Okay, in an attempt to be productive, I took a moment and submitted a comment via their website.
"This document touches on a wide range of the FAA's concerns, and while I commend its thorough nature, the LHFE subject addresses so many variables as to be difficult to define in the manner set forth by the FAA. Given the variety of operators, aircraft types, performance, and flight profiles, I do not believe that any rule can succinctly cover LHFE and ensure common sense prevails.
My position: I support LHFE exemptions to be granted on a case by case basis. I believe the existing FARs for weather, aerobatics, and observing Flight Manual limitations should be maintained - just as they would be if these flights were not for hire. Allowing passengers access to flight controls under direct supervision of an instructor pilot is reasonable. An exemption for formation, as managed by known organizations such as FAST, should be included. Just as with Experimental Amateur-built aircraft, an initial DAR inspection could be required, a placard displayed for passenger awareness, and then the aircraft released for flight in accordance with its Operating Limitations. Reasonable oversight of these for-hire programs would be expected by the FAA, but there should be no presumption that approved groups and certificated airmen would not operate to their certificate standards/limitations.
In summary, the public desires these flights and there have been, and still are, groups willing to safely provide them. Whether the motivation lies with historical preservation or pure marketing, given our nation's ideals regarding free market and freedom of choice, I see no need to curtail or prohibit these operations. The FAA should Inspect, Approve, and Monitor, but there is no reason to generate an additional layer of restrictions in an attempt to define myriad options when a case-approval method would be more efficient and appropriate within the framework of existing FARs."
If you would like to comment, the web link is:
https://www.federalregister.gov/article ... ducted-forKen