pilots, airport operators, and maintenance technicians wishing to report suspicious activity at their airfield.
The program materials are the Airport Watch brochure explaining the program and what to watch for, warning poster, warning decal, warning sign, and an instructional video featuring the Secretary of the Department of Homeland Security. The Airport Watch program has been actively supported by the TSA, FAA, Civil Air Patrol, aviation businesses on airports, pilot groups, manufacturers, and state departments of transportation.
In launching the program, AOPA distributed Airport Watch materials to all 550,000 general aviation pilots and 5,280 public-use general aviation airports. AOPA continues to make program materials available, and during the past 12 months AOPA has fully funded efforts to send additional Airport Watch materials to pilots and aviation officials in Iowa, Massachusetts, Tennessee, and New Jersey. Since the program's inception, AOPA has spent more than $1 million of Association funds in developing, distributing, and promoting the Airport Watch program. Another industry-wide mailing is anticipated later this year.
Congress has shown its support of the Airport Watch program with directive language in the Homeland Security Appropriations bill for the past two years, and the House-passed Homeland Security Appropriations bill for FY06, which contains funding for an additional nationwide educational and promotional effort.
The Airport Watch concepts have been proven to work. Even though actionable calls are rare, they have been viewed as beneficial. Time and again, the TSA has praised the valuable information they receive from pilots reporting suspicious behaviors. Below is a small sampling of reports taken through the Airport Watch program.
Immediately following the tragic events of four commercial airliners being hijacked to be used as weapons against the United States on the morning of September 11, 2001, the FAA issued a notice to airmen (notam) grounding all civil air traffic. This historic action was unprecedented and underscored the concern security policy makers had about civil aircraft being used as weapons. It set the stage for changes in security policies for the commercial airline industry and the general aviation community.
The report to Congress, "Improving General Aviation Security," issued in December 2001 by the newly formed Transportation Security Administration (TSA), launched the strategy for addressing security of general aviation. This included airspace restrictions, scrutiny of pilots and improvement of their credentials, and security enhancements for general aviation airports - and the all-important issue of educating the pilot community. One of the underlying principles is the importance of balancing security requirements with the threat that general aviation presents. That is one of the reasons the Department of Homeland Security (DHS) has adopted risk-based approaches to security - balancing the cost for security, the limitations and restrictions, with the security benefits.
It is absolutely essential that any security requirements do not eliminate the very industry they are designed to protect. If that occurs, the terrorists have won. Many pilots are asking this very question about the airspace restrictions in the Baltimore-Washington, D.C., area (National Capitol Region). Just last week, over 5,000 pilots visited our headquarters in Frederick, Maryland, and the most-discussed topic was the flight restrictions around the National Capitol Region.
To understand the general aviation perspective on the National Capitol Region airspace, it is important to recognize that prior to 9-11, temporary flight restrictions (TFRs) were issued but were typically smaller, shorter duration and did not come with the severe penalties for violations. Today, a pilot can face FAA enforcement action, including the loss of their pilot certificate and the extreme prospect of losing their life by being shot down for violating a TFR. As an example of the magnitude of airspace restrictions, anytime the President travels, a 30-mile TFR is established. Last year there were over 200 of these TFRs.
While much of the emphasis on general aviation has been access to Washington Reagan National Airport, and this Committee is to be commended for its work to reopen this airport to general aviation, the majority of AOPA members are concerned about the airspace restrictions around the National Capitol Region. As illustrated in the chart, there are two areas of airspace restrictions on general aviation operations created since 9-11: the inner-ring Flight Restricted or "No Fly" Zone (FRZ), and the outer Air Defense Identification Zone (ADIZ).
In the days following 9-11, the FAA implemented a total ban on general aviation operations in the 15-mile-radius FRZ, sometimes referred to as the "No-Fly-Zone,"which extends from ground level to 18,000 feet around Washington, D.C. In February 2002, the FAA partially lifted this ban by allowing limited operations at College Park and Potomac airports, as well as Hyde Field in Maryland. Until then, no general aviation aircraft could operate to or from these airports, referred to as the "DC-3," unless the aircraft was based at the airport prior to 9-11 AND the pilot has undergone FBI fingerprinting and criminal history record check before being permitted to operate under very strict flight rules. This meant that all three general aviation airports were closed to all but 300 based aircraft since 9-11.
