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.
