March 31, 2004
The Honorable John L. Mica, Chairman
U. S. House of Representatives
2445 Rayburn House Office Building
Washington, Dc 20515-0907
Dear Representative Mica:
Two weeks ago on March 16, you led a subcommittee hearing on Opening Reagan National Airport to General Aviation. I testified before you that day on behalf of the more than 400,000 member pilots of the Aircraft Owners and Pilots Association (AOPA) and raised our concerns on the Washington, D.C., Air Defense Identification Zone (ADIZ).
The Washington, D.C., ADIZ is not operationally viable because the air traffic system was not designed to support the increased work load caused by its operational requirements. 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. This has created significant financial and operational hardships on pilots and the businesses that support their operations, and has created safety problems for pilots and is taking its toll on individual air traffic controllers.
That is why the aviation subcommittee acted by including Section 602 in Public Law 108-176 Vision 100 Century of Aviation Reauthorization Act. This section required that the FAA provide Congress with justification for the ADIZ within 30 days of enactment. The FAA is also required to "include a description of any changes in procedures or requirements that could improve operational efficiency or minimize operational impacts of the ADIZ on pilots and controllers."
It has been well over 90 days since the initial reporting requirement in the law was established, yet the FAA has not provided this required report to Congress. This is insulting to Congress and the pilots in the area, who continue to be smothered by operational requirements that are impractical and difficult to meet.
To fly in the ADIZ, all general aviation aircraft must comply with operational procedures similar to those designed for instrument flying. Specifically, pilots must file either an ADIZ flight plan or an instrument flight plan, maintain two-way radio communication, use a transponder with an assigned discrete beacon code, and follow standard air traffic procedures before entering the ADIZ. At the hearing you heard testimony from me quoting the National Air Traffic Controllers Association:
Simply put, the Washington ADIZ creates an unworkable situation for both pilots and controllers. The ATC system is being asked to perform a function for which it is not designed and for which it lacks the capacity. It creates confusion for both pilots and controllers, proper resources have not been allocated to provide equipment and procedures to meet the objective, and ultimately there is no evidence to suggest that the intended goal is achieved.
These requirements have overloaded the Washington-area ATC system, and pilots continue to experience extreme difficulties in gaining access to the 19 public-use airports in the ADIZ.
I ask that you hold the FAA and the other agencies accountable for the actions that they are taking in the National Capitol Area that are adversely affecting general aviation. The congressionally required report, and, most importantly, the elements of that submission to address operational problems of the ADIZ, is extremely important to the aviation community. Please insist the FAA not insult your committee by this lack of response and to immediately meet the requirements of the law by reporting back to Congress.