;)
(Photo Courtesy of AOPA)
The aircraft was photographed with a Cessna 182 owned by the Boeing Employee Flying Association in preparation for an upcoming article in AOPA Pilot.
Wednesday, October 12, 2005
When is 120 faster than 600???
The bigger one might be able to go non-stop for 24 hours, but for flights to locations 750 miles or less, the tortoise beats the hare with no 21-day booking penalty.
;)
;)
Tuesday, October 11, 2005
Just keep thinking that ... this won't hurt a bit
Regarding the Federal preparedness for a new pandemic of Avian flu, The Washington Post editors wrote today:
It was disturbing to hear the president ruminate on the use of
military troops for mass quarantines. That comment -- conjuring images of
soldiers shooting as sick people try to cross a cordon sanitaire -- could have
been a scare tactic.
In fact, there is no legal, let alone ethical, means of
enforcing mass quarantine in this country....
For those of us that fly (well try to) near DC, we know better. The rule of law and democratic principles have been usurped by a simple sentiment: where there's a will, there's a way.
Sunday, October 09, 2005
The ADIZ is wrong for democracy and freedom
Oppose the erosion of democratic principles. Oppose the ADIZ!
Keep America free.
Saturday, October 08, 2005
Response to the DOT NPRM FAA-2003-17005
October 8, 2005
Federal Aviation Administration
800 Independence Avenue, SW
Washington, DC 20591
RE: Docket No. FAA-2003-17005, Wash, DC Metropolitan Area Special Flight Rules Area
On 4 August 2005, the U.S. Department of Transportation, Federal Aviation Administration issued a Notice of Proposed Rule Making (NPRM) "to codify current flight restrictions for certain aircraft operations in the Washington, DC Metropolitan Area." The NPRM requests comments from interested parties. As a resident, pilot, voter and employee of a flight school in the region, as well as a member of the Aircraft Owners and Pilots Association (AOPA) and a volunteer Angel Flight pilot, I feel particularly compelled to comment on the NPRM.
My considered opinion is that the assertions and justifications provided in the NPRM do not satisfactorily substantiate an overwhelming need for the expense and drastic actions being suggested. In summary, the NPRM fails to acknowledge or consider that the facts presented consist of out-dated information – most of the content can be traced to information available in the 2003 timeframe – or that the analysis of the threat profile as perceived by the DoD and DHS of general aviation aircraft is exceedingly narrow, and thin, with no cost/benefit discussion whatsoever. This response analyzes the core justifications offered by the FAA in the NPRM.
1) DC is home to all three branches of the Federal government, as well as numerous Federal buildings, foreign embassies, multi-national institutions, and national monuments
Yes, the United States is a “federal” government. As such, there are elements and components represented in every state of the Union, which is representative of the institutional strength and resiliency that such a form of government offers. Moreover, we know from the attacks of 11 September 2001 that Washington, DC is not the only city that the terrorists assign a high value. Without trying to speculate where those other locations might be, no one except the terrorists can really know the values that might be assigned to any number of high profile buildings, memorials and locations within the entire United States. For example, recent bombings in Egypt occurred in resort communities far away from the seat of government there. Thus, the formation of a permanent ADIZ for Washington, DC will lead the way, and become the model for, additional implementations nationwide.
To enact this NPRM is to support directly the objectives of the original 2001 terrorists at an intangible cost to liberty… and upwardly spiraling costs to taxpayers and users of the National Airspace System (NAS). In fact, the NPRM notes that the deterrent value provided in the security protocols in place for Part 121 operations might encourage the terrorists to consider general aviation aircraft to use in an attack. This is consistent with the belief that the terrorist mentality is to select targets they believe will have the largest psychological impact with the least amount of operational risk. As such, the ADIZ/FRZ airspace construct might actually encourage the terrorists to attack so-called “softer” or less defended targets. The Government should consider the tactical advantages of discontinuing the ADIZ to let the terrorists mistakenly believe that an attack on DC can be successful.
2) There is a need for continued vigilance in aviation security.
There is no question that vigilance is necessary. The terrorists leveraged outdated and lackadaisical protocols in commercial transport security operations to carry out the September 11th attacks. That said, the FAA notes that there really is “no evidence” to support more drastic security protocols like the ADIZ/FRZ. Moreover, just as Waleed bin Attash was apprehended on the ground with explosives in Pakistan, the DHS should be called upon to justify why it is that Americans cannot reasonably expect similar results for thwarting such plots through U.S. law enforcement initiatives and awareness efforts in the U.S. aviation community. If the answer is that these initiatives are inadequate and do not serve as inherent and significant operational risks to terrorist plots trying to use light aircraft for terrorist purposes, then that needs to be explained and/or corrected.
