Section 8. SUA Review and Analysis
21-8-1. GENERAL
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 airspace personnel.
21-8-2. POLICY
a. The service area office shall 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 shall 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
Section 7 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 Agreement.
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 being reviewed.
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
available.
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 section).
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 evaluated:
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 the description.
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 mission requirements.
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 submitted.
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 used?
f. Area Scheduling. Does the using agency
schedule the area in accordance with FAAO
JO 7610.4, Special Operations, requirements?
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 and Rules for processing.
h. Other Issues. Determine if there are any other
issues that require further investigation, such as:
1. Adverse impact on NAS operations.
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.
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