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December 30, 2004

NTSB Issues Icing Alert To Pilots

The NTSB has issued an Alert to Pilots: Wing Upper Surface Ice Accumulation. This advisory follows in the aftermath of the November 28, 2004 crash of a Bombardier Challenger 604 in Montrose, CA. The NTSB's preliminary investigation into the accident has revealed "that atmospheric conditions conducive to upper wing surface ice accumulation existed at the time of the accident".

The advisory discusses several accidents involving upper wing ice accumulation and also research that has been conducted regarding the effects of upper wing ice accumulation on aircraft performance. The NTSB notes that "it is critically important to ensure, by any means necessary, that the upper wing surface is clear of contamination before takeoff. That is why the Safety Board recently issued Safety Recommendation A-04-66, urging pilots to conduct visual and tactile inspections of airplane wing upper surfaces." In the NTSB's opinion, "no amount of snow, ice or frost accumulation on the wing upper surface can be considered safe for takeoff."

The bottom line is that pilots have to both "look" at the wings and "touch" them to confirm that no ice or other contamination has accumulated on the upper wing surface. If it has, removal is required before takeoff. Extra vigilance is required during the winter months to ensure flight safety.

Posted by Greg

December 29, 2004

Reporting Alcohol Related Driving Offenses To The FAA

At this time of year when opportunities abound for celebration and consumption of holiday "cheer", I thought it would be helpful to re-visit the obligations of an airman who is arrested for driving-while-intoxicated ("DWI")(this would include similar charges such as driving-under-the-influence ("DUI") and operating-while-intoxicated ("OWI")). If an airman finds himself or herself in the unfortunate position of being arrested for DWI, he or she should know that FAR 61.15(e) imposes certain reporting requirments on airmen. For more information regarding these requirements, you can read my new article on the topic here.

Posted by Greg

December 28, 2004

NTSB Proposes Revisions To Accident/Incident Reporting Requirements Of Part 830

The National Transportation Safety Board published a Notice of Proposed Rulemaking yesterday in the Federal Register proposing to expand 49 CFR Part 830 to include certain events that are not currently subject to Part 830's reporting requirements. The proposed amendment is "intended to enhance aviation safety by providing the NTSB direct notification of these events so that [they] can investigate and take corrective actions in a timely manner."

The proposed amendment includes revision of the definitions in Part 830.2 to remove reference to ground damage to helicopter rotor blades from the list of exclusions in order to "bring events involving ground damage to main or tail rotor blades within the definition of an accident and clearly make them reportable events."

The NTSB is also proposing to amend Part 830.5 so that the following events are added to the current list of events requiring immediate NTSB notification: (a) failure of any internal turbine engine component that results in the escape of debris other than out the exhaust path; (b) structural failure of a propeller resulting in the release of all or a portion of a propeller blade from an aircraft, excluding release caused solely by ground contact; (c) loss of information from a majority of an aircraft's certified electronic primary displays (excluding momentary inaccuracy or flickering from display systems that are certified installations); and (d) any Airborne Collision and Avoidance System (ACAS) resolution advisories (RA) issued when an aircraft is being operated on an instrument flight rules (IFR) flight plan.

These amendments seem appropriate and the NTSB would likely receive safety related information sooner. This would in turn probably result in the NTSB issuing safety recommendations sooner than they otherwise might. However, given the delays and oftentimes reluctance on the part of the FAA and affected industry players to implement NTSB safety recommendations, it remains to be seen whether the additional notification requirements proposed by the amendments would result in timelier implementation of NTSB safety recommendations and enhanced aviation safety.

Comments concerning the proposed rule are due on or before February 25, 2005 and should be sent to Deepak Joshi, Lead Aerospace Engineer (Structures), National Transportation Safety Board, Room 5235, 490 L'Enfant Plaza, SW., Washington, DC 20594. For more information, the NPRM provides greater detail and explanation for the proposed revisions, or you may also contact Deepak Joshi directly at (202) 314-6348.

Posted by Greg

December 27, 2004

DOT Authorized To Continue To Provide Insurance To U.S. Flag Commerial Carriers

By Presidential Determination 2005-15 dated December 21, 2004 and published in the Federal Register today, the Department of Transportation has been authorized to continued to make insurance coverage available to U.S. Flag Commercial Carriers. The order is effective through August 31, 2005 and no later than December 31, 2005.