Please note that the cost just to the FAA of the NPRM is estimated at $11M, while the Airport Watch initiative is being funded nationwide with just $275,000. The cost/benefit ratio of these two programs should be studied. I would suggest that the disparity in the benefit of each dollar spent between the two efforts will be staggering. On the surface, one program covers the whole country including Alaska and Hawaii, and one covers a relatively small geographic region at a much higher expense.
I also submit that the $296M cost estimated in the NPRM for the ADIZ/FRZ would be better spent to supplement what can only be reasonably concluded as inadequately capable law enforcement initiatives and awareness efforts rather than continue the ADIZ/FRZ. Awareness efforts and initiatives like Airport Watch are a significant and cost-effective deterrent to such plots because of the uncertainty of success that they create for terrorists.
As noted in recent ADIZ/FRZ violations involving a pilot from Pennsylvania, a governor from Kentucky, and a flock of birds on April 27, 2005, the “temporary” airspace restrictions actually create results that terrorists consider successful at no cost to them! Summarily, it is now established through these incidents that the existence and enforcement of the ADIZ airspace will create permanently an ongoing source of panic, chaos, disruption, and other unforeseeable safety issues in addition to economic distortions to the underlying NAS infrastructure (i.e., airports). The effects on cost and safety are incalculable while the security benefit is negligible. In four years, there has yet to be one successful intercept of a terrorist anywhere in the nation or over DC; yet the residents of the DC metropolitan region have been “terrorized” by the flare dropping F-16s and other fast moving, loud and dangerous, low altitude intercept aircraft. The DOT proposes to make this security posture a permanent reality, but the NPRM never mentions these issues?
Furthermore, since 2001 subsequent terror attacks launched by al Qaeda around the world have not used any form of aircraft. Recent bombings in Spain, Egypt and England have used more traditional forms of ground-based attacks. This is tangible fact, and not speculation about how the terrorists might attack next. In fact, despite the success of the attack on the USS Cole prior to the September 11th attacks, the Department of Transportation has made no provision even remotely similar to this NPRM to address similar threats on rivers and ports within the vicinity of Washington, DC. Before the NPRM is approved, this needs to be explained. Have not rental trucks proven to be highly effective conveyances for terrorist weapon delivery in New York and Oklahoma? What has been done to fingerprint and identify drivers of these vehicles, and log every trip conducted by them since these incidents took place? The myopic, over-analysis of the threat posed by small aircraft must end. It is needlessly diverting resources from considering more likely attack profiles for the next incident. This NPRM should be not be enacted in favor of the presumption of innocence standard – a right that all Americans are supposed to enjoy equally.
Finally on this point, the GAO found that the “FAA has not established written policies or procedures for reviewing and revalidating the need for flight restrictions that limit access to airspace for indefinite periods of time and could negatively affect the general aviation industry.” As such, once enacted, the costs of the ADIZ will be born in perpetuity by American taxpayers and the aviation industry even if it provides no benefit.
3) While the DHS has no specific information that terrorist groups are currently planning to use general aviation (GA) aircraft to perpetrate attacks against the U.S., it remains concerned that (in light of completed and ongoing security enhancements for commercial aircraft and airports) terrorists may turn to GA as an alternative method for conducting operations.
First, this argument is reminiscent of the infamous “white van” of the 2002 DC Sniper attacks. In that case, considerable law enforcement resources were utilized to detain and inspect thousands of “white” vans, which later proved irrelevant to the investigation. Just as finding the white van had no bearing on locating the snipers and preventing further terror and loss of life, the continuation of the DC ADIZ and prohibitions on GA aircraft operations in the ADIZ/FRZ will not prevent terrorists from achieving their objectives. In fact, the ADIZ is an ongoing terrorist success because they have affected a change in our behavior as a result of their actions.
Should the NPRM be approved, I would hope then the we’ll start looking for “missing red fire trucks” again. That was another risk profile broadcast publicly in the aftermath of September 11th.
Moreover, the ability of the Intelligence community to prove the validity of its assertions and conclusions is not without reproach. Specifically prior to moving forward with this NPRM, the FAA and DOT must consider whether or not the threat estimate regarding general aviation aircraft is any more accurate than the 2002-2003 analysis that Iraq possessed weapons of mass destruction. If DHS is unable to provide or share substantive and irrefutable information with DOT that a substantiated threat (not a risk) exists, this NPRM should not go forward.
