1. The prevailing ceiling for approximately half the time over the marine sanctuary is below 2,500ft. This proposed regulation would effectively prohibit VFR flight along an over 70 nm portion of the NW coast half of the time. Also, the terrain rises precipitously immediately to the east, adding a safety of flight issue if pilots deviate over land to avoid the marine sanctuaries. (Note: there is one WX station along this route, an ASOS at UIL.)
2. What does "or within one nautical mile seaward from the coastal boundary of the Sanctuary" mean?
3. The southern boundary of the marine-sanctuary abuts and would interfere with operations at S16, there being no provision for exceptions of taking off and landing at airport.
4. Why is there no provision for safety of flight exceptions as per the currently applicable AC? Do we really intend to value human lives less than "disturbing" marine mammals and placing the PIC in the position of either violating FARs or NOAA regulations?
Comment from William Vaughn
This is comment on Proposed Rule
National Marine Sanctuary Regulations: Low Overflights in Designated Zones; Amendments
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