ADF Urges FAA to Keep Midway Atoll Open as a Trans-Pacific ETOPS Alternate

The Airline Dispatchers Federation, representing more than 2,000 FAA-certificated aircraft dispatchers, has submitted a formal comment to the U.S. Department of Transportation on FAA Docket 2026-8185, the request for comments on the future of Midway Atoll’s Henderson Field (MDY/PMDY). ADF’s position is direct: PMDY should continue to serve as a critical piece of the ETOPS architecture for trans-Pacific flying.

The comment was filed on September 21, 2026 and is now pending agency review on Regulations.gov. The full letter is available in the ADF document archive (link below).

Under FAA rules, a twin-engine airliner flying more than 60 minutes from an adequate airport operates under ETOPS (Extended Operations), and the FAA’s guidance in Advisory Circular 120-42B directs operators to plan for a maximum diversion of 180 minutes or less. With Russian airspace closed to U.S. carriers for the foreseeable future, every flight between the mainland or Hawaii and Japan, China, South Korea and Southeast Asia depends on a small set of mid-ocean and Aleutian airports to stay inside that limit. PMDY is the one in the middle.

ADF’s comment lays out four recurring threats to the Aleutian and northern-Japan airports that the docket proposes to lean on instead:

• Volcanic ash. The Kamchatka Peninsula holds 29 active volcanoes, with several impactful eruptions a year sending ash across the northern routings and cutting flights off from the Aleutian airports they would otherwise rely on.
• Aleutian weather. Eareckson Air Station (PASY) is historically below landing minimums as much as 74% of the time from June through August; Cold Bay (PACD) about 28%; northern Japan airports 22% to 44%. Anything above 14% means an airport is unusable for ETOPS at least one day a week.
• Unavailable equipment. PASY’s automated weather broadcast is routinely NOTAM’d out of service, leaving manual observations at the airport with the worst weather in the chain.
• Rocket launches and military firing. Russian exercises on Kamchatka regularly close airways between the United States and Japan (R220, M523, R580 and others).

Midway’s weather runs the other way. A 20-year lookback of Henderson Field observations shows the field below alternate minimums only 3.7% of the time, peaking at 5.3% in April and dropping to about 2% from July through September, the inverse of the Aleutian pattern. Once a flight is en route and only landing minimums apply, the figure is 1.9%.

Without PMDY, ADF wrote, Pacific ETOPS coverage would rest on four airports, and the loss of any one of them, PASY above all, would open holes in the ocean that cannot be closed under ETOPS-180. Covering them would require ETOPS-207 or ETOPS-225 operations, contrary to FAA guidance, along with added equipment costs for carriers. Hawaii-to-Japan flights would fall back on Wake Island (PWAK), and beyond that on Kwajalein (PKMJ), which plays little role in Pacific ETOPS today.

The airport is not theoretical. The docket itself records 11 diversions into PMDY between 2003 and 2021; at least four in the last fifteen years were Part 121 airline flights carrying more than 800 passengers and crew combined, diverting for smoke in the cabin, a cracked windshield and low engine oil pressure.

ADF thanked the agency for the opportunity to comment and offered to continue the discussion on PMDY, ETOPS and operational control.

Read the full comment: FAA Docket 2026-8185 — ADF Comment (PDF)