**[SECTION I PETITION FOR AIRSPACE DESIGNATION]{.underline}**

**PETITIONER INFORMATION**

Headquarters Air Combat Command (HQ/ACC) Airspace, Ranges and Airfield
Operation Division (A3A) POC: Edward H. Odom, 205 Dodd Blvd. Ste. 101,
Langley AFB, VA 23665-2789, Duty: 757-764-6002, Fax: 757-764-6009,
email: <edward.odom@us.af.mil>

**PROPOSED ACTION**

The United States Air Force (USAF), HQ/ACC petitions the Federal
Aviation Administration (FAA) to apply a Special Air Traffic Rule (SATR)
under the Code of Federal Regulation (CFR) Title 14, Part 93 for the
airspace over Beale Air Force Base's (BAFB) Class "C" airspace. The SATR
airspace would be from and including 4,100 feet mean sea level (MSL) up
to and including 18,000' MSL, the floor of Class "A" airspace, within a
10 nautical mile radius (NMR) of 390817N/1212610W. The SATR will allow
BAFB to safely operate the RQ-4 Global Hawk (GH) unmanned aircraft
system (UAS) around their terminal environment. The SATR should require
all Instrument Flight Rule (IFR) and Visual Flight Rule (VFR) aircraft
to be transponder equipped and while entering or exiting the SATR
airspace, maintain two-way radio contact with Northern California
Terminal Approach Control (NCT). NCT will provide radar service and/or
traffic advisories to all aircraft within the SATR during GH operations
within the SATR.

**HISTORY**

Beale Air Force Base was selected as the first operational base for GH
in 1999. Other locations evaluated were Wright Patterson AFB, OH, Tinker
AFB, OK, Ellsworth AFB, SD and Edwards AFB CA. The charter at the time
was to identify bases that could accommodate the GH, evaluating traffic
density and airspace congestion, regardless of associated restricted
airspace. Edwards AFB was the only base with associated restricted
airspace which is required for UAS operations when operating without a
Certificate of Authorization (COA). The restricted airspace requirement
was IAW FAAO 7610.4, Chapter 12, section 9. Based on airspace, Edwards
AFB was the most logical choice with restricted airspace available.
Ellsworth AFB had uncongested airspace and a DOD managed ATC radar
facility available. Beale AFB was the third choice. The determining
factor to base GH at Beale can be attributed to mission commonality; GH
is the successor to the U-2's reconnaissance mission based at Beale AFB.
In-depth GH briefings were provided to Oakland ARTCC and (then)
Sacramento TRACON. Both facilities indicated they could accommodate GH
operations with very little disruption to the local ATC environment.
Airspace segregation was considered, but not an overriding factor since
there was broad FAA support from HQ and local ATC agencies to operate
from BAFB.

**PURPOSE**

The primary purpose of a SATR at BAFB is to increase the safety factor
during GH operations; by reducing the possibility that a non-cooperative
aircraft, unreported or unseen visually or on radar, would conflict with
terminal UAS operations at BAFB. SATRs are permanently depicted on
charts for all pilots to see and in FAAO Part 93. Requiring aircraft to
have operational transponders with mode C and two-way radio
communications with ATC within the SATR will be in addition to the GH
pilot using radar to (sense) see-and-avoid (SAA) traffic. Although
technological efforts have begun to equip GH with a SAA capability that
proposes to exceed those SAA capabilities of manned aircraft, that
capability will not be available until the 2017-2020 timeframe.
Currently, a Temporary Flight Restriction (TFR) is used at BAFB to
supplement radar as a means to segregate and identify traffic. The TFR
will continue until a longer term fix is established. The USAF proposes
the SATR designation be used as an additional safety measure, moving
from the current TFR operations and eventually achieving a SAA long term
fix. The USAF does not propose the SATR replace SAA on GH at BAFB, but
to supplement radar monitoring by the UAS pilot and current requirements
already imposed over Beale's Class C airspace by FAR Part 91.215(b).
This requires all aircraft to be transponder/mode C, equipped within the
lateral boundaries of the Class C and up to 10,000' MSL. Above 10,000',
all aircraft [except]{.underline} those not originally certified with an
engine-driven electrical system, balloons or gliders must also be
transponder /mode C equipped. The possibility of an "excepted aircraft"
operating above 10,000'over BAFB's Class C is very remote, but a SATR
would further reduce that possibility. After SAA equipment is developed
and added to GH, the SATR may remain in place to continue providing
additional safety or discontinued as deemed appropriate by a record of
safety.

