I urge the NTSB to maintain the existing rules of practice for emergency revocation proceedings. Appeals from emergency orders of revocation are already granted expedited hearing. I believe this expedited hearing gives ample due process to airmen who wish to contest these actions. The loss of airman privileges is relatively short. The NTSB must remember that the airman's ability to exercise the privileges of his or her certificate must be considered in light of the public's far greater right to expect safety in air transportation.
While there may occasionally be circumstances where the NTSB finds the Administrator's decision that an emergency exists to be unwarranted, I believe the statistics show that in the vast majority of cases this decision was valid. The NTSB does and must continue to grant considerable latitude to the Administrator in identifying circumstances that pose concrete and imminent threats to aviation safety. The NTSB's primary mission is to promote transportation safety. This mission will be jeopardized if reckless airmen are permitted to exercise the privileges of their certificates without fear of a swift penalty. The "reasonableness" standard is sufficient and should not be changed.
Comment from Eric Basile, Self
This is comment on Proposed Rule
Practice in Air Safety Proceedings, etc.
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