Finally, the November 2004 GAO Report to the Subcommittee on Homeland Security, Committee on Appropriations, House of Representatives says it best, “Additionally, industry and TSA officials stated that the small size, lack of fuel capacity, and minimal destructive power of most general aviation aircraft make them unattractive to terrorists and, thereby, reduce the possibility of threat associated with their misuse.”
The NPRM for creating the ADIZ continues to perpetuate the search for the “boogeyman in a small plane” despite documented assessments by the Government that small aircraft are not a threat.
4) One area that the FAA does not address in the NPRM is the cost to upgrade inadequate radar facilities. At the moment, the radar coverage available to the FAA is not capable of the task created by the NPRM. Moreover, neither the costs to flight operations for GA aircraft in the ADIZ to comply with the limitation of the radar facilities nor the cost to upgrade these facilities to address the issue is addressed in the NPRM. I have specifically been instructed by ATC to avoid such facility deficiencies (e.g., below 3000 AGL SW of EMI VOR and below 5000 AGL SW of CSN VOR) in flights through the ADIZ. The costs to upgrade and enhance radar facilities on an accelerated timeline must be forthrightly produced and considered.
5) Ongoing and recurrent training expenses for both pilots and controllers are another cost element not considered in the NPRM. This cost may have been addressed beneath other costs, or omitted. It is unclear which is the case.
In summary, it is important to note that the American Bald Eagle is the greatest American symbol of freedom. The freedom that flight affords is a significant component of that symbol. By this comment to the NPRM, I implore the DOT and FAA to consider the needs of all Americans to allow those who have earned the privilege to fly in the NAS to be able to exercise those privileges free from unnecessary encumbrances that provide little, if any, security value. The airspace around Washington, DC is a critical component of the NAS, supporting the busiest and most economically significant aircraft operations anywhere in the world.
Making the ADIZ/FRZ construct permanent provides nothing more than a false sense of security at a substantial cost to freedom and national heritage that is totally unquantifiable and antithetical to America’s founding principles.
Finally on September 20, 2001, President Bush said, “It is my hope that in the months and years ahead, life will return almost to normal. We'll go back to our lives and routines, and that is good.” Unfortunately, this NPRM codifies an ADIZ that represents nothing close to a“return almost to normal.” The NPRM is inconsistent with the President’s stated vision and should be withdrawn. The costs of implementation and enforcement are considerable and dire, while no one can quantify any actual benefits. The impact on lives and routines dependent upon aviation activities is quantifiable to an extent, and they are outrageous in the fact of no quantifiable benefit achieved. The Administrator should exercise statutory authority to rescind this NPRM and retire the ADIZ/FRZ without any further delay.
Federal Aviation Administration
800 Independence Avenue, SW
Washington, DC 20591
RE: Docket No. FAA-2003-17005, Wash, DC Metropolitan Area Special Flight Rules Area
On 4 August 2005, the U.S. Department of Transportation, Federal Aviation Administration issued a Notice of Proposed Rule Making (NPRM) "to codify current flight restrictions for certain aircraft operations in the Washington, DC Metropolitan Area." The NPRM requests comments from interested parties. As a resident, pilot, voter and employee of a flight school in the region, as well as a member of the Aircraft Owners and Pilots Association (AOPA) and a volunteer Angel Flight pilot, I feel particularly compelled to comment on the NPRM.
My considered opinion is that the assertions and justifications provided in the NPRM do not satisfactorily substantiate an overwhelming need for the expense and drastic actions being suggested. In summary, the NPRM fails to acknowledge or consider that the facts presented consist of out-dated information – most of the content can be traced to information available in the 2003 timeframe – or that the analysis of the threat profile as perceived by the DoD and DHS of general aviation aircraft is exceedingly narrow, and thin, with no cost/benefit discussion whatsoever. This response analyzes the core justifications offered by the FAA in the NPRM.
