AN SMA INST PLT RPTS PCT APCH CTLR COMPLAINED HIS FLT CONTACTED ATC TOO LATE. THE FLT FOLLOWED PROCS NORMAL UNTIL THAT TIME FOR ZZZ/ADIZ FLTS.

Narrative

TRAINING PRIMARY STUDENT IN ACFT WITH POWERFUL ENGINE (210HP) AND CLB PROPELLER. INTRODUCING STUDENT TO MAKING 'FIRST CONTACT' ATC RADIO CALL SIMULTANEOUS TO LIMITING ACFT CLB UNDER 1500 FT MSL CLASS B LAYER. STUDENT TOOK OF ON RWY 28 (SHORT TKOF TECHNIQUE DUE HOSTILE TERRAIN UNDER EARLY-UPWIND LEG; SO HIGH CLB RATE); TURNED TO X-WIND AND CLBED TO TPA; TURNED TO 140 HEADING AND CLBED TO 1300 FT MSL. I REHEARSED STUDENT IN CONTENT OF 'FIRST CONTACT' RX CALL TO PCT APCH. DURING THIS TIME STUDENT INADVERTENTLY CLBED TO 1475 FT. I REQUESTED STUDENT TO RETURN TO 1300 FT AND TRIM ACFT. THEN STUDENT SWITCHED RADIO FROM ZZZ CTAF FREQ TO PCT APCH. STUDENT WAITED 5 SECONDS TO ENSURE NO-ONE ELSE ON FREQ. 4NM SE ZZZ; LITERALLY AS STUDENT PRESSED TRANSMIT BUTTON; PCT APCH CALLED OUR ACFT. STUDENT RESPONDED WITH CALL-SIGN. ATC ADVISED THEY OBSERVED CORRECT TRANSPONDER CODE; AND HAD CALLED US REPEATEDLY SINCE WE WERE 2 NM SOUTH OF ZZZ; WITH NO REPLY. ATC CLAIMED WE WERE THEN 5.5 NM SOUTH OF ZZZ. ATC ADVISED THEY HAD ALERTED US MILITARY TO 'NO-RADIO' ACFT PROCEEDING SE FROM ZZZ. US MILITARY MIGHT CTC US DIRECTLY. (NO CTC TO-DATE; 3 HOURS AFTER EVENT.) CAUSE OF IMPLIED VIOLATION OF 'IMMEDIATE RADIO CONTACT' REQUIREMENT IN ADIZ NOTAM: I HAVE OPERATED AND TAUGHT WITHIN ADIZ (INCLUDING AT LEAST 200+ VFR FLTS DEPARTING ZZZ ROUTING SE OR NW) SINCE ADIZ INCEPTION. CONSISTENT PRACTICAL EXPERIENCE GAINED FROM THESE HUNDREDS OF FLTS (TYPICALLY AT LEAST DAILY; 5 DAYS/WEEK) IS THAT PCT APCH WILL ACCEPT A 'FIRST CONTACT' CALL FROM ACFT PROCEEDING AWAY FROM ZZZ; BETWEEN 3-5 NM FROM DEP ARPT. THEREFORE; I WAS OPERATING TODAY IN ACCORDANCE WITH MY INTERPRETATION OF ACCEPTABLE DISTANCE AT WHICH TO SWITCH FROM CTAF TO PCT APCH; CONSISTENTLY DEMONSTRATED TO BE ACCEPTABLE TO PCT APCH DURING EACH OF SEVERAL HUNDRED PREVIOUS IDENTICAL-RTE FLTS. ROOT CAUSE: ADIZ NOTAM STATES (URL TFR.FAA.GOV SAVE_PAGES/DETAIL_7_0206.HTML; PART 1 BULLET# 7): 'PLTS MUST ESTABLISH AND MAINTAIN TWO-WAY RADIO COMS WITH THE APPROPRIATE ATC FACILITY WHILE OPERATING IN THE DC ADIZ.' ADIZ NOTAM DOES NOT DEFINE WHEN -- UPON DEP FROM AN UNCONTROLLED AIRFIELD LOCATED WITHIN ADIZ -- PLT SHOULD SWITCH FROM CTAF TO ASSIGNED PCT APCH FREQ. CONSEQUENTLY; THIS DISTANCE HAS TO BE DETERMINED BY PLT; BALANCING THE FOLLOWING CONTRADICTORY CRITERIA: 1. HOW FAR FROM ARPT TFC PATTERN IS SAFE TO ABANDON CTAF FREQUENCY? 2. HOW FAR FROM ARPT TFC PATTERN IS 'TOO FAR' TO DELAY 'FIRST CONTACT' CALL TO PCT APCH? (IN ABSENCE OF ANY DEFINITION; 5 NM APPEARS A REASONABLE LIMIT IF PROCEEDING AWAY FROM ZZZ; SMALLER DISTANCE IF PROCEEDING TOWARDS ZZZ. UNTIL TODAY; PCT APCH DID NOT OBJECT TO THAT DE FACTO LIMIT.) 3. HOW DOES INSTRUCTOR INSTRUCT STUDENT PLT TO AVIATE/NAVIGATE IN CONFINED AREA BELOW CLASS B AIRSPACE; IN TIMELY MANNER; IF RADIO CALLS TAKE PRIORITY OVER STAYING WITHIN PERMITTED AIRSPACE? 4. HOW DOES INSTRUCTOR TEACH STUDENT TO MAKE THAT 'FIRST CONTACT' CALL IN TIMELY MANNER; WHILE GIVING PRIORITY TO AVIATING AND NAVIGATING OVER COM? IF DHS/TSA REQUIRES ACFT DEPARTING ADIZ ARPTS IN DIRECTION AWAY FROM ZZZ TO MAKE 'FIRST CONTACT' CALL CLOSER THAN 4-5 NM FROM DEP ARPT; FAA SHOULD STATE THIS SPECIFICALLY IN NOTAM; NOT REQUIRE INDIVIDUAL ATC CTLRS TO INTERPRET NOTAM AND DECIDE IF 'FIRST CONTACT' WAS MADE AT ACCEPTABLE OR UNACCEPTABLE DISTANCE. BECAUSE WHAT WAS ACCEPTABLE TO ALL CTLRS UNTIL TODAY; IS NOT ACCEPTABLE TO ONE CTLR TODAY. SO I RISK BEING VIOLATED BECAUSE ONE EXCEPTIONAL CTLR DISAPPROVES THE DE FACTO ACCEPTABLE PRACTICE APPROVED REPEATEDLY BY HIS COLLEAGUES. DEFINE THE MAXIMUM ACCEPTABLE DISTANCE. DON'T LEAVE IT TO INDIVIDUALS TO INTERPRET.