800 Independence Ave., S.W. Washington, DC 20591

AFS

- 11

- 182

- P September 26, 2014

Mr. Jason Blair

Executive Director National Association of Flight Instructors

730 Grand Street Allegan, MI 49010

Ms. Kathryn Fraser Manager of Operations

General Aviation Manufacturers Association 1400 K Street, NW, Suite 801 Washington, DC 20005

M s. Kristine Hartzell Manager, Regulatory Affairs

Aircraft Owners and Pilots Association 421 Aviation Way Frederick, MD 21701

Mr. David Oord Government & Advocacy Specialist Experimental Aircraft Association 3000 Poberezny Road Oshkosh, WI 54902

Dear P etitioners:

This is in response to your letter dated January 31, 2011 , posted to the public docket (No.

FAA

- 2011

- 0 138 )

, petitioning the Federal Aviation Administration (FAA) to initiate rulemaking to amend part 61 of Title 14, Code of Federal Regulations (14 CFR). In your request, you asked to remove the term “authorized instructor” from §§ 61.99(a), 61.109(a), and 61.109(b). The proposed rulemaking, if granted, would allow the flight training time acquired from a certified flight instructor with a sport pilot rating to be used to meet certain aeronautical experience requirements for recreational and private pilot applicants.2 When the FAA responds to petitions for rulemaking, it must follow the requirements of

part 11, particularly those guidelines for processing petitions for rulemaking found in § 11.73. As stated in that section, the FAA uses the following criteria when making a decision whether to amend current regulations based on a petition for rulemaking:

1) The immediacy of the safety or security concerns you raise; 2) The priority of other issues the FAA must deal with; and 3) The resources we have available to address these issues

.

Proper certification of pilots operating in the National Airspace System constitutes a large part of maintaining the sa fe aerospace system in place today. The FAA also recognizes the potential for change to regulation and policy, when feasible, to ease any unnecessary burden on pilot applicants.

For the reasons listed above the FAA was unable to take action on your pet ition until recently

. T he FAA initiated rulemaking to address necessary changes to part 61 ; several of these changes include expanding the existing opportunities for logging flight time

. The proposed rule is titled “ Part 61 and 91 Recommended Rule Change s (Retrospective Regulatory Review)”

, and is included as a Department of Transportation (DOT) current rulemaking . The DOT provides information and status of non

- significant rulemakings in

the DOT semi

- annual regulatory agenda , through the Office of Manag ement and Budget’s (OMB) Office of Information and Regulatory Affair’s (OIRA) Unified A genda ( http://www.reginfo.gov/public/do/eAgendaMain )

.

When the notice of proposed rulemaking (NPRM) is p osted to the public docket ( http://www.regulations.gov ), you can review the NPRM and comment on it. After the comment period closes, the FAA will evaluate and disposes of all received comments.

For the reasons above, we are dismissing your petition for rulemaking in accordance with 14 CFR § 11.73.

Sincerely

,

/s/

John Barbagallo Acting Deputy Director, Flight Standards Service