AOPA letter on SUA

AOPA letter regarding special-use airspace

Mr. Barry Valentine
Acting Administrator
Federal Aviation Administration
800 Independence Avenue, SW
Washington, DC 20591

RE: Recent Warning Area Incident

Dear Barry:

We thought it might be worthwhile to submit a few comments on the recently publicized conflict between Air National Guard F-16s and a commercial jet transiting a Warning Area off the coast of New Jersey. While AOPA views this specific incident as isolated, we feel it is indicative of the type of conflict that can arise when communication breaks down. The event seems to dramatically illustrate the shortcomings of the present communications system between the Federal Aviation Administration (FAA) and the military

Military and civil aviation operators have repeatedly demonstrated that they can jointly utilize airspace safely. To do this, pilots need timely access to traffic status information. However, as this incident illustrates, the information exists but is not always disseminated to the end users -- the pilots. The problem in this instance was not necessarily with equipment (aircraft positions were known, and each of the pilots was in contact with a controlling agency), but with communication procedures. Equipment limitations may result in excessive controller workloads that make it difficult or impossible to meet user requirements.

Not only is the military and FAA communication woefully behind in usefulness, but the FAA does not have an effective system to inform civil operators of the planned and actual status of Special Use Airspace (SUA). As a result, general aviation pilots have a great deal of trouble accessing the strategic and tactical information needed to transit SUA safely. The current Notice to Airman (NOTAM) system is woefully inadequate and does not provide real-time SUA information in a usable format. The military acknowledges that they only use SUA a fraction of the charted available time. When a general aviation pilot calls up a Flight Service Station (FSS), he or she often gets a rote readback of the charted times, and is not able to find out whether the airspace is actually scheduled or if it contains military activity. Additionally, each FSS only has information on SUA within a 100 nautical mile radius of its location. These shortcomings make it difficult to plan a safe and efficient flight.

The FSS coverage limitations, the inaccurate representation of the active times for SUA on aeronautical charts, combined with a NOTAM system that cannot provide meaningful and timely SUA status, leave the general aviation VFR pilot in a quandary. Should a pilot simply take-off and hope he can raise Center? The Air Traffic Controller's primary mission is to separate aircraft under instrument flight rules, not aircraft from airspace. Therefore, giving timely or even accurate SUA status to a VFR pilot is low priority. Should a pilot just fly on through VFR and hope for the best, or perhaps go ahead and just plan to circumnavigate the airspace in question, at the penalty of increased flight time and expense?

While AOPA recognizes that the FAA has begun to work with the industry to improve the dissemination of information to pilots, the process is creeping along much too slowly. To better avoid incidents such as recently occurred in the Warning Area, the FAA must accelerate this process.

AOPA urges the FAA to actively work with the aviation industry to expeditiously improve the flow of airspace status information to the end users, the pilots.

Thank you very much for considering our views on this. I would be pleased to discuss the issue with you in more detail.

Sincerely,

Phil Boyer
President