Story ID: 
AIN Blog: Notams Still Incomprehensible
By: Matt Thurber
Caption: The FAA's Notam system is still broken, and for safety's sake it needs to be fixed.
Word Count: 2177
Here we are in a wonderful modern age, with amazing avionics that show where we are down to the sub-meter, 3-D synthetic vision, fly-by-wire flight controls that can save us from flying badly and even (well, almost) flying cars. Yet the FAA still cannot publish a Notice to Airmen that isn't unnecessarily incomprehensible. Come on! Isn't it time to get with the program and write these important safety documents in a form of English that your average human pilot can actually read and understand?
Indulge me with an example, pictured above. This was issued on December 14. I will summarize its key element in one sentence: "Foreign-registered aircraft that weigh 100,309 poundsor less will require a TSA waiver to fly through U.S. airspace."
The full Notam is at the end of this blog. I was tempted to put it right here, but that would probably scramble your brains so much that you would never make it to the end of my diatribe.
I do have to give credit to Rockwell Collins ArincDirect for publishing a clearly written explanation of this Notam.
So what is wrong with the original Notam? Go ahead, try reading it. I dare you. Give up?
What's wrong is that the chosen format is completely antithetical to comprehension. Hello! ALL CAPS IS HARD TO READ AND GIVES US A HEADACHE. Add to that zero paragraph breaks, and there is absolutely no way to parse the important information in this Notam. There is a reason that written languages use formatting, punctuation and fonts to express ideas and explain new and important information.
So why are Notams still published this way?
The simple answer is that some receivers of Notams apparently still rely on teletype machines, for which this formatting was designed. The lowest common denominator applies, so the rest of us with modern Internet access and virtually unlimited cheap storage have to put up with this lousy and, yes, terribly unsafe system. Here’s the official response from the FAA, when I asked why Notams such as this one are so incomprehensible: “We design NOTAMs so that they can be distributed to even the most undeveloped country, which in some cases still use older communications methods, such as teletype. Air traffic controllers, pilots and flight planners are all familiar with and able to interpret NOTAMs the way they are written."
Well, sorry, I beg to differ. Never in all the flight training I’ve been through has a single instructor provided any information about how to decipher Notams. They just left it up to me to figure it out. Sure there are useful Notam-decoding helpers on the Web, but why should Notams have to be decoded? In any case, I plugged this Notam into a decoder, and it choked on it.
It’s been proved over and over again than when obstacles get in the way of dissemination of safety information, removing those obstacles can’t help but benefit safety. It is way beyond time to dump this useless Notam-dissemination system. If that takes ICAO changing its lowest-common-denominator requirements, so be it. For the FAA to assume that all pilots are able to decipher and understand the incredibly high volume of poorly written and badly formatted Notams issued for a particular flight plan is ludicrous and dangerous and just sets pilots up for a violation.
I’m aware that the Pilots Bill of Rights, currently (we hope) on its way to making it into law, addresses the violation aspect of the Notam situation, but this industry shouldn’t have to rely on legislation to combat a safety deficiency. We’re smart enough to fix this on our own. Let’s get to work.
