April 26, 2002
The Honorable John Magaw Under Secretary Transportation Security Administration 400 Seventh Street, SW Room 10126, Nasif Building Washington, DC 20590-0001
RE: Enhanced Security Procedures for Operations at Certain Airports in the Washington, D.C., Metropolitan Area Special Flight Rules Ares (SFAR 94)
Dear Mr. Magaw:
The Aircraft Owners and Pilots Association (AOPA), representing the interests of over 380,000 general aviation pilots nationwide, requests that your office take action to restore access to College Park Airport (CGS), Potomac Airfield (VKX), and Washington Executive/Hyde Field (W32), Maryland, for transient general aviation aircraft. Transient refers to those aircraft not based at the airport. Currently, the provisions of SFAR 94 allow only locally based aircraft to operate to or from these three airports. Although SFAR 94 was a critical first step in reopening these three airports, the continued prohibition on transient operations undermines the viability of each airport and threatens their future existence. General aviation operations at these airports do not pose a security threat, and action must be taken to eliminate the ban on transient operations and consider revisions to the requirements for based aircraft.
In SFAR 94, the FAA states, "after an initial procedural validation period, the FAA may authorize operations to or from an affected airport by persons operating aircraft not based at the airport." It is our understanding that following a 60-day validation period, TSA and the FAA would revisit the subject of expanded operations. This time period has now passed with no major security issues, and we believe it is time to permit transient operations.
Because the longest runway at the three Maryland airports is 3,000 feet, large, heavy jet aircraft cannot fly into or depart from these facilities. The largest general aviation aircraft that could operate from these locations is a light-twin engine airplane weighing less than 6,000 pounds.
With appropriate control mechanisms, transient operations should be permitted. These requirements could include a mandate to file a VFR/IFR flight plan and be in communication with air traffic control when entering the SFAR and require departing aircraft to exit using a routing that leads away from the District of Columbia.
Currently, only 360 pilots are authorized to fly into the three airports combined. The daily operations count is miniscule when compared to pre-September 11th traffic. Prior to the airspace closure in September, the "DC3" airports hosted over 110,000 annual GA operations, illustrating their importance for access to the Washington, D.C., area.
College Park Airport was home to over 69 based aircraft, while Hyde and Potomac fields housed 110 and 112 aircraft, respectively. College Park, the oldest continuously operating airport in the world, established by the Wright brothers themselves to teach the first two Army officers to fly, has been reduced to a single full-time employee and only 39 based aircraft. This is nearly half of the number based there prior to September 11th. The privately owned Hyde and Potomac airports experienced losses that were equally dramatic. Hyde is now down to 30 based aircraft, and Potomac has 80.
The operating restrictions have caused significant economic hardship by impacting airport operators, aircraft owners, and businesses that are based or dependent upon the continued airport operations. In an effort to serve our members suffering from current restrictions, AOPA has been working with your office to restore full general aviation access to the three public airports. However, if the restrictions are not lifted soon, it is likely that these three airports will not survive.
Andrew V. Cebula Senior Vice President, Government and Technical Affairs Aircraft Owners and Pilots Association
April 26, 2002
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