AOPA opposes nighttime lights-out Air Force flights in military operations areas
The Aircraft Owners and Pilots Association is opposing an undocumented U.S. Air Force proposal to fly unlighted aircraft at night in military operations areas (MOAs). AOPA said military aircraft without operating position lights would be invisible to VFR pilots.
“AOPA believes that lights-out flight operations are a safety hazard and an inappropriate use of MOA airspace,” said Melissa Bailey, AOPA director of air traffic services in a letter to the Federal Aviation Administration. “We also want to know why this proposal was withheld from the public, denying general aviation pilots the opportunity to comment on an important safety issue.”
In October 1998, the Air Force petitioned the FAA for a blanket exemption to Federal Aviation Regulation 91.209, which requires all aircraft to have lighted position lights when operating between sunset and sunrise. The exemption would apply to operations in MOAs.
Contrary to federal guidelines, the petition was not published in the Federal Register. But AOPA learned of the petition and uncovered it inside the FAA.
In its protest against the lights-out proposal, AOPA noted that military operations areas were implemented to notify VFR pilots of possible non-hazardous military activity and to segregate IFR aircraft from military aircraft. VFR flight is not restricted in MOAs.
“The guiding principle of VFR flight is ‘see and avoid,’” said Bailey, “and VFR pilots obviously can’t see and maintain separation from unlighted military aircraft at night.” That places the entire responsibility for collision avoidance on the military pilots.
To make the matter worse, civilian pilots would have a difficult time finding out when to expect lights-out operations in specific MOAs, since MOA activity information is not widely disseminated to general aviation pilots through the FAA’s notices to airmen (notam) system. Only flight service stations within 100 nm of the MOA have activity information, and the pilot has to ask for it specifically.
“That makes it unlikely that transient pilots would receive safety information critical to flight planning,” said Bailey.
“AOPA strongly opposes the Air Force petition to conduct hazardous nighttime lights-out operations in MOAs,” Bailey told the FAA. “We also request that any future petition on this matter be published for public comment and review.”
The 345,000-member Aircraft Owners and Pilots Association is the world’s largest civil aviation organization. More than one half of the nation’s pilots are AOPA members.
April 14, 1999