Mr. Ronald E. Morgan
Air Traffic Services
Federal Aviation Administration
800 Independence Avenue, SW
Washington, DC 20591
RE: Temporary Flight Restrictions (TFRs) in the New York VFR Corridor
Dear Mr. Morgan:
This letter concerns the lack of user notification regarding TFRs imposed on the Hudson River VFR corridor west of Manhattan from May 26 through May 31. The TFRs are associated with the U.S. Navy’s “Fleet Week” and are imposed by the Federal Aviation Administration (FAA). There is no justification for these TFRs, which prohibit VFR flight in portions of the corridor for several hours each day. They appear to reflect a change in FAA policy concerning TFRs, and closing the VFR corridor over a holiday weekend, with no prior notification to users, is an untenable occurrence that could have been avoided.
There are nine TFRs for the following activities:
The notice states that the TFRs are to prevent unsafe congestion of helicopter and other aircraft traffic in the vicinity of the demonstrations.
Despite past assurances from the FAA of a commitment to coordinate with users concerning TFR policies, these TFRs were issued with absolutely no prior coordination or notification to the users. Shutting down this corridor over a major holiday weekend will severely impact general aviation users in the area and necessitate long, unplanned, circuitous re-routes around the New York Class B airspace.
The only notice pilots will receive is an FDC notam, which, unless specifically requested during a briefing, is not disseminated. The notam system is woefully inadequate, and its limitations make it very difficult to access FDC notam information. It is troubling that the FAA had ample advance notice to publish the TFR notams in the FDC publication but did not make it a priority to notify the affected users of the proposed action.
This lack of user coordination is in stark contrast to the fine manner in which the FAA coordinated with users during the recent North Atlantic Treaty Organization (NATO) 50th Anniversary Summit held in Washington, D.C., April 23 though 25, 1999. Coordination between the FAA and users allowed reasonable general aviation access to Washington area airspace while still providing a high level of security. The TFR information was widely disseminated to the general aviation community in advance of the event, which promoted cooperation. The management of this event is an example of the benefits of coordination and communication with the user community.
After all the promises that the FAA has given us concerning TFRs, this is an extremely disappointing development. There is no operational justification for these TFRs, and they accomplish nothing meaningful to protect DoD aircraft.
There is absolutely no need for TFRs during Fleet Week. The VFR corridor has a published aeronautical advisory frequency that pilots monitor, and the DoD aircraft could self-announce prior to entering the corridor. This action alone would do more for aviation safety than any amount of TFRs could ever accomplish. In addition, issuing TFRs for aerial demonstrations clearly reflects an FAA policy change regarding TFRs. This policy change was implemented with no prior notification to users, let alone opportunity for user input.
The FAA has not issued TFRs for annual Fleet Week events in the past, and to our knowledge, there have been no reported near-midair incidents with non-participating air traffic. What are the justifications for suddenly issuing TFRs for this event? Approval and publication of these TFRs required pre-planning coordination. Why were the users not notified?
A few years ago, when we had a similar TFR problem, we received a letter from the FAA Air Traffic Division stating the staff’s intent to coordinate TFRs with affected users. The FAA also stated a commitment to establish TFR policy standards, but to our knowledge, this has not occurred.
These TFRs were imposed for an event that never before required TFRs, they occur during a major holiday weekend when corridor use is high, and they were not coordinated with the users. We regret that we have been unable to work together to prevent issues like this one, but without prior knowledge, our efforts to enter into a meaningful dialogue are hampered.
It is clear the entire TFR process is flawed, and we bring this information to your attention in hopes that your organization will seriously consider addressing the core issues that have created this unfortunate situation. In the meantime, an evaluation to determine whether Fleet Week activities truly justify these TFRs is greatly appreciated.
Dennis E. Roberts
Government and Technical Affairs
May 27, 1999