David Shain

Document ID: FAA-2011-0078-0004
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: April 14 2011, at 12:00 AM Eastern Daylight Time
Date Posted: April 15 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: March 8 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: April 22 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80c2d79b
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Docket Number FAA-2011-0078 April 5, 2011 Dear Representative of the Federal Aviation Administration: My name is David Shain. I am an instrument rated commercial pilot with single engine land, multi-engine land, and single engine sea certificates. I am currently a senior attending Bowling Green State University in Bowling Green, Ohio for a Bachelors of Science in Flight Technology and Operations. I am writing you regarding the notice of proposed rulemaking pertaining to the establishment of low attitude GPS routes for helicopters operating under instrument flight rules. In my opinion, establishment of these routes would be very beneficial. Currently, helicopters are simply assigned victor airways, which are also used by high speed fixed wing aircraft. The speed differential between these high speed fixed wing aircraft and relatively low speed helicopters can cause delays at best, and collision hazards at worst. For example: Over a victor airways that is 50 or so miles long, it is very plausible that an aircraft moving at 250 knots could easily catch up to a helicopter moving at 130 knots. This would cause the air traffic controller to vector the faster aircraft around the helicopter, possibly causing conflicts with other traffic and increasing overall flight time. Giving helicopters their own routes away from this faster moving traffic would significantly reduce this possibility. In addition, since these routes will be presumably closer to the ground than typical victor airways, it will allow helicopters to operate at altitudes they were originally intended to operate at. Thank you very much for your consideration. I greatly appreciate the chance that you have given me to respond and voice my opinion. Sincerely, David Shain Senior at Bowling Green State University

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