**PROPOSED SATR LANGUAGE FOR SECTIONAL AERONAUTICAL CHART**

SPECIAL AIR TRAFFIC RULE, F.A.R. PART 93, BEALE TERMINAL AREA,
CALIFORNIA (VFR or IFR CONDITIONS)

UNMANNED AIRCRAFT OPERATIONS IN VICINITY OF BEALE AFB

A SPECIAL AIR TRAFFIC RULE FAR PART 93, REQUIRES AIRCRAFT TO BE
TRANSPONDER WITH MODE C CAPABILITY EQUIPPED AND PILOTS TO MAINTAIN 2-WAY
RADIO COMMUNICATIONS WITH NORCAL TRACON FOR ENTRY INTO/EXIT FROM THE
SATR AIRSPACE WITHIN A 10 NM RADIUS OF 390817N/1212610W FROM AND AT
4100' MSL UP TO AND INCLUDING 18,000' MSL.

**[SECTION II JUSTIFICATION]{.underline}**

**GENERAL**

Currently, TFR activation by NOTAM is used for launch and recovery of
Global Hawk at BAFB. The FAA UAS ATO office has determined that a TFR is
the best way to guarantee segregation of GH and non-cooperative aircraft
in addition to the pilot's use of radar to identify traffic conflicts.
Although the TFR restricts access to the airspace between Beale's Class
C airspace and the base of the Class A airspace above, the NOTAM could
be missed by pilots of non-cooperative aircraft. One particular incident
highlighted that possibility when a General Aviation aircraft on a VFR
flight plan was seen on radar entering the active TFR which caused an
immediate altitude restriction for GH on departure and averted a near
miss. The GA pilot had not read the NOTAM, was not aware of the TFR and
was cited for violating it. The TFR adds an additional safety measure at
BAFB, but the "on/off" transient nature of the TFR and NOTAM
dissemination process exacerbates the possibility of oversight. A SATR
however, is full-time and reduces the possibility of oversight as the
local aviation community is involved with its development and its
depiction on aeronautical charts. Once established and briefed annually
in Beale's Midair Collision Avoidance (MACA) program, the existence and
operating rules of the SATR will be highly visible, stable and difficult
to overlook; thereby increasing flight safety. NCT monitoring of the
SATR would allow real time airspace oversight during GH operations and
thereby enhancing access by civil aviation. The current TFR method is
constrained by 24 hour advance notice for NOTAM action and offers no
flexibility for arrivals/departures due to unexpected circumstances or
an in-flight emergency. Keeping a TFR in place during an extended
mission is overly restrictive to airspace and use by other aircraft,
whereas a SATR would provide full flexibility of airspace utilization by
NCT.

**SPECIFIC**

A TFR by nature is restrictive and increases Air Traffic Services
workload. The FAA currently limits the weekly number of TFR's at BAFB.
This is disruptive and limiting to military requirements. It has
inhibited BAFB's ability to fulfill training requirements levied on USAF
units to meet Combatant Commanders (COCOM) growing need for
Intelligence, Surveillance and Reconnaissance (ISR). Specifically, the
9RW, in coordination with ACC, has determined that 186 RQ-4 pilots are
required by FY12 to satisfy COCOM requirements (285 if Grand Forks AFB
is included as a second main operating base). In FY07, using a
combination of 37 local sorties, in-garrison as well as deployed Global
War on Terrorism missions; the 9RW qualified 25 new RQ-4 pilots and 11
instructor pilots. Currently, 48 pilots and 16 IPs are programmed in
FY08; however, the actual stated requirement from ACC is 60 pilots/20
instructors annually requiring over 295 local RQ-4 sorties per year for
initial and continuation training. While a normal year has approximately
230 Operations &Maintenance days, this requires at least one sortie
every day driving a need for an increased operational tempo than the
current TFR process allows.

The 9RW developed procedural plans to optimize mission
effectiveness/sortie generation given current TFR constraints. These
procedural changes require a heavy reliance on training during actual
combat sorties and adjustments to current training syllabi; however,
this arrangement temporarily reduces the total number of sorties
available to train aircrews from Beale as noted above (approximately 200
vs 295 sorties).

Under current constraints, BAFB is unable to train effectively and
operate as required.

As a result, Beale is unable to maintain combat readiness to meet COCOM
requirements. A SATR at Beale would eliminate TFR constraints and allow
BAFB to fulfill national defense needs.

