AOPA ASF President Bruce Landsberg moderated a raucus public meeting 15 September to discuss the FAA working group's suggestions for the Hudson Corridor.

Most of the discussion was specific to the area, but one element of interest nationwide is the suggestion that the area be established as SFRA - Special Flight Rules Area -- requiring special training for flight.

A second suggestion that might have national implications is a proposed requirement that pilot be required to carry the Terminal Chart or Helicopter Chart when flying in the exclusion zone.

The exclusion zone was established in 1971. The recent tragedy was the first midair in the zone in forty five years.

Today, pilots, including students, are required to have area specific training to fly near Washington DC. This single accident will likely trigger New York specific training. The danger is that every time a politician screams about air safety in his district, a new SFRA and training will be required.

Review if you will the number of regulations we have to train our students. Tell me, truthfully, is it valuable to teach students about the frequency of battery replacement in an ELT? (This equipment is required as the result of a 1972 accident involving two congressmen.)

Knee-jerk regulation may result in other silly procedures. I know you all combat sloppy radio procedure at non-towered fields. The Hudson Corridor has its own CTAF with the same problems. The FAA working group described its hard work to develop procedures and mandatory reporting checkpoints that would work in both daylight and night-time. Five minutes later thay descibed mandatory CTAF transmission that include aircraft type, color, altitude, postion and direction. What value is it to know that traffic is a Eurocopter 120 or 130, or Agusta 139? Then they described mandatory color description. The group went wild. It was unclear that a description of green trim on a Cessna would help pilots discriminate the aircraft from one with blue trim. And at night?

The pilots all realized that there needs to be some procedure change, even if it's eyewash. The politicians are demanding it. The alternative is that the Hudson corridor will be eliminated altogether. If the whole Hudson is Class B, many pilots will be discouraged from one of the most scenic flights in the world. And taxpayers will probably have to support another twenty controllers to monitor the river (two positions 24x7x365).

It was fun to shout and clap at the meeting, but the real forum is the public comment on the Notice of Proposed Rulemaking that will start today (16 September). The comment period will be short, so make sure you get in on the discussion. What isn't in writing will be ignored.

Robert
Frequent flyer on the Hudson Corridor
most recent flight 15 September 2009

Docket Operations
Federal Aviation Administration
Fax 202 493-2251

RE: [Docket No. FAA–2009–0837; Airspace Docket No. 09–AWA–2; Notice No. 09–11]

Dear Sir/Madam:
I am a Commercial Pilot based at Morristown NJ. I last flew the Hudson Corridor yesterday, 15 September 2009. I agree that additional measures can be taken to improve the safety of the Hudson Corridor. The proposed rule includes specific points that will decrease the safety of the airspace.

Communications:

The Hudson CTAF 123.05 is currently used by almost all pilots on the river. Making communication mandatory and eliminating slang will improve safety. So will elimination of tour operator business on the frequency, including fuel requests and passenger counts. The other requirements of the proposed rule will add to radio congestion and will not contribute to safety.

Aircraft Type

The proposed rule requires all aircraft to report type. Type is defined in FAR 1.1, and includes aircraft make and model. This is additional radio chatter and does not contribute to safety. It is of no interest to other pilots whether a helicopter is a Bell, Sikorsky, or Eurocopter. Describing the model as a 130 or 212 does not contribute to safety on the river.

The current practice, which is sufficient and superior, is to identify aircraft category or class, as defined in FAR 1.1. The description would be helicopter, airplane, or airship.

Color

Representatives of the rulemaking task force described at a public meeting held 15 September in Newark, New Jersey that the proposed rule was designed to work in both daylight and nighttime hours. A requirement to report color is extraneous. The predominant color for airplanes is white. They vary only in the color of stripes and trim. To require pilots to differentiate themselves by green stripes or blue stripes is specious. The color is irrelevant at night.

SFRA

Institution of a Special Flight Rules Area would require special training for every pilot in Corridor. As an FAA flight training provider, I see this will stimulate business in the short run, but will eventually constitute one more regulatory and training burden to pilots in the area. Insofar as there has been only one midair over the Hudson in 45 years, it is unclear that this increase in regulation is necessary.

The SFRA and training requirement will join the list of burdens already piled on the private pilot, such as the requirement to memorize the permitted life of a battery in an Emergency Locator Transmitter. This requirement became obligatory after the loss of Congressman Wade Boggs in 1972.

Robert Hadow
Chief Pilot

http://edocket.access.gpo.gov/2009/E9-22344.htm

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