Dale Hooper, of the US Ultralight Association, filed this report
on the ultralight view of the ever-restrictive Washington ADIZ. We
thought that this was a viewpoint that needed to be seen by the
rest of the aviation biz... Herewith, USUA's report.
USUA ADIZ Report
The Washington DC ADIZ
(Air Defense Identification Zone) restricts GA activity to the area
around our Nations Capital, and presents certain procedures for
operation within the zone. These restrictions and procedures were
put into place shortly after September 11, 2001, and have been
defined as "temporary" by FAA. In August of last year, FAA
announced, by way of NPRM (Notice Of Proposed Rule Making) that
there where intentions of codifying (making permanent) these
procedures. This would carve in stone the good and bad of the
situation. But before further action was taken on this matter, FAA,
along with Homeland Security, TSA, The US Secret Service, the US
Border Patrol and other government agencies affected by this
action, decided to open communication with public meetings. USUA
members and staff attended these meetings, held in various
locations around the Washington area, and made comment on the
NPRM.
The problem affecting most ultralight pilots operating in and
around the ADIZ concerns the part of the rule related to
transponder use. Since ultralights typically have no transponder,
access to the ADIZ is prohibited. As would be expected, this
condition is prohibitive to ultralight activity. Because of this
problem, USUA has great concern. And, because of this concern, USUA
felt a need to make the feelings and thoughts of the ultralight
pilot known.
When researching data for USUA's comment to FAA, USUA EVP Dale
Hooper (pictued above) contacted USUA Flying Club 1 in Northern
Virginia (whose operational area is directly affected by the ADIZ),
for input. With much thanks to Club 1 president Len Alt, USUA
submitted the following comment:
To All Concerned,
While most submissions and comments to the NPRM will most likely
come from General Aviation pilots and representatives, I speak to
the issue from an ultralighter's perspective.
The Washington DC ADIZ has proven to be effective. It has been
effective in reducing the privileges of the ultralight pilot, it
has been effective in reducing the sales of and instruction in
ultralight vehicles, and it has been effective in curbing the
growth of sport aviation in the Washington DC/Maryland /Virginia
areas. The only thing that has proven to be ineffective is the
amount of increased security created by the ADIZ.
Ultralights, as you
know, are defined and regulated under FAA FAR Part 103, which
limits their weight to under 254 pounds, and their fuel capacity to
no greater than 5 gallons. Simply put, ultralights typically fly
low and slow, and are limited in their scope of operation. While
cross-country flights have grown in popularity, you won't go far on
5 gallons of fuel...
A typical safe ultralight is configured with only a minimum of
avionics, with usually no available flexibility to include
transponders (which are not required under Part 103). These
vehicles cannot operate in the ADIZ. When an ultralight pilot with
the required instrumentation DOES contact Flight Services to file
an advance flight plan (as required), he or she is routinely denied
access.
USUA has effectively been responsible for the safe training and
registering of ultralight pilots and vehicles for the past twenty
years, and our training programs have not only gained FAA approval,
but have served as the template for other ultralight training
programs such as those operated by EAA and other organizations.
Additionally, many ultralight pilots are also FAA certificated
Private Pilots (or higher), but choose to fly ultralights for the
sheer enjoyment of this type of craft. When the ultralight pilot
who has complied with all directives concerning flight within the
ADIZ is refused access, there is a dilemma. This type of prejudice
cannot be tolerated.
Since grass roots sport aviation, such as characterized with
ultralights, has proven to be one of the fastest growing segments
of GA in the USA, it is no wonder that it was at one time very
popular in this scenic and historical part of our nation. There are
several ultralight clubs in the area, and USUA ultralight pilots
total over 1000 in the surrounding regions. Flying contact with
each other has been limited to the point where all activity has
been either removed from the area, or circumvented to areas outside
of the ADIZ. Ultralight pilots who at one time routinely flew to
and from small flightparks and strips in and around the ADIZ have
been either grounded, or have had great difficulty in pursuing
their aviation activities. Simple cross country flights to
neighboring activities such as fly-ins and competitions have been
impossible in many cases, and for those willing to "fly-around" the
ADIZ created quite a hardship (refer to the 5 gallons of fuel
issue).
USUA has continually cooperated with FAA, TSA and other
government agencies in regard to Homeland Security issues, and
completely understand the necessity for reevaluating the US
aviation environment. And, while the reasoning behind the ADIZ has
basis in that reevaluation, there are issues with the current
system that should not be codified into permanent existence.
USUA strongly suggests that the issues brought forth by this
comment, and other comments that have been and will be submitted to
this commission, be pursued. With these valuable insights, there
should be not only a reevaluation of the aviation environment, but
of the ADIZ as well. Do not codify the ADIZ and it's procedures, as
it exists.
Respectfully
Submitted,
Dale Hooper,
Executive Vice President
United States Ultralight Association (USUA)