This insurance coverage was originally implemented pursuant to 49 U.S.C. 44302 as a direct result of the events of September 11, 2001. Following the terrorist attacks, most aviation insurers cancelled the war risk coverage they previously provided to air carriers. The insurers that did not cancel the coverage increased their premiums so significantly that the government intervened to ensure that air carriers would still be able to obtain the needed coverage. Presidential Determination 2005-15 merely extends the time period for that legislative program.

Posted by Greg

December 22, 2004

Proposed Advisory Circular For Part 145 Repair Station Training Published

The FAA today published an Announcement in the Federal Register for a proposed AC 145-RSTP relating to Part 145 Repair Station Training Programs. The AC is only a draft and, even if it becomes a final published AC, repair stations would not be required to follow it. The draft AC merely "provides an acceptable means, but not the only means, for developing a repair station employee training program for repair stations certificated under part 145" and "[T]he sample programs only represent a possible way to structure a training program that meets the requirements of the regulations."

Comments to this draft AC are due no later than January 21, 2005 and should be sent to Mr. Herbert E. Daniel, Aircraft Maintenance Division, General Aviation and Repair Station Branch (AFS-340), Federal Aviation Administration, 800 Independence Ave., SW., Washington, DC 20591; facsimile (202) 267-5115; e-mail Herbert.E.Daniel@faa.gov.

For more information you should review proposed AC 145-RSTP in detail, or you can contact Mr. Herbert E. Daniel, AFS-340, at the address, facsimile, or e-mail listed above, or by telephone at (202) 267-3109; or Mr. Dan Bachelder, AFS-340, at the address or facsimile listed above or e-mail Dan.Bachelder@faa.gov or by telephone at (202) 267-7027.

Posted by Greg

December 21, 2004

New European Union Insurance Requirements To Take Effect

Effective April 30, 2005, new minimum liability insurance requirements will go into effect in the European Union. The EC 785/2004 regulation is intended to standardize insurance requirements across the EU member states. If you fly into any of the EU member states, you will need to be aware of, and in compliance with, the new regulation as of April 30, 2005. Failure to comply could result in loss of license, prohibition of flights and possibly criminal prosecution.

For more information on the regulation's requirements and the anticipated effects of the new regulation, check out the article here.

Posted by Greg

December 18, 2004

New FAA Website Addresses Safety For Children Flying On Airplanes

The FAA published a new website to help parents learn about the use of child safety seats for travel on airplanes. The URL for the site is www.faa.gov/passengers/childtips.cfm. The web site provides recommendations and requirements for use of child safety seats and appears to be directed toward airline travel. However, having traveled with a young child in a Cessna 182RG as well as on the airlines, I can tell you first hand that the recommendations apply to private aircraft as well as airlines.

From a practical standpoint, a child strapped into his or her seat remains seated. This prevents the child from running up and down the aisle of an airliner or from squirming around and wreaking havoc on your weight and balance in a small airplane. At least in my case, I know my son prefers being in his seat. He feels more secure and the safety seat also raises him up higher than the airplane's seat, giving him a better view out the windows.

Although carrying the safety seat with you can seem like an additional burden, it is in your child's best interest. Aside from the extra weight, it can also ease your burden as a parent by keeping your child in his or her seat during the flight.

For more information about flying with children, check out the FAA's new website.

Posted by Greg

December 17, 2004

Florida Hurricanes No Excuse For Untimely Appeal To NTSB Board

In Administrator v. Brantley, the airman filed his appeal 14 days after service of the administrative law judge's decision, 4 days late. In his response to the FAA's motion to dismiss, the airman argued that he had good cause for the untimely filing based upon the Florida hurricanes in September, 2004, the resuling closure of government offices and his allegedly living in an evacuation zone.

Unfortunately for the airman, the NTSB didn't buy his arguments. The record showed that the airman signed for the certified letter containing the ALJ's decision on September 18, 2004, six days before his appeal was due. The Board then reviewed data from the Federal Emergency Management Administration and observed that "during the six days within which he should have filed his appeal (September 18 to 24, 2004) there was no hurricane activity in or near Florida." The Board also rejected the airman's argument regarding closure of government offices given that the post office was open when the airman signed for the letter and when he mailed his appeal.

