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Captain Harry Orlady

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should, therefore, be thoroughly reviewed now, and the result should be, if not that the age 60 rule is operationally invalid in any environment, that, at the very least it should be applied with selectivity and care, based upon its relevance in particular circumstances.

As a result of our several talks on March 8-10, as we revised the petition, I came to believe that the revised petition was supportable, or at least I strongly arguable, principally because of the confidence which I understood you to express in the validity of these two fundamental propositions.

We did consider, at that time, the desirability of having available a completed operational study when this matter comes before FAA for decision, but we also recognized that, because of the timing of this effort, we would probably have to face the FAA without such assistance. As a result of our discussions, it was my view that

(1) we could, in an FAA hearing, develop a means of placing on the record the same evidence which had apparently convinced you that our confidence in the operational validity of our position was sound; possibly, this might involve the creation of our own study, or study group, using an interdisciplinary approach, specifically in contemplation of and in preparation for the FAA hearing. This approach has never been used before;

(2) if we are all convicted of the correctness of the Association's position on the ultimate issue, which I assume to be the case, and thus if our concern is addressed primarily to the problem of producing hard evidence to support that position on a public record, I would make the further assumption that it would not be deemed offensive to utilize such advantages as advocacy may provide, to their fullest possible extent, and as in any other matter involving litigation, to place our position in the most favorable possible light, and as well to reduce the effectiveness, to the extent possible, of the position of our adversaries. Conceivably, this might result in certain advantages which might not be present in the pure, scholarly approach.

I fully agree with your observation that it would have been preferable to devote more Committee time to a study of this new approach, particularly with respect to its effects upon other related and pending programs. I am also in agreement that this subject deserves serious interdisciplinary study.

It was also, however, the intention of the Committee, as I understand it, to address itself to the practical problem of extending the greatest possible protection to the greatest number of affected pilots, and this factor seemed to warrant the promptest possible action on a broad scale. Based upon past experience and on anticipated FAA action, it seemed unlikely that the continued filing of individual exemption petition would do much more than to feed age 60 pilots into the meat grinder, one by one,