FLIGHT SCHOOLS TO REMAIN OPEN
|As our country works through this challenge, an important factor is continuing the viability of the current and future air transportation system to provide transit of persons and goods as necessary during the emergency and during the recovery. Without continued training and currency of our pilot community, this ability would be hindered. As such, FSANA has sought input and interpretation from legal counsel. |
On March 24, 2020, attorney Gregory Winton, who has previously served as a Senior Attorney for the Federal Aviation Administration and U.S. Department of Justice, and now operates The Aviation Law Firm in Annapolis, MD, provided a memorandum of understanding that was additionally submitted to the Department of Homeland Security’s Cybersecurity and Infrastructure Security Agency (CISA)’s Director, Christopher C. Krebs.
This memorandum affirms the statement that under CISA issued guidance, flight training would be included as a critical infrastructure activity. Those engaged in the provision of and receipt of flight training who work to provide enhanced compliance with CDC recommendations for limiting potential COVID-19 exposure and spread would be considered exempt from travel limitations imposed by local authorities.
The letter begins by noting that, “CISA listed Other Community-Based Government Operations And Essential Functions as follows: Workers who support necessary credentialing, vetting and licensing operations for transportation workers.
The aviation sub-sector stakeholders involved with operation of recreational aircraft and flight schools, who employ Essential Critical Infrastructure Workers from the Transportation Sector, support necessary credentialing, vetting and licensing operations for transportation workers seeking pilot certification by the Federal Aviation Administration. Since CISA intended to be overly inclusive to reflect the diversity of industries, the aviation mode stakeholders understand that essential employees involved with the operation of recreational aircraft and flight schools continue to be identified as Essential Critical Infrastructure Workers from the Transportation Sector. Accordingly, the aviation sub-sector stakeholders who employ Essential Critical Infrastructure Workers from the Transportation Sector will continue to operate recreational aircraft and flight schools, appropriately modified to account for CDC workforce and customer protection guidance, based upon the CISA memorandum dated March 19, 2020.”
This leads FSANA to the position that flight training operations qualify as essential transportation infrastructure during this time and that their customers seeking training continuation are doing so under exemptions from travel restrictions that have been issued in some locales as they work to become certified or maintain their qualifications as pilots for our transportation system.
We are implementing additional measures to keep every one safe and we are following procedures as recommended by the CDC. All our staff are healthy and are asked to stay at home if they feel any symptoms.
Thank you for your continuous support,
RexAir Director and CEO.