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ALPA [[image: line drawing of a globe]]

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AIR LINE PILOTS ASSOCIATION
55TH STREET & CICERO AVENUE
CHICAGO, ILLINOIS 60438
PORTSMOUTH 7 - 1400

AFFILIATED WITH A.F.L. - C.I.O.
INT'L [[/right margin]]

April 29, 1968

General William F. McKee, Administrator
Federal Aviation Administration
800 Independence Avenue S.W.
Washington, D.C.

Re: Regulatory Docket No. 8783

Dear General McKee:

The Denial of Exemption by your Administration Regulatory Docket No. 8783, dated April 23, 1968, and bearing the signature of James F. Rudolph, Director, Flight Standards Service, has been received by this Association.

The Association is deeply troubled by FAA's disposition of this and other applications addressed to Section 121.383(C), the "Age 60" provision of the Federal Aviation Regulations. We have particular concern for the swift and summary fashion in which such applications have, in every case, been dismissed notwithstanding the plain indications, made time and time again, that a principal object of such applications is the development of a full and complete public evidentiary record on which a reasoned decision can fairly be based.

As you know, no opportunity has ever been made available so that all of the relevant evidence bearing on the age 60 limitation might be fully heard and resolved. Indeed, though an informal conference with FAA was sought prior to a decision on the current Petition, not even that element of procedural courtesy and fairness was satisfied on this occasion. Our concern with the procedures followed here is rooted not only in the age 60 problem; we are equally disturbed that such procedures may reflect a failure to recognize that our joint responsibilities to our Nation's air transportation system and to those whom we represent require a far greater degree of willingness to receive and consider factual evidence than has been demonstrated in this proceeding.

It continues to be the firm view of this Association that the Petition which has been denied raises serious and troublesome issues which fully deserve our joint effort to insure that they are heard and resolved in a public forum without further delay.  Equally nec-

"SCHEDULE WITH SAFETY"