October 23, 2007

Mr. Robert A. Sturgell

Federal Aviation Administration

Acting Administrator

FAA Headquarters

800 Independence Ave SW

Washington, D. C**.** 20591

Dear Mr. Sturgell:

:

(Summary)

I am writing to you today to request an immediate waiver to the "age 60
rule", FAR 121.383(c), in its entirety. I specifically request that the
waiver allow me to act, without any limitations other than those that
apply to the entire commercial pilot population, as a pilot in Part 121
operations until I have reached my 65^th^ birthday, and that the waiver
allow any U.S. certificated airline to use my services as a pilot until
that time. I further request that the exemption cover international
operations, as I anticipate my duties would require international
flights.

(Body)

In support of my request, I would like to point out that I believe the
granting of this waiver would: (1) improve aviation safety; (2) provide
a material public benefit; (3) remove an arbitrary restraint to the
pursuit of happiness by a U.S. citizen and to that U.S. citizen\'s
pursuit of a chosen profession; (4) align FAA practices with the
opinions, mandate and protections of the EEOC; (5) align the
requirements of the FAA with the international community; and (6) remove
the absurd situation we now have, where if I were an Iraqi or Saudi (or
any other nationality) pilot, I could legally act as a pilot on
commercial air service into this country, but precisely and solely
because I am a U.S. Citizen who wants to lend my efforts to a U.S.
company, I am denied that opportunity by the arbitrary, archaic policies
and practices of one branch of the U.S. Government. I would further like
to point out that (7) the FAA, in honoring the new ICAO standards for
pilots of foreign air carriers, has already in essence ruled that an
extension to age 65 does, in fact, meet the requirements of (a) public
benefit, and (b) no adverse effect on safety.

To expand on the supporting points above, I request that you please
consider the following thoughts.

1.  Public safety would be improved by keeping an experienced Captain,
    whose judgment is mature and has been honed and tempered by a
    professional lifetime of experience. This maturity of judgment is
    not easily gained, and should not be carelessly discarded. My
    health, abilities, and competence are still strong, and embellished
    by my experience. Current procedures are fully in place to monitor
    our abilities on a regular basis, both in flight simulators and in
    "line checks" by the airline, and additionally we are subject to
    random line checks by FAA inspectors. To quote then FAA
    Administrator Blakely, "The objections of the past don't cut it
    anymore. This is the right thing to do. *Experience* counts, it's an
    added margin of safety, and at the end of the day, that *is* what
    counts. Isn't it?"

2.  There is a material public benefit to granting this request. The
    public would benefit obviously and directly from the improvements in
    safety generated by the retention of experienced and capable airmen.
    Perhaps more subtle, but in my opinion, more far-reaching, is the
    boost of public confidence in the integrity of their government at
    work. Granting this waiver would show that the responsible parties
    in the government agency are actually giving due and full
    deliberation to the issues at hand, fulfilling their duties and
    obligations of fair representation to the people of this country,
    and not simply resorting to bureaucratic platitudes and habitualized
    obeisance to outdated and arbitrary policies that echo down the
    hallways of the past. Again, from Administrator Blakely, "The
    objections of the past don\'t cut it anymore."

3.  The current (and soon-to-change) rule was born directly as a
    political favor almost 50 years ago. It has never had any viable
    physiological data to support it -- it is, and has been for its
    entire life, a textbook example of arbitrary and capricious
    rule-making. It abridges the rights and liberties of an ordinary
    citizen of these United States to pursue his or her chosen
    profession. In short, it manifests and codifies an attitude which is
    diametrically opposed to the American spirit.

4.  The EEOC, for a quarter of a century, has recognized that this rule
    violates the spirit and the law of our great country. For a quarter
    of a century! The current situation runs counter to every concept of
    fairness and justice that is embodied in the ideals of America. As a
    footnote, the\
    Canadian equivalent of our EEOC has reached the same conclusion --
    that there is no justifiable Bona Fide Occupational Qualification
    element to the age 60 requirement.

5.  The entire international community has recognized that the age 60
    requirement is unsupportable and without reason. ICAO amended its
    age rule some time ago, and it has now been in effect for a year.

6.  It is a hugely unjust irony that a non-citizen can find gainful
    employment as a pilot within the borders of the United States, while
    a U.S. citizen is prevented from doing so. This prevention is
    unnecessary, it\'s unfair, and it grossly offends even the most
    rudimentary sense of justice and American fair-play. Think about
    this -- if I were an Egyptian national, or Communist Chinese, or
    Bulgarian, or just about anything [except]{.underline} a U.S.
    national, I could exercise the right to fly here; but since I was
    born in the U.S.A., raised in the U.S.A., pay taxes in the U.S.A.,
    and my passport says United States of America, I am prohibited from
    pursing my profession. Your granting of my waiver request would
    right this wrong.

7.  The FAA has already essentially granted this exemption to pilots of
    foreign carriers. In honoring the new ICAO standards, the FAA has,
    de facto, already determined that (a) the public interest is
    beneficially served by allowing the age extension, and that (b) the
    exemption has no adverse effect on safety. My request for this
    waiver seeks equal treatment for a U.S. citizen in furtherance of
    the operations for a U.S. air carrier.

Thank you for your consideration, I hope to see a positive response from
you at your earliest convenience.

Respectfully,

![](media/image1.png){width="2.9930555555555554in"
height="0.7097222222222223in"}

William P Campbell , ATP #2003126

4833 E Juana Ct

Cave Creek, AZ, 85331