For many AOPA members, the DC-3 airports were the aviation access point to the nation's capital, essentially the light aircraft operators' Washington Reagan National Airport. That is why we were pleased when the TSA in February of this year allowed vetted transient pilots to apply to operate at the DC-3 airports. These pilots must undergo the same rigorous background check as pilots based at the airport. Pilots are required to complete an FBI fingerprint background check and security training prior to receiving a unique PIN code to operate in the FRZ. Underscoring the importance of these airports to AOPA members, just this past weekend, over 180 pilots took advantage of the opportunity to complete two of the three required steps by participating in a seminar held during AOPA's Fly-In.
The FRZ was deemed to be sufficient for the 17 months following 9-11. This was due in part to the large Washington, D.C., Class B airspace area over the capital region that requires all aircraft contact air traffic control (ATC) and obtain a clearance to enter the airspace. Additionally, all aircraft operating in the Class B airspace must remain under positive ATC contact.
However, in early February 2003 over a weekend, the general aviation community was told by the TSA that a Washington, D.C., ADIZ would be established as a temporary security measure in response to an increase to the National Threat Level Alert status and the pending hostilities in Iraq.
The Washington, D.C., ADIZ is huge, encompassing 19 public-use airports, over 10,000 pilots, 2,147 aircraft, accounting for nearly 1 million operations per year. Geographically, the ADIZ spans a distance of 90 miles, stretching from the tip of West Virginia, across the Chesapeake Bay to Maryland's Eastern Shore, and south to just outside of Fredericksburg, Virginia.
To fly in the ADIZ, all general aviation aircraft must comply with operational procedures similar to those designed for instrument flying. Specifically, all pilots must file and activate a flight plan with a flight service station (FSS) and obtain a discrete transponder code from air traffic control (ATC) or FSS. Once in the air, pilots must maintain two-way radio communication with ATC, squawk the assigned code on their transponder, and fly according to the flight plan while following instructions from the ATC until they are outside the ADIZ boundary.
In the months following the ADIZ implementation, the federal government subsequently decreased the National Threat Level Alert Status to yellow, and the President declared an end to the major fighting in Iraq. The federal government has taken steps to eliminate all the heightened security measures related to the Code Orange, including eliminating an ADIZ over New York City and a TFR over downtown Chicago, Illinois, when the threat level was lowered.
Despite the fact that the threat level was lowered more than two years ago, the ADIZ remains in place. AOPA has also learned that there is currently a proposed rule at the Office of Management and Budget (OMB) to make the ADIZ permanent, something that AOPA opposes.
The ADIZ adversely affects safety, is costly to operate, and is negatively impacting pilots and aviation businesses - it doesn't work.
Because it is such an anomaly, the ADIZ creates operational challenges that the government has been unable to remedy. Even experienced pilots and aviation officials are often confused in regard to its requirements and procedures. As a result, in addition to the high-profile violations that occasionally make the news, there have been numerous military and police aircraft that have violated the ADIZ airspace. This underscores the need for change.
Operationally, the ADIZ has been a disaster affecting pilots and slowly smothering the businesses that employ people in the National Capitol Region. With the ADIZ in place, the limited resources of the government and congested airspace have created unnecessary safety risks for both general aviation and commercial flights. Because the ADIZ requires that all aircraft be on a flight plan, controller workload has quadrupled. The increased workload for controllers consequently often diverts controllers from their primary responsibility - traffic separation.
Significant safety concerns also arise for pilots in the air. Pilots and ATC report that aircraft forced to circle outside the ADIZ while waiting for a discrete beacon code creates safety problems. There are safety implications of forcing multiple aircraft to circle and loiter over common points while they wait to enter the ADIZ. In one instance, a pilot faced an unexpected delay to enter the ADIZ, ran out of fuel, and made a forced landing. Thankfully no one was seriously injured, but the aircraft sustained extensive damage.
Inside the ADIZ, a visual flight rules (VFR) pilot's attention is divided between his traditional "see and avoid" responsibilities and compliance with complicated ADIZ requirements. The air traffic controllers even have a policy memo making it clear that VFR aircraft flying in the ADIZ are not receiving traffic advisories - creating confusion because the pilots expect this when talking to ATC.
