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