The Honorable Marion Blakey
Federal Aviation Administration
800 Independence Ave., SW
Washington, DC 20591
Dear Administrator Blakey:
I am writing on behalf of the Aircraft Owners and Pilots Association's (AOPA) 388,000 members to express our concern over the proliferation of airspace restrictions impacting flying in general aviation. Most recently, a 10-nautical-mile-radius temporary flight restriction (TFR) has been established around Camp David (P-40), Maryland, in anticipation of a Presidential visit. AOPA has also learned that this restriction may be expanded to a 30-nautical-mile radius, mirroring recent restrictions put in place at the Crawford ranch in Texas and the Bush compound in Kennebunkport, Maine. AOPA is on record opposing the new restrictions at these locations as well. This sudden proliferation of TFRs prompts the question, which is perhaps rhetorical, what has changed in the nation's threat profile to drive these new airspace restrictions?
These TFRs impact general aviation flying and flight training, air charter operations, and airport businesses. In the case of Camp David, the TFR is over a busy Maryland metropolitan area and seriously impacts general aviation commerce. For example, two large general aviation airports, Hagerstown and Frederick Municipal, both sit just on the edge of the 10-mile TFR, and their respective operations are negatively impacted. The TFR closes Frederick's precision instrument landing system to all practice approaches and student traffic. Second only to BWI, Frederick is the busiest airport in the state of Maryland. It is a magnet for business aviation and student training and is home to a large soaring club. Hagerstown Airport is the fifth busiest Maryland airport, and it is similarly impacted by the restriction. With a stellar weekend weather forecast, the new Camp David restriction will result in lost revenue for the flight schools at Hagerstown and Frederick. The fact that this restriction will be in place over a beautiful fall weekend compounds this impact.
Pilots in the metropolitan D.C. area, over 35,000 of them AOPA members, are already suffering under the most significant post-9/11 airspace restrictions in the entire country. Many of these pilots were forced to relocate to the west by the 15-nautical-mile flight restriction surrounding Washington, D.C.—Special Federal Aviation Regulation 94 (SFAR 94). Now these operators face additional restrictions surrounding Camp David. For transient pilots, the impact is equally negative. The Camp David TFR (especially if it grows to 30 miles), coupled with the existing SFAR 94 airspace, creates a "wall" of restricted airspace (north to south) nearly 50 nautical miles long. When you consider that GA has already lost access to Reagan National, College Park, Hyde Field, and Potomac Airpark, the burden placed on civil pilots by this new restriction becomes evident.
AOPA is very concerned that pilots will inadvertently violate the expanded Camp David restriction. Typically the notam system does a poor job of disseminating flight restriction information, and as you saw firsthand just two weeks ago at AOPA's Expo in Palm Springs, the notam system does not provide any graphical depiction of the airspace to assist pilots. Furthermore, in September the FAA produced a special issuance aeronautical chart that clearly depicts the "expanded" P-40 airspace restriction at 5 nautical miles. This conflicting information creates confusion and potential for mistakes.
A 30-nautical-mile restriction around Camp David would cover some 66 private- and public-use airports in Maryland, Virginia, West Virginia, and Pennsylvania. The most troubling question is, why does the security community feel such restrictions are needed, when the 5-mile TFR has proven adequate for more than a year, even during the time of the code orange heightened security alert?
Marion, I urge you to take action to educate the Secret Service about the effects that TFRs have on aviation. I also implore you to restore the airspace around Camp David and limit the TFR to the charted 5-mile radius.
November 8, 2002