TSA Waiver Notam: Decipher if You Can
FDC 5/6289 ZZZ PART 1 OF 9 SECURITY SPECIAL SECURITY INSTRUCTIONS FOR CIVIL AIRCRAFT OPERATIONS WITHIN OR TRANSITING THE TERRITORIAL AIRSPACE OF THE UNITED STATES (U.S.). THE FOLLOWING SPECIAL SECURITY REQUIREMENTS FOR CIVIL AIRCRAFT OPERATIONS WITHIN OR TRANSITING U.S. TERRITORIAL AIRSPACE ARE IN EFFECT PURSUANT TO 14 CFR 99.7, SPECIAL SECURITY INSTRUCTIONS, AND 49 USC 40103 AND 41703, IN ADDITION TO THE REQUIREMENTS PRESCRIBED IN 14 CFR PART 99, SECURITY CONTROL OF AIR TRAFFIC. THE REQUIREMENTS IN THIS NOTAM SUPERSEDE THE REQUIREMENTS FOR CIVIL AIRCRAFT OPERATIONS WITHIN OR TRANSITING U.S. TERRITORIAL AIRSPACE FORMERLY PUBLISHED IN FDC NOTAMS 3/2735, 3/2768, AND 3/3013. SECURITY REQUIREMENTS FOR CIVIL AIRCRAFT OPERATIONS TO OR FROM U.S. TERRITORIAL AIRSPACE ARE PROVIDED IN A SEPARATE NOTAM. IN ADDITION TO THE REQUIREMENTS OF THIS NOTAM, CIVIL AIRCRAFT OPERATIONS WITHIN OR TRANSITING THE TERRITORIAL AIRSPACE OF THE U.S. MUST ALSO COMPLY WITH ALL OTHER APPLICABLE REGULATIONS PUBLISHED IN TITLE 14, CODE OF FEDERAL REGULATIONS (CFR). PART I. CIVIL AIRCRAFT OPERATIONS WITHIN U.S. TERRITORIAL AIRSPACE A. CIVIL AIRCRAFT WITH A MAXIMUM CERTIFICATED TAKEOFF GROSS WEIGHT LESS THAN OR EQUAL TO 100,309 POUNDS (45,500 KGS) ARE AUTHORIZED TO 1512140040-PERM END PART 1 OF 9 FDC 5/6289 ZZZ PART 2 OF 9 SECURITY SPECIAL SECURITY INSTRUCTIONS FOR CIVIL OPERATE WITHIN THE TERRITORIAL AIRSPACE OF THE U.S. IN ACCORDANCE WITH ALL APPLICABLE REGULATIONS AND IN VFR IN AIRPORT TRAFFIC PATTERN AREAS OF UNITED STATES AIRPORTS NEAR THE UNITED STATES BORDER WITH THE EXCEPTION OF AIRCRAFT DESCRIBED IN PARAGRAPH 1) BELOW: 1) CIVIL AIRCRAFT WITH A MAXIMUM CERTIFICATED TAKEOFF GROSS WEIGHT LESS THAN OR EQUAL TO 100,309 POUNDS (45,500 KGS) AND REGISTERED IN A U.S. STATE DEPARTMENT-DESIGNATED SPECIAL INTEREST COUNTRY OR OPERATING WITH THE ICAO THREE LETTER DESIGNATOR OF A COMPANY IN A COUNTRY LISTED AS A U.S. STATE DEPARTMENT-DESIGNATED SPECIAL INTEREST COUNTRY, UNLESS THE OPERATOR HOLDS VALID FAA PART 129 OPERATIONS SPECIFICATIONS, MUST OPERATE WITHIN THE TERRITORIAL AIRSPACE OF THE U.S. IN ACCORDANCE WITH THE SAME REQUIREMENTS OF CIVIL AIRCRAFT WITH A MAXIMUM CERTIFICATED TAKEOFF GROSS WEIGHT GREAT THAN 100,309 POUNDS (45,500 KGS) DESCRIBED IN PARAGRAPH B. B. CIVIL AIRCRAFT WITH A MAXIMUM CERTIFICATED TAKEOFF GROSS WEIGHT GREATER THAN 100,309 POUNDS (45,500 KGS) ARE AUTHORIZED TO OPERATE WITHIN THE TERRITORIAL AIRSPACE IF IN COMPLIANCE WITH THE FOLLOWING CONDITIONS: 1512140040-PERM END PART 