July 2, 2012
US Department of Transportation
1200 New Jersey Avenue S.E., West Building Ground Floor
Room W12-40
Washington, DC 20590
RE: Docket #FAA-2012-0350, Petition for Exemption from Federal Aviation Regulation Sections 61.3 and 61.23
The National Air Transportation Association (NATA), the voice of aviation business, is the public policy group representing the interests of aviation businesses before the Congress, federal agencies and state governments. NATA's over 2,000 member companies own, operate and service aircraft and provide for the needs of the traveling public by offering services and products to aircraft operators and others such as fuel sales, aircraft maintenance, parts sales, storage, rental, airline servicing, flight training, Part 135 on-demand air charter, fractional aircraft program management and scheduled commuter operations in smaller aircraft. NATA members are a vital link in the aviation industry providing services to the general public, airlines, general aviation and the military.
The Aircraft Owners and Pilots Association (AOPA) and the Experimental Aircraft Association (EAA) have joined together in petitioning for an exemption from Title 14 Code of Federal Regulations, Part 61 sections 3(c), 23(a)(3) (FAA Docket # FAA-2012-350-). The petition seeks to allow members of both associations to fly recreationally without a third-class medical certificate. Those who chose not to have a medical certificate could continue to fly by assessing their own physical condition prior to each flight after having completed an in-depth course on aeromedical factors and flight physiology. The free course would be offered online, but must be retaken every two years. However, restrictions for those without a medical certificate would include operations in a single-engine aircraft with less than 180 hp operating in day VFR conditions.
NATA supports the AOPA / EAA petition. By providing the option for pilots to medically self-assess themselves, NATA believes that the aviation community could thrive without compromising safety.
Safety
NATA believes the proposed exemption would not adversely affect safety and could actually serve as a safety benefit.
Sport pilot regulations do not require pilots to obtain a medical certificate but, rather, places the responsibility on the pilot for judging his or her level of fitness to fly. Since the creation of these regulations, the level of safety regarding medically related issues has remained constant for those operations that do require an FAA medical certificate. Therefore, expanding the privileges of aircraft operations without a medical certificate would be of no detriment to the aviation industry.
NATA believes that providing pilots with an in-depth aero medical education would not compromise the integrity of safety within the general aviation community. While an FAA medical examination is a one-time exam, pilots would be able to assess their own physical condition more thoroughly prior to every flight. The education provided to pilots would allow them to take a more preventative stance, recognizing early symptoms before the onset of a serious problem.
Promotion of Aviation
Granting this petition would alleviate much of the burden pilots face when obtaining an FAA medical certificate. Between the time and expenses it takes to obtain the medical certificate, the burden for many pilots is just too much to continue flying. Allowing properly educated pilots to medically assess themselves would not only incentivize pilots to keep flying, but would also attract many future pilots to aviation. The petition serves the public interest by helping to maintain a strong aviation community.
Conclusion
NATA supports the petition as a benefit to safety and the public. The use of an in-depth aero medical education program would enable pilots to better assess their own physical conditions prior to every flight. There is no doubt that those who will benefit the most from this exemption will be both current and future pilots as well as the airports in the communities that rely on general aviation .
Collin Smith
Manager, Regulatory Affairs