The Federal Aviation Administration (FAA) has received thousands of comments in opposition to its proposal to establish an air defense identification zone (ADIZ) around the Washington, D.C., metropolitan area.
"It is premature to permanently clap onerous flight restrictions on nearly 2,000 square miles of the East Coast. In the four years since 9/11 - and in the middle of an ongoing war - an aircraft has not been used in a terrorist attack on the U.S.," writes Dennis Smith of Goshen, Indiana.
The ADIZ would be accompanied by an inner area, called a flight restricted zone (FRZ), of approximately a 15 nautical mile (NM) radius covering the capital city itself. Details of the FAA's plan to make permanent the ADIZ put in place following the 9/11 terrorist attacks were outlined in an Aug. 4 notice of proposed rulemaking (NPRM).
As the 29-page NPRM argues, "This alternative is preferred because it balances the government's security concerns about a terrorist attack in this area against the costs that would be imposed by more draconian measures" (see ASW, Aug. 15).
The existing ADIZ and its procedures are already too draconian, argue the overwhelming majority of people submitting comments to the docket in response to the NPRM. In fact, the FAA has received more than 18,400 comments from individuals, corporations, airports and industry associations, largely in opposition (e.g., 99 out of 100 submissions). By way of comparison, the FAA received some 6,000 comments on its proposal to not require child restraint systems (see ASW, Sept. 12). Clearly, the FAA's proposed aviation security measures have touched a nerve, so much so that the comment period has been extended to Feb. 6, 2006. A public meeting on security measures to be applied for the Washington, D.C., metropolitan area will be convened at a future date yet to be announced.
It is too soon to foretell the FAA's final decision, but it seems fair to say that (1) the FAA will not be the sole arbiter, as the Bush Administration, the Department of Transportation, the Department of Homeland Security and the Department of Defense will be involved, and (2) public and industry opposition have figured in other rulemaking activities (in modifying or shortstopping them).
The ultimate decision has nationwide implications, as the ADIZ presently established for the Washington D.C. area could also be applied elsewhere. Below, a sampling of comments the FAA has already received on its proposal for a permanent ADIZ around Washington, D.C.:
Fred Scott - "I object to the proposal ... This new 'National Defense Airspace' (NDA) would permanently expand and replace the current 'TEMPORARY' [ADIZ] and it will include nearly 2,000 square miles and extend to an altitude of 18,000 feet. This NDA will be located above 46 airports, most of which will be effectively closed by the proposed rule. ...
"No aviator I know objects to complying with useful rules for aviation safety, but this proposal - which probably sounds good to non-aviators - makes no useful contribution ...
"Since the Sept. 11 attacks, the government has made numerous upgrades to security systems around the nation's capital, including a new visual warning system that uses lasers to warn pilots away from restricted airspace, anti- aircraft missile batteries, and greatly improved radar coverage. Such measures significantly enhance the protection ... making the ADIZ unnecessary. ...
"The only aircraft used as weapons on our cities have been heavy airliners. These still operate in and out of the ADIZ with impunity, yet harmless light aircraft will be restricted. ...
"As an aviator with 40+ years of experience ... and living in central Virginia where the ADIZ intrudes, I sincerely suggest this NDA airspace proposal is a 'feel-good idea' that should be relegated to the circular file."
James Fallows - [ASW note: The writer, a private pilot, had an editorial along these lines in The Washington Post on Nov. 2, titled "Restricting Airspace - And Common Sense."]
"Like many other such responses ... the logic behind [the ADIZ] has not stood up well to the passing years. The ADIZ has the worst features of many other stop-gap measures: it does nothing to impede attackers genuinely determined to do harm, while it inconveniences large numbers of ordinary civilians. Like the color-coded chart and the 30-minute seating rule, it should be retired.
"The ADIZ is ineffective because its protections would be laughably easy for a determined attacker to evade. A pilot needs to call before taking off to file an ADIZ plan, and then get a [transponder] code before entering the airspace. But security officials have no way of knowing whether a person who made the original call actually is the person he or she claims to be; or whether they are the same person who is taking off in the airplane; or whether the airplane requesting to enter the airspace has the tail number that was filed for a clearance. The 'safety' provisions of all these clearances is purely symbolic - on the order of people who have to fill out their names on a 'security' log before entering a building, in front of a guard who never bothers to read the names. If a small aircraft really were intent on causing harm in Washington, the ADIZ would do nothing to deter it. It would be stopped, with or without the ADIZ, by other means.