2 OF 9 FDC 5/6289 ZZZ PART 3 OF 9 SECURITY SPECIAL SECURITY INSTRUCTIONS FOR CIVIL 1) FILE AND ARE ON AN ACTIVE IFR OR VFR FLIGHT PLAN; 2) ARE EQUIPPED WITH AN OPERATIONAL MODE C OR S TRANSPONDER AND CONTINUOUSLY SQUAWK AN ATC ASSIGNED TRANSPONDER CODE; 3) MAINTAIN TWO-WAY COMMUNICATIONS WITH ATC; 4) ARE OPERATING UNDER AN APPROVED TSA AVIATION SECURITY PROGRAM OR ARE OPERATING WITH AN FAA/TSA AIRSPACE WAIVER, IF THE AIRCRAFT IS NOT REGISTERED IN THE U.S.; 5) ARE IN RECEIPT OF AN FAA ROUTING AUTHORIZATION AND AN FAA/TSA AIRSPACE WAIVER IF THE AIRCRAFT IS REGISTERED IN A U.S. STATE DEPARTMENT-DESIGNATED SPECIAL INTEREST COUNTRY OR IS OPERATING WITH THE ICAO THREE LETTER DESIGNATOR OF A COMPANY IN A COUNTRY LISTED AS A U.S. STATE DEPARTMENT-DESIGNATED SPECIAL INTEREST COUNTRY, UNLESS THE OPERATOR HOLDS VALID FAA PART 129 OPERATIONS SPECIFICATIONS. FAA ROUTING AUTHORIZATION FOR OPERATIONS WITHIN U.S. TERRITORIAL AIRSPACE BY AIRCRAFT DESCRIBED IN THIS SUBPARAGRAPH B.5 MAY BE GRANTED ONLY FOR IFR OPERATIONS. VFR FLIGHT OPERATIONS ARE PROHIBITED WITHIN U.S. TERRITORIAL AIRSPACE FOR ANY AIRCRAFT REQUIRING AN FAA ROUTING AUTHORIZATION. 6) WHEN CONDUCTING POST-MAINTENANCE, MANUFACTURER, PRODUCTION, OR 1512140040-PERM END PART 3 OF 9 FDC 5/6289 ZZZ PART 4 OF 9 SECURITY SPECIAL SECURITY INSTRUCTIONS FOR CIVIL ACCEPTANCE FLIGHT TEST OPERATIONS, IF THE AIRCRAFT IS NOT REGISTERED IN THE U.S. THE FOLLOWING REQUIREMENTS MUST BE MET: A) A U.S. COMPANY MUST HAVE OPERATIONAL CONTROL OF THE AIRCRAFT; B) AN FAA-CERTIFICATED PILOT MUST SERVE AS PILOT IN COMMAND; C) ONLY CREWMEMBERS ARE PERMITTED ONBOARD THE AIRCRAFT; D) MAINTENANCE FLIGHT IS INCLUDED IN THE REMARKS SECTION OF THE FLIGHT PLAN. PART II. CIVIL AIRCRAFT OPERATIONS THAT TRANSIT U.S. TERRITORIAL AIRSPACE A. CIVIL AIRCRAFT ARE AUTHORIZED TO TRANSIT THE TERRITORIAL AIRSPACE OF THE U.S., IF IN COMPLIANCE WITH THE FOLLOWING CONDITIONS: 1) FILE AND ARE ON AN ACTIVE IFR OR DVFR FLIGHT PLAN; 2) ARE EQUIPPED WITH AN OPERATIONAL MODE C OR S TRANSPONDER AND CONTINUOUSLY SQUAWK AN ATC ASSIGNED TRANSPONDER CODE; 3) MAINTAIN TWO-WAY COMMUNICATIONS WITH ATC; 4) ARE OPERATING UNDER AN APPROVED TSA AVIATION SECURITY PROGRAM OR ARE OPERATING WITH AN FAA/TSA AIRSPACE WAIVER, IF: (A) THE AIRCRAFT IS NOT REGISTERED IN THE U.S.; OR (B) THE AIRCRAFT IS REGISTERED IN THE U.S. AND ITS MAXIMUM TAKEOFF 1512140040-PERM END PART 4 OF 9 FDC 5/6289 ZZZ PART 5 OF 9 SECURITY SPECIAL SECURITY INSTRUCTIONS FOR CIVIL GROSS WEIGHT IS GREATER THAN 100,309 POUNDS (45,500 KGS); 5) ARE IN