1) DC is home to all three branches of the Federal government, as well as numerous Federal buildings, foreign embassies, multi-national institutions, and national monuments
Yes, the United States is a “federal” government. As such, there are elements and components represented in every state of the Union, which is representative of the institutional strength and resiliency that such a form of government offers. Moreover, we know from the attacks of 11 September 2001 that Washington, DC is not the only city that the terrorists assign a high value. Without trying to speculate where those other locations might be, no one except the terrorists can really know the values that might be assigned to any number of high profile buildings, memorials and locations within the entire United States. For example, recent bombings in Egypt occurred in resort communities far away from the seat of government there. Thus, the formation of a permanent ADIZ for Washington, DC will lead the way, and become the model for, additional implementations nationwide.
To enact this NPRM is to support directly the objectives of the original 2001 terrorists at an intangible cost to liberty… and upwardly spiraling costs to taxpayers and users of the National Airspace System (NAS). In fact, the NPRM notes that the deterrent value provided in the security protocols in place for Part 121 operations might encourage the terrorists to consider general aviation aircraft to use in an attack. This is consistent with the belief that the terrorist mentality is to select targets they believe will have the largest psychological impact with the least amount of operational risk. As such, the ADIZ/FRZ airspace construct might actually encourage the terrorists to attack so-called “softer” or less defended targets. The Government should consider the tactical advantages of discontinuing the ADIZ to let the terrorists mistakenly believe that an attack on DC can be successful.
2) There is a need for continued vigilance in aviation security.
There is no question that vigilance is necessary. The terrorists leveraged outdated and lackadaisical protocols in commercial transport security operations to carry out the September 11th attacks. That said, the FAA notes that there really is “no evidence” to support more drastic security protocols like the ADIZ/FRZ. Moreover, just as Waleed bin Attash was apprehended on the ground with explosives in Pakistan, the DHS should be called upon to justify why it is that Americans cannot reasonably expect similar results for thwarting such plots through U.S. law enforcement initiatives and awareness efforts in the U.S. aviation community. If the answer is that these initiatives are inadequate and do not serve as inherent and significant operational risks to terrorist plots trying to use light aircraft for terrorist purposes, then that needs to be explained and/or corrected.
Please note that the cost just to the FAA of the NPRM is estimated at $11M, while the Airport Watch initiative is being funded nationwide with just $275,000. The cost/benefit ratio of these two programs should be studied. I would suggest that the disparity in the benefit of each dollar spent between the two efforts will be staggering. On the surface, one program covers the whole country including Alaska and Hawaii, and one covers a relatively small geographic region at a much higher expense.
I also submit that the $296M cost estimated in the NPRM for the ADIZ/FRZ would be better spent to supplement what can only be reasonably concluded as inadequately capable law enforcement initiatives and awareness efforts rather than continue the ADIZ/FRZ. Awareness efforts and initiatives like Airport Watch are a significant and cost-effective deterrent to such plots because of the uncertainty of success that they create for terrorists.
As noted in recent ADIZ/FRZ violations involving a pilot from Pennsylvania, a governor from Kentucky, and a flock of birds on April 27, 2005, the “temporary” airspace restrictions actually create results that terrorists consider successful at no cost to them! Summarily, it is now established through these incidents that the existence and enforcement of the ADIZ airspace will create permanently an ongoing source of panic, chaos, disruption, and other unforeseeable safety issues in addition to economic distortions to the underlying NAS infrastructure (i.e., airports). The effects on cost and safety are incalculable while the security benefit is negligible. In four years, there has yet to be one successful intercept of a terrorist anywhere in the nation or over DC; yet the residents of the DC metropolitan region have been “terrorized” by the flare dropping F-16s and other fast moving, loud and dangerous, low altitude intercept aircraft. The DOT proposes to make this security posture a permanent reality, but the NPRM never mentions these issues?
Furthermore, since 2001 subsequent terror attacks launched by al Qaeda around the world have not used any form of aircraft. Recent bombings in Spain, Egypt and England have used more traditional forms of ground-based attacks. This is tangible fact, and not speculation about how the terrorists might attack next. In fact, despite the success of the attack on the USS Cole prior to the September 11th attacks, the Department of Transportation has made no provision even remotely similar to this NPRM to address similar threats on rivers and ports within the vicinity of Washington, DC. Before the NPRM is approved, this needs to be explained. Have not rental trucks proven to be highly effective conveyances for terrorist weapon delivery in New York and Oklahoma? What has been done to fingerprint and identify drivers of these vehicles, and log every trip conducted by them since these incidents took place? The myopic, over-analysis of the threat posed by small aircraft must end. It is needlessly diverting resources from considering more likely attack profiles for the next incident. This NPRM should be not be enacted in favor of the presumption of innocence standard – a right that all Americans are supposed to enjoy equally.
