Proposed Establishment of Prohibited Area P-50, Kings Bay, Georgia

April 12, 2004 U.S. Department of Transportation Room Plaza 401 400 Seventh Street, SW Washington, DC 20590-0001 Dear Sirs: Reference:DOT Docket No. FAA-2003-15976 (NPRM), Airspace Docket No. 03-AWA-5, Proposed Establishment of Prohibited Area P-50; Kings Bay, GA EAA (Experimental Aircraft Association) is the world leader in recreational aviation. With an international membership of 171,000 people in more than 100 nations, EAA brings together aviation enthusiasts, pilots and aircraft owners who are dedicated to the continued growth of aviation, the preservation of its history and a commitment to aviation's future. EAA programs, activities and events are known throughout the world for supporting aviation safety and promoting personal enjoyment and responsibility within an aviation lifestyle. These efforts are made possible through massive volunteer involvement in support of the organization, as well as EAA's special interest Divisions, and a global network of nearly 1,000 local Chapters and the affiliated National Association of Flight Instructors (NAFI). EAA is opposed to the proposed establishment of a Prohibited Area for the U.S. Navy Submarine base located at Kings Bay, GA. As stated in the discussion section of the NPRM "On September 11, 2001, the United States suffered catastrophic terrorist attacks involving four hijacked U.S. commercial aircraft. In response to these attacks, the FAA took action to temporarily shut down the National Airspace System, except for certain military, law enforcement and emergency aircraft flight operations. Additionally, to hinder the potential for further airborne attacks and to specifically respond to security concerns, the FAA issued numerous TFR's, via the U.S. Notice to Airmen (NOTAM) System, to limit or prohibit aircraft flight operations in the vicinity of critical military, government and national infrastructure locations across the country. As a direct result of these attacks, key members of the General Aviation Coalition (GAC), lead at the time by EAA, worked hand-in-hand with the Department of Transportation (DOT) and agencies that eventually made up the Department of Homeland Security (DHA) to mitigate the impact of airspace and airport restrictions on the U.S. general aviation industry and the communities they support. As part of this U.S. Department of Transportation EAA Comments to DOT Docket No. FAA-2003-15976 (NPRM) April 12, 2004 Page 2 effort, key leaders and staff members of the GAC were selected (and approved) by DHS to receive security clearances in order take part in sensitive briefings concerning the threats facing the U.S. In addition to the vetted GAC members, the briefings were attended by personnel from the DOT, FAA, DHS, DOD and DOJ, all experts in the threat and security issues facing the U.S. As threats were discovered, broad ranging TFR's were developed to protect national assets. Over time, this unofficial working group was able to further define threat concerns narrowing TFR's to specific areas and periods of time in lieu of the previously issued broad ranging TFR's. An example of this "narrowing" was the TFR and ADIZ positive-controlled flight area established around New York City. In the early stages of implementation, this airspace restriction was large and in place for prolonged periods. However, once the threat evaluations determined a lack of a "specific" threat, the protected airspace was reduced and ultimately eliminated. The key to this process is that DOT and DHS worked in partnership with civil aviation leaders to ensure the economic impact on the U.S. citizens, communities and industries were and are minimized to the fullest extent possible consistent with national security. This effort is still in process today as work continues to allow general aviation access to the "DC Three Airports" and to Reagan Washington National (DCA) Airport. What is striking about this airspace proposal, is that during the ongoing combined effort between…