Early last month the FAA issued a notice of proposed rulemaking (NPRM) that would require VFR pilots to complete Internet-based training before being allowed to fly near–as opposed to into–the Washington, D.C. metropolitan area’s air defense identification zone (ADIZ).

The NPRM would require special awareness training for anyone who flies VFR within 100 nm of the Ronald Reagan Washington National Airport VOR/DME. To the northeast, that comes to within about three nautical miles of Philadelphia International Airport. To the south it dips below Richmond, Va.

AOPA called the proposed rule a de facto expansion of the ADIZ, and said that such a rule could lead to more enforcement actions against pilots who do not actually violate the ADIZ. For example, a pilot flying from Northeast Philadelphia Airport to Cape May County Airport in Wildwood, N.J., would have to complete the online ADIZ training, even though he would be 60 nm outside the ADIZ at the closest point.

Similarly, for a flight from Raleigh-Durham International Airport in North Carolina to Richmond International Airport, the pilot would still have to get the ADIZ training. Richmond is 55 nm outside the ADIZ.

“Would a pilot in either case reasonably expect that he would have to be concerned about the ADIZ?” asked Andy Cebula, AOPA executive vice president of government affairs. “And the FAA is not planning on marking the ‘training ring’ on any charts. It’s a ‘gotcha’ waiting to happen.”

The purpose of the NPRM, the FAA said, is to reduce the number of unauthorized flights into the airspace and the flight-restricted zone, which is a 15-nm radius from the DCA VOR/DME.

AOPA claimed that 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, this counts as an incursion under the Department of Homeland Security’s “zero tolerance” policy.

AOPA supports training but said it cannot support the FAA’s proposed implementation of the training requirement.

The National Air Transportation Association said it will submit comments to the FAA on areas that could be improved to ensure that pilots are aware of the training requirements and that the online training is readily accessible.

The proposed rule includes exceptions to the training requirement for certain military and aeromedical flights. Pilots operating under IFR who must cancel their IFR flight plan due to equipment failure or emergency are not required to comply with this proposed rule. However, compliance is required should a pilot on an IFR flight plan cancel IFR voluntarily.

The FAA would require compliance 180 days from publication of the final rule. The agency’s Web site will feature a free training module that will satisfy the proposed requirement, and one-time training ensures compliance.