Finally on this point, the GAO found that the “FAA has not established written policies or procedures for reviewing and revalidating the need for flight restrictions that limit access to airspace for indefinite periods of time and could negatively affect the general aviation industry.” As such, once enacted, the costs of the ADIZ will be born in perpetuity by American taxpayers and the aviation industry even if it provides no benefit.
3) While the DHS has no specific information that terrorist groups are currently planning to use general aviation (GA) aircraft to perpetrate attacks against the U.S., it remains concerned that (in light of completed and ongoing security enhancements for commercial aircraft and airports) terrorists may turn to GA as an alternative method for conducting operations.
First, this argument is reminiscent of the infamous “white van” of the 2002 DC Sniper attacks. In that case, considerable law enforcement resources were utilized to detain and inspect thousands of “white” vans, which later proved irrelevant to the investigation. Just as finding the white van had no bearing on locating the snipers and preventing further terror and loss of life, the continuation of the DC ADIZ and prohibitions on GA aircraft operations in the ADIZ/FRZ will not prevent terrorists from achieving their objectives. In fact, the ADIZ is an ongoing terrorist success because they have affected a change in our behavior as a result of their actions.
Should the NPRM be approved, I would hope then the we’ll start looking for “missing red fire trucks” again. That was another risk profile broadcast publicly in the aftermath of September 11th.
Moreover, the ability of the Intelligence community to prove the validity of its assertions and conclusions is not without reproach. Specifically prior to moving forward with this NPRM, the FAA and DOT must consider whether or not the threat estimate regarding general aviation aircraft is any more accurate than the 2002-2003 analysis that Iraq possessed weapons of mass destruction. If DHS is unable to provide or share substantive and irrefutable information with DOT that a substantiated threat (not a risk) exists, this NPRM should not go forward.
Finally, the November 2004 GAO Report to the Subcommittee on Homeland Security, Committee on Appropriations, House of Representatives says it best, “Additionally, industry and TSA officials stated that the small size, lack of fuel capacity, and minimal destructive power of most general aviation aircraft make them unattractive to terrorists and, thereby, reduce the possibility of threat associated with their misuse.”
The NPRM for creating the ADIZ continues to perpetuate the search for the “boogeyman in a small plane” despite documented assessments by the Government that small aircraft are not a threat.
4) One area that the FAA does not address in the NPRM is the cost to upgrade inadequate radar facilities. At the moment, the radar coverage available to the FAA is not capable of the task created by the NPRM. Moreover, neither the costs to flight operations for GA aircraft in the ADIZ to comply with the limitation of the radar facilities nor the cost to upgrade these facilities to address the issue is addressed in the NPRM. I have specifically been instructed by ATC to avoid such facility deficiencies (e.g., below 3000 AGL SW of EMI VOR and below 5000 AGL SW of CSN VOR) in flights through the ADIZ. The costs to upgrade and enhance radar facilities on an accelerated timeline must be forthrightly produced and considered.
5) Ongoing and recurrent training expenses for both pilots and controllers are another cost element not considered in the NPRM. This cost may have been addressed beneath other costs, or omitted. It is unclear which is the case.
In summary, it is important to note that the American Bald Eagle is the greatest American symbol of freedom. The freedom that flight affords is a significant component of that symbol. By this comment to the NPRM, I implore the DOT and FAA to consider the needs of all Americans to allow those who have earned the privilege to fly in the NAS to be able to exercise those privileges free from unnecessary encumbrances that provide little, if any, security value. The airspace around Washington, DC is a critical component of the NAS, supporting the busiest and most economically significant aircraft operations anywhere in the world.
Making the ADIZ/FRZ construct permanent provides nothing more than a false sense of security at a substantial cost to freedom and national heritage that is totally unquantifiable and antithetical to America’s founding principles.
Finally on September 20, 2001, President Bush said, “It is my hope that in the months and years ahead, life will return almost to normal. We'll go back to our lives and routines, and that is good.” Unfortunately, this NPRM codifies an ADIZ that represents nothing close to a“return almost to normal.” The NPRM is inconsistent with the President’s stated vision and should be withdrawn. The costs of implementation and enforcement are considerable and dire, while no one can quantify any actual benefits. The impact on lives and routines dependent upon aviation activities is quantifiable to an extent, and they are outrageous in the fact of no quantifiable benefit achieved. The Administrator should exercise statutory authority to rescind this NPRM and retire the ADIZ/FRZ without any further delay.
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