Air Traffic Services and Technology
Air Traffic Services Brief: Security Officials Want Washington, D.C., Air Defense Identification Zone (ADIZ) to Be Made Permanent
Update
On July 26, 2007, the FAA Administrator Marion Blakey announced changes to the Washington Air Defense Identification Zone (ADIZ), something AOPA has been advocating for years and anticipating for weeks. Instead of a "Mickey Mouse" pattern around Washington and Baltimore, which is difficult to navigate and enforce, the ADIZ will become a 30-nautical-mile-radius circle around the DCA VOR/DME. This will free up four public-use general aviation airports and 1,800 square miles of airspace. That leaves 15 public-use airports covered by the ADIZ restrictions. Of these, three are in the Flight Restricted Zone (FRZ), closer to the city, and will still be under heavy restrictions. In addition, there will be VFR speed restrictions inside and immediately surrounding the ADIZ airspace. The changes become effective August 30. Current charts will be valid until that date, and new charts will be revised accordingly.
Thanks to the more than 22,000 pilots who filed comments in opposition to the proposal and testified at four public meetings about the hardships the restrictions have caused, federal officials have begun to scale back the ADIZ. While the changes will be implemented by a notice to airmen (notam), the FAA is still expected to issue a final rule sometime in early 2008.
The issue
The Federal Aviation Administration (FAA) has acquiesced to a Department of Homeland Security (DHS) and Department of Defense (DoD) demand to make the Washington, D.C., outer Air Defense Identification Zone (ADIZ) permanent. The ADIZ extends security measures outside of the preexisting 15-mile Flight Restricted Zone (FRZ) and restricts general aviation access to airspace under 18,000 feet in roughly a 15- to 38-mile radius around Washington, D.C. The proposal also codifies the FRZ, which was implemented immediately following the terrorist attacks of September 11, 2001. AOPA has persistently advocated for relief from the flight restrictions that impact pilots and general aviation airports in the National Capital Region (NCR).
The D.C. ADIZ was hastily established during a weekend in February 2003 and was intended to be a temporary security measure imposed in preparation for the then-pending Iraq war. GA access to the NCR has been, and will continue to be, significantly impacted by large-scale flight restrictions imposed in the aftermath of the terrorist attacks.
On Thursday, August 4, 2005, the FAA released a notice of proposed rulemaking (NPRM) to permanently establish what will be called "National Defense Airspace" (NDA) over Washington, D.C. The proposed rule would amend FAR Part 93, Special Air Traffic Rules, by adding Subpart B — Washington, D.C., Metropolitan Area Special Flight Rules Area (SFRA). The proposed law closely mirrors the existing restrictions that were implemented through a notam in February 2003, known as the D.C. ADIZ.
The importance to our members
The D.C. ADIZ imposes substantial burdens on Washington-area airports and general aviation pilots who want to traverse the area. The impact is most severely felt by the 19 public-use airports, 2,100 based aircraft, and more than 10,000 pilots who conduct close to 1 million operations annually. The ADIZ also imposes substantial burdens on the FAA, diverting it from its primary mission of aviation safety.
The D.C. ADIZ is the only ADIZ that presently exists inside the U.S. borders, and the procedures for entering, exiting, and transiting it are different from those required in the long-established coastal ADIZ around the U.S. mainland. Because it is the only one of its kind, even experienced pilots and aviation officials are often unfamiliar with its requirements and procedures. This uncertainty has resulted in confusion among pilots, as well as FAA employees responsible for enforcing the ADIZ requirements, placing an unanticipated burden on busy air traffic controllers.
The D.C. ADIZ provides little, if any, additional security beyond that provided by the FRZ. Further, the application of the ADIZ to small general aviation aircraft has never been evaluated using a rigorous threat analysis, taking into account the fact that there is little risk posed by such aircraft.
Background
The FAA and other agencies issued a notam creating the Washington, D.C., ADIZ on February 10, 2003, in response to an increase to the National Threat Level Alert status and the pending hostilities in Iraq. The ADIZ restricts general aviation access to airspace less than 18,000 feet in roughly a 15- to 38-mile radius around Washington, D.C., and extends security measures outside of the preexisting 15-mile no-fly zone around Washington known as the FRZ. The ADIZ and FRZ impact 19 public-use airports.
To fly in the ADIZ, all general aviation aircraft (both IFR and VFR) must comply with IFR operational requirements. Specifically, they must file an IFR or ADIZ flight plan, maintain two-way radio communication, use a transponder and discrete beacon code, and follow standard air traffic procedures before entering the ADIZ.
These requirements have created significant operational and administrative problems.