"While doing virtually nothing to slow down an intruder, the ADIZ is nonetheless cumbersome for all normal users of the airspace. ... An ADIZ clearance is the only flight plan in American airspace that cannot be entered by computer; it has to be done over the telephone, often with very long delays. (The logical reason for requiring voice contact is hard to understand. Is it to hear that the pilot has an accent?) The rule makes no distinction between big, fast jet planes and tiny, slow general aviation aircraft."
Phil Boyer, President, Aircraft Owners and Pilots Association (AOPA) - "The current ATC [air traffic control] infrastructure was designed and staffed to control only those aircraft flying under Instrument Flight Rules (IFR), which historically represent approximately 33 percent of the total number of aircraft in the airspace. In 2003, however, when the ADIZ was hastily implemented, the number of aircraft that ATC had to control tripled, since flight plans would now be required for all aircraft. The flight plan requirement has increased the workload for controllers by approximately 2,000 operations per day, and consequently often diverts controllers from their primary responsibility of IFR traffic separation. ...
"If the temporary ADIZ cannot be eliminated, AOPA recommends an alternative approach that would eliminate or replace the ADIZ procedural requirements for aircraft that weigh 6,000 pounds or less, and that limit their speed to 160 knots indicated or less. Due to their small size and limited cargo- carrying capacity, these aircraft are the least likely candidates for use by terrorists. Under this alternative, the FAA would retain all existing requirements within the FRZ, but would apply the existing ADIZ requirements only to larger, faster aircraft. On special notice from the FAA, during high threat periods, the requirements applicable to heavier, faster aircraft could be extended to lighter, slower, exempted aircraft until the threat level is reduced."
Michael Truffer - "While the greater Washington, D.C., area certainly contains many national assets, a great many other national assets are located in other parts of the county. Should we impose permanent flight restrictions on those areas, too?"
Oxnard Airport Association, Md. - "General aviation poses no more of a threat to national security than an RV, SUV, rental truck, or even the family van. Yet general aviation is continually singled out as a possible threat. Large vehicles can carry many times the amount of explosives as a small plane but they are allowed to travel freely in any city, including Washington, D.C."
Imram Anwar - "If we stop building skyscrapers because terrorists hit them, start restricting airspace over the free world's capital, or start limiting our freedoms (including free speech or the right to fly over the land of the free) we may as well announce to the terrorists that we are afraid even in our own home and homeland. That is homeland INSECURITY."
Ron Lane, Essex Skypark Association - "The current and proposed [procedures] have created a condition that puts pilots, aircraft and public safety at risk. The most significant is in the case of a transponder failure such as the failure of the Kentucky Governor's airplane. [ASW note: On June 9 a Kentucky State Police King Air 200 carrying Gov. Ernie Fletcher had a transponder failure when it encountered restricted Washington, D.C., airspace; the plane landed at Washington National Airport, with the pilots following directives from air traffic controllers]. Requiring a pilot to leave the ADIZ and not land at the nearest airport is a recipe for disaster.
"Last year a pilot left Essex and when they were less than 4 miles from the airport their transponder failed. They were instructed to leave the ADIZ and they landed at an airport 15 miles from their home airport. The failure turned out to be a tripped circuit breaker, but it could have been the beginning of a cascading electrical failure or worse. The proper course would have been for the pilot to return to the airport that they just departed from.
"The list can go on of the safety compromises pilots have made not to get busted in the ADIZ."
Washington Special Flight Region, Springfield, Va. - "The size and complexity of the ADIZ has resulted in over 1,700 infractions; most of these were minor and none of these were 'attacks on Washington' ... The underlying cause of the infractions is because the ADIZ is too large, which results in the procedures becoming too complicated. ...
"Other countries provide protection to their leadership without severely limiting aviation in large areas. South Korea has a well-identified, prohibited area around their 'Blue House' and supports it with their version of a visual warning system. South Korea doesn't have a 3,600 sq. mile ADIZ to protect their president.
"There is an inherent governmental bureaucracy to keep existing infrastructure and programs which took time and effort to build. There will be a natural resistance to reduce the ADIZ because of the command and control system now in place. But similar to a former president taking the U.S. bomber force off nuclear alert in 1989, it is time for the ADIZ to be 'right sized.'
"Recommendation: Reduce the ADIZ to the size of the DCA 15 NM ring (the Flight Restriction Zone) and change the Flight Restriction Zone to the size of the inner ring of the Class B airspace (surface to 10,000 MSL)."
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