Air Tour Virtual Meeting

[Jim]

I'm asking everyone in the group to please take the time to visit the FAA
site and post a comment or two on the proposed National Air Tour Safety
Standards Public Meeting.

I was just there and disappointed in the lack of comments.

http://www1.faa.gov/avr/arm/rulemakingforum.cfm?nav=part
--
Jim Burns III

Remove "nospam" to reply

[[email protected]]

What is there to comment on, unless you're in the air tour business? The way
I see the helicopter operators operate in Hawaii they could stand a whole lot
more regulating.

Jim wrote:

> I'm asking everyone in the group to please take the time to visit the FAA
> site and post a comment or two on the proposed National Air Tour Safety
> Standards Public Meeting.
>
> I was just there and disappointed in the lack of comments.
>
> http://www1.faa.gov/avr/arm/rulemakingforum.cfm?nav=part
> --
> Jim Burns III
>
> Remove "nospam" to reply

[Larry Dighera]

On Tue, 24 Feb 2004 05:16:11 -0800, wrote in
Message-Id: >:

>What is there to comment on,

As I understand it, present Private Airman's Certificate holders will
lose the right to conduct sightseeing flights within 25 miles of the
departure airport. Is that the camel's cold nose I feel slipping into
the tent?

[Teacherjh]

>>
Is that the camel's cold nose I feel slipping into
the tent?
<<

No. The camel's nose slipped into the tent when they rewrote the sharing
expenses rule.

Jose

--
(for Email, make the obvious changes in my address)

[Peter Duniho]

"Larry Dighera" > wrote in message
...
> As I understand it, present Private Airman's Certificate holders will
> lose the right to conduct sightseeing flights within 25 miles of the
> departure airport.

What do you mean? Nothing about the new rule-making appears to affect
holders of Private certificates at all. Private pilots don't have any
specific allowance for making sightseeing flights within 25 miles of the
departure airport, though of course they can make a sightseeing flight of
arbitrary length as long as they are not taking money beyond those allowed
in the "sharing" rules.

What I don't get about this "town meeting" thing is what the point is. We
already had a way to provide comments through the docket web site, which I
did. Is the FAA not going to bother looking at those comments? How are
comments provided through the "town meeting" different, and why should I
bother adding anything there, given that I already provided my comments
through the usual channels previously?

Pete

[[email protected]]

Peter Duniho wrote:

>
> What I don't get about this "town meeting" thing is what the point is. We
> already had a way to provide comments through the docket web site, which I
> did. Is the FAA not going to bother looking at those comments? How are
> comments provided through the "town meeting" different, and why should I
> bother adding anything there, given that I already provided my comments
> through the usual channels previously?
>
> Pete

The FAA looks at comments, then kisses them off. The regulate by political
mandate. Comments from individual pilots are pretty much meaningless. You
can thank your Congress and a series of presidents for that. Since 911,
general aviation has lost what clout it had remaining from the days when the
public actually had a positive view of small aircraft.

[Jim]

"Peter Duniho" wrote in message >
> What do you mean? Nothing about the new rule-making appears to affect
> holders of Private certificates at all.

The proposal would raise the minimum number of hours required for private
pilots conducting charity fundraising flights from 200 to 500

>Private pilots don't have any
> specific allowance for making sightseeing flights within 25 miles of the
> departure airport, though of course they can make a sightseeing flight of
> arbitrary length as long as they are not taking money beyond those allowed
> in the "sharing" rules.

But Commercial pilots do. This rule would remove the exemption listed in
part 119 that allows commercial pilots to conduct <25nm sightseeing flights
without haveing to establish and meet the requirements of a part 119/135
operation.
a.. FAA estimates that the proposed rule could affect approximately 1,670
operators with 3,100 aircraft currently providing commercial air tour
flights under Part 91.
b.. The FAA estimates that about 700 Part 91 operators currently providing
sightseeing flights will elect to stop providing the service.
Jim Burns III

[Larry Dighera]

On Tue, 24 Feb 2004 18:29:58 -0800, "Peter Duniho"
> wrote in Message-Id:
>:

>"Larry Dighera" > wrote in message
...
>> As I understand it, present Private Airman's Certificate holders will
>> lose the right to conduct sightseeing flights within 25 miles of the
>> departure airport.
>
>What do you mean? Nothing about the new rule-making appears to affect
>holders of Private certificates at all.