From an operational perspective, the ADIZ has created significant problems. The ADIZ subjects a whole new class of aircraft and pilots to tracking requirements. The ATC infrastructure was designed and staffed to track only those aircraft under instrument flight rules (IFR). Inside the ADIZ, however, controllers are required to track visual flight rules (VFR) aircraft as well. That requirement has increased the workload for controllers by approximately 2,000 operations per day and consequently often diverts controllers from their primary responsibility of IFR traffic separation. The lack of consistency in handling aircraft subject to ADIZ requirements creates confusion for pilots and controllers alike. The ATC system was not designed and is not presently equipped to monitor and control the substantial increase in the number of aircraft that must be tracked as a result of the ADIZ requirements. The additional tracking burden causes significant delays for aircraft and increases the risk of ATC errors. In response to that problem, on May 1, 2005, the FAA agreed that controllers have no responsibility to provide VFR aircraft on ADIZ flight plans any services, such as traffic separation advisories and safety alerts.
The inability of the system to handle the administrative demands of the ADIZ is also evidenced by the extensive hold times faced by pilots waiting for clearance both on the ground and in the air. Due to the demand, general aviation pilots have routinely experienced delays in reaching ATC ranging from 10 minutes to over two hours. Pilots attempting to obtain discrete transponder codes while waiting clearance to take off have reported delays of over 45 minutes while holding on the runway with the engine running. Additionally, aircraft requiring IFR release clearance at nontowered airports are delayed because of the additional VFR traffic and report having difficulty in contacting controllers.
Flight instructors have complained that the ADIZ limits the space in which training aircraft can operate, creating safety issues for flight training.
The ADIZ has imposed significant economic burdens on the general aviation community.
The ADIZ has a far-reaching impact on the area's economy. Prior to the restrictions being implemented, general aviation generated almost $123 million in annual economic activity for the region and accounts for more than 60 percent of aircraft operations in the Washington area. There has been a reduction in the number of aircraft based within the ADIZ, a decrease in flight activity, and a decrease in transient traffic that have led to losses of between 30 and 50 percent of the business at the general aviation airports. Fuel sales have also decreased as much as 45 percent at some of the area airports. If the ADIZ is not eliminated or modified, it will permanently jeopardize the economic viability of general aviation operations in the Washington area.
The D.C. ADIZ also diverts substantial sums from the government that could be better spent on alternative measures. The FAA reports that it spends $18 million annually to support the ADIZ.
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 eliminated all the heightened security measures related to the Code Orange, except for the D.C. ADIZ. An ADIZ over New York, New York, was eliminated, as was a temporary flight restriction (TFR) over downtown Chicago, Illinois.
Congress has questioned the ADIZ requirements.
Congress has called security officials to testify on several occasions about the airspace restrictions surrounding Washington, D.C. In addition to holding hearings, committees and the full House of Representatives have passed legislation that seriously questions the need for the ADIZ.
In 2003, TSA Administrator James M. Loy testified in a congressional hearing that, following the attacks of September 11, some security officials might have overstated the threat from general aviation aircraft. In 2004, TSA Administrator David Stone told a congressional panel, "We are currently not aware of any specific information regarding terrorist plans to use general aviation or charter aircraft to strike targets in the Washington metropolitan region." Later that year, Jonathan Fleming, TSA's chief operating officer, testified that he was unaware of any specific, credible threat that terrorists will use general aviation aircraft to carry out an attack on Washington.
Under the leadership of the House Homeland Security Committee and the Transportation Committee, the U.S. House of Representatives has gone on record expressing its concern and opposition for the ADIZ.
On May 18, 2005, the U.S. House of Representatives passed H.R.1817, The Department of Homeland Security Authorization Act, which included the following provision:
"The Committee is concerned about the ongoing operational and economic impact associated with the 90-mile area of the Washington, DC ADIZ and encourages the Department of Homeland Security officials to work with other relevant agencies to update the reports and operational improvements called for in Section 602 of P.L. 108-176."
On May 26, 2005, the House Committee on Transportation and Infrastructure approved H.R.1496, The Return of General Aviation to Ronald Reagan National Airport Act. This bill clearly outlined the belief from committee members that the ADIZ should not be permanent. The relevant section of the bill reads as follows:
"The Committee also believes that reopening DCA is a first step to allowing GA operators' access to the National Capital Region. In addition to the 15-mile no fly zone surrounding Washington, DC, there is an almost 40-mile Air Defense Identification Zone (ADIZ), which was established by the FAA in 2003 as a temporary and specific response to a heightened security threat, the highest terrorist threat level since the attacks on September 11. The Committee understood that when the threat level was reduced, the ADIZ would no longer be needed by the FAA. Should the threat level again be raised, then the ADIZ might again be an appropriate response by the FAA. However, the ADIZ was never intended to be permanent. The Committee believes that the FAA should not make the ADIZ permanent."
Requirements
Any pilot who wishes to conduct flight into the Washington ADIZ must follow the requirements set forth in Notam 7/0206. Those requirements consist of the following:
ADIZ Flight Plan — You MUST file a flight plan for every departure* and entry into the ADIZ. This means two separate flight plans if you depart the ADIZ airspace for any reason, even if you do not land at an airport outside of the ADIZ.