This isn't to say that the Board would reject such arguments as representing good cause for delay in filing an appeal. In fact, the Board stated that "[w]e are not unsympathetic to respondents in Florida whose ability to take timely action has been hampered by post office closures or other hurricane-related difficulties. However, this respondent does not appear to fall into that category of respondents." Unfortunately for the airman in this case, the actual facts did not support his arguments. His appeal was thus dismissed as untimely without good cause for his late filing.

Posted by Greg

FAA Proposes New Advisory Circular Regarding Aircraft Marking And Identification

The FAA today published Proposed Advisory Circular 45-2C, Identification and Registration Marking in the Federal Register. The proposed AC is intended to provide "guidance and information to comply with the requirements for identifying aircraft and related products with identification plates, and identifying aircraft with nationality and registration marks." The AC does not, however, represent the only means and methods of complying with 14 CFR 45

Comments to proposed AC 45-2C are due no later than January 18, 2005 and must identify the proposed AC and docket number FAA-2004-19834. You may send comments to the Docket Management System, U.S. Department of Transportation, Room Plaza 401, 400 Seventh Street, SW., Washington, DC 20590-0001. You may also submit comments to the Internet here.

For further information you can contact David Broughton, Airworthiness Certification Branch, AIR-230, Production and Airworthiness Division, Aircraft Certification Service, 800 Independence Avenue, SW., Washington, DC 20591; telephone: (202) 267-8361.

Posted by Greg

December 16, 2004

Airport Closures No Easy Sell

Recently people have been talking about closing the Minneapolis-Crystal Airport (KMIC), again. It seems some people feel it is a better, safer use of the land to close the airport and redevelop it, even though the people supporting closure haven't really done any due diligence to support their position. Reading behind the "safety" excuse, the real reason is that they feel they can make more money through redevelopment.

Interestingly, and fortunately for those of us who fly out of the Crystal Airport and want to keep it open, the same people touting the benefits of airport closure and redevelopment appear to have no idea how complicated and lengthy a process it is to close an airport. Not to mention the extreme opposition they would face. Several very large hurdles would need to be overcome in order to close the Crystal Airport.

First, and probably most importantly, the FAA would need to approve closure of the Crystal Airport. This is unlikely. The FAA doesn't like closing airports. Especially when the airport being closed is not being replaced. The FAA's position is that all airports play an integral role in the air transportation system of this country. More specifically, the Crystal Airport plays a critical role in relieving traffic congestion from the Minneapolis-St. Paul International Airport (KMSP).

Next, the Metropolitan Airports Commission has no intentions of closing the Crystal Airport. The Crystal Airport is part of its "reliever system" that relieves congestion at Minneapolis. Also, closure of the Crystal Airport would displace approximately 250 aircraft to the other already over-crowded reliever airports. This would leave little room for added growth the MAC is expecting at these airports in the future.

Also, the MAC can't afford to close the Crystal Airport. Every year the MAC receives money from the Airport Improvement Program in the form of grants. Each year it uses some of this money at the Crystal Airport. One of the conditions of receiving this grant money is that the airport operator agrees to keep the airport open for 20 years from the date it receives the grant. Alternatively, if the operator wanted to close the airport sooner than 20 years, the operator would need to repay the grant money it received. (This happened in Chicago when the city repaid its grant obligations before its midnight assault on Meigs Field). Given MAC's current fiscal crisis, it clearly cannot afford to repay those grants.

Finally, closure of the Crystal Airport would require legislative approval. The legislature created the MAC and the reliever airport system for reasons. Those reasons have not changed. Additionally, closing the Crystal Airport would be a tough sell in light of the legislative clout possessed by aircraft owners and operators.

I think the Crystal Airport is safe for the time being. However, on-going diligence and participation will be required to ensure that the Crystal Airport remains open and successful.

Posted by Greg

December 15, 2004

RVSM Equipment Suffix Available For Flight Plan Filing After January 5, 2004

As we have discussed before, Reduced Vertical Separation Minimum (RVSM) will be implemented in Domestic U.S. airspace between FL 290-410 (inclusive) on January 20, 2005. To get ready for this change, effective January 5, 2004, RVSM-compliant operators/aircraft filing an FAA Flight Plan, other than through DUATS and and certain Flight Service Stations, should file /Q or /W, as appropriate, for flight between FL 290-410 (inclusive). This is Phase II of the FAA's implementation of domestic RVSM.

