Comments on FAA NPRM urgently needed

As you are probably aware, the FAA has issued a Notice of Proposed
Rules Making seeking to make the temporary ADIZ around Washington, DC
permanent. This action is so dangerous that AOPA has sent out a rare
National Pilot Alert to all members, asking us to submit comments
before the Nov 2 deadline, opposing the NPRM, with copies to our
Congressional representatives and a copy to so they can
monitor the flow. I imagine many of you have or are planning to send
the FAA such comments and thought you might find the following helpful.
(It took more time than I thought it would to research the numbers.
Hoping this can save you time if you find them helpful.) I also sent
the comments in the following type of email to my two Senators and my
Representative.

You can view the NPRM at

http://dms.dot.gov/search/document.c...docketid=17005

and the AOPA call to action at

http://www.aopa.org/whatsnew/newsite...51005adiz.html

Hoping you find this helpful.

Martin
====begin letter to Congress ====
Dear ---:

I am a constituent of yours and just sent the following comment to the
FAA in response to one of their Notice of Proposed Rules Making which
is open to public comment until November 2. I am sending this copy to
you in the hope that you can take action to help prevent this major
mistake from happening. Thank you for your consideration.

Sincerely,

Martin Hellman

730 Alvarado Court
Stanford, CA 94305
=== begin comment to FAA===
I am writing to strongly oppose the FAA's Notice of Proposed Rule
Making, Docket Number FAA-2004-17005, which would make the Washington,
DC ADIZ (Air Defense Identification Zone) permanent. The current,
temporary restrictions are cumbersome, imposing a heavy burden on
pilots and air traffic controllers with little or no increase in
security for the reasons detailed below.

As background, I am a private pilot who flies approximately 200 hours
per year, with a total of over 2,200 hours logged flight time. My home
base is at Hayward, CA, approximately 15 nm from San Francisco
International airport and, if this NPRM is approved, I fear similar air
space restrictions will be proposed in the future for this area.

We all must pay a price in the fight against terrorism and I am willing
to do my part. But I am confident that if a cost-benefit analysis had
been performed, this NPRM would be seen to be an extremely poor use of
resources. If national security is viewed in a broader sense than just
preventing terrorist attacks, the unnecessary, increased burden that
this NPRM imposes on air traffic controllers may actually decrease
security by increasing the probability of mid-air and other major
aircraft disasters. As the response to the recent hurricanes shows, we
must not let terrorism blind us to other threats to our security.

It is generally accepted that the collapse of the Twin Towers was
caused by the extreme heat caused by huge quantities of burning fuel.
Each aircraft used in the 9/11 attacks had a fuel capacity of
approximately 80 tons, with energy equivalent to 800 tons of TNT since
jet-A has 10 times the energy content of TNT. Taking into account that
the 9/11 aircraft were carrying only about 40% of their maximum fuel
capacity at the time of impact, this still is comparable to the energy
in a small tactical nuclear weapon. In contrast, my plane's fuel
capacity is 200 pounds, 800 times smaller than each jet's.

While general aviation aircraft could cause damage in other ways than
by fuel induced fires, the potential damage is determined by the
payload. A large jet has a payload of approximately 60 tons. My plane
has a payload of approximately 400 pounds, 300 times smaller than a
large jet.

In summary, one would need a fleet of at least 300 planes like mine to
make a coordinated attack that has the same level of devastation as
hijacking one large jet. Such a scenario is ludicrous and helps explain
why no general aviation aircraft has ever been used in a terrorist
attack.

Attacks by truck, as in the 1993 World Trade Center attack, are much
more likely and potentially much more devastating than anything a
terrorist could do with a small general aviation aircraft. Yet we do
not see any call for each truck entering Washington, DC to wait for
permission to enter and then be in constant radio contact with a
"ground traffic controller." To compare with my earlier figures, a
tractor-trailer truck can have a payload in the vicinity of 50 tons and
carry explosives or fuel comparable a large jet. Again, it would take a
fleet of hundreds of planes comparable to mine to inflict comparable
devastation.

I hope that the FAA will reconsider the thinking that led to this
ill-advised NPRM and withdraw it. Thank you very much for considering
my comments.