Transponder — You MUST squawk a discrete transponder code, and your transponder must be operational at ALL times. If your transponder reads as intermittent or inoperable, or if ATC has trouble receiving it, you MUST exit the ADIZ immediately, no exceptions.
- If you are departing from a towered airport within the D.C. ADIZ, you will receive your squawk code from ground control before a takeoff clearance is issued.
- If you are departing from a towered airport within the D.C. ADIZ and are remaining in the pattern, squawk 1234 and contact the tower. (Pattern operations are exempt from the flight plan filing requirement as long as they remain in the pattern — this is detailed in Notam 7/0206.)
- If you are departing from a nontowered airport within the D.C. ADIZ, you should contact either clearance delivery or call Potomac Approach PRIOR to takeoff to receive your squawk code.
- If you are flying to an airport within the D.C. ADIZ from outside the D.C. ADIZ, contact Potomac Approach over the fix you designated in block five of your flight plan to receive a squawk code.
Communication — You MUST establish and maintain two-way communication with ATC before operating in the ADIZ.
There are several procedures and exceptions to the requirements listed above that are explained in Notam 7/0206 detailing the fringe airport special procedures, the Bay Bridge/Kentmorr procedures, and the procedures for flying in the FRZ Notam 7/0211.
AOPA has developed extensive D.C. ADIZ training tools and detailed information on operating in the airspace. For more information, go to the Notams and TFRs page.
AOPA's position
AOPA is opposed to making the ADIZ restrictions permanent. The D.C. ADIZ has imposed significant economic costs on general aviation and has increased the administrative burden on the FAA. The government has never provided a specific, intelligence-based threat assessment to justify the design and specific procedures of the ADIZ. Worse, the government has provided no evidence or analysis demonstrating that the ADIZ results in any measurable increase in security. In light of these facts, the government should eliminate the D.C. ADIZ restrictions and consider less burdensome measures that could provide an equivalent level of security.
GA security enhancements since 2001 have greatly improved airspace security.
In January 2003, the FAA issued a rule providing for security screening of current pilots and student pilots, and if the TSA determines a pilot poses a national security threat, it can direct the FAA to revoke that pilot's certificate. Thus, all pilots and student pilots are now subject to heightened security.
A number of regulatory restrictions have been imposed on flight training and access to aircraft by foreign nationals. Flight schools and aviation training centers must now notify and provide information, including fingerprints, to the DHS before giving flight training to non-U.S. citizens. Finally, all flight school employees must undergo security awareness training. These measures all make it more difficult for potential terrorists to obtain the training necessary to carry out an attack by air.
In addition, since 2001 a number of steps have been taken to improve security at general aviation airports. Working with AOPA, the TSA created "Security Guidelines for General Aviation Airports," providing a list of specific recommendations and best security practices. Also, TSA partnered with AOPA on the AOPA Airport Watch program to address vulnerabilities at airports and train pilots and airport personnel to spot and report suspicious activity. AOPA's Airport Watch includes a pilot hotline, linked to a national response center to report suspicious activity by calling 866/GA SECURE. Airport operators have voluntarily taken measures such as installing fencing and increasing police patrols at airports.
Finally, NORAD's new system of cameras and lasers called the visual warning system, implemented in May 2005, greatly enhances tracking and threat identification capabilities in the Washington-area airspace.
The FAA and security officials have not demonstrated the ADIZ provides any significant security benefit, or any real security benefit at all. In light of the fact that the government has made no serious attempt to analyze whether the ADIZ measurably increases security and in view of the missile defense system that is presently in operation around Washington, and the voluntary and regulatory security enhancements put in place since 2001, the ADIZ should be rescinded.
Status
July 30, 2007 — The FAA is continuing to review the more than 22,000 comments received during the NPRM comment period. Based on the most current information available, AOPA expects a final rule to be issued in early 2008.
November 7, 2005 — Transportation Secretary Norman Y. Mineta promised it at AOPA Expo in Tampa, Florida and the FAA delivered the formal paperwork, reopening the comment period on the Washington, D.C., Air Defense Identification Zone (ADIZ). By early November 2005, more than 18,600 pilots, an unprecedented number, had spoken out against making the ADIZ permanent around Washington and against allowing ADIZs to metastasize to other Class B airspace. With this announcement, the comment period was extended through February 6, 2006. The FAA also has granted AOPA's request for public meetings on the ADIZ. The meetings were held January 12 and 18, 2006, in the Washington, D.C., area.
August 4, 2005 — The FAA released the NPRM proposing to codify the existing restrictions within the ADIZ and FRZ, with one minor exception that would allow some relief from filing a flight plan and talking to ATC for traffic-pattern operations at nontowered airports. The FAA sought comments on the Paperwork Reduction Act portion of the NPRM through October 2, 2005, and comments on the actual rule through February 6, 2006.
Updated Wednesday, August 29, 2007 4:54:13 PM
