CPR PIC COMPLAINT REGARDING THE NOISE ABATEMENT PROC OUT OF DCA. CLAIMS THAT WITH THE REQUIREMENT TO FOLLOW THE RIVER VISUALLY FOR 4 MI PRIOR TO THE 328 DEG RADIAL INTERCEPT THAT TOO MANY THINGS CAN GO WRONG.

Narrative

WE WERE ASSIGNED THE NW NOISE ABATEMENT PROC WHICH CALLS FOR FOLLOWING THE POTOMAC RIVER VISUALLY UNTIL THE DCA 4 DME; THEN INTERCEPTING THE 328 DEG RADIAL DCA OUT TO THE 10 DME. THIS IS INHERENTLY A DANGEROUS PROC. WHAT WE FOUND OURSELVES DOING IMMEDIATELY AFTER DEPARTING RWY 33 WAS MAKING A R TURN TO FINAL AND FOLLOW THE RIVER WHILE LOOKING INTO LOW ANGLE SUN ON A HAZY MORNING. USING THE NOISE ABATEMENT PROCS; WE HAD A DECK ANGLE OF 15+ DEGS WHICH FURTHER REDUCED VISIBILITY FROM A JET IN WHICH YOU CAN'T SEE DIRECTLY BELOW YOU UNDER ANY CIRCUMSTANCE. WITH RESTR AREA P56 SOMEWHERE OUT TO OUR R FRONT AND WITHIN 1 MIN OF DEP FROM DCA; WE WERE BOTH LOOKING DOWN TRYING TO SEE THE RIVER SO WE COULD TURN L AND FOLLOW IT; RATHER THAN LOOKING WHERE WE WERE GOING IN A HIGH DENSITY TFC AREA. THE RESULTING RISKS ARE IMPRECISE NAV DUE TO THE INHERENT LIMITATIONS OF TRYING TO VISUALLY FOLLOW A WINDING RIVER FROM A CLBING ACFT WITH RESTR OUTWARD VISIBILITY AND THE ALMOST REQUIRED ABANDONMENT OF SEE AND AVOID DUE TO THE TRICKY NAV. OUR ONLY HOPE WAS THAT RADAR WOULD ADVISE US IF WE WERE WANDERING CLOSE TO P56 OR OTHER ACFT. THE PROC SHOULD BE MODIFIED TO REQUIRE IMMEDIATE INTERCEPTION AND TRACKING OF THE DCA 328 DEG RADIAL; THEREBY KEEPING AN IFR PROC IFR.