Comment from James DeNoyer

I strongly urge the FAA to grant this exception. The process to obtain and maintain a medical certificate as an individual with Insulin Controlled Type I or Type II Diabetes Mellitus is overly burdensome and cumbersome. It takes a new diabetic a minimum of 6 months of being a diabetic to even be considered (possibly 12 months depending on how the GAME is interpreted) along with however long the AAM takes to make a decision. The initial and renewal of a medical certificate through the special issuance process exposes a diabetic to standards that are not communicated and are arbitrarily decided. This opens the individual to many unstandardized reasons for deferral or denial, including reasons not related to diabetes. These reasons can cause the AAM to act like doctors, requiring multiple medical appointments from specialists that the individual does not normally see and their primary care did not deem necessary. After the AAM has decided that this is necessary, and likely with only a month left before the individual’s medical certificate “drops dead” because of the imposed “Not valid for any class after” date, the individual must now obtain a referral from their primary care physician, allow insurance to process that referral, obtain a new patient appointment from the required specialist(s), resubmit whatever paperwork AAM deems necessary through mail, wait on AAM to make a decision, then if approved, make an appointment with an Aviation Medical Examiner to issue the medical be able to legally fly again. This lengthy process makes it likely that the individual will not be able to work because the medical will expire from the “drop dead” date. It creates great amounts of stress not knowing whether a special issuance applicant will be able to continue to work and provide for his or her family because they cannot know if the medical will be approved or denied, knowing that they meet or exceed the communicated standard because the AAM can choose to defer or deny based on uncommunicated standards (if they are standards at all). The aviation community has a phenomenal track record for diabetic pilots operating aircraft safely, and diabetic pilots should be able to obtain a medical certificate as routinely as non-diabetic pilots.