FAA reopens comment period on MOA lights-out proposal
AOPA continues opposition
Following an AOPA request, the Federal Aviation Administration has reopened the comment period on a U.S. Air Force proposal to fly unlighted aircraft at night in military operations areas (MOAs). Pilots now have until August 2 to comment.
To train its pilots in the use of night vision equipment, the Air Force has 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.
AOPA opposes the proposal because military aircraft operating in MOAs at night without position lights would be invisible to VFR pilots. They would be unable to “see and avoid” military aircraft. That would place the entire responsibility for collision avoidance on the military pilots, already busy with their training flight.
Furthermore, AOPA has learned that the U.S. Air Force doesn’t yet have an operational policy for “night-vision goggle training,” a critical element in the military’s plan to “see and avoid” nonparticipating aircraft.
AOPA is far from alone in its opposition.
A retired Air Force officer, who served as an airspace manager, wrote the FAA, “The idea that the U.S. Air Force would operate aircraft in a MOA without position and navigation lights is unconscionable!”
He said that, in 1987, the Strategic Air Command had considered, and rejected, lights-out operations in a Wisconsin MOA. “We decided it was too risky to both military and civil aircraft. Actually, as the airspace manager, it was a quick decision with the statement that it was ‘stupid and will get someone killed.’”
He told the FAA that lights-out operations should be limited to special-use airspace that is off-limits to civil aircraft.
“That’s what restricted and warning areas are for,” said Melissa Bailey, AOPA director of air traffic services. “We support the military’s special training needs, but when those needs involve hazardous operations, they should be conducted in the airspace set aside for that purpose.”
AOPA urges pilots to comment on the lights-out proposal. Comments must include the petition docket number (29396) and be mailed in triplicate to Federal Aviation Administration, Office of the Chief Counsel, Attn: Rule Docket (AGC-200), Petition Docket No. 29396, 800 Independence Avenue, SW, Washington, DC 20591.
Comments may also be e-mailed to 9-NPRMemail@example.com.
The 350,000-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.
July 16, 1999