Section 8. SUA
Review and Analysis
Under Title 49 U.S.C. 40101 the
FAA is charged with ensuring the safe and efficient
use of the nation's airspace. In carrying out this
responsibility, the FAA must periodically review
existing SUA and take appropriate airspace amendment
action, if warranted, based on the findings of its
review. The following paragraphs set forth SUA
review policy and provide suggested analysis
techniques for use by regional and headquarters
a. The service area office
must conduct an annual review of restricted areas,
MOAs, and warning areas under its jurisdiction. CFAs
and Alert Areas may be reviewed as deemed necessary
by the service area office. The purpose of the
annual review is to:
1. Confirm that the user
has a continuing requirement for the airspace.
2. Determine if the
airspace is being used for its designated purpose.
3. Determine if actual use
supports the designated dimensions and times of use.
4. Determine if joint-use
airspace is being released to the controlling agency
when not needed for its designated purpose.
5. Determine if any
adjustments should be considered to enhance the
efficient use or management of the airspace.
b. When the review
indicates that airspace amendment or other
corrective action should be considered, the service
area office must discuss the findings with the
respective regional military representative, or
responsible official for non-military SUA, and
determine an appropriate course of action.
21-8-3. SOURCES OF INFORMATION
There are a variety of sources of
information pertinent to SUA utilization. Using
agencies are required to submit annual reports on
restricted areas and MOA utilization as described in
of this chapter. Additional information may be
obtained through coordination and research to
augment these reports or to compile specific
information about SUA areas that are not covered by
the annual reporting requirement. Coordination with
controlling agencies may be necessary to obtain
detailed information regarding real-time use and
area scheduling practices, or to identify airspace
operational problems. The Special Use Airspace
Management System (SAMS) will provide a more
centralized and comprehensive source of SUA data for
review purposes. As it becomes available, SAMS data
should be incorporated into the review process.
Additional sources of SUA information include:
a. Controlling agency or
using agency input.
b. Regional/service area
office SUA onsite review team reports.
c. FAA Air Traffic
Representative (ATREP) reports.
d. SUA Letters of
e. User meeting feedback.
f. Routine use of
restrictions imposed by the controlling agency on
the activation of SUA, or frequent denials of using
agency activation requests.
g. Recurring ATC problems,
spill outs, or NMAC reports associated with the SUA
21-8-4. UTILIZATION STANDARDS
a. The General Accounting
Office (GAO) recommended that the FAA establish
standards to be used to measure the effectiveness of
SUA utilization, and to serve as a starting point
for regional/service area office discussions with
the user about the possible need for an airspace
amendment or revocation action. In fulfillment of
the GAO recommendation, this paragraph presents
a limited, basic standard to be considered when
reviewing SUA utilization data. It applies primarily
to the review of restricted area and MOA annual
utilization reports, but may be used to evaluate
other SUA areas where sufficient utilization data is
b. Reviewers are cautioned
that many factors affecting SUA use cannot be
quantified. Therefore, it is impractical to develop
an all-encompassing standard that would fully
measure SUA effectiveness. A thorough evaluation of
SUA will require a combination of utilization data
analysis, plus a subjective review of each area with
consideration given to any unique circumstances.
c. The following standard
may be applied in reviewing SUA utilization data:
1. Activities. The
activities conducted must be appropriate for the
type and designated purpose of the SUA.
2. Times of Use. Hours
actually utilized should equal at least 75 percent
of the hours the area was activated, discounted for
weather cancellations and delays, or loss of use for
reasons beyond the using agency's control (as
documented in the utilization report Remarks
3. Designated Altitudes.
Activities conducted/altitudes used indicate a need
for retaining the published altitude structure of
the SUA area.
21-8-5. SUA REVIEW GUIDE
This paragraph may be used as a
framework for conducting a review of SUA. It applies
primarily to the review of restricted areas and MOAs
for which annual reports are submitted. However, it
may also be used for reviewing warning areas when
sufficient utilization data are available. This
should not be considered an all-inclusive list.
Reviewers may modify the factors to be examined or
the extent of the review based on the availability
of information or to fit the specific area/situation
under review. The following items should be
a. Activities. Are the
activities conducted appropriate for the type and
purpose of the SUA area? If inappropriate activities
are conducted, notify the military representative,
or responsible official, that the activity must be
terminated in that SUA area or an airspace proposal
must be submitted to establish the proper category
of SUA to accommodate the activity.
b. Altitudes. Does the
actual use of altitudes support those specified in
the descriptions? Are there less frequently used
portions that could be subdivided as separate areas
to enhance real-time joint use of the airspace? Are
any portions of the vertical dimensions no longer
required for the mission? If the answers indicate a
need for change, action should be initiated to amend
c. Times of Use. Compare
scheduled, activated, and actual utilized data. Low
usage rates do not necessarily indicate a need to
revoke or amend airspace. Consideration must be
given to the designated purpose of the area and
whether limitations were imposed on its use as a
condition for the original establishment of the SUA.
