Is The Government Justified In Closing Airspace Over King's Bay?

The General Aviation Manufacturing Association (GAMA) doesn't think there's a need for the FAA to close off the airspace over the King's Bay submarine base in Georgia. So, GAMA Vice President for Government Affairs, Brian Riley, has put his organization's opinion on paper and in the federal record. In part, the letter reads:

This action proposes to establish a prohibited area (P-50) over the U.S. Naval Submarine Base at Kings Bay, GA. The proposed prohibited area would replace a Temporary Flight Restriction (TFR) that is currently in effect. The FAA is proposing this action to enhance the security of the Naval Submarine Base, at Kings Bay, GA. However, this NPRM does not reference any specific and credible risk information that justifies the federal government’s proposed action to establish prohibited area P-50.

GAMA cannot support the precedence that would be created by the permanent closure of airspace without adequate security justification. THE IMPORTANCE OF GENERAL AVIATION General aviation (GA) is defined as all aviation other than military and commercial airlines. It is one of our nation's most important and dynamic industries, carrying 160 million passengers annually on general aviation aircraft ranging from two-seat training aircraft to intercontinental business jets. There are over 230,000 general aviation aircraft in the United States operating under part 91, 125 and 135. This includes personal and recreational flying, traffic observation and news reporting, crop dusting, emergency medical evacuation and business air travel. General aviation is relied on exclusively by more than 5,400 communities for their air transportation needs (scheduled airlines only serve about 500) and approximately 70 percent of the hours flown by general aviation are for business purposes.

GAMA has seen a handful of private enterprises and local governments, long opposed to general aviation operations for non-security reasons, begin to use security as a pretext for airspace restrictions. GAMA is working to ensure that any flight restrictions or security procedures are implemented only in response to an identified specific or credible risk and not due to local political pressure.

The question regarding this NPRM is does it meet the test of a specific and credible risk that forces the federal government to permanently close airspace? Based on the information provided in the NPRM, GAMA does not believe the Department of Defense (DOD) has provided enough information as to the security threat that necessitates the permanent closure of the airspace. WHY GAMA CANNOT SUPPORT THE PROPOSED PERMANENT RESTRICTION Nothing within the NPRM suggests why the DOD wishes to make this TFR permanent.

The only information provided is the one sentence request by the United States Navy in the NPRM that states:

"Due to the current world situation and continued security concerns at this facility, the U.S. Navy has requested that the FAA designate a prohibited area at Kings Bay, GA, to enhance Navy security efforts at the base. This proposal responds to that request."

While GAMA is not asking the DOD to release security sensitive information in a public forum, we are requesting that the DOD provide adequate justification for their request. GAMA believes the following questions must be fully addressed before it can support the permanent closure of this airspace.

What security purpose will be accomplished by the request for a permanent 2-NM, 3,000 feet MSL flight restriction above the facility? What GA activity has DOD officials concerned for the security of the facility? Did these security concerns exist before September 11, 2001? If not, what has occurred since September 11, 2001 to concern the DOD with GA access to this airspace? Does DOD have credible threats by GA against the facility? Has DOD pursued alternative means with GA other than the published NPRM?

GAMA has supported federal security actions regarding GA where the circumstances warrant federal action. If the federal government has provided a specific and credible reason for such actions, GAMA has supported these activities. As discussed earlier, GAMA has provided technical assistance during the formulation of federal security policies and assisted in their implementation in the GA community. GAMA is ready to assist the FAA and DOD when possible, but we cannot support this NPRM until federal officials have taken the time to fully address the security reasons for the permanent closure of the airspace in question. GAMA cannot support the precedence that would be created by the permanent closure of airspace without adequate security justification. If the FAA agrees to the DOD request and closes the airspace over the Kings Bay, GA facility without adequate justification, how could the FAA ever deny any future request by the DOD in which the only submitted justification for the action is to "enhance security efforts at the base"?

Sincerely,

Brian Riley

Vice President, Government Affairs

FMI: www.generalaviation.org