You are correct. That should have been 'Commercial' certificate
holders.

[Barry]

> The FAA looks at comments, then kisses them off.

I think that's an unfair exaggeration. When Part 61 was revised a few years
ago, the FAA incorporated many of the comments that it received. A long
description of the comments and the FAA's responses is given in the final
rule, available at:

http://www.avweb.com/news/news/184485-1.html

Barry

[Peter Duniho]

"Jim" > wrote in message
...
> The proposal would raise the minimum number of hours required for private
> pilots conducting charity fundraising flights from 200 to 500

Okay, so there is one minor change. I'm not convinced that particular one
is a bad thing, frankly. I do stand corrected.

> >Private pilots don't have any
> > specific allowance for making sightseeing flights within 25 miles of the
> > departure airport [...]
>
> But Commercial pilots do.

The comment to which I was responding stated a "right to conduct sightseeing
flights within 25 miles" for *Private* pilots. I'm well aware of the
Commercial privilege to that effect. But that's not what was said.

Pete

[Stan Gosnell]

wrote in :

> The FAA looks at comments, then kisses them off.

The FAA is required by law to consider all comments. They may not accept
all of them, but they are required to consider and provide an answer to all
of them.

That said, the air tour guys are way behind the power curve on this one.
The comment period for the NPRM has already been extended, and this is the
second period that is about to expire.

I'm a professional helicopter pilot, and I would never, ever get on a
helicopter tour, nor allow anyone in my family to get on one. I have no
sympathy for the air tour operators at all. They use inexperienced pilots
who they overwork badly, in many instances, and accidents are probably
inevitable under the current regulations. Not all operators do this, of
course, but enough do to make more regulation necessary. If a segment of
the industry doesn't regulate itself, and kills enough passengers, it's
going to get regulated by the government, whether or not the regulation wil
actually prevent more accidents.

--
Regards,

Stan

[Rick Pellicciotti]

"Jim" > wrote in message >...
> "Peter Duniho" wrote in message >
> > What do you mean? Nothing about the new rule-making appears to affect
> > holders of Private certificates at all.
>
> The proposal would raise the minimum number of hours required for private
> pilots conducting charity fundraising flights from 200 to 500
>
> >Private pilots don't have any
> > specific allowance for making sightseeing flights within 25 miles of the
> > departure airport, though of course they can make a sightseeing flight of
> > arbitrary length as long as they are not taking money beyond those allowed
> > in the "sharing" rules.
>
> But Commercial pilots do. This rule would remove the exemption listed in
> part 119 that allows commercial pilots to conduct <25nm sightseeing flights
> without haveing to establish and meet the requirements of a part 119/135
> operation.
> a.. FAA estimates that the proposed rule could affect approximately 1,670
> operators with 3,100 aircraft currently providing commercial air tour
> flights under Part 91.
> b.. The FAA estimates that about 700 Part 91 operators currently providing
> sightseeing flights will elect to stop providing the service.
> Jim Burns III

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

http://www.planeride.info

The comment period closes on 19 April. FAA refused to hold public
meetings so Congress has schedule hearings on the 30th of March.

This does effect private pilots. In the past, a charity could apply
for an exemption and conduct sightseeing rides in exchange for a
donation. Private pilots were allowed to do these rides providing
that they had 200 hours total time. The FAA is proposing in this
convoluted rule to increase the total time required to 500 hours,
eliminating a lot of pilots from the pool of ones willing to do these
types of flights. This will have a severe effect on charities.

Vintage plane ride operators and others stand to loose their
businesses and aircraft prices will be depressed further when a flood
of no longer needed aircraft come onto the market. The FAA
themseleves estimate that 700 businesses will close if this rule goes
into effect.

Rick Pellicciotti, Memphis, TN

[Larry Dighera]

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?

[Larry Dighera]

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:


-------------------------------------------------------------------
AVflash Volume 10, Number 20b -- May 13, 2004
-------------------------------------------------------------------

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/archives/avflash/237-full.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/archives/avflash/237-full.html#187288