ADIZ NPRM Response
I am a private pilot with an instrument rating for single-engine airplanes. To date, I have about 380 hours of total flight time and fly approximately 45 hours per year - which is about double that of the typical private pilot. I am a part-owner in a single-engine airplane based at Leesburg, Virginia. Most of my flying is in and around the DC area where I live. Some of the more popular destinations in my logbook include Bay Bridge airport on the eastern shore of the Chesapeake Bay in Maryland, Richmond, VA, Hagerstown, MD and several of the smaller airports along the Shenandoah Valley like Front Royal, VA, Winchester, VA, and Martinsburg, WV. Most of my flying is for pleasure, but recently I've been involved with charitable flights including the Angel Flight organization. I also fly my family to vacation spots like the Outer Banks of North Carolina.
I was preparing to take my instrument practical test when the first version of the DC ADIZ went into effect. I could not fly myself to Frederick, MD to take the test because only IFR flights were allowed in the ADIZ at that time. That meant I had to convince my flight instructor (who only instructed as a part-time job) to take a day off from his day job to fly me to the test. The designated flight examiner had to alter her normal flight routine to accommodate the restrictions. I have the questionable honor of being able to fly myself home under my own IFR flight plan, but it was a sign of things to come.
I was happy to see most of the DC area restrictions lifted a few months later and I flew as much as I could. Little did I realize how short-lived that freedom would be.
Since February 2003, I have flown perhaps half a dozen flights under visual flight rules. Due to the ADIZ requirements, I've found it far simpler to file and fly under instrument flight rules. Even then, it has not been unusual to wait for over 30 minutes trying to contact a flight service station to file the required flight plan. It has not been unusual to have to wait another 10 to 20 minutes trying to contact overworked clearance delivery controllers to get the required transponder code. This inconvenience severely limits the utility of the plane I co-own.
I have been planning to achieve a commercial and instructor rating, but have had to delay those activities due to the additional costs imposed by the ADIZ. I would have to pay for a larger, more complex airplane plus an instructor for all that additional time. On top of that, I will be forced to fly further to reach a suitable practice area. I had hoped to have those ratings by now.
Quite frankly, I've never quite understood the value of the ADIZ. It seems it was thrown together to prove to the non-flying public that their government was "Doing Something" to protect them. Those of us who fly can look at a chart and see that it's unnecessary. The very extensive Class B airspace around the National Capital Region serves to filter out most small planes since all aircraft in the Class B need to be under air traffic control. This provides quite a lot of notice of intent. Questionable actions can be verified quickly by ATC since they are in contact with these planes with unique transponder codes.
Further, it must be remembered that small planes have never been used by terrorists. We have heard many times terrorists have considered using small planes to cause mischief, but it has not happened. Perhaps the ridiculously low capacity of most small planes have kept them from doing so. Perhaps it's the "small town atmosphere" of most general aviation airports that has prevented suspicious activity. Pilots have become all too aware of the public eye placed on our activities and we have greatly increased surveillance and security procedures as a result. AOPA's Airport Watch program is one example. Another is the proliferation of various locking devices to provide additional deterrents to theft.
Even if a typical small plane were to be used as another human-guided missile, the damage would be minimal. For example, the Tampa building struck by a stolen Cessna 172 succeeded in merely killing the suicidal pilot and breaking a couple windows.
The ADIZ encompasses three thousand square miles up to an altitude of over three miles and has severely curtailed flight activities at some of the busiest general aviation airports in the area - including the second busiest in the state of Virginia: Leesburg. Nearly all of my pilot associates have stopped flying VFR for pleasure flights.
Another issue we have to deal with is operational overload on the air traffic controllers. Unfortunately, it's not simply a matter of throwing more bodies at the problem. There are only a limited number of ATC frequencies available for use so there is a finite limit on the number of controllers that can be working at any given time. Controllers have seen a huge increase in their workload since the ADIZ was implemented. I fear this significantly increases the chance of a mid-air collision as ADIZ traffic is funneled to a few "entry/exit" points. Radar targets will merge and the pilots will be responsible for "see and avoid". We're used to that, but we usually have a lot more flexibility in routing to help with the "avoid" part. Since VFR pilots are being vectored to those few transit points, there is a lot more traffic there to deal with - for both the pilots and controllers. This is not a safe idea. Allowing these VFR planes (most of which weigh under 2500 pounds fully loaded) to navigate under the Class B airspace greatly increases the safety of the pilots, their passengers as well as persons and property below.
I admit there are unique assets in the National Capital Region. The Smithsonian's National Air & Space Museum, for instance, is filled with many rare artifacts that could never be replaced if destroyed. However, protection of these assets is not significantly improved by implementation of the ADIZ. It's obvious that those wishing us harm do not consider Washington to be the sole or even primary target. Even assuming the ADIZ itself has prevented a single attempted terrorist action, it's a simple matter for them to target another major city - many of which also have irreplaceable treasures and artifacts.
Beyond the facade of security some think the ADIZ provides, it seems to me we've become a nation of cowards. A single small team of terrorists succeed in surprising us and we respond with the virtual closure of airspace equivalent to all of Vermont plus half of Rhode Island. What happened to "the land of the brave"? Where are the adherents of "give me liberty or give me death"? The bottom line is we have given the terrorists what they could not take by force. We have given up our liberty on a silver platter. It is an embarrassment to consider this an American response.
The ADIZ does nothing to enhance real security of national assets and increases the chance of other aviation related tragedies. It needs to be abolished, not made permanent.
To provide your own comment, see http://www.aopa.org/adizalert.