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Comment-helper templates

Skeletons for comments
FAA rule writers actually read.

Comments aren't votes. The FAA isn't tallying "I agree" vs. "I disagree" — they're reading for substantive analysis. These templates structure your comment so it lands as analysis, not noise. We do not pre-fill opinions. You write the substance.

What makes a comment count

  • ·Cite the specific paragraph of the proposed rule you're addressing. "Paragraph (b)(2) of proposed § 91.227" beats "this rule" by orders of magnitude.
  • ·Propose an alternative. "Disagree" gets categorized "concern noted" and discarded. "Disagree, and here's an alternative that meets the agency's stated safety objective" gets engaged.
  • ·State your standing. Who you are and why your view counts in the agency's calculus. Pilots, mechanics, operators, owners, individuals affected.
  • ·Keep it under one page. Rule writers read hundreds of comments. Concision is courteous.
  • ·Don't copy/paste. The agency identifies form-letter comments and treats them as one signature. Originality is your leverage.

Private pilot

When a rule changes pilot certification, currency, medical, or operating privileges (Part 61, 67, 91, 141).

My name is [your name]. I am a private pilot based in [city, state] with [N] hours of flight time. I [agree / disagree / partially agree] with the proposed rule [Doc #] for the following reasons:

1. [Specific point — cite the paragraph or proposed § that concerns you]
   Why: [practical effect on you, your operation, or your training]

2. [Second specific point]
   Why: [...]

3. [Third specific point]
   Why: [...]

I propose the FAA consider [specific alternative]. This would [achieve the agency's stated objective] while [reducing X burden / increasing Y safety / preserving Z]).

[Optional: 1-2 sentences of personal context — what you fly, where, what kind of operation.]

Respectfully submitted,
[Name, certificate number, contact]

Commercial / ATP

When a rule changes commercial ops, training, scheduling, or 121/135 certification.

My name is [your name]. I hold an [ATP / Commercial] certificate ([number]) and currently fly [type] under 14 CFR Part [121 / 135 / 91 subpart F]. I have [N] total hours, [N] in type.

The proposed rule [Doc #] [specifically: paragraph X] would [describe the operational change, in your own words].

My analysis:
1. [Operational impact — schedule, training, dispatch, equipage]
2. [Safety case — does this raise or lower risk based on your experience?]
3. [Cost-benefit observation — what your operator already does vs. what the rule mandates]

I [support / oppose / partially support] [paragraph X] because [reason]. The agency's stated objective of [X] could be better achieved by [alternative].

Respectfully,
[Name, certificate number, employer (optional), contact]

A&P / IA mechanic

Maintenance, repair-station, ADs, parts (Part 39, 43, 65, 145).

My name is [your name]. I hold an A&P certificate ([number]) [and IA authorization]. I work at [type of operation: GA shop / Part 145 / airline / OEM] performing [airframe / powerplant / avionics / structures] maintenance.

The proposed rule [Doc #] [paragraph X] would change [describe in plain English what the rule changes about a procedure you perform].

In practice, the change would mean:
1. [What's different in the workflow / paperwork / inspection]
2. [What it costs — labor hours, materials, downtime]
3. [Whether it actually improves the safety case it claims to address]

[Specific recommendation:] The FAA should [keep / modify / drop] paragraph X because [reason from the floor / shop / hangar]. An alternative that meets the safety objective: [specific alternative].

Respectfully,
[Name, certificate number, contact]

School / training operation

Part 141 / 142 / 147 schools, university aviation programs.

My name is [your name]. I am the [chief instructor / DOT / owner] at [school name], a Part [141 / 142 / 147] [flight school / training center / AMT institution] in [city, state]. We train [N] students per year and operate [N] aircraft.

The proposed rule [Doc #] would [describe the change as it lands on a working school].

Operational impact at our school:
1. [Curriculum / syllabus impact — what changes for students]
2. [Cost impact — equipment, instructor pay, fleet]
3. [Throughput impact — does this slow or speed up checkride-ready timing]
4. [Quality / safety impact — does this measurably improve outcomes]

Recommendation: [specific change to the proposed rule].

Respectfully,
[Name, role, school name, contact]

Aircraft owner

Registration, airworthiness, modifications, ADs (Part 21, 23, 25, 39, 43, 47).

My name is [your name]. I own [N-number, make, model, year] based at [airport]. I [self-maintain under 43.3(g) / use a shop / have a Part 145 service center].

The proposed rule [Doc #] [paragraph X] would affect my aircraft as follows: [in your own words, what the rule means for your tail].

1. [Cost: estimated $ to comply]
2. [Schedule: estimated hours / days of downtime]
3. [Mission impact: what flights become harder, easier, or impossible]

I [support / oppose / partially support] this rule because [reason rooted in your specific operation]. An alternative the FAA should consider: [specific alternative].

Respectfully,
[Name, N-number, contact]

UAS operator

Part 107, BVLOS, remote ID, drone operations.

My name is [your name]. I hold a Part 107 Remote Pilot certificate and operate [type / N drones] for [hobbyist / commercial / public-safety / agricultural / inspection] purposes. I fly approximately [N hours / N flights] per year.

The proposed rule [Doc #] [paragraph X] would [describe the change in operational terms].

Specific concerns / observations:
1. [Effect on your specific operation type]
2. [Cost / equipment compliance reality — can existing fleets meet this without retrofitting?]
3. [Safety case — does this measurably reduce risk in your experience?]
4. [Privacy / regulatory boundary — federal vs. state / local overlap]

Recommendation: [specific alternative that achieves the agency's safety + airspace integration objectives].

Respectfully,
[Name, Part 107 cert #, contact]

Individual citizen affected (no certificate)

When a rule affects you as a passenger, neighbor, or general public — TFRs, environmental, noise, security.

My name is [your name]. I am a [resident / passenger / business owner] in [city, state] writing about proposed rule [Doc #].

This rule affects me as follows: [how you encounter it — a frequent flyer, an airport-adjacent resident, a small-business owner whose operations depend on aviation, etc.].

My specific concerns:
1. [Concrete observation — not "I disagree" but a specific scenario]
2. [Second observation]

I [support / oppose / partially support] this rule because [reason rooted in your direct experience]. I would suggest [specific alternative or modification].

[Optional: 1 sentence about your standing / interest.]

Respectfully,
[Name, city/state, contact]

When you're ready

Pick a rule from the open-comments list, copy the template that fits, fill in the [bracketed] sections, and click "File comment" on the rule's page. Or read the step-by-step regulations.gov walkthrough if you've never filed before.