The ADIZ was designed and is currently staffed as a temporary measure. We understand that it costs the FAA $18 million per year to operate the ADIZ ($8 million for ATC cost and $10 million related to enforcement actions). The ADIZ requirements have overloaded the ATC system, and pilots continue to experience extreme difficulties in gaining access to the 19 public-use airports in the ADIZ. The air traffic system was not designed to support the increased workload caused by imposing instrument flight rules (IFR) operational requirements on VFR traffic, and 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.
Contacting ATC via landlines has led to delays that ranged from 10 minutes to over two hours because of the ADIZ. Likewise, 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.
The current system does not deal well with routine situations that occur while flying. Even a small power surge can reset a transponder, and as we have seen with the recent violation by a Canadian pilot, aircraft do occasionally have difficulties with lightning. The sheer size of the ADIZ, combined with the fact that a minor mechanical difficulty can technically cause a pilot to violate the airspace, means that the probability of future problems is high.
There have been a few high-profile ADIZ violations, including the May 11 violation by a Cessna 150, and a transponder failure on the plane carrying the Kentucky governor. From January 2003 to July 2004, the FAA has tracked 2,000 "tracks of interest" ranging from cloud formations and flocks of birds to aircraft infringing on the Washington airspace.
For the general aviation community, the May 11 event was unacceptable. Certainly the pilot knows that and has apologized. However, it also underscores that there must be reason applied as Congress and agencies address issues of national security. A small, slow-flying aircraft does not present a major terror threat. On that day, the intercept pilots understood this and responded appropriately.
AOPA has continually heard from pilots on the difficulties with the ADIZ. Below is a list of a few short examples that help highlight the issue:
For these reasons and others, AOPA has continually sought changes to the ADIZ and continues to believe that a more reasonable approach can by taken for lighter, smaller aircraft.
Congress has supported attempts to make changes to the ADIZ. Vision 100 (PL 108-176) contained a section requiring a report to Congress on changes in procedures or requirements that could improve the operational efficiency or minimize the operational impacts of the ADIZ on pilots and controllers. The law also calls for the FAA to justify the necessity of the ADIZ. Unfortunately, federal agencies have not been capable of fulfilling the requirements of the law.
Looking at all this from a security perspective - none of the ADIZ violations or "tracks of interest" has been tied to terrorism. It raises the question, "Is the ADIZ worth the cost?"
As the GAO pointed out in its analysis of general aviation, to date, there has been no systematic or detailed assessment analyzing the security threat posed by general aviation in the Washington area. Further, the government has made no serious attempt to analyze whether the ADIZ measurably increases security. Certainly the security of the President and Congress are paramount, but security measures such as the ADIZ should be imposed only after a careful analysis of the threat and the actual benefits of proposed security measures. Maintaining the ADIZ costs more than $18 million for the FAA alone, and the economic losses of the general aviation community are estimated in the millions.
To improve the data on the economic impacts, AOPA has contracted with a firm to conduct an analysis of the cost of the ADIZ and anticipate that we will have this completed by the end of the summer. The ADIZ is slowly smothering an industry that generates almost $123 million in economic activity for the Washington region each year, and that accounts for more than 60 percent of aircraft operations in the National Capitol Region. The impact on the local aviation economy has been dramatic. The ADIZ has caused reductions in the number of aircraft based at airports in the ADIZ, a decrease in flight activity, resulting in a dramatic domino effect on businesses that support aviation. The last time AOPA surveyed the ADIZ airports we learned that there has been a 30- to 50-percent decrease in business at these airports. Fuel sales have decreased as much as 45 percent at some airports. If the ADIZ is not eliminated or modified, it could permanently jeopardize the economic viability of general aviation operations in the Washington area.
Although rumored to be in existence for some time, a story in the February 27, 2005, issue of the Washington Post validated that missile batteries, intended to shoot down aircraft, augment the National Capitol Region airspace security. While the hope is these would never be necessary, their presence illustrates an additional capability available to defend the region.
