Comment from Eric Boyken
Eric BoykenSupportIndividual
Summary: The commenter, a former pilot with type 1 diabetes, supports the petition for reconsideration of the FAA's special issuance criteria for insulin-treated diabetes mellitus. They argue that the current requirements are unnecessarily burdensome and outdated, noting that the administrative hurdles led them to give up their pilot certificate.
I am submitting this comment as a former third class medical certificate holder with type 1 diabetes, in strong support of the petition for reconsideration regarding the FAA’s special issuance criteria for insulin-treated diabetes mellitus.
The current FAA protocol governing special issuance for insulin-treated diabetes is unnecessarily burdensome, inefficient, and misaligned with both current medical evidence and the FAA’s stated principles of risk-based oversight. The requirements imposed—including redundant, excessive, and often duplicative data collection—do not reflect the safety record or advancements in continuous glucose monitoring (CGM) and insulin pump technology. As a direct result of these inefficiencies, I made the difficult decision to forgo further renewals of my certificate. The administrative burden and recurring cost imposed by the special issuance process outweighed the practical opportunity to remain active as a private pilot. More significantly, it discouraged me from pursuing a professional aviation career, despite the absence of any medical incident history and the availability of modern management tools that provide real-time glycemic data far exceeding historical norms.
The petition for reconsideration appropriately highlights factual inaccuracies in the FAA’s denial of the original petition. I respectfully urge the FAA to grant the petition for reconsideration and adopt a modernized, specific, and risk-appropriate special issuance framework for type 1 diabetic pilots, grounded in both fairness and the demonstrated safety record of this population.
Thank you for your consideration.