AOPA expresses concern over the four national security TFRs in effect in the Puget Sound area

Admiral Vern Clark
Chief of Naval Operations
Department of the Navy
2000 Navy Pentagon
Washington, DC 20350-2000

RE: Flight Restrictions: Washington State Department of Defense Temporary Flight Restrictions (TFRs)

Dear Admiral Clark:

I am contacting you directly as president of the Aircraft Owners and Pilots Association (AOPA) expressing our concern over the four national security temporary flight restrictions (TFRs) in effect in the Puget Sound area of Washington state since shortly after 9/11. These restrictions have a tremendous adverse operational impact on aviation in the Puget Sound area that has prompted some members of Congress to ask for an evaluation of the need for continuing these restrictions.

AOPA supports the elimination of these TFRs and recommends replacing them with an advisory similar to that used for nuclear power plants. That notice to airmen (notam) specifically advises that "...PILOTS CONDUCTING FLIGHT OPERATIONS WITHIN THE TERRITORIAL AIRSPACE OF THE U.S. ARE ADVISED TO AVOID THE AIRSPACE ABOVE OR IN PROXIMITY TO ALL NUCLEAR POWER PLANTS. PILOTS SHOULD NOT CIRCLE OR LOITER IN THE VICINITY OF SUCH FACILITIES...." This notam protects national assets while still allowing legitimate use of the National Airspace System by pilots.

Our organization appreciates the formidable challenges that faced the defense community in the uncertain times directly following the terror attacks and therefore did not oppose the implementation of these TFRs at that time. Like the majority of the post-9/11 airspace restrictions, we understood them to be temporary in nature, based on the uncertainties associated with security nationwide. However, in the more than two years since the attacks, numerous steps have been taken to address general aviation and national security, and the TFRs are no longer warranted. We are not supportive of any effort to make these temporary restrictions in the Puget Sound area "permanent."

Pilots and business owners in the Puget Sound area have contacted AOPA expressing their concerns about the adverse affects of the Navy's TFRs. Flying through this heavily populated airspace corridor is much like trying to thread a needle due to the multiple restricted areas that currently exist. AOPA staff members have worked with local users to quantify the impacts these flight restrictions have on the local flying communities. The DOD TFRs created by FDC Notices to Airmen (notams) 2/0447, 2/0449, 2/0451, and 3/6719 collectively have a tremendous impact to GA pilots in the Puget Sound region. Operations of pilots flying under visual flight rules (VFR) are the most significant. These include:

• Raising the minimum enroute altitude of several airways including V165, V287, and V4 airways;
• Restricts VFR arrivals/departures from/to north of Snohomish County Airport;
• Restricts VFR arrivals/departures from/to east of Jefferson County Airport;
• Restricts VFR arrivals/departures from/to north of Apex Airport;
• Closure of the Port of Poulsbo Seaplane Base;
• Restricts VFR arrivals/departures from/to northeast of Bremerton National Airport;
• Limits practice and training access to the Bremerton ILS 19 approach; and
• Extreme difficulty to VFR flights throughout the region.

Nearly all of these impacts result in extended flight routes around the restricted airspace areas. In some situations there is the potential for safety to be compromised as a result of maneuvering while arriving or departing airports to avoid restricted airspace abutting the airport traffic pattern.

In February of 2002, AOPA sent a formal request to the Federal Aviation Administration (FAA) requesting that these TFRs be reevaluated and possibility eliminated. We followed this action with an April 2003 request to the Transportation Security Administration (TSA), recommending that immediate steps be taken to eliminate the Puget Sound TFRs. The U.S. House of Representatives has called for a review of the DOD TFRs through language included in H.R.2115, the Federal Aviation Administration reauthorization legislation. In October 2003, U.S. representatives Rick Larsen and Jennifer Dunn wrote to Secretary of Defense Donald H. Rumsfeld outlining the tremendous operational impact the TFRs have on pilots and requesting that the department reevaluate them.

AOPA encourages the Department of the Navy to eliminate the four TFRs in the Puget Sound area.

Sincerely,

Phil Boyer
President, AOPA

December 4, 2003