Comment from Terry Cross

The proposed mandatory restriction of flights along the California coast creates a safety hazard and a very significant burden on pilots and their passengers. There frequently are low ceilings along the coast line during winter months and during other times of year due to persistent marine low stratus clouds. Many times, the only safe route of flight is in visual meteorological conditions beneath the clouds, often below 1,000 agl. Aircraft that are not equipped for flight in known icing conditions often cannot operate safely in clouds or precipitation near or above the freezing level. Pilots who are not instrument rated may be unable to proceed unless they are able to maintain visual conditions below clouds. The Airmans Information Manual correctly states that the safest altitude to fly below low ceilings is in the center third of the altitude beneath the ceiling and above the ground (for example, between 500' and 1000' beneath a ceiling of 1,500'). The reason is to allow forward visibility sufficient to allow the pilot to see and avoid obstacles and to make necessary course corrections. Prohibiting flights below a certain altitude along the coast will create a legal barrier and a trap for pilots who have no other route available to continue safe travel. I have personally experienced these conditions in past years along the coast north of the Golden Gate up to Mendocino. This is a good example of why regulation of flight should be the sole province of the FAA. Other agencies work with the FAA to implement flight restrictions for national security and fire fighting. NOAA should discuss its request and needs with the FAA, which is conversant with the needs of the public and which will also allow sufficient time for affected members of the public to participate in the process and comment. Based on the forgoing, I oppose the proposed regulation and request that it not be implemented.