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obligation requires the extension of a public opportunity for a full and fair review of the basis for the age 60 rule.

22. In 1959, FAA recognized not only the arbitrary nature of the cutoff at age 60; it also recognized that there was need for the development of a reasoned and logically supportable criterion for the desired objective, and that the arbitrary use of chronological age as a basis for the limitation was intended primarily as an interim measure pending such development. What began as a temporary provision seems somehow to have evolved into the permanent standard.

23. When the age 60 rule was formulated in 1959, some 35 pilots were, according to the Administrator's affidavit, immediately affected by it. Indeed, ALPA's records show that, shortly prior to the 1959 action, only some 315 pilots out of ALPA's total membership fell within the age 50-59 category. However, a significant change has, since 1959, overtaken the normal age distribution of airline pilots. ALPA records show more than 2200 pilots in that age group in 1967, with a projected increase to nearly 6000 in the 50-59 age group