The FAA will use the Phase II time period to see that operators are filing correctly for flight in RVSM airspace as the implementation date approaches. If you are filing through DUATS or certain flight service stations, you may not file "/Q" until January 20. For more information, review the "Area of Operations Specific Information" section of the FAA web site at: http://www.faa.gov/ats/ato/rvsm_documentation.htm

Posted by Greg

December 14, 2004

FAA Proposes Regulations For Certificate Disqualification After Alcohol Test Failures And Refusals

In a Notice of Proposed Rulemaking issued today, the FAA is proposing to amend the regulations relating to disqualification for airman or medical certificates based upon alcohol use. Specifically, the FAA proposes to 1) amend the airman medical certification standards to disqualify an airman based on an alcohol test result of 0.04 or greater breath alcohol concentration (BAC) or a refusal to take a drug or alcohol test required by the Department of Transportation (DOT) or a DOT agency; 2) standardize the time period for reporting refusals and certain test results to the FAA, and to require employers to report pre-employment and return-to-duty test refusals; 3) amend the airman certification requirements to allow suspension or revocation of airman certificates for pre-employment and return-to-duty test refusals; and 4) amend the regulations to recognize current breath alcohol testing technology.

Although the .04 BAC limit has been used as an indicia of disqualification in the past, the proposed rule would make such a positive test conclusive proof of substance abuse and automatically disqualifying. Additionally, test refusals would also be considered conclusive proof of substance abuse. The tests included in this rule would also be expanded to include pre-employment and return-to-duty test refusals, rather than the existing tests administered prior to an employee engaging in safety-sensitive duties. The FAA argues that these revisions are consistent with NTSB cases that have held a single event of alcohol misuse can be considered substance abuse and disqualifying. It appears that the FAA has taken to heart NTSB Member Hersman's concurring statement as discussed in my December 8, 2004 post.

The proposed rules appear to be restricted to tests administered pursuant to the mandatory drug and alcohol testing programs required of aviation employees in safety-sensitive positions (e.g. pilots, mechanics etc.) or administered by their employers in connection with pre-employment screening or return to duty testing. However, the proposed rules could affect a person subject to testing who holds an airman medical certificate for reasons unrelated to their safety-related job, such as a mechanic who also holds a pilot certificate.

The proposed rules are not a surprise. However, I don't think the FAA will stop here. I believe it is just a matter of time before the FAA will propose further rules that will extend disqualification to any test revealing a BAC greater than .04 or any refusal to take a drug or alcohol test. Under such rules, an airman receiving his or her first DWI (in almost all states this would involve a BAC of .08 or greater) would automatically be disqualified from holding a certificate. The FAA appears to be rejecting the discretionary judgment it used to exercise in relation to alcohol use and medical qualification in favor of bright line tests for disqualification.

Comments to the proposed rule are due by March 14, 2005. If you would like to submit comments, they may be sent, identified by Docket Number 2004-19835, 1) electronically via http://dms.dot.gov or http://www.regulations.gov; 2) via U.S. Mail to Docket Management Facility; U.S. Department of Transportation, 400 Seventh Street, SW., Nassif Building, Room PL-401, Washington, DC 20590-001; 3) via facsimile to 1-202-493-2251; or 4) via hand delivery to Room PL-401 on the plaza level of the Nassif Building, 400 Seventh Street, SW., Washington, DC.

For further information read the NPRM in its entirety or you may contact Sherry M. de Vries, Aeromedical Standards and Substance Abuse Branch, Medical Specialties Division, AAM-210, Office of Aerospace Medicine, Federal Aviation Administration, 800 Independence Avenue SW., Washington, DC 20591; telephone (202) 267-8693.

For all of those individuals holding airman or medical certificates and who also enjoy a cocktail now and then, beware. It is imperative that you exercise good judgment when consuming any alcohol. If your judgment lapses, you could end up losing your certificates. Given these consequences, the decision to exercise good judgment should be an easy one to make.


Posted by Greg

December 09, 2004

Dismissal Of FAA Charges After Hearing Does Not Guarantee Award Of Attorney Fees Under EAJA

In Administrator v. Ted Ray Moore, the FAA charged the airman with violations of FAR's 91.123(a)(deviation from ATC clearance) and 121.525(f)(careless and reckless). After a hearing, the ALJ dismissed the 91.123(a) charge but affirmed the 121.525(f) charge. The airman appealed to the NTSB Board who upheld the ALJ's dismissal of the 91.123(a) charge and reversed the ALJ's finding on the 121.525(f) charge, dismissing that charge as well.

