Warbird Information Exchange

The Honorable Sam Graves
Chairman
House Transportation and
Infrastructure Committee
Washington, DC 20515

The Honorable Garret Graves
Chairman
House Aviation Subcommittee
Washington, D.C. 20515

The Honorable Rick Larsen
Ranking Member
House Transportation and
Infrastructure Committee
Washington, DC 20515

The Honorable Steve Cohen
Ranking Member
House Aviation Subcommittee
Washington DC 20515

February 19, 2024

Dear Chair Graves, Ranking Member Larsen, Chair Graves, and Ranking Member Cohen:

The undersigned organizations represent general aviation pilots, aircraft owners, and small
businesses that safely conduct thousands of local non-stop sightseeing and skydiving flights in
their communities. We write to highlight our concerns that, as currently drafted, Section 315
entitled Air Tour and Sport Parachuting Safety of the Senate’s FAA Reauthorization Act of 2023
(S. 1939) will, if enacted, have significant and insurmountable direct impacts on thousands of
small general aviation businesses and the airports at which they operate.
In July, the House of Representatives passed, with broad bipartisan support, the Securing
Growth and Robust Leadership in American Aviation Act (H.R. 3935) to reauthorize the Federal
Aviation Administration (FAA) for the next five years. We appreciate, that under your
leadership, H.R. 3935 was passed without similar provisions as S. 1939 that would negatively
impact those conducting air tours and sport parachuting operations.

These small businesses safely conduct local flights following FAA regulations and provide an
important commercial stimulus for airports and their surrounding communities through
employment opportunities, fuel sales, and off-airport expenditures at surrounding businesses
including restaurants and hotels. These flights also support the experience and mission of
regional aviation museums that maintain the history while promoting the future of aviation
throughout our country. These flights highlight the positive benefits of general aviation providing
important touchpoints through recreation, tourism, and educational activities between airports
and their surrounding communities. Moreover, our industry's activities promote interest and
opportunities in professional aviation that benefit small businesses, local airports, and our entire
industry.

Section 315 introduces requirements that would be nearly impossible and financially
unattainable for these small businesses, resulting in their likely closure. If adopted, Section 315
would burden the FAA's limited resources with a flood of new certificate applications and the
ongoing costs of administering flight operations under 14 CFR Part 135, diverting resources that
currently oversee commercial point-to-point charter flights and other safety-critical functions.
The FAA has for decades permitted these flights through various regulations and the issuance
of a Letter of Authorization (LOA) under 14 CFR part 91.147. FAA regulations also address
pilot, aircraft, and operational qualifications for these types of activities. Additionally, these
operators will fall under the FAA’s requirements for the implementation of Safety Management
Systems which further enhances a robust safety culture.

As safety is paramount to ensuring a thriving aviation industry, our organizations would
welcome the opportunity to work with the FAA and Congress to address specific concerns as
they arise.

In closing, our organizations have deep concerns that the proposed requirements, if enacted,
are not scalable and do not support a data-driven approach to enhancing safety for these
segments of general aviation. They will result in the closure of small aviation businesses without
improving safety, and they will deprive the FAA of the resources and manpower needed to
address priority issues. We respectfully request that the Senate’s Section 315 provisions be
omitted from any final FAA Reauthorization bill.
Thank you for your attention and support.

Collectively,

Aircraft Owners and Pilot Association

Experimental Aircraft Association

Commemorative Air Force

National Warbird Operators Conference

Parachute Industry Association

Professional Warbird Operators Association

United States Parachute Association

EAA Warbirds of America

I am only in my 20s but someday I will fly it at airshows. I am getting rich really fast writing software and so I can afford to do really stupid things like put all my money into warbirds.