November 12, 2003
Docket Management System U.S. Department of Transportation Room Plaza 401 400 Seventh Street, SW Washington, DC 20590-0001
Re: Docket No. FAA-1998-4521; Notice of Proposed Rulemaking (NPRM); National Air Tour Safety Standards
REQUEST FOR PUBLIC MEETINGS
The Aircraft Owners and Pilots Association (AOPA), representing over 400,000 general aviation pilots and professionals nationwide, requests that the Federal Aviation Administration (FAA) hold public meetings to assess the impact of its National Air Tour Safety Standards NPRM on pilots participating in charitable sightseeing events and general aviation operators conducting sightseeing tours under FAR Part 91. We are concerned that the FAA has failed to consider the true impact of this proposal on the general aviation community and contend that conducting public meetings will give Agency officials the opportunity to hear directly from those most affected.
Following the release of the proposal, AOPA received immediate strong member response that this proposed rule will have an adverse impact on thousands of general aviation pilots and small aviation businesses.
The FAA's proposal to increase the minimum flight time for private pilots participating in charitable sightseeing events from 200 hours to 500 hours reduces the pool of available pilots to help in charity and fundraising flights and it is important this be evaluated by the FAA. Hearing in-person from representatives from the general aviation community in a public forum will help achieve this important part of the rulemaking process.
In addition to the charity flights issue, members have also expressed concern that the sightseeing elements of the proposed rule will adversely affect their livelihood. Through the FAA's own admission, the proposed rule will result in hundreds of small sightseeing operations going out of business. Many of these companies are also involved in flight training, a segment of the general aviation community that continues to face economic hardships. Again, AOPA argues that the FAA should provide these entities with the opportunity to explain firsthand how the proposal affects their operations and determine the accuracy of the FAA's analysis of the proposal.
This NPRM touches at a foundational use of general aviation aircraft. Because of the potential adverse impact of this NPRM on thousands of general aviation pilots and businesses, it is incumbent upon the FAA to ensure the proposed rule and its impact is thoroughly evaluated. A series of public meetings is an excellent mechanism to assist the agency in its analysis of the affected user community.
Andrew V. Cebula Senior Vice President Government and Technical Affairs
November 12, 2003
Department of Transportation,
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