The existing exemption language while trying to raise the level of safety of FAR 91 VPO's and Pilots engaged in fuel reimbursement, has the unintended consequence of imposing Part 135-like requirements which make compliance extremely difficult thereby contradicting the intent of Congress.
I suggest that the Air Care Alliance can provide industry leadership with straight forward suggestions as to raising the level, which everyone wants, while at the same time differentiating between Air Carrier and Volunteer flying. That line is blurred in the existing exemption language. While some VPO's may choose not to reimburse there are others for whom this is vital to their ability to sustain high levels of service to needy individuals in their communities.
Finally, please make certain that those who do not wish to receive reimbursement are not bound by the same criteria as those who do.
Thank you for your hard work in addressing this!
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Total: 1
Cody Welch Public SubmissionPosted: 02/25/2013
ID: FAA-2013-0190-0002
Cody Welch
This is comment on Rule
Charitable Medical Flights
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Public Submission Posted: 02/25/2013 ID: FAA-2013-0190-0002