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 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 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 Regulations and ATC Procedures Group 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.