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Another Part of the Envelope – Aviation Advocacy

Tupper on the ramp with DC-3 N134D

My contributions to this blog are largely about exploring the envelope of aviation.  That means aerobatics, flying different aircraft, and a lot more.  Some of it unexpected.

Like taking on the responsibility of staying informed and sometimes speaking out.

As pilots, there’s much we have to read and understand.  Everything from the Pilot’s Operating Handbook for the airplane to takeoff and landing distances Notices to Airmen (“NOTAMs”), and more.  But, as the bearers of the heritage of aviation, our jobs go well beyond just flying these aircraft.  We need to understand the ways in which the public views aviation and the ways in which our government can affect aviation.

For example, as you’re probably aware, the Transportation Security Administration (the “TSA”) promulgated a Notice of Proposed Rulemaking (an “NPRM”) in October in which the TSA set out to make new rules that affect “large aircraft” (defined by regulation as any aircraft certified to take off with passengers, cargo, fuel, etc. at more than 12,500 pounds).  The new TSA program is called the Large aircraft Security Program (or “LASP”).

Federal agencies often (but not always) publish an NPRM when they’re thinking about making big or important regulations.  The NPRM usually contains the text of the proposed rule and some explanatory material in which the agency tells the public what’s on the agency’s mind and why it is proposing to make the regulation.  After the NPRM is published in the Federal Register, the agency gives the public an amount of time during which to comment, and then the agency ostensibly takes the public comments into account in making the rule.

The comment period for the LASP just ended on Friday, February 27.  Thousands of pilots and others commented on the proposed LASP. 

I commented, too, for the first time.  I was a political science major as an undergrad and I’m a lawyer by profession, so it embarrassed me a little that this was the first time I had ever commented on an NPRM.

Being an independent media producer and not obliged to avoid stepping on toes, I gave full vent to my feelings, although I kept it PG-rated in terms of language.  If you want to check out the comment, there’s a copy posted at 

I feel pretty strongly about the LASP.  Perhaps more strongly than others because I’m one of the relatively rare people who has a type rating (second in command) in the mighty Douglas DC-3/C-47 Skytrain.  Even more so because I’m only a private pilot (not commercial or airline transport pilot) and I got the rating because I wanted to know what it was like to fly an airliner from the golden age of aviation.  The DC-3/C-47, with a max gross takeoff weight (in the configuration in which I flew it) of 25,500 pounds, falls squarely within the crosshairs of the LASP.

Bear in mind that AOPA speaks for itself (very well, I might add), that my views are not necessarily those of AOPA, and that AOPA doesn’t endorse my views just because I happen to blog here.

The point is that I’m about to preach to you about aviation advocacy and I’d feel sheepish about preaching it if I didn’t practice it.

As pilots, we  represent something like 0.2% of the American population.  We’re vastly outnumbered by non-pilots.  The mainstream media does an awful job of reporting aviation to the general public and that, among other things, means that we have our work cut out for us in terms of helping people to understand aviation.

It therefore falls to us to educate the non-pilot public about what we love.  And many of the regulators that have power to regulate aviation, are non-pilots who need information as badly as the rest of the non-pilot public.

When you become a pilot or a flight student or an aviation enthusiast, you take on an obligation to speak for aviation and explain aviation to the public and to regulators.  It’s not just that we love to fly.  The fact is that the public and regulators need facts so that they can make informed decisions.  And they need to know that, if the likely direction of the regulation as we see it is counter to the facts, we’ll be unhappy.

And, for that matter, when the government gets it right, we need to speak up about that, too.

Your reading list as a pilot needs to extend to more than just the most recent Airport and Facilities Directory (“A/FD”) and updating your charts.  It needs to include news about the regulatory environment in which we operate.  And then you need to participate in the process by speaking up when opportunities arise.  Locally, statewide, and nationally.

Not a part of the envelope of aviation that you thought you were going to be exploring with me?  Hey, I didn’t think so either until the LASP came along.  Maybe some future issue will capture your attention and you’ll want to stand up for or against.  If it does, you need to be ready and that means reading all you can and then being prepared to write and speak.

So go subscribe to your favorite aviation news feeds and blow the pretzel crumbs out of your keyboard.  We each have 499 fellow Americans out there to educate and there’s no better time than the present!


One Response to “Another Part of the Envelope – Aviation Advocacy”

  1. Alex Kovnat Says:
    March 3rd, 2009 at 1:36 pm

    I already submitted my thoughts to the Transportation Security Administration, regarding the ill-conceived idea of requiring airline-type security precautions for any aircraft weighing 12,500 lb or more. Hopefully by now, those in decision-making positions have heard our voices.

    What many people don't realize is that if our nation were to stamp out corporate aviation and use of business jets by the entertainment community, corporate VIP's and entertainment world celebrities would have to commandeer the whole front or rear of commercial airliners, owing to the security needs of people who, by nature, will either be mobbed by fans (celebrities) or who face danger by disgruntled former employees (corporate CEO's) in the absence of such measures.

    I've been to Oshkosh 10 times, and I enjoy seeing big planes like privately owned DC-3's, Flying Fortresses, the last flyable Lockheed Super Constellation, and rarities like the British Shackelton antisubmarine aircraft. I agree it would be an abomination to ground such aircraft just to satisfy the emotional and ego needs of neurotics.

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