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July 9, 2006
AOPA is objecting to the FAA's proposed special awareness training for the Washington, D.C., Air Defense Identification Zone (ADIZ) on three grounds: It won't solve the problem the agency is trying to fix; it's too broad; and the action itself is premature.
The FAA is still in the middle of rulemaking for codifying the ADIZ size, configuration, and operating rules.
"More than 22,000 anti-ADIZ comments and three public meetings are still pending, without the FAA answering or mitigating the concerns raised by law-abiding pilots and members of Congress," said AOPA President Phil Boyer. "It begs the question of whether the agency is truly committed to considering public comment and following the rulemaking process as required by law."
The FAA is proposing to require mandatory training for any VFR pilot flying within 100 nautical miles of the DCA Vortac. That effectively increases by six times the area affected by ADIZ regulations and engulfs 117 airports.
Proposing a training requirement even before the rules are final "...gives the appearance that the comment process on the August proposed rule is a mere formality with the outcome preordained, despite overwhelming objections in both written comments and at public meetings," Boyer wrote in comments on the proposal.
While AOPA supports the concept of security awareness training for pilots intending to fly near Washington, D.C., and the National Capital Region, "The FAA's overly broad proposal won't stop the most common ADIZ 'incursions' and will likely lead to even more violations," said Boyer.
That's because most ADIZ "incursions" are violations in name only and have to be recorded because of the Department of Homeland Security's (DHS's) "zero tolerance" policy.
Most of the recorded violations are by pilots already familiar with ADIZ procedures but who make a small mistake in resetting their transponders.
Most common is the "rolling early" mistake, in which a pilot reverts to an ingrained habit of resetting the transponder code to 1200 when released by air traffic control (ATC) to "change to advisory frequency approved" for landing at a nontowered airport within the ADIZ. The rules require the pilot to keep squawking the ATC-assigned code until the aircraft is on the ground.
Another rolling early mistake comes when ATC advises the pilot that he or she is "clear of the Class Bravo, frequency change approved." Again, pilots' habits ingrained over years of operating experience is to switch the transponder to the VFR code. But the ADIZ includes more airspace than the Class B, so it is entirely possible to be outside Class B but still in the ADIZ and not talking to ATC.
Sometimes a rolling early mistake happens as an aircraft is about to exit the ADIZ, simply because ATC's and DHS's radar maps don't perfectly align, or a pilot's GPS map is not quite aligned with the radar maps. Homeland Security's radar is the only one that "counts," but of course the pilot can't see that.
"A recent AOPA survey of pilots revealed that the biggest ADIZ-related concern they had was making a mistake while following procedures," said Boyer. "This clearly demonstrates that most pilots likely to fly in the ADIZ know the rules already.
"Mandatory training for anyone flying up to 70 nm away from the ADIZ boundary isn't going to reduce significantly the number of technical incursions."
In fact, voluntary, targeted training programs by AOPA and the FAA have already reduced the number of incursions. From October 2004 to October 2005, monthly violations dropped almost 60 percent.
None of the ADIZ incursions since its inception have involved an attempt to breach security. And only one of the incursions in the last three years has been intentional.
Therefore, the more reasonable approach would be to activate the ADIZ during a declared national security emergency. The ADIZ would remain on the charts, but the procedures activated only when there is a specific, credible threat to the National Capital Region.
"This approach would be consistent with how the FAA handles other security-sensitive areas of the country," said Boyer, "and this solution would work well in the Washington, D.C., area."
AOPA also recommended that ADIZ training be mandatory only for pilots intending to fly VFR as pilot in command inside the ADIZ.
"Requiring training for any pilot flying within some 142,000 cubic miles of airspace sets up a nearly impossible new requirement," said Boyer.
"AOPA believes that the ADIZ has never been justified as a permanent security measure, and this training proposal is premature," Boyer said.
"But for the purposes of responding to the proposal, AOPA supports the concept of security awareness training for pilots operating within the ADIZ, but the training requirement as currently proposed covers an excessively large geographic area and is not targeted at reducing the most common type of ADIZ violations.
"In short, it doesn't solve the problem."
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