Likewise, last month the Department of Defense implemented its visual warning system (VWS) that enables it to notify pilots that have flown into the protected airspace in the National Capitol Region. A series of red and green laser lights signals a pilot that they have flown into an area without meeting the security requirements necessary for entry. This is another tool to protect the seat of the nation's government and is supported by AOPA.
From a government and industry perspective, both public and private resources are limited, requiring that security measures as extreme as the ADIZ should not be imposed without a careful cost-benefit analysis. Considering the enhancements made to security in the area, the experiences since it was implemented and the security enhancements outlined later in this statement, AOPA believes it is time to reexamine the ADIZ to determine whether its questionable contribution to security justifies the high costs it has imposed on the industry. Unless such a justification is produced, the ADIZ should be eliminated or modified to provide an equivalent level of security in a less intrusive way.
Significant progress has been made in enhancing the security of general aviation. Nearly 60 percent of AOPA members reported to the Association earlier this year that there has been a noticeable increase in the security at their home airport. There is also an amazing commitment by general aviation pilots to help by serving as the eyes and ears for security at local airports through AOPA's Airport Watch program. Over 80 percent of the members operating at general aviation airports are aware of the program.
Congress, TSA, FAA, and state legislative and executive branches have also acted on general aviation security since 9-11. The requirements related to pilots have been significantly increased.
Shortly after the events of September 11, current and student pilots in the FAA's databases were reviewed for links to known or potential terrorists. This has now been enhanced by the TSA and FAA Airman Revocation regulation, which enables the agencies to prevent an applicant from receiving a pilot certificate, or revoke one already issued to individuals who are deemed to pose a security threat to the United States. Through the Aviation and Transportation Security Act and Vision 100, Congress specifically directed the TSA to establish procedures for notifying the FAA of the identity of individuals known to pose a risk to aviation.
Building on a congressional requirement for screening of individuals receiving flight training in large aircraft (12,500 pounds and above), on September 21, 2004, the TSA issued an interim final rule requiring proof of citizenship and background checks for all individuals receiving flight training, regardless of the size of the aircraft. U.S. citizens must prove citizenship before receiving flight training, and all foreign flight students are required to complete a fingerprint background check process with the TSA. The rule requires individuals to validate their status with the TSA for initial training, multiengine training, or training to receive an instrument rating.
Responding to the need for improvements in the pilot's paper certificate that does not contain a photograph, AOPA took a rare step in February 2002 by asking for an immediate final rule mandating that pilots carry, and present for inspection, government-issued photo identification. This was viewed as an interim step to be replaced by an FAA-issued pilot certificate with a photograph. Later that year, in October 2002, the FAA issued the final rule implementing this requirement.
Work continues on improving the security of pilot certificates. In July 2003, the FAA began to issue new difficult-to-counterfeit pilot certificates to be used in conjunction with government-issued photo identification.
In December 2004, through the leadership of members of the Senate aviation subcommittee, the National Intelligence Reform Act (NIRA) of 2004 mandated the development of an improved pilot certificate that includes a photograph of the pilot and the ability to record biometric information within one year. While AOPA supported the concept, we were pleased the legislation included provisions to allow the use of FAA designees for facilitating the photographic information, rather than mandate pilots visiting the limited number of FAA facilities. For pilots, this will greatly improve accessibility for providing this information to the FAA and eliminates opposition to the requirement. The FAA successfully makes use of designees in many of its requirements, the one most obvious to pilots is for medical certification.
It is our understanding that the FAA is developing a rule to meet this requirement.
The TSA has also been active in improving general aviation security. One of the major initiatives of the TSA was addressing security at the 18,000-plus landing facilities across the country. The vast difference in size between, for example, a rural Alaska airport and a busy general aviation facility near a major metropolitan area necessitates that a one-size-fits-all policy will not work and could easily consume massive government resources with little security benefit. TSA sought to address this reality by developing a set of guidelines for all airports.
In May 2004, the TSA published its "Security Guidelines for General Aviation Airports." These guidelines were developed under the Aviation Security Advisory Committee and provide a list of recommended security best practices for airport operators, sponsors, and tenants. The Aviation Security Advisory Committee is a broad-based group including victims of terrorist acts against aviation, law enforcement and security experts, government agencies, aviation consumer advocates, airport tenants and general aviation, airport operators, airline labor and management, and air cargo representatives.