RECEIPT OF AN FAA ROUTING AUTHORIZATION IF THE AIRCRAFT IS REGISTERED IN A U.S. STATE DEPARTMENT-DESIGNATED SPECIAL INTEREST COUNTRY OR IS OPERATING WITH THE ICAO THREE LETTER DESIGNATOR OF A COMPANY IN A COUNTRY LISTED AS A U.S. STATE DEPARTMENT-DESIGNATED SPECIAL INTEREST COUNTRY, UNLESS THE OPERATOR HOLDS VALID FAA PART 129 OPERATIONS SPECIFICATIONS. FAA ROUTING AUTHORIZATION FOR TRANSIT OF U.S. TERRITORIAL AIRSPACE BY AIRCRAFT SUBJECT TO THIS SUBPARAGRAH A.5 MAY BE GRANTED ONLY FOR IFR OPERATIONS. DVFR AND VFR FLIGHT OPERATIONS ARE PROHIBITED FOR ANY AIRCRAFT REQUIRING AN FAA ROUTING AUTHORIZATION. B. CIVIL AIRCRAFT REGISTERED IN MEXICO OR CANADA AND ENGAGED IN OPERATIONS FOR THE PURPOSES OF AIR AMBULANCE, FIRE FIGHTING, LAW ENFORCEMENT, SEARCH AND RESCUE, AND EMERGENCY EVACUATION ARE AUTHORIZED TO TRANSIT U.S. TERRITORIAL AIRSPACE WITHIN 50 NM OF THEIR RESPECTIVE BORDERS WITH THE U.S., WITH OR WITHOUT AN ACTIVE FLIGHT PLAN, PROVIDED THEY HAVE RECEIVED AND CONTINUOUSLY TRANSMIT AN ATC-ASSIGNED TRANSPONDER CODE. PART III. FAA/TSA AIRSPACE WAIVER, TSA AVIATION SECURITY PROGRAM, 1512140040-PERM END PART 5 OF 9 FDC 5/6289 ZZZ PART 6 OF 9 SECURITY SPECIAL SECURITY INSTRUCTIONS FOR CIVIL AND FAA ROUTING AUTHORIZATION INFORMATION. A. FAA/TSA AIRSPACE WAIVERS 1) OPERATORS MAY SUBMIT REQUESTS FOR FAA/TSA AIRSPACE WAIVERS AT HTTPS://WAIVERS.FAA.GOV BY SELECTING INTERNATIONAL AS THE WAIVER TYPE. 2) INFORMATION REGARDING FAA/TSA AIRSPACE WAIVERS CAN BE FOUND AT: HTTP://WWW.TSA.GOV/FOR-INDUSTRY/GENERAL-AVIATION OR CAN BE OBTAINED BY CONTACTING TSA AT 571-227-2071. 3) ALL EXISTING FAA/TSA WAIVERS ISSUED UNDER PREVIOUS FDC NOTAMS REMAIN VALID UNTIL THE EXPIRATION DATE SPECIFIED IN THE WAIVER, UNLESS SOONER SUPERSEDED OR RESCINDED. B. TSA AVIATION SECURITY PROGRAMS 1) CONTACTS FOR INFORMATION REGARDING TSA AVIATION SECURITY PROGRAMS FOR APPLICANTS FOR U.S. AIR OPERATOR CERTIFICATES WILL BE PROVIDED BY THE U.S. DEPARTMENT OF TRANSPORTATION DURING THE CERTIFICATION PROCESS. 2) FOR INFORMATION ABOUT APPLICABLE TSA SECURITY PROGRAMS, U.S. AIR CARRIERS AND COMMERCIAL OPERATORS MUST CONTACT THEIR TSA PRINCIPAL SECURITY SPECIALIST (PSS), AND FOREIGN AIR CARRIERS MUST CONTACT 1512140040-PERM END PART 6 OF 9 FDC 5/6289 ZZZ PART 7 OF 9 SECURITY SPECIAL SECURITY INSTRUCTIONS FOR CIVIL THEIR INTERNATIONAL INDUSTRY REPRESENTATIVE (IIR). C. INFORMATION ABOUT FAA ROUTING AUTHORIZATIONS FOR U.S. STATE DEPARTMENT-DESIGNATED SPECIAL INTEREST COUNTRY FLIGHT OPERATIONS IN U.S. TERRITORIAL AIRSPACE IS AVAILABLE BY COUNTRY AT: HTTP://WWW.FAA.GOV/AIR_TRAFFIC/PUBLICATIONS/US_RESTRICTIONS/ OR BY CONTACTING THE FAA SYSTEM OPERATIONS SUPPORT CENTER (SOSC) AT 202-267-8115. PART IV. SPECIAL EMPHASIS A. PILOTS ARE REMINDED THAT THERE ARE INCREASED SECURITY MEASURES IN PLACE AT MANY AREAS. IN ACCORDANCE WITH 14 CFR 91.103, PRIOR TO DEPARTURE, PILOTS MUST BECOME FAMILIAR WITH ALL AVAILABLE INFORMATION CONCERNING THAT FLIGHT, INCLUDING ANY TEMPORARY FLIGHT RESTRICTIONS ALONG THEIR ROUTE OF FLIGHT OR AT THEIR POINT OF DEPARTURE/ARRIVAL. B. NONCOMPLIANCE WITH THESE SPECIAL SECURITY REQUIREMENTS MAY RESULT IN DENIAL OF FLIGHT ENTRY INTO U.S. TERRITORIAL AIRSPACE OR GROUND STOP OF THE FLIGHT AT A U.S. AIRPORT. C. PURSUANT TO 49 USC 40103(B)(3), THE FAA ADMINISTRATOR HEREBY ORDERS THAT ALL U.S. TERRITORIAL AIRSPACE IS NATIONAL DEFENSE 1512140040-PERM END PART 7 OF 9 FDC 5/6289 ZZZ PART 8 OF 9 SECURITY SPECIAL SECURITY INSTRUCTIONS FOR CIVIL AIRSPACE. PILOTS OF AIRCRAFT THAT DO NOT ADHERE TO THE PROCEDURES IN THE SPECIAL SECURITY REQUIREMENTS CONTAINED IN THIS NOTAM MAY BE INTERCEPTED, DETAINED AND INTERVIEWED BY LAW ENFORCEMENT, U.S. SECRET SERVICE (USSS), OR OTHER SECURITY PERSONNEL. ANY PERSON WHO KNOWINGLY OR WILLFULLY VIOLATES THESE SPECIAL SECURITY REQUIREMENTS MAY BE SUBJECT TO PENALTIES UNDER 49 USC 46307. PART V. DEFINITIONS A. AS USED IN THIS NOTAM, THE TERM U.S. TERRITORIAL AIRSPACE MEANS THE AIRSPACE OVER THE UNITED STATES, ITS TERRITORIES, AND POSSESSIONS, AND THE AIRSPACE OVER THE TERRITORIAL SEA OF THE UNITED STATES, WHICH EXTENDS 12 NAUTICAL MILES FROM THE BASELINES OF THE UNITED STATES DETERMINED IN ACCORDANCE WITH INTERNATIONAL LAW. B. TRANSIT MEANS ANY FLIGHT DEPARTING FROM A LOCATION OUTSIDE OF THE U.S., ITS TERRITORIES OR POSSESSIONS, WHICH OPERATES IN U.S. TERRITORIAL AIRSPACE ENROUTE TO A LOCATION OUTSIDE THE U.S., ITS TERRITORIES OR POSSESSIONS WITHOUT LANDING AT A DESTINATION IN THE U.S. C. WITHIN MEANS ANY FLIGHT DEPARTING FROM A LOCATION INSIDE OF THE U.S., ITS TERRITORIES OR POSSESSIONS, WHICH OPERATES IN THE 1512140040-PERM END PART 8 OF 9 FDC 5/6289 ZZZ PART 9 OF 9 SECURITY SPECIAL SECURITY INSTRUCTIONS FOR CIVIL TERRITORIAL AIRSPACE OF THE U.S. ENROUTE TO A LOCATION INSIDE THE U.S., ITS TERRITORIES OR POSSESSIONS WITHOUT EXITING U.S. TERRITORIAL AIRSPACE AT ANY POINT. D. THE U.S. STATE DEPARTMENT-DESIGNATED SPECIAL INTEREST COUNTRIES ARE CUBA, IRAN, THE DEMOCRATIC PEOPLES REPUBLIC OF KOREA (NORTH KOREA), THE PEOPLE'S REPUBLIC OF CHINA, THE RUSSIAN FEDERATION, SUDAN, AND SYRIA. 1512140040-PERM END PART 9 OF 9