Stephen Edwards

Document ID: FAA-2011-0628-0005
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: August 01 2011, at 12:00 AM Eastern Daylight Time
Date Posted: August 2 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: June 23 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: August 22 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80ed28cd
View Document:

This is comment on Notice

Clarification of Prior Interpretations of Seat Belt and Seating Requirements for General Aviation Flights

View Comment

The proposed rule shows ignorance or disregard for the circumstances encounted while seating passengers for private Part 91 flight in vast numbers of GA aircraft. The rule references several requirements for "double seating" but the information required for this decision is not available to the pilot in most circumstances. One suggestion is "belt must be rated for this use". No belt shows this, they only have a total strenth on the tag. Another suggestion is "flight manual must show this arrangement". Many older GA aircraft do not have a flight manual. They may have a "Owners manual" which only shows seating positions, not belting arrangement. Also the suggestion that the seat loading limit be evaluated is useless as this information is not available to the pilot. I suggest you just decide what the rule will be and write it, not just pass this off on published info that does not exist.