AOPA recommends two-pronged approach to prevent presidential TFR incursions

Mr. Steven J. Brown, ATS-1
Associate Administrator, Air Traffic Services
Federal Aviation Administration
800 Independence Ave, S.W.
Washington, DC 20591

Dear Mr. Brown:

On behalf of the 385,000 members of the Aircraft Owners and Pilots Association (AOPA), I am writing to express my concern over the sudden proliferation of large temporary flight restrictions (TFRs), such as those surrounding President Bush's ranch in Crawford, Texas, and the Bush family compound in Kennebunkport, Maine.

The size and duration of these TFRs, coupled with the ambiguous (and sometimes poor) wording used in the notices issued to pilots, creates a situation that is more conducive to violating pilots than promoting national security. AOPA asks that your office, along with those of the Transportation Security Administration (TSA) and the Secret Service, commit to work with the civil aviation community to reduce the number of airspace violations through the elimination of large, wholesale restrictions. This collaborative approach would do much to help federal agencies in the performance of their respective duties, while avoiding untenable operational burdens to general aviation pilots. Short of eliminating these TFRs, the FAA must take steps to improve communication of the restrictions to local airspace users.

AOPA was recently asked by the FAA for some possible reasons for the increased numbers of violations to the Crawford, Texas, TFR. The following highlights our response and will hopefully help you to better understand the conditions under which general aviation pilots must now operate:

• This is the first time a TFR of this size has been used to "protect" the President. The pilots in this area are used to 10-nautical-mile (nm) restrictions, not 30 nm. This increase in size envelops nearly 7,400 cubic miles of additional airspace! Increasing the volume of airspace has a dramatic and exponential impact on the number of flight operations encumbered by this restriction.
• There are four airports that lie proximate to the TFR border. Without a definitive airport listing or graphic, an incorrect "hand plot" could lead pilots at these facilities to assume their airports fell outside of restricted airspace.
• The TFR envelops over 20 private airports that may be too remote for VHF ground or low-altitude air traffic control (ATC) reception. Without established (and published) procedures for these airports, pilots can easily get themselves into trouble due to a lack of radio coverage.
• The TFR extends over some very remote areas. Along most of the TFR's border, there are no good landmarks for identification. This makes it easy for a pilot to stray into restricted airspace.
• Updates to the Federal Aviation Administration's (FAA's) graphical TFR Web site are not always timely. For example, one day prior to the effective start time of the Kennebunkport restriction, the FAA's graphical TFR Web site had not been updated to reflect this restriction. This compromises the value of this site and may serve to lull pilots who check into a false sense of security when a restriction is absent.
• The lack of clarity in the notices to airmen (notams) also creates difficulties for pilots. For example, what exactly is meant by "flights within this area are for ingress/egress only?" That could be interpreted to mean for ingress/egress to a particular airport, ingress/egress of the restricted airspace, etc. While AOPA very much appreciates the effort to be precise in the construct of notams, the wording still needed to be clarified. AOPA also needs assurance that all of the principles within the federal government, including the FAA, TSA, Secret Service, and Department of Defense agree as to what operations are and are not permitted.

The establishment and enforcement of such large restrictions places a tremendous demand on the resources of the United States, and to what end? Violations continue, civil pilots are losing their hard-earned certificates, FAA personnel conduct more investigations and process more paperwork, and military airframes (and pilots) continue to accumulate flight hours at great expense to the American taxpayers. With a reduction in the terrorist threat level from orange to yellow, AOPA asks stakeholders within the federal government to adopt a more reasonable approach to this problem, one that mitigates the impact on airspace users and airports by soliciting active input of the civil aviation community. AOPA is concerned that absent such an approach, violations may continue, as will the drain on national resources.

AOPA recommends a two-pronged approach to reducing the TFR incursions by general aviation pilots. First, the FAA must work with security officials to reduce the size and scope of presidential and other security TFRs. Second, the FAA must take the following steps to improve communication of the TFRs to local pilots, especially in the areas of Kennebunkport, Maine; Crawford, Texas; and Washington, D.C.:

• The FAA should distribute a mailing to pilots and airport operators (both private and public) in the areas surrounding Kennebunkport, Maine; Crawford, Texas; and Washington, D.C., outlining the potential for TFRs during times of national crisis or Presidential visits.
• A complete listing of the airports impacted by the Presidential TFR airspace should be included in the notice to airmen.
• A current graphical depiction of the TFRs should be maintained on the FAA's Web site, along with clear landmarks to help pilots identify the boundaries of the airspace.
• Clear instructions regarding flight prohibitions and permissions, including contact information for further details, should be provided in the notice to airmen.
• VFR waypoints and radial/DME fixes need to be given to help pilots identify the TFR boundaries.
• A public outreach program should be undertaken whereby security officials and the FAA visit each airport impacted by the Presidential TFRs in Crawford, Texas, and Kennebunkport, Maine, to discuss the restrictions and ways to improve communication.

As in the past, AOPA stands ready to assist the government in its efforts to enhance national security, while preserving the rights that we as citizens have come to value so dearly. We look forward to meeting with you this Thursday as we take this first step toward addressing our mutual concerns.

Respectfully,

Andrew V. Cebula
Senior Vice President
Government and Technical Affairs

October 8, 2002