Comment from Anonymous
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Summary: The commenter, an insulin-dependent pilot, supports Captain Eric Friedman's Petition for Reconsideration. They argue that the FAA's initial denial was procedurally flawed and that the current special issuance process for insulin-treated individuals is unnecessarily burdensome and bureaucratic.
As an insulin-dependent pilot who has fully complied with all published FAA medical certification guidelines, I strongly support Captain Eric Friedman’s Petition for Reconsideration. The FAA’s denial of his original Petition for Exemption appears not only procedurally flawed but also indicative of a fundamental misunderstanding of the Petition’s purpose and content.
The FAA failed to follow its own established procedures and policies for exemption processing, as outlined in ARM-002-002-WI, and incorrectly classified the Petition as a request for rulemaking rather than an exemption—despite clear, consistent references to the correct regulatory framework. This mischaracterization deprived the Petition of a proper merits-based review and denied the aviation community a critical opportunity to advance regulatory consistency and fairness.
From personal experience, I can attest that the current special issuance process for insulin-treated individuals is excessively burdensome and bureaucratic. Even after meeting all FAA requirements, I must wait for a clerk—unfamiliar with my medical history—to decide whether I am fit to fly. Meanwhile, my Aviation Medical Examiner (AME), who is intimately familiar with my case and has the training and certification to assess my condition, has no authority to make that decision. This delays certification unnecessarily and adds stress and uncertainty for pilots who are otherwise qualified and stable in their condition.
The Petition reasonably proposes a more structured and predictable path forward by seeking exemption from an outdated blanket ban. It deserves to be evaluated on its merits—not dismissed due to procedural error. Reconsideration is both justified and necessary to ensure that affected pilots are treated fairly, efficiently, and in alignment with modern medical understanding.