AOPA's comments opposing plans to make the Washington, D.C., Air Defense Identification Zone (ADIZ) permanent stretch to 27 pages - the culmination of the association's extensive efforts to understand and explain the true impact of the ADIZ. Those efforts have included talking to hundreds of affected pilots, numerous meetings with security officials from the White House and a wide array of government agencies, an independent economic analysis of the ADIZ, and ongoing meetings with members of Congress.
To see how that information shaped AOPA's formal comments, see the excerpt from the executive summary below.
In Washington, D.C., more than 10,000 pilots (8,000 of which are AOPA members) are based at airports in the area. These pilots, as well as those not based in the area, conduct approximately 80 percent of the 900,000 operations annually from 19 public-use airports in the region. For those pilots who live and work in the area, the existing ADIZ flight restrictions are a daily problem. For members who live outside of Washington, D.C., the proposal to make the flight restrictions permanent raises a substantial concern that the FAA will use them as a template for establishing similar restrictions in the airspace around other major cities.
AOPA believes that the NPRM would make permanent a number of requirements that are difficult for general aviation pilots to meet, and which have already caused many pilots to reduce or stop flying in the Washington area altogether. The procedural requirements of the ADIZ, which were developed originally as temporary security measures with no public input, have had a substantial effect on the airports and businesses in the National Capitol Region, and have dramatically increased the workload on air traffic controllers - with minimal security benefit.
AOPA opposes the NPRM in its current form. The FAA must not implement the NPRM as a final rule but should modify the existing flight restrictions. AOPA contends that the FAA can maintain the special safety and security needs of the region but also better accommodate the practical needs of those who live and work and need access to the area.
AOPA believes that the Washington, D.C., area can be protected through a combination of the existing requirements of the 15-mile Flight Restricted Zone ("FRZ"); the existing temporary ADIZ requirements should either be eliminated or modified to apply only to larger, faster aircraft; and a new, simpler set of requirements applicable to slower, lighter aircraft. In the time since the existing requirements were first introduced, security in the region has been augmented by other measures, including ground-based missile systems, more nimble air interdiction capability with U.S. Customs helicopters, a laser warning system, and establishment of an interagency air security coordination center.
In addition, the pre-existing air traffic control requirements of the already highly restrictive Class B controlled airspace around Ronald Reagan Washington National, Dulles International, and Baltimore-Washington airports also aid in the surveillance of light aircraft. In AOPA's view, the FAA should implement safer, smarter, and more efficient security procedures for the airspace in the Washington, D.C., area. Logically, lighter aircraft, flying at slower speeds, do not pose the same threat as larger, faster aircraft, and therefore should not be subject to the same flight restrictions. The FAA should examine whether the current ADIZ requirements of filing a flight plan, obtaining a unique transponder code, and maintaining two-way communications with air traffic control should be modified for slower, lighter aircraft. The NPRM does not analyze that issue.
In Vision 100, Congress required the FAA to report every 60 days on the need for the ADIZ, and required the FAA to describe ways the ADIZ could be improved to increase operational efficiency and to minimize impacts on pilots and controllers. The FAA has essentially ignored that legal requirement, and the NPRM ignores it again. In light of the FAA's previous failure to perform the operational analysis required by Vision 100, AOPA requests that the FAA give serious consideration to the alternatives discussed in these comments.
November 2, 2005