As of October 23, the Federal Aviation Administration had received 904 responses from all facets of aviation regarding the Notice of Proposed Rule Making to amend certification of pilots and flight instructors as well as pilot school certification and ground instructors.
Of this total, 141 comments were received that were directly related to issues that impact balloons.
140 comments were opposed to the creation of a flight instructor rating for balloons. The respondents cited many reasons including: loss of business, increased costs, negative impact on small business, no accident statistics to justify increased regulation, present system is working, it would cause over regulation, and one person noted that balloon pilots are already qualified as instructors.
One of the above commenters did suggest that a high hour requirement be implemented but did not offer a recommendation.
One person was opposed to the requirement of three takeoffs and landings at night in the last 90 days to be current. They argued that balloons do not normally land at night but, rather takeoff in the dark and fly until it is light.
The one person who did not comment on the instructor rating was in favor of the differentiation between gas and hot air balloons that is proposed in the certification of pilots.
The greatest number of comments pertaining to the instructor rating were 65 form letters received from people in the Midwest. The form was opposed to the creation of the instructor rating because it would decrease the number of balloons and thus impact the number of participants at balloon events and thus the number of events.
Thirty commenters felt that the present system works. Another thirty-five comments expressed, to some degree, that the increased cost to earn and/or maintain a balloon rating would have a negative impact ballooning.
Although these are generalizations of specific letters they do reflect the general consensus of comments received.
Some people have even written in more than once.
The largest issue receiving comments to the docket addressed the proposed recreational rating without the requirement of a third class medical certificate. Lots of form letters from general aviation on this one.
As of the date that Balloon Life examined the docket only one balloon manufacturer had submitted a comment, The Balloon Works. The only Board member of the Balloon Federation of America to comment was Bill Murtorff. It should be noted that alphabet organizations such as AOPA, EAA, etc. will not make their comments until near the end of the filing deadline of December 11, 1995.
The NPRM is very broad in its scope and impact, not only on ballooning but all of aviation. To date the comments have only focused on a few subjects.
The major proposed change for ballooning is the instructor rating for balloons. The arguments that have appeared on the Internet for and against this rating have generally echoed the pros and cons of the past.
What is not being addressed in these arguments is how can the balloon community provide better training. In the September issue Balloon Life noted that ballooning will not get better instructors simply because the government says you must now have a rating. The simple evidence of this are the arguments the proponents of the rating are making to make it seem more palatable, namely, that if you have had a successful student you get the rating simply by presenting your credentials. To maintain the rating all one has to do is attend a refresher course every two years. They point to the fact that organizations like AOPA offer these courses frequently. These arguments may fit the letter of the law but they hardly make better balloon flight instructors.
Balloon Life’s arguments against this rating are printed in the September issue beginning on page 54. as are the other real issues in the NPRM that need to be addressed by the balloon community.
In addressing elements of the NPRM that you support or are opposed to it would be best to address your reasons in reference to Administrator David Hinson’s General Aviation Policy Statement issue September 8, 1993. It is this guideline that the FAA uses to justify the proposals made in the NPRM.
General aviation plays a crucial role in flight training for all segments of aviation and provides unique personal and recreational opportunities. It makes vital contributions to activities ranging from business aviation, to agricultural operations, to Warbird preservation, to glider and balloon flights. Accordingly, it is the policy of the FAA to foster and promote general aviation while continuing to improve its safety record. These goals are neither contradictory nor separable. They are best achieved by cooperating with the aviation community to define mutual concerns and joint efforts to accomplish objectives. We will strive to achieve the goals through voluntary compliance and methods designed to reduce the regulatory burden on general aviation.
The FAA's general aviation programs will focus on:
Comments should be sent in triplicate to:
Federal Aviation Administration
Office of the Chief Counsel
Attention: Rules Docket (AGC-10), Docket No. 25910
800 Independence Ave SW
Washington, DC 20591
or you mail e-mail your response to:
nprmcmts@mail.hq.faa.gov
All responses must reference "Docket No. 25910."
Comments must be received on or before December 11, 1995.