AOPA's Letter (4-16-03)
The Honorable Asa Hutchinson
Undersecretary for Border, Transportation Security
Department of Homeland Security
3801 Nebraska Avenue, NW
Washington, D.C. 20528
Dear Undersecretary Hutchinson:
The almost 400,0000 members of the Aircraft Owners
and Pilots Association (AOPA) were very encouraged by the news
today that the federal government has lowered the National Threat
Level Alert status to Yellow, and will be "standing down" Operation
Liberty Shield. Nearly 65,000 AOPA members base their airplanes
and/or fly in the New York and Washington DC areas. As Americans
concerned with this nation's security, these pilots have tolerated
an ill-conceived operational plan during the period of heightened
alert. Now, with the reduction in the nation's threat condition,
the Aircraft Owners and Pilots Association (AOPA) requests the
immediate suspension of the Air Defense Identification Zones (ADIZ)
around Washington DC and New York City.
Fortuitously, you and I have a scheduled meeting next Monday
morning (April 21) and this request will be the most important
discussion point. Over the past several days I have been conducting
meetings with our members in the New York City area and they have
made it clear that these restricted flying areas are an operational
disaster. Some 91% of the more than 400 pilots attending a meeting
held in Teterboro, New Jersey, said the New York ADIZ had adversely
impacted their flying.
In public statements, the Transportation Security Administration
(TSA) and the Federal Aviation Administration (FAA) emphasized that
enhanced airspace control measures were put into place consistent
with a heightened National Threat Level Orange. TSA Administrator
James Loy was quoted in the TSA press release as saying, "We
appreciate the cooperation of the general aviation community as we
implement sound security measures and tighten our defenses during
this period of heightened alert."
AOPA's
members are now not just asking, but demanding with the reduced
threat level, that the ADIZ areas be rescinded. We want to support
your efforts on national security and realize this may mean
temporary restrictions, however, elevated threat conditions should
not be an excuse to impose airspace restrictions that are not
eliminated after the threat conditions are lowered. Will these
restrictions be like taxes, once imposed as a temporary measure,
they never go away? What is so different now, than during almost
all of last year when there was no ADIZ, and the nation was
challenging the Middle East with war?
The TSA, FAA and other agencies created the ADIZ for Washington,
DC and New York City in response to heightened terrorism threat
levels. This encompasses 30 nautical miles around Kennedy, La
Guardia, and Newark Airports and impacts 27 public-use landing
facilities in New York. The Washington ADIZ covers some 23,000
square miles around Baltimore, Washington, and Dulles International
Airports and impacts some 23 public-use facilities. General
aviation pilots in the ADIZ must maintain two-way radio
communications use a transponder and discrete beacon code, file
IFR/VFR flight plans, and follow standard air traffic procedures
before entering the ADIZ. This has overloaded the ATC system,
causing extreme difficulties for pilots in gaining access to the
airspace.
AOPA has been flooded with complaints from pilots
who have been subject to lengthy delays and even denied service.
For example, a pilot in the Washington DC area reported waiting 55
minutes on the ground for approval of a flight plan, 30 minutes to
get through on the telephone to the FAA Flight Service Station and
another 20 minutes for a briefer to actually pick up the phone. All
told, this pilot invested more than 1 hour and 45 minutes to file
the required ADIZ flight plan, contact ATC, receive a transponder
code, and obtain clearance into the ADIIZ -- an amount of time
equal to the total flight time for the planned trip! An AOPA member
in New York waited "more than two hours on the ground after engine
start up" to receive clearance into the New York City ADIZ -- for a
flight that was to take less than one-hour enroute! These are but
two of the many horror stories we have heard that includes
countless reports of extreme delays, cancelled flights, terminated
flight lessons, and lost business at general aviation airports.
Based on real world experiences by pilots, the ADIZ is not
working. It is clear that the air traffic control system does not
have the resources in place to effectively manage, for extended
periods of time, the volume of general aviation traffic requiring
access. This system was not designed to accommodate visual flight
rule traffic loads; rather it was put in place to separate aircraft
on instrument flight plans, mainly commercial air carriers. Early
in the implementation of the Washington DC ADIZ, AOPA spent
considerable time and resources developing a comprehensive plan on
how to make it operationally more efficient, while retaining the
perceived or real security the ADIZ represented. Those
recommendations were provided to the TSA and the FAA on March 12th,
but have never been answered.
On behalf of the nearly 400,000 members of AOPA, under this
reduced threat level, I urge you to rescind the ADIZ restrictions
immediately.
Sincerely, Phil Boyer
Cc: Blakey, Loy, Shkor
[We concur --ed.]