**PUBLIC INTEREST**

The explosion of UAS technology in DOD has outpaced policy changes to
CFRs and in the National Airspace System. Currently, UAS conform to CFR
traditionally designed for manned flight with no consideration for
unmanned aircraft. Consequently, UAS flights are segregated from
commercial and general aviation flights by confining them to Restricted,
Warning, or Prohibited Areas. Outside those areas, UAS flight is by
exception and waived or authorized through the use of a COA. Safety
mitigations are required to compensate for the lack of SAA and
identified in the request for a COA. The primary methods of mitigations
at Beale are through radar monitoring, FAR Part 91.215 requirements and
a National Security TFR. The TFR's construct is to keep non-cooperative
aircraft away from specified areas, but as the title indicates,
temporary and restrictive in nature. Beale is the first permanent
operational base for GH. A permanent fix for Beale is needed to ensure
the flying public is aware of the unique flying operations and that all
aircraft and their altitudes are displayed on radar. A SATR would insure
all traffic is known and allow NCT real-time use of the airspace to move
aircraft unimpeded through the Beale terminal area. Charting and full
time monitoring of the airspace would significantly reduce the
possibility that a non-cooperative, non-squawking aircraft would
inadvertently enter the area while UAS operations are in effect.

**SAFETY CONSIDERATIONS**

Time, experience, and safety studies should precede full integration of
manned aircraft and UAS. Until such time that manned and unmanned
aircraft have proven safe and compatible flying together in desegregated
airspace, mixing those flights in uncontrolled airspace should have
additional safety measures in place. Currently, the airspace between
Beale's Class "C" airspace (4100'MSL) and the floor of the Class "A"
airspace (18,000' MSL) is uncontrolled. During the launch and recovery
of GH a National Security TFR goes into effect. The TFR allows for
positive control of the airspace above Beale. It requires all aircraft
to squawk a discrete code, maintain two-way radio communications and
request approval from NCT to enter. The TFR is dependent on the NOTAM
system to disseminate the details and activation of the TFR. As a
result, the possibility of civil aircraft not receiving the NOTAM
information exists. This possibility was highlighted by the scenario in
May 2007 when the GA aircraft unaware of the Beale TFR entered the TFR
during a GH departure. The aircraft was identified on radar, but took an
unexpected turn northbound into the TFR at Beale. NCT immediately
informed the GH pilot to maintain an altitude of 7000' on departure to
avoid the GA traffic. GH leveled off at 7000' and the GA aircraft passed
overhead avoiding a near miss. The pilot GA was unaware of the UAS
operations at Beale AFB or of the TFR in effect. Under SATR this
information is described Under Part 93 of CFR 14, annotated on
aeronautical charts on a full time basis and not dependent on the NOTAM
system. The SATR would soon be known by and normalized within the
aviation community. In addition BAFB has an excellent MACA program
designed to inform the local flying community of the type and frequency
of Beale's flying operations. The MACA program, in conjunction with the
SATR requiring transponder with altitude information and two-way radio,
would make the possibility of an aircraft intrusion even more unlikely
than a TFR alone.

**LOCATION/DISCRIPTION OF AIRSPACE DESIGNATION**

That airspace above Beale AFB California, from the top of Beale's
Surface Class "C" airspace (at and above 4100' MSL) to the base of
Surface Class "A" airspace (up to and including 18,000' MSL), within a
10 NM Radius of Beale AFB (390817N/1212610). The USAF is petitioning the
FAA to designate, under FAR Part 93, a Special Air Traffic Rule that
stipulates certain operational rules within this airspace: SATR requires
aircraft transiting this area to be transponder with Mode C equipped and
in direct two-way radio communications with NCT.

**DESCRIPTION OF ACTIVITY IN SATR**

Daily GH departures and arrivals would be the only activity requiring
close monitoring of airspace between manned aircraft and UASs. The
amount of time GH would be utilizing the SATR for each departure and
arrival would be less than 10 minutes for each operation. Daily
operations would normally be 2 arrivals and 2 departures in a 24 hour
period. NCT would have full use of that airspace to operate as needed
providing traffic advisories and service as necessary. The dynamic
nature of DOD requirements, USAF operations and maintenance, make it
unpredictable as to a specific daily schedule. As a result, the SATR
must remain in effect fulltime. The actual times that UAS traffic
advisories would be necessary should only constitute a small portion of
a 24 hour day. NCT would maintain full awareness of operations in the
SATR to include GH operations. Real time use and availability under the
SATR would be unobtrusive to civil aviation and its effect would be
minor to all but a very few aircraft.

