Mr. Jeff Griffith
Air Traffic Service
Federal Aviation Administration
800 Independence Avenue, SW
Washington, DC 20591
Re: Graphical TFR Notams
Dear Mr. Griffith:
The Aircraft Owners and Pilots Association (AOPA), representing the interests of over 380,000 general aviation pilots nationwide, has learned that your office is developing a graphical temporary flight restriction (TFR) Notice to Airmen (notam) product. This graphical TFR product is intended to aid flight service station (FSS) specialists in interpreting the confusing textual airspace descriptions currently used in TFR notams. It is our understanding that a working group has been formed to develop a prototype product, comprised of Federal Aviation Administration (FAA) and National Association of Air Traffic Specialists (NAATS), the union representing the interests of FSS specialists. With this letter, AOPA requests that the FAA include AOPA in its working-group activity. Graphical TFRs are of great interest to general aviation pilots because of the critical safety of flight and system efficiency issues related to these airspace restrictions.
Prior to the September 11, 2001, terrorist attacks, the number of TFRs issued was relatively limited, and for the most part pertained to Presidential movements and aerial forest firefighting activities. Because Presidential TFRs are small, uniform in size, and of limited endurance, they do not typically have a significant impact on general aviation pilots. In some isolated cases they have been problematic but, for the most part, manageable. In the case of firefighting TFRs, recognizing notam system shortfalls, the Forest Service developed an outreach and education program, called "Stay Away, Stay Alive," to increase pilot awareness of the aerial hazards associated with fire-fighting activities. This program has worked well, but it does not solve the underlying notam system problems.
For many years, serious shortcomings with the existing notam system have plagued the FAA, air traffic controllers, and the general aviation community. The problems relate to the actual notam formatting and an ineffective and inadequate dissemination methodology. Post-September 11th, these system shortfalls have created considerable operational confusion for pilots and FAA air traffic controllers alike, resulting in unintentional airspace incursions, with potentially deadly consequences as a result of the "shoot-down" policy being enforced by the military. Put simply, the safety and efficiency of the air traffic system are compromised by the current notam system deficiencies.
The notam format is based on archaic teletype keystroke limitations and difficult to decipher. This is especially true in the case of TFRs, the descriptions of which often defy interpretation. The current notam platform is at capacity and of limited functionality. Local (L) notams are no longer even put into the system for wide dissemination. Further, notams are distributed to air traffic facilities via a hodgepodge of methods that include telephone calls and faxes. Simply put, the system is not fully automated, and it does not widely disseminate notams to service providers or users in a timely and easily accessible manner.
AOPA is pleased that your office is being proactive in addressing this notam system shortfall by developing the graphical TFR format. The purpose of our participation in the work group would be to ensure that the FAA's final product meets the operational requirements of the general aviation community—easily understood, widely disseminated TFR information—available to users (outside of the FAA) as soon as possible.
Given the growing proliferation of security TFRs, the military's shoot-down policy, and the current notam system deficiencies, AOPA looks forward to your positive response to its request to participate in the development of a graphical TFR notam product that is widely disseminated to service providers and users.
Melissa K. Bailey
Air Traffic Services
Cc: Mike Cirillo
February 19, 2002