SUA may be established to accommodate less frequent
activities such as certain research, test, and
development profiles. Determining the continued
requirement for, or validity of, such areas will
require discussions with the user and cannot be
determined strictly based on utilization times.
Additionally, low or infrequent use may result from
factors beyond the using agency's control, such as
adverse weather, unit deployments, maintenance
delays, ATC-imposed restrictions, etc.
1. Compare time actually
utilized to time activated. This is the most
important factor in analyzing SUA utilization.
Significant disparity between the time activated and
actually utilized may indicate inefficient airspace
use and the need to improve real-time use procedures
so that the airspace is released to the controlling
agency for joint use when not needed by the user for
its designated purpose. Determine whether the
published times of use are valid or should be
amended to match current mission requirements. If
actual utilization is less than 75 percent of the
time activated, coordinate with the regional
military representative to determine the reason and
whether corrective action is required. If
information is available, the impact of weather
and/or ATC delays on the actual utilization of the
area should be considered when evaluating this item.
2. Compare scheduled use
to published times of use. If scheduled use is
significantly less than or greater than (e.g., by
use of NOTAMs) the published times, discussions
should be held with the user to determine if the
published times should be amended to reflect current
3. Compare scheduled time
to activated time. Is the amount of time the area is
being activated consistent with the amount of
scheduled use? A significant difference between
these times may indicate a need to discuss real-time
use or revalidate published times of use with the
user. Consideration should be given to the effects
of weather or maintenance cancellations, or other
factors limiting the using agency's use of the area.
4. NOTAM Activation. If a
NOTAM provision is included in the SUA legal
description, and activation by NOTAM is extensive or
routine, consider whether it would be advantageous
to increase the published times of use to include
the routine NOTAM period. This action may better
inform the flying public of expected area usage
periods, and reduce NOTAM system workload.
5. Intermittent Time of
Use. If regular use of the area occurs during a set
time period daily, or if use has become other than
sporadic, consider whether specific times of use
should be published to better inform the flying
public of expected area usage periods and reflect
current mission requirements.
d. Non-utilization of SUA.
A using agency is required to explain in the remarks
section of its annual utilization report why it did
not use the SUA area during an entire reporting
period. If no such explanation is provided, request
that the military representative or using agency
provide the reasons and the using agency's plans for
future use of the airspace.
1. If the user responds
that the SUA is no longer required, initiate action
to revoke the airspace.
2. If the user validates a
continuing need for the airspace, coordinate with
the user to determine if the area's dimensions
and/or times of use remain valid or should be
amended to reflect current requirements.
3. If the airspace remains
unused for a second consecutive fiscal year period,
inform the military representative of the FAA's
intent to revoke the area unless additional
justification for retaining the airspace is
e. Joint-use and Real-time
Use Procedures. Evaluate the effectiveness of
joint-use procedures and real-time
activation/deactivation procedures (if applicable).
Obtain input from the controlling agency as needed.
1. Are procedures for
timely release of joint-use airspace contained in a
letter of agreement?
2. Are real-time
activation/deactivation procedures specified and
f. Area Scheduling. Does
the using agency schedule the area in accordance
with FAAO JO 7610.4, Special Operations,
g. Aeronautical Charts and
Publications. Check the accuracy of SUA information
shown on aeronautical charts and contained in
applicable publications. Submit required corrections
to Airspace Regulations and ATC Procedures Group for
h. Other Issues. Determine
if there are any other issues that require further
investigation, such as:
1. Adverse impact on NAS
2. Recurring spill outs.
3. Frequent instances of
limitations on the use or activation of the SUA by
the controlling agency.
21-8-6. SUA REVIEW FOLLOW UP ACTION
The service area office's annual
SUA review forms the basis for further discussions
with user representatives to resolve any
discrepancies noted or other issues that were
identified. Results of the review should be
documented and maintained on file in accordance with
current administrative guidance. Regional/service
area office follow up actions are dependent on the
results of the review as follows:
a. If it is determined
that the existing SUA parameters (times, altitudes,
boundaries) are valid, no further action is required
other than documentation of the review results.
b. If any SUA parameters
are found to exceed the user's requirements or if it
is determined that the SUA does not accommodate the
user's current mission requirements, then the
service area office should discuss the finding with
the military representative/using agency official.
When appropriate, the service area office should
request the user to submit an airspace proposal to
amend the SUA description.