**COSTS AND BENEFITS**

Main costs associated with SATR would involve a slight increase in
workload for the Beale sector of NCT. Providing full time monitoring for
that airspace over Beale AFB would have some impact, but indications
from NCT are that the service would not be significantly disruptive or
costly in terms of additional manpower. NCT has suggested that these
services are acceptable under current manpower standards. An
environmental analysis of the SATR's affects would be accomplished by
ACC and FAA as necessary. The cost of the analysis will be dependent on
the depth required to support establishing the SATR. Other costs would
be the administrative costs associated with the rule-making action,
public comments, and the time and costs of the committee determining
merits of the petition. The main benefit to the flying public would be
an additional layer of safety until a reliable safety record is
recorded. Until UAS activity has proven to be as safe as manned aircraft
activity, to err on the conservative side of safety is paramount. Time,
experience, safety studies, and SAA equipage will determine the future
of UAS NAS operation integrated with manned aircraft. Until enough data
is collected to fully assess the compatibility of integrated flight,
efforts to segregate UAS flight or mitigate with additional safety
measures should be the standard. A SATR will restrict flight above Beale
only to those aircraft not required to be equipped with a transponder
under FAR Part 91.215, aircraft not originally certified with an
engine-driven electrical system, balloons or gliders. Those aircraft
without equipage would be a very small percentage of the activity
utilizing that airspace proposed for SATR. The need to confirm and
ensure flight safety concerns overrides the inconvenience of a minute
number of unequipped GA aircraft that could not access the Beale SATR.

**SUMMARY**

Beale AFB in northern California is the first operational wing to fly
the RQ-4, Global Hawk, high altitude, high endurance UAS designed for
Global Intelligence, Surveillance and Reconnaissance missions. CFRs and
FARs were written for manned aircraft without regard to unmanned
aircraft. GH currently uses primarily radar monitoring and a TFR to
mitigate SAA shortcomings and is not expected to be equipped with SAA
capability until 2017 or later. The current use of a TFR between Beale's
Class "C" and up to the Class "A" airspace to launch and recover GH from
Beale is overly restrictive to civil aviation, coordination intensive
and the NOTAM process ineffective to insure an inadvertent
nonparticipating aircraft could enter the TFR undetected. Until there is
a major rewrite of CFRs and FARs to include UASs, operators of UAS and
manned aircraft need to be extra vigilant and safe. A SATR requiring
transponder operations and two-way radio communication for all aircraft
operations above BAFB would eliminate the remote possibility of an
aircraft "excepted" by FAR Part 91.215 from straying into the
environment. The USAF is petitioning the FAA to designate a Special Air
Traffic Rule requiring all aircraft that fly in the airspace above BAFB
Class "C" airspace up to and including the floor of Class "A" airspace
be transponder equipped/mode C capable and maintain two way radio
communications with ATC.

**CURRENT TFR (SAMPLE) NOTAM/MAP**

BEALE AFB, CA, (DATE) LOCAL. PURSUANT TO 49 USC 40103(B), THE FEDERAL
AVIATION ADMINISTRATION (FAA) CLASSIFIES THE AIRSPACE DEFINED IN THIS
NOTAM AS \'NATIONAL DEFENSE AIRSPACE\'. ANY PERSON WHO KNOWINGLY OR
WILLFULLY VIOLATES THE RULES CONCERNING OPERATIONS IN THIS AIRSPACE MAY
BE SUBJECT TO CERTAIN CRIMINAL PENALTIES UNDER 49 USC 46307. PILOTS WHO
DO NOT ADHERE TO THE FOLLOWING PROCEDURES MAY BE INTERCEPTED, AND MAY BE
DETAINED AND INTERVIEWED BY LAW ENFORCEMENT/SECURITY PERSONNEL.

PURSUANT TO TITLE 14 CFR SECTION 99.7, SPECIAL SECURITY INSTRUCTIONS,
ALL AIRCRAFT FLIGHT OPERATIONS ARE PROHIBITED WITHIN A 10 NMR OF
390803N/1212615W OR THE MYV055006.7 FROM AND INCLUDING 4100 FT MSL UP TO
AND INCLUDING 18000 FT MSL EFFECTIVE 0804301725 UTC (1025 LOCAL
xx/xx/08) UNTIL 0804301925 UTC (1225 LOCAL 04/30/08).

EXCEPT AS SPECIFIED BELOW AND/OR UNLESS AUTHORIZED BY ATC:

1\. ALL AIRCRAFT ENTERING OR EXITING THE TFR MUST BE ON A DISCRETE CODE
ASSIGNED BY AN AIR TRAFFIC END PART 1 OF 2. WIE UNTIL UFN. CREATED:
Date/Time

FDC 8/5074 - PART 2 OF 2 CA.. FLIGHT RESTRICTIONS. CONTROL (ATC)
FACILITY.

2\. AIRCRAFT MUST BE SQUAWKING THE DISCRETE CODE AT ALL TIMES WHILE IN
THE TFR.

3\. ALL AIRCRAFT ENTERING OR EXITING THE TFR MUST REMAIN IN TWO-WAY
RADIO COMMUNICATIONS WITH ATC.

4\. NORTHERN CALIFORNIA TRACON, PHONE 916-366-4080, IS THE FAA
COORDINATION FACILITY.

END PART 2 OF 2. WIE UNTIL UFN. CREATED: 26 APR 19:58 2008

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**PART 93 MAP AND PROPOSED MAP
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