Being both a pilot and a diver I completely support the decision to try to protect the wildlife. But I feel this would set a bad precedent by trying to circumvent the FAA’s authority over airspace restrictions. I would suggest that NOAA work with the FAA to enact the restrictions or recomendations they feel are necessary to protect the wildlife.
The NOAA restrictions add a level of unstated penalty on the recommended altitude restrictions already in effect over the areas mentioned. Most pilots do follow these recommendations.
Given the areas in question and their tendency for quick changes in visibility due to marine layers and wind speeds, enacting a penalty for altitude violations becomes a safety issue for pilots. This also creates complications in aircraft separation minimums in a very complex and busy airspace.
So although I do support the effort to protect wildlife, I feel this NOAA rule would make it overly complicated to have pilots track multiple agencies for the already complex airspace restrictions. It would duplicate restrictions that pilots already conform to. And it could possibly create an unsafe situation where pilots may need to choose between completing a flight safely and violating the restrictions set by NOAA.
Comment from Michael Delpier
This is comment on Proposed Rule
Amendments to National Marine Sanctuary Regulations Regarding Low Overflights in Designated Zones
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