AOPA and the FAA agree on this: All of the Washington, D.C., Air Defense Identification Zone (ADIZ) incursions (save one) have been unintentional, and that training is the solution to the problem.
"But AOPA and the FAA diverge when it comes to how to implement that training," said Andy Cebula, AOPA executive vice president of government affairs.
"The FAA wants a de facto expansion of the ADIZ. That could very well lead to more 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 nautical miles of the DCA Vortac. 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.
"Would a pilot in either case reasonably expect that he would have to be concerned about the ADIZ?" asked Cebula. "And the FAA is not planning on marking the 'training ring' on any charts. It's a 'gotcha' waiting to happen."
There's another 'gotcha' 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.
Gotcha! You're now VFR and must have the ADIZ training, even though you're 43 nm outside the ADIZ.
The FAA is proposing the training requirement to reduce the number of "unauthorized" flights in the Washington, D.C., ADIZ. But in fact, the majority of ADIZ violations are purely technical, most stemming from a pilot changing a transponder code a bit early or late. For example, if a pilot exiting the ADIZ "squawks VFR" just before crossing the ADIZ boundary, it's counted as an incursion under the Department of Homeland Security's "zero tolerance" policy.
"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.," said Cebula.
"That said, training to improve pilot awareness of ADIZ operations is clearly the preferable action. AOPA supports training, but we can't support the FAA's proposed implementation of the training requirement."
July 6, 2006