I have a copy of the Federal Aviation Regulations, published by Boeing Field’s Merrell Aviation in Seattle. It dates from 1965 and is deliciously compact. For example, Part 91 spans 21 pages ranging from 91.1 (Applicability) to 91.175 (Rebuilt engine maintenance records).
Pulling just one section (91.5 — Preflight action) from 1965 reads as: Each pilot in command shall, before beginning a flight, familiarize himself with all available information concerning that flight. This information must include, for a flight under IFR or a flight not in the vicinity of an airport, available weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delays of which he has been advised by ATC. (Just 66 words from start to finish.)
Today, 91.5 is now 91.103. It reads: Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include (a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delays of which the pilot in command has been advised by ATC; (b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information: (1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and (2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature. (160 words).
That is bloat of 142% in 46 years. The language that confounds me is exactly what was added. I don’t ever recall seriously or otherwise considering the use of any runway shorter than my plane was capable of operating from. Simply put, if a runway didn’t pass the pucker test, it was ruled out. I know the additional language is most likely the result of a lawsuit, but for me it boils down to an attempt to regulate common sense, or put another way, to regulate all possible alternatives, which isn’t possible. I see no benefit, as a pilot, for the additional 94 words. The original language covers all aspects necessary for a safe flight. Period.
Couple the above with an email I received from Steuart Walton asking, “Do you know people who can help public airports be more public friendly? Our local airport is getting a big FAA-spec fence and I’d like to speak with someone about options for the airport. I’m an avid aerobatic pilot, but I really hate to see airports develop an off-limits feel, particularly to their often public-facing areas.”
Somehow erecting another airport boundary fence fulfills the FAA’s mission to… “provide the safest, most efficient aerospace system in the world.” Furthermore, the vision of the FAA reads, “We strive to reach the next level of safety, efficiency, environmental responsibility, and global leadership. We are accountable to the American public and our stakeholders.” So are pilots and aircraft owners considered stakeholders or are we part of the American public?
I’d like to see if it’s possible to turn back the hands of time. Can you provide specific examples of regulations you feel are unneeded or overly burdensome? Furthermore, tell me WHY with sound reasoning. “Because I don’t like it” doesn’t count. Dust off that FAR/AIM and let the editing commence.
Ben Sclair is publisher of General Aviation News.
