The Honorable Jane Garvey
Federal Aviation Administration
800 Independence Avenue, SW
Washington, DC 20591
On behalf of the over 380,000 members of the Aircraft Owners and Pilots Association (AOPA), I want to emphasize our support for the Federal Aviation Administration's responsibility for the airspace. Since the events of 9/11, many temporary flight restrictions (TFRs) have been issued, affecting pilots and FAA employees charged with controlling traffic, enforcing airspace/air traffic regulations, and briefing pilots. We have collectively spent a great deal of resources educating all those involved during this difficult time.
An area of confusion has been the vague language of the blanket-sporting event, open-air assembly notam 1/3353 that currently reads:
1/3353 - ... SPECIAL NOTICE ... FLIGHT RESTRICTIONS EFFECTIVE IMMEDIATELY UNTIL FURTHER NOTICE. PURSUANT TO 14 CFR SECTION 99.7, SPECIAL SECURITY INSTRUCTIONS. THIS IS A RESTATEMENT OF A PREVIOUS RESTRICTION. ALL AIRCRAFT OPERATIONS ARE PROHIBITED WITHIN A THREE NAUTICAL MILE RADIUS/3000 FEET AGL AND BELOW OVER ANY MAJOR PROFESSIONAL OR COLLEGIATE SPORTING EVENT OR ANY OTHER MAJOR OPEN AIR ASSEMBLY OF PEOPLE UNLESS AUTHORIZED BY ATC. WIE UNTIL UFN
This has been difficult, if not impossible, for both pilots and the FAA to understand and follow. While it is preferable the notam be withdrawn, if the concept is to be retained for some period, it must be revised. Recently, we have been engaged with representatives from professional and collegiate sporting associations about this notam.
AOPA has assisted in the development of language revising this notam providing clarification for pilots on "major sporting events." Revised language is needed to provide pilots with clear and concise direction and enable airspace users the resources to remain outside restricted airspace.
The concept for revised wording reads:
As the FAA develops revisions to temporary flight restrictions to address security issues for events held in stadiums, consideration should be given to limiting the scope of the TFR to large-crowd events taking place in open-air (including those with retractable domes) stadiums with a seating capacity of 30,000 or more. The prohibition on aircraft operations should apply within a three-nautical-mile radius/3,000 feet above ground level of the stadium, except for aircraft arriving at or departing from airports under ATC control (or at nontowered airports) using standard air traffic procedures, and would be in effect one hour prior to the event until one hour after the event. This restriction would apply to professional football, professional baseball, and college football.
AOPA realizes any waivers to national security notams are subject to security analysis and expects both the Transportation Security Administration (TSA) and the FAA to act accordingly.
We strongly encourage you to take these suggestions into consideration as revisions to the current language are developed. And AOPA extends the offer of assistance as you take on this necessary endeavor.
July 12, 2002