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H.R. 3939, To increase the safety for crew and passengers on an aircraft providing emergency medical services
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40 - Mile Air, Ltd.
I am adamantly opposed to H.R. 3939 as its provisions will not increase operational safety and has the potential to accomplish the opposite. FAR part 91 provides sufficient regulation to provide for operational safety.
Under FAR part 135 before an aircraft can commence an instrument approach they must have weather reporting at the destination airport from an approved weather-reporting source, which Tok does not have. The only means of arriving in Tok on an IFR flight plan under FAR part 135 is to fly the approach to Northway, which is fifty miles east of Tok, and then fly under the weather at night, with no visual reference to the ground, and in mountainous terrain. While this is clearly not conducive to safety, it is legal under FAR part 135. A professional pilot will not try this maneuver but it illustrates clearly that rules do not ensure safe operation, properly trained professionals do.