V1 Consulting Group, LLC

In response to open comment period regarding FAA Docket 2011-0045, V1 Consulting Group maintains, that the FAA did not “overstate their position in allowing the PIC unfettered authority to deny flight deck access under 121.547 (a) (3) and (a) (4).” And that the current docket continues to support and reiterate the details of the negative impacts of lessons learned, when an employer attempts to chill PIC authority. Specifically in regard to the great amount of legal interpretation and investigative detail by the FAA, that went into FSAT 02-06, which clearly identifies the potential negative impacts to safety, when the PIC may feel that a decision to allow or deny flight deck access may have potential disciplinary consequences. We wholeheartedly support the language of FSAT 02-06 Appendix 3, which after years of research and legal proceedings, which in no small part included the parties of V1 Consulting Group produced the following: “In a situation involving Sections 121.547(a)(3) or 121.547(a)(4), the Federal Aviation Regulations contain no language for someone -- not even an FAA official - to second guess the PIC’s decision to deny permission to someone seeking admission to the flight deck under Section 121.547(a)(3) or Section 121.547(a)(4). PICs can be held accountable if something in their control on the flight deck causes a violation of the safety rules. A PIC might make the judgement that something in particular about a person seeking to enter the flight deck under paragraphs (a)(3) or (a)(4) of Section 121.547 might distract the flight crew. That assessment by the PIC to deny permission to admit someone to the flight deck in a situation under Section 121.547(a)(3) or Section 121.547(a)(4) cannot be second-guessed. Even if the potential jumpseat rider is assessed as probably being a quiet-noninterferring jumpseat rider, the PIC might, for example, decide not to admit that person to the flight deck because the next flight segment will involve travelin