Response to Request for Public Comment on the Modernization of Pilot Schools

 February 8, 2025

Filed electronically through the Federal Register, Docket ID: FAA-2024-2531

Thank you for the opportunity to submit this comment regarding the FAA’s Request for Comment on the Modernization of Pilot Schools (Docket ID: FAA-2024-2531). This comment is jointly authored and submitted by the Aviation-Impacted Communities Alliance (AICA), Save Our Skies Alliance, and Groton Ayer Buzz.

AICA represents over 90 groups nationwide, including Save Our Skies Alliance, and Groton Ayer Buzz, all of which actively advocate at both local and national levels for effective measures to reduce aviation noise and its health impacts on communities.

The modernization effort presents an opportunity to advance pilot training while ensuring all stakeholders—including impacted communities—are meaningfully considered. As stated in the Federal Register notice, the FAA has encouraged public input on innovative ideas, methods, and solutions that could significantly impact pilot school training, and we appreciate the opportunity to contribute. Many of our recommendations align with ongoing industry-supported efforts to enhance training, safety, and community engagement. Strengthening these measures will further the FAA’s commitment to operational excellence while fostering transparency and accountability. We urge the FAA to adopt these recommendations as it modernizes Part 141 to benefit both aviation and the communities it serves.

Firstly, we endorse the City of Phoenix Aviation Department’s comment (Comment ID FAA-2024-2531- 0003)1 which highlights the importance of improving communication with and recognition of impacted communities. Additionally, we recommend key initiatives to strengthen the modernization efforts to reflect a holistic approach to safety, operational excellence, and community well-being:

1. Incorporating Noise Abatement Training – Enhance pilot education on noise-sensitive operations in accordance with Advisory Circular 91-36D to minimize community impact.
2. Optimizing Training Efficiency – Continue work to reduce student dropout rates by improving resource allocation, streamlining training programs, and minimizing unnecessary environmental impacts.
3. Integrating Competency Assessments into Flight Hour Requirements – Encourage the reevaluation of the 1500-hour rule through a competency-based framework that improves student outcomes and professional readiness.
4. Increasing Transparency – Consider requiring flight schools to publish graduation rates and safety track records, providing clearer insights into program effectiveness, helping students make informed decisions, and promoting accountability within the industry.
5. Enhancing Flight Training with Historical Accident Analysis – Further strengthen curriculum with most current data-driven insights and advanced technologies to improve pilot competency and overall flight safety.
6. Leveraging Innovation – Continue to advance modern technologies and training methods to enhance efficiency, improve pilot proficiency, and reduce community impacts from outdated systems.
7. Ensuring Balanced Stakeholder Inclusion and Community Engagement – Strengthen collaboration with impacted communities to enhance transparency, reduce conflicts, and create a more efficient, safe, and community-conscious training environment that benefits both pilots and the aviation industry.

We recognize that flight school training fulfills a fundamental role in preparing the next generation of pilots and influences the quality of life in communities across the country. As the FAA advances this initiative, we encourage a balanced approach that enhances pilot proficiency while promoting transparency, accountability, and thoughtful noise mitigation strategies. We appreciate the opportunity to contribute to this discussion and look forward to continued engagement in shaping a framework that benefits both the aviation industry and the communities it serves.

Respectfully submitted,
Darlene Yaplee, President and Co-founder, Aviation-Impacted Communities Alliance (AICA)
Save Our Skies Alliance
Groton Ayer Buzz

CC:
Members of the Quiet Skies Caucus
Members of the Aviation-Impacted Communities Alliance

See letter in its entirety here.