Comment from Anonymous

I strongly support this petition for exemption. Petitioner explained in his petition why a grant is in the public interest and will increase aviation safety. The petition was filed on November 4, 2024, so it is now over one year old. This is well beyond normal exemption processing timelines for the FAA. And petitioner has not requested any novel relief. Instead, he has asked the FAA to formalize, standardize and stabilize the relief it is already providing, albeit via a variable and unstable discretionary issuance process. In addition, Petitioner has asked to comply with the rule governing medical certificate durations (14 CFR section 61.23(d)) which is applicable to all medical certificates. Compliance with an applicable rule is reasonable and can be presumed to be in the public interest and in the service of aviation safety. A response to the petition is overdue. I ask the FAA to complete the processing of the petition and to expeditiously issue it as requested by petitioner. Other FAA offices provide the public clear eligibility standards for the licenses they issue, For example, the Flight Standards Service (AFS) has published Airman Certification Standards (ACS) which are incorporated by reference into 14 CFR part 61. These ACS documents provide applicants for pilot certificates the regulatory certainty to which they are entitled, in advance of their applying for a license covered by an ACS. The FAA's Office of Aerospace Medicine (AAM), by contrast, controls the issuance of medical certificates to insulin treated applicants through an unofficial, informal, and non-regulatory policy document called the Guide for Aviation Medical Examiners (GAME). AAM changes the GAME requirements without public notice, and worse, deviates from its own guidance apparently at will and without explanation. Petitioner's request to formalize and stabilize AAM's insulin treated eligibility requirements through a formal grant of exemption is reasonable. It is also consistent with the way other parts of the FAA (such as AFS) formally publish and make publicly available the eligibility standards for licenses. Issuing the requested exemption is also consistent with the way other Department of Transportation agencies currently operate. The Federal Motor Carrier Safety Administration (FMCSA) medically certifies interstate truck drivers. These operators drive large, heavy vehicles at high speeds on public roadways without human backup (unlike professional pilots, who always operate with another fully trained and qualified person). FMCSA previously had a regulatory blanket ban on medically certifying interstate truck drivers. When FMCSA abandoned this blanket ban, it did so via individual grants of regulatory exemption. Eventually, in light of the administrative overhead involved in individual exemptions, FMCSA incorporated all of its insulin treated requirements into its applicable rule. FAA should take the first step in intermodal consistency by issuing the requested exemption. Petitioner did not ask the FAA to engage in rulemaking, simply to take the first step consistent with the highly successful path followed by FMCSA. Consistency between Department of Transportation "modes" or agencies makes administrative sense. It's time for the FAA to issue this exemption as an important step towards eliminating its variable discretionary issuance process, which imposes steep public administrative burden and simultaneously detracting from public safety. Issuing the requested exemption will benefit the public as a whole, not just petitioner (as petitioner explains in detail in his petition) and is also in the interest of aviation safety. Further delay is both unreasonable and harmful to the public interest. Petitioner's request to comply with the applicable medical certificate durations is also reasonable. Please issue the requested petition immediately and include in it a return to the durations specified at section 61.23(d).