The airman then filed a petition seeking recovery of his attorney's fees and expenses under 5 U.S.C 504, the Equal Access to Justice Act ("EAJA"). The ALJ denied the airman's petition finding that the Administrator was substantially justified in pursuing the case to hearing because key factual issues were present which hinged on credibility. In affirming the ALJ's order, the Board determined that the Administrator's position was substantially justified because it was reasonable both in law and fact. That is, the Board found that the facts alleged had a reasonable basis in truth, the legal theory propounded was reasonable, and the facts alleged reasonably supported the legal theory.

In this case, the airman was fortunate that the ALJ found the airman and his fellow crewmember more credible than the FAA's witnesses. This credibility determination resulted in dismissal of the charges. Had the ALJ found the FAA's witnesses more credible, the facts alleged would have supported the FAA's charges. As a result, because the case necessarily depended upon credibility determinations that, if made in favor of the FAA would have supported its charges, the FAA's decision to pursue the case to hearing was substantially justified. Unfortunately for the airman, this resulted in the denial of his petition for fees under EAJA.

Posted by Greg

December 08, 2004

A Single Instance Of Substance Abuse Can Be Disqualifying For Medical Certification

The NTSB Board has reaffirmed its precedent that "a single incident of substance abuse is sufficient to establish disqualification for medical certification". In Administrator v. Schroeder the airman, an ATP rated pilot employed by Delta, showed up for a flight the day after Christmas. While being processed through the security checkpoint, two TSA employees noticed a strong smell of alcohol. The airman was subsequently detained and testing indicated a blood alcohol level in excess of the .04 allowed by FAR 91.17(a)(4).

The ALJ upheld the FAA's emergency revocation of the airman's ATP and First Class medical certificates. The NTSB Board affirmed, finding that the airman's alcohol consumption on Christmas and his condition when he showed up for work the next day, coupled with Board precedent, amply supported the ALJ's decision.

What makes this case notable is the concurring statement by Board Member Hersman. Although she agrees with the outcome of the case, she makes it a point to voice her concern with the use of a bright line test where a single instance of alcohol abuse is used as a basis for "de facto" denial or revocation of a medical certificate. She urges both the FAA and the Board to give careful consideration to the factual and medical evidence relevant to this issue.

Member Hersman's final comment suggests that it appears that the FAA is not exercising any discretion when it "automatically" seeks revocation of an airman's medical certificate in connection with a violation of FAR 91.17. She suggests that if this is in fact the FAA's position, contrary to the current regulations which require the exercise of discretionary medical judgment, that the FAA should change the regulations to accurately reflect the standards to which airman will be held accountable.

In my opinion, a case by case approach using reasonable medical judgment and discretion is clearly more appropriate than the "de facto" approach which is becoming more common. This approach does not excuse the exercise of poor judgment as exhibited in this case. Revocation of the airman's ATP certificate was clearly appropriate. However, to automatically deny or revoke a medical certificate for this violation (although perhaps appropriate in many situations) is inconsistent with the existing regulations and it relieves the FAA of the discretionary medical judgment it is required to exercise.

Hopefully the FAA and the Board will take Member Hersman's statements to heart and reevaluate the current enforcement approach in relation to alcohol use and medical certification.

Posted by Greg

December 07, 2004

Chicago Responds To FAA Investigation Into Use Of Airport Revenues For Closure Of Meigs Field

On December 3, 2004, the City of Chicago filed a 41-page legal brief in response to the FAA's Notice of Investigation regarding Chicago's use of airport revenues in connection with its closing of Meigs Field. Although the City admits using the airport revenues in connection with the closure it argues that its use of the funds was proper and justified.

The City argues that 1) its use of the funds are a legitimate capital and operating expense for the Chicago Airport System; 2) it is not prohibited from making such expenditures after closure of an airport; 3) FAA precedent (Denver Stapleton and Austin's Robert Mueller airport) allows such expenditures; 4) the City is obligated to remove airport structures and remediate the property under its lease with the Park District and under Illinois law; and 5) its post-closure use of airport revenue is consistent with legislative history and public policy. Interestingly, the City's response does not address the proposed fine for its failure to provide 30-days advance notice of the closure.

