EAA Declines FAA Exemption for Young Eagles, Eagle Flights Pilots
October 10, 2013 - EAA has notified the FAA that it is declining a partial grant of exemption that would have allowed Young Eagles and Eagle Flights pilots to obtain reimbursement for fuel costs and logging of flight time. While EAA welcomed the time the agency spent considering and formulating the partial exemption, its mandated record-keeping, coordination, and notification requirements would cause complete restructuring of the program with enormous time and expense burdens.
Sean Elliott, EAA's vice president of advocacy and safety, stated in a letter to John S. Duncan, FAA director of Flight Standards Service, that, "EAA sincerely appreciates the substantial efforts of the FAA in reviewing, publishing for comment, analyzing, and finally granting an exemption in response to EAA's petition dated April 17, 2012. Unfortunately, EAA is unable to accept the exemption because of the severe requirements imposed by the FAA grant."
The FAA's Partial Grant of Exemption 10841 would require EAA to maintain a record of all fuel disbursements under the exemption. The partial exemption would also require notification of all flight operations to the local Flight Standards District Office (FSDO) in advance and provide a copy of the exemption to that FSDO no less than 72 hours prior to each event. Such requirements would end the ability for Young Eagles and Eagle Flights programs to operate in a decentralized and autonomous manner as is now done.
"Meeting this requirement would literally be impossible for EAA without a total restructure of the EF/YE programs and an unaffordable and questionable investment of assets in a brand new chapter monitoring, data gathering, and approval system," Elliott wrote.
EAA also finds other aspects of the exemption requirements to be problematic, such as the prohibition on pilots of amateur-built aircraft from claiming the reimbursement even if they met all other requirements.
"EAA believes that the program conversion that would be required to meet the FAA's record-keeping, coordination, and notification requirements would be unaffordable, disruptive, and counterproductive," Elliott added. "Therefore, EAA regretfully will not exercise the privileges of exemption 10841, and does not intend to renew it."