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'But, It Ain't Broke...' General Aviation Takes Aim at Senate's Section 315

'Air Tour and Sport Parachuting Safety' Act an Economic Gut Punch, Say Stakeholders

A group of GA-related stakeholders addressed proposed Senate regulations that would have "significant and insurmountable" impacts on small operators around the country.

The group includes a wide variety of big industry names related to general aviation, parachuting, and warbird operations, each throwing their weight behind a letter urging lawmakers to reconsider regs surrounding parachute use and air tours. "We write to highlight our concerns that, as currently drafted, Section 315 entitled Air Tour and Sport Parachuting Safety of the Senate’s FAA Reauthorization Act of 2023 (S. 1939) will, if enacted, have significant and insurmountable direct impacts on thousands of small general aviation businesses and the airports at which they operate," the letter reads.

It gives a rundown of the 'broad bipartisan support' seen in the FAA reauthorization bill, while noting that it passed without similarly difficult provisions last July. The group notes that small business surrounding air tourism provide an important commercial stimulus to communities, thanks to their small-town locations and far-flung sceneries, often making them the only game in town for future aviators to gain experience in the industry. Passing Section 315 would negatively impact them, introducing requirements that are "nearly impossible" to comply with.

"Section 315 introduces requirements that would be nearly impossible and financially unattainable for these small businesses, resulting in their likely closure," the group says. "If adopted, Section 315 would burden the FAA's limited resources with a flood of new certificate applications and the ongoing costs of administering flight operations under 14 CFR Part 135, diverting resources that currently oversee commercial point-to-point charter flights and other safety-critical functions."

They say that the industry has done just fine without such rules in the past, noting an ad-hoc solution in the form of FAA permissions under an LOA issued via 14 CFR part 91.147. "FAA regulations also address pilot, aircraft, and operational qualifications for these types of activities. Additionally, these operators will fall under the FAA’s requirements for the implementation of Safety Management Systems which further enhances a robust safety culture."

The letter goes on to offer broad industry support in finding another way to bolster tourism safety, so long as it's an actionable and effective pathway to do so. "In closing, our organizations have deep concerns that the proposed requirements, if enacted, are not scalable and do not support a data-driven approach to enhancing safety for these segments of general aviation. They will result in the closure of small aviation businesses without improving safety, and they will deprive the FAA of the resources and manpower needed to address priority issues. We respectfully request that the Senate’s Section 315 provisions be omitted from any final FAA Reauthorization bill."

Bizarrely; Sport Parachuting (in particular) has never been safer... a trend that has been more positive over the years... making the need for such 'safety improvements' absolutely inexplicable... and without viable rationale.

FMI: www.faa.gov


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