Air Traffic Services and Technology

Air Traffic Services Brief

FAA Special Awareness Training for the Washington, D.C., Metropolitan Area

The Issue

The Federal Aviation Administration (FAA) is proposing a rule to require pilots operating under visual flight rules (VFR) within 100 nautical miles (nm) of the Washington, D.C., VHF omnidirectional range/distance measuring equipment (DCA VOR/DME) to complete special awareness training. The FAA training program is Web based and focuses on the special air traffic procedures for flying in the Washington, D.C., metropolitan area Air Defense Identification Zone (ADIZ) and Flight Restricted Zone (FRZ). The purpose of the proposed training requirement is to reduce the number of unauthorized flights or airspace incursions of the ADIZ and FRZ.

AOPA believes that the ADIZ creates an unnecessary burden on law-abiding general aviation pilots whose relatively slow-moving, small aircraft do not represent a significant threat to Washington, D.C.

While training to improve pilot awareness of ADIZ operations is clearly a positive action, AOPA does not support the FAA's proposed training plan because the scope and some aspects of the training requirement are unreasonable.

Background

Since the creation of the FRZ shortly after the 9/11 attacks and the ADIZ in February 2003, there have been over 1,000 unauthorized flights, also known as airspace incursions. Despite the fact that all of the incursions have been determined to be inadvertent in nature, several of those incursions have come close enough to the Capitol and the White House that evacuation of these buildings and other federal office buildings was required.

In addition to the Washington ADIZ and FRZ, other temporary flight restrictions (TFRs) have been established over sensitive areas throughout the country for various reasons. The proposed training would include information on these TFRs, as well as the Washington, D.C., restricted airspace areas. General aviation pilots have accounted for most (88 percent) of all the violations of restricted airspace, and according to a General Accountability Office (GAO) report, "pilot error is the biggest contributor to restricted airspace violations."

In an effort to reduce the number of incursions, the FAA is proposing to mandate security awareness training to educate pilots and raise their awareness of regarding restricted airspace. The training also teaches pilots about the procedures that must be followed to either operate in or avoid those areas.

The Importance to Our Members

AOPA believes that the ADIZ, as presently configured, is an unnecessary burden on law-abiding general aviation pilots whose relatively slow-moving, small aircraft do not represent a significant threat to Washington, D.C.

That said, training to improve pilot awareness of ADIZ operations is clearly a positive action. However, AOPA does not support the FAA's proposed training plan because the scope and some aspects of the training requirement are unreasonable.

If enacted as proposed, this rule would impact any pilot who intends to operate VFR within 100 miles of the DCA VOR/DME. The FAA would require compliance within 180 days after the rule goes into effect and require pilots to complete this one-time only FAA training course in accordance with 14 CFR Part 91.161. Pilots would have to complete the free online course offered at www.faasafety.gov or attend an FAA Safety Program seminar offered by local flight standards district offices (FSDOs).

Upon completion of the online course, pilots would print the certificate of training completion. While the document would not need to be carried with the pilot, it would be required to be provided in a "reasonable amount of time" if requested.

The FAA intends to maintain a database of all the pilots who have completed the FAA's online training course, and a duplicate copy of the certificate of training completion can be printed at any time without having to re-take the course.

All of the following operations are exempt from the training requirement:

Pilots operating under instrument flight rules (IFR);
Law enforcement, military, and aeromedical operations; and
A pilot who must deviate to the extent necessary to address an emergency situation.

However, if a pilot operating under IFR within 100 nm of the DCA VOR/DME decides to cancel IFR and continue the flight under VFR, he must have completed the training course requirement.

AOPA's Position

AOPA supports training to improve pilot awareness of ADIZ operations, but we do not support the FAA's proposed training requirements as currently written. The proposal is essentially a de facto expansion of the ADIZ and leads to more (not fewer) enforcement actions against pilots who have not actually violated the ADIZ.

How? The FAA is proposing to require mandatory training for any VFR pilot flying within 100 nm of the DCA VOR/DME. That effectively expands the ADIZ to engulf 117 airports.

For example, a pilot flying from Northeast Philadelphia (PNE) to Cape May, New Jersey (WWD), would have to have ADIZ training, even though he'll be 60 nm outside the ADIZ at the closest point. Or a flight from Raleigh, North Carolina (RDU), to Richmond, Virginia (RIC) — Richmond is 55 nm outside the ADIZ, yet the pilot would still have to get the ADIZ training.

AOPA does not believe that a pilot in either case reasonably expects that he would have to be concerned about the ADIZ. Additionally, the FAA is not planning on marking the "training ring" on any charts.

There's another problem for IFR pilots. Pilots flying near the ADIZ on an IFR flight plan wouldn't be required to have the ADIZ training. But consider someone flying IFR from Wilmington, Delaware (ILG), to Lancaster, Pennsylvania (LNS). The weather is good, so the pilot cancels IFR 10 nm out to expedite his arrival. The pilot is now VFR and must have the ADIZ training, even though he is 43 nm outside the ADIZ.

AOPA still believes that the ADIZ, as presently configured, is an unnecessary burden on law-abiding general aviation pilots whose relatively slow-moving, small aircraft do not represent a significant threat to Washington, D.C.

That said, training to improve pilot awareness of ADIZ operations is clearly the preferable action. However, AOPA does not support the FAA's proposed implementation of the training requirement.