The guidelines also include an assessment tool to discriminate security needs at differing airports. This tool, the Airport Characteristics Measurement Tool, helps airport operators assess the local situation at their airport and helps operators determine which security enhancements would be most appropriate.
In addition, as part of Homeland Security Presidential Directive 7 (HSPD-7), DHS was required to develop a National Critical Infrastructure Protection Plan and Sector Specific Security Plans. Section 4001 of Public law 108-458, the "Intelligence Reform and Terrorism Prevention Act of 2004" required DHS to submit the National Strategy for Transportation Security, including the modal security plans by April 1, 2005.
One component of those plans is an assessment of vulnerabilities and prioritization of transportation assets. The General Aviation Vulnerability Identification Self-Assessment Tool (VISAT) is currently in development and is expected to be out in late summer/early fall. This tool will:
Assessment tools for other modes of transportation, such as regulated ports, have been developed. When complete, the tools will work together to evaluate vulnerabilities across multiple-transportation modes in order to determine resources needed to protect critical infrastructure. TSA recently provided several airport operators the opportunity to demonstrate the tool and to offer feedback.
Virtually all states have taken action to improve general aviation security. For many of the nation's 5,400 public-use airports, the local pilots, airport managers, law enforcement, and first responders are the critical element of general aviation security.
These airports also range from small grass strips with just a few based aircraft, to large centers of general aviation activity with an air traffic control tower. This wide range of airport necessitates a broad range of security programs and responses. The Airport Watch program has been accepted and promoted by nearly every state in the country as an efficient means to enhance security by successfully enlisting pilots and other individuals who routinely work or fly at an airport.
Many states and local municipalities have taken additional steps to improve the security of their general aviation airports. Below are a few examples:
These efforts are paying off in visible ways. In a recent survey of our members, 78 percent of members say their general aviation airport has a fence while nearly 60 percent have said they have seen a noticeable increase in security implemented at their local airport since September 11. The majority of AOPA members reported that they lock or store their aircraft inside a locked hangar. In addition, nearly all AOPA members say they are familiar with Airport Watch and that their local airport has posted signs requesting pilots to report all suspicious activity to 1-866/GA-SECURE.
AOPA is committed to working with the FAA and TSA to educate pilots about general aviation security requirements. These efforts include:
Direct e-mails to AOPA members anytime security-related TFRs are issued. In 2004, there were 209 security-related TFRs. During this time, AOPA sent 4,772,210 e-mails to members alerting them to airspace restrictions and changes.
AOPA Web site is continuously updated with all announced airspace restrictions and has devoted an entire section of the front page to educating members on post 9-11 security measures.
AOPA's monthly magazine, AOPA Pilot, runs an airspace story in every issue. This magazine reaches over 400,000 pilots each month. Furthermore, AOPA Pilot runs an expanded feature story on airspace about three times a year.
Air Safety Foundation training programs. AOPA's Air Safety Foundation (ASF) has committed substantial efforts to educate pilots, with much of this work focusing on the Washington, D.C., ADIZ. The AOPA Air Safety Foundation has also developed interactive airspace instruction programs and printed advisories and education materials distributed through industry, FAA, and TSA.
Highlights of the AOPA and ASF work that focus on the ADIZ include:
Clearly, AOPA is committed to doing all possible to train and educate pilots on security related information.
The government and the general aviation community have taken numerous steps to enhance security since 9-11. AOPA is committed to continue the Airport Watch program, pilot education and outreach, and work with Congress, TSA, FAA, and state and local government to implement appropriate security measures for general aviation.
However, there are grave concerns that the pilot community has over the continuation of the ADIZ. In its current form it simply does not work, jeopardizing safety, imposing significant cost on the government and the aviation community for questionable security benefit. With the implementation of general aviation security enhancements, AOPA contends that it is time to either eliminate or dramatically change the requirements of the Washington, D.C., ADIZ.
Again, thank you for the opportunity to appear before you this morning; I would be pleased to respond to any questions.
AOPA expressed concern in a meeting with town officials from East Hampton, New York, that restrictions proposed to curb airport noise “overwhelmingly” generated by transient commercial flights would unfairly burden traditional airport users.
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