I think the City's fourth argument is definitely its weakest. The City's obligations under its lease and under state law do not necessarily justify its use of airport revenues, as opposed to revenues from other non-aviation sources, to meet those obligations.

Their best argument may be their reliance on FAA precedent. In both the Denver and Austin cases, substantially greater dollars were involved for work that was clearly beyond the scope of simply removing airport structures and remediating the property. However, the distinction between those two situations and Meigs may be the fact that the FAA was involved in those closures early on, as opposed to Meigs where the FAA learned of the closure the morning after Daley's pre-dawn raid, and in both cases the airports were being replaced by new airports.

It will be interesting to see how this works out. If the FAA pursues a civil penalty, supporters of Meigs everywhere will take heart. However, rest assured that if that happens, the City of Chicago will not roll over. I have no doubt the City will request a hearing and, if it is unsuccessful at the hearing, will appeal that decision. The saga of Meigs continues... Stay tuned.

Posted by Greg

December 06, 2004

Untimely Filing of Appeal Continues To Result In Dismissal by NTSB

In a recent NTSB case, Administrator v. Chin Yi Tu, the Board upheld an ALJ's dismissal of a pilot's appeal of two FAA orders of suspension. Apparently the pilot was "away on travel" and not at his "official address". In his absence, the FAA orders sent via certified mail were not accepted. The pilot argued that his appeal would not have been late if the orders of suspension had been sent via certified mail and first-class mail because the first-class mail would have been forwarded to him.

The Board affirmed the ALJ's rejection of the pilot's arguments holding that "the Administrator was not obligated to serve the respondent in multiple ways and constructive service of an order of the Administrator is valid under our rules of practice". The Board also noted that the pilot could have advised the FAA to also send any orders of suspension via first-class mail "in an enforcement matter he knew was underway and in which he was expecting important documents".

None of this is a surprise, nor is it inconsistent with Board precedent. However, what is of interest in this case, is the concurring statement of Board Member Hersman and the dissenting statement of Board member Healing. Both of these statements question the methods of service of process used by the FAA and the computation of the time within which a certificate holder can timely file an appeal.

Member Hersman's points out that the FAA's communications with certificate holders who are under investigation is not as clear or consistent as it might be in that she feels many respondents do not understand the timing requirements for properly appealing an FAA order. She also notes that having the time in which to submit a response to an FAA order run from the "date of mailing", as opposed to from the "date of receipt", may be impractical "given the mobility of the population that these regulations are intended to cover and the time that it may take for them to receive the complaint". Finally, she notes that the Board has historically chosen to decide cases on their merits, and now it appears in her opinion that respondents may not be receiving due process when their appeals are dismissed based upon failure to comply with the timing requirements when they may not have received the complaint in a timely fashion.

Member Healing is more direct. He notes that this case "once again illustrates how the FAA's reliance on a flawed system of delivery can cause confusion and potentially unwarranted damage to an airman's livelihood". He takes issue directly with the "flawed mailing system" method of service of the complaint and with the use of the date of mailing for calculating the time for appeal. He also believes that the FAA's letter should "clearly reflect the date by which an appeal should be filed". (Doesn't seem like that should be too tough for the FAA to do). He concludes that "when there is action against a certificate holder that will have a large impact on the recipient's livelihood, it is imperative that there is a system in place that will ensure that appeals are decided on the merits and not on a procedural basis that relies at least in part "on a seriously flawed process for serving notice".

These two Board members have definitely identified two issues in need of further thought and consideration. It will be interesting to see whether their views influence the FAA, and hopefully future Board decisions.

Posted by Greg

December 03, 2004

FSDO's Authorized To Issue Student Pilot Certificates To Light Sport Aircraft Applicants

On November 30, 2004, the FAA issued a Notice authorizing local FSDO's to issue student pilot certificates to light sport aircraft applicants. The FSDO will process the application according to the guidelines set forth in Order 8700.1, vol. 2, ch. 4 and will also need to determine that the applicant holds either a valid U.S. driver's license or a medical certificate. When completing Form 8710-1 (Airman Certificate and/or Rating Application) the FSDO will add "Sport Pilot" in the "Other" box in Section I.

If you have questions about how a FSDO will be handling this, contact the specific FSDO directly or call the FAA's Certification and Flight Training Branch, AFS-840, at (202) 267-8212.

Posted by Greg

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