On Wed, 17 Mar 2004 05:07:34 GMT, Larry Dighera
wrote in Message-Id: :

On 16 Mar 2004 18:57:45 -0800, (Rick Pellicciotti)
wrote in Message-Id:
:


Vintage plane ride operators have brought a public awareness/education
web site online regarding this NPRM:

http://www.planeride.info

It was my understanding that accidents among Hawaiian tour operators
prompted this NOPRM. How does the accident rate among commercial
certificate holders within 25 miles of the departure airport compare
to the Hawaiian rate? Are there appropriate grounds to support the
FAA's proposal to remove the commercial 25 mile exemption? What are
the quantified statistics?


Perhaps this recent AvWeb report answers a few questions:


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AVflash Volume 10, Number 20b -- May 13, 2004
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FAA RULING "WITHOUT CAUSE" OR "JUSTIFICATION" ...
Though proposed Oct. 22, 2003, and blasted with the majority of 2,225
written statements offered through two comment periods (initial and
extended) -- including comments from the U.S. Small Business
Administration, comments from AOPA and comments from EAA -- it was
Tuesday that saw the first public meeting held by the FAA in D.C. on
the proposed rules for air tour and sightseeing operations. Nearly all
comments so far submitted have said the FAA offers "no justification"
for the rule, its conclusions are unsupported and its impact would be
economically destructive for more than scores of businesses (AOPA
estimates the rule would prove terminal for 1,370). Representing the
interests of larger pilot groups, most alphabet groups are calling for
the rule to be withdrawn entirely. Expect another public meeting, May
21 in Las Vegas (for details, scroll to page four).
http://www.avweb.com/eletter/archive...ll.html#187287

....GOOD INTENTIONS, (RUSHED RULE?), SCARY QUOTES
Though inspired in part by a special investigation report by the NTSB
it appears application of 11 safety recommendations has gone somehow
askew. Wading through a steady tide of condemning comments from
industry advocates, the trail of quotes left by the latest public
meeting implies serious problems with the FAA's administrative
process. "The very foundation of this proposal, as written, is so
flawed that it would only be prudent for the FAA to withdraw the
NPRM," EAA offered. "[i]t harms both general aviation businesses and
charities" and "is bad policy, is not justified by safety data, and
should be withdrawn," AOPA said.
http://www.avweb.com/eletter/archive...ll.html#187288