I strongly oppose the proposed regulation for three reasons:
NOAA has no authority: Title 49, USC clearly designates the Federal Aviation Administration as the agency responsible for plans, policy, and regulation of United States airspace: “The Administrator of the Federal Aviation Administration shall develop plans and policy for the use of the navigable airspace and assign by regulation or order the use of the airspace necessary to ensure the safety of aircraft and the efficient use of airspace. The Administrator may modify or revoke an assignment when required in the public interest.”
Contrary to Public Policy: The proposed rules seek to implement a “guilty until proven innocent” presumption that is clearly contrary to the policy of the United States as reflected in US and British common law traditions.
The proposed rule is unnecessary: NOAA has offered no scientific study that documents and assesses aviation “disturbance” and the negative effects thereof. Therefore there is no established requirement for the proposed regulation.
Comment from N/A N/A
This is comment on Proposed Rule
Amendments to National Marine Sanctuary Regulations Regarding Low Overflights in Designated Zones
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