Michael Mohlenbrok

Proposed legal interpretation incorrectly limits PIC authority for flight deck access to a defined and verbalized safety risk associated with the denial of access. Many decisions made by the PIC are judgement calls where intangible factors are considered and a PIC chooses the safest course of action. Hundreds of decisions are made during each flight where options are weighed and action taken. The requirement for the PIC to be restricted by multiple jumpseat occupants by UPS who are clearly not enhancing the safety of flight is quite burdensome and contrary to best practices in the industry. UPS requires the carriage of these other employees and contractors only to avoid the cost associated with providing commercial travel. Additionally since UPS has chosen to remove or not install flight deck doors on all aircraft it is reasonable for the PIC to have unlimited discretion on each and every jumpseat occupant consistent with the FAR's and past practice.