Secretary Tom Ridge
Director of Homeland Security
Office of Homeland Security
The White House
Washington, DC 20502
Dear Secretary Ridge:
I am writing on behalf of the Aircraft Owners and Pilots Association's (AOPA) almost 400,000 members to express my organization's opposition to a Department of Defense (DOD) request to arbitrarily expand the standard Presidential movement temporary flight restriction (TFR) to a 30-mile radius, including a no-fly zone out to 10 nm and very restrictive flight procedures for operations in the 10- to 30-mile radius of the TFR.
In the "backyard" of AOPA's headquarters located in Frederick, Maryland, this translates to a swath of airspace that is 60 miles across, or the driving distance from the White House to the front door at Camp David. AOPA urges you to not support the DOD request because it is excessive and would unnecessarily restrict air commerce. The current 10-mile Presidential movement TFR provides an appropriate level of protection, without unnecessarily infringing on general aviation's freedom of transit.
Pursuing enforcement action against violations, we believe, is the most important step that security officials can take to preserve the security functions of the TFRs.
Strong enforcement of the current 10-mile Presidential TFRs is the best course of action for maintaining presidential security. Pursuing enforcement action against violations, we believe, is the most important step that security officials can take to preserve the security functions of the TFRs. To that end, we continue to emphasize compliance with airspace restrictions to our members, and those associated with the President are of the highest importance.
The DOD request does not appear to be in response to any specific credible threat, nor does it address any ongoing security concern posed by general aviation.
AOPA is concerned that the DOD request does not appear to be in response to any specific credible threat, nor does it address any ongoing security concern posed by general aviation. Security officials, who have shown little interest in understanding the general aviation flight environment, are pushing for this increase (and in fact have been pushing for it for over a year) simply because they want it, without any justification or even support from the Transportation Security Administration (TSA) and the Federal Aviation Administration (FAA).
At no time in its 61-year history has Camp David been subject to an airspace restriction of this magnitude.
As mentioned above, this arbitrary size increase would be particularly bad in the area of Camp David (P-40), Maryland. The 30-nautical-mile restriction around P-40 would impact 11 public-use airports in the Washington metropolitan area, including two large general aviation airports, Hagerstown and Frederick Municipal, which sit just on the edge of the current 10-nm-radius TFR. 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 would be similarly impacted by the restriction. The latter has the further security of an FAA control tower, monitoring direction of flight for arrivals and departures.
At no time in its 61-year history has Camp David been subject to an airspace restriction of this magnitude. In use as a presidential retreat since 1942, Camp David has been the site of numerous summits and meetings. After 9/11 it has been used extensively by President Bush and visiting dignitaries. At no point during this time has Camp David ever been under direct threat by a general aviation aircraft, and the proposed airspace expansion is unwarranted. In fact, incursions into the current P-40 airspace area have decreased over time. Pilots are aware of the current restriction and are taking the appropriate steps to avoid the airspace.
Expanding airspace restrictions over P-40 would have a devastating impact on general aviation operators, airports, and the local economy.
AOPA conducted an economic impact analysis of the 11 public-use airports threatened by the proposed TFR. According to data AOPA collected through phone surveys by members of our staff with airport management, airport businesses, and flight school operators, the impact of expanded airspace restrictions around P-40 would be significant. With 244 based employees and 842 based aircraft at the 11 airports contacted, they would lose an average of $236,124 per day during an airspace closure. These airports support 456,269 annual aircraft operations, which break down to 138,150 transient operations, 309,285 local operations, and 8,834 air taxi/air carrier operations. Expanding airspace restrictions over P-40 would have a devastating impact on general aviation operators, airports, and the local economy. Even if limited operations were permitted, using the restrictive Air Defense Identification Zone (ADIZ) operational procedures (requirement for flight plan, discrete transponder code, and two-way communication), the impact would be severe. The FAA's air traffic system is unable to support these operational requirements, and as a result general aviation is "de facto" grounded.
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.
The current airspace restrictions have forced many metropolitan D.C.-area pilots to relocate to the west. The 15-nautical-mile flight restriction surrounding Washington, D.C.—special flight rule 94 (SFAR 94) and 30-mile air defense identification zone (ADIZ) have had a cumulative impact on these pilots, and many have relocated to airports like Frederick and other locations west of D.C. 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 30-nm-radius air defense identification zone and flight free zone around Washington, D.C., creates a "wall" of restricted airspace (north to south) nearly 70 nautical miles long. When you consider that general aviation 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.
The most troubling question is why does the security community feel such restrictions are needed, when the 5-nm-radius TFR proved adequate for more than a year following the tragic events of 9/11, even during a time of the code orange heightened security alert? Last year that 5-nm-radius restriction was suddenly expanded to 10 nm with no explanation or justification.
I ask that you preserve the airspace around Camp David and other locations and limit the presidential movement TFRs to their current 10-nm-radius size.
April 9, 2003