(1) I think there needs to be a safe passage corridor for transit operations, from 800' to 1300' with different mandatory altitudes northbound and southbound; standard ingress/egress landmarks; a dedicated air-to-air, self-announce frequency; and a standard squawk code. This VFR corridor would be for aircraft that are simply transiting (or looking while they transit) but unable or not desiring the "new" Class B clearance (which I also strongly support). Pls ref LAX VFR corridor.
(2) Below 800' should be a SFRA with mandatory training a la the DC SFRA, "special" or "authorized" operators only (doesn't mean helicopter or commercial, but it means you have had the special training). Since those aircraft down below 800' ARE going up and down, and circling things, and moving laterally--- they have a lot of position reports to make. Those position reports should be irrelevant to the transients above 800' who are following a standard track at a mandatory altitude. Their chatter could in fact impede the radio calls by those transients. So I'd at least re-consider a separate frequency for the special operations below 800'. As for the training or special operator designation, I'd use KPHL IFR approaches and the Grand Canyon as examples of what could be done. At PHL there is a higher bar to do the simultaneous ILS approach and Part 91 operators must self-certify that they have properly briefed. At the Grand Canyon, there are flyways for special operators and other airspace areas for everyone else. For the DC SFRA, we all have a little certificate on board the aircraft to demonstrate that we have taken the required training.
I tried to attach a file for my full remarks; the BROWSE button did not function. These remarks are somewhat truncated owing to the 2000 character limit.
Thank you.
Alan Sheiness
Commercial Pilot- Airplane ASEL, AMEL, Instrument Airplane
1300 total hours
Alan Sheiness
This is comment on Rule
Proposed Modification of the New York, NY, Class B Airspace Area; and Proposed Establishment of the New York Class B Airspace Hudson River and East River Exclusion Special Flight Rules Area
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