Aircraft Owners and Pilots Association Comments - 10.16.19

Sep 19, 2026

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Comments submission to the FAA on docket 2019-0599 concerning requests for comments and clearance of renewed approval for information collection related to FAA medical standards and certification. The Aircraft Owners and Pilots Association argues Form 8500-8 was materially revised without adequate notice, expands information collection scope, and introduces confusing “additional instruction” text boxes that conflict with regulations and GAO recommendations. AOPA also cites inaccuracies in burden estimates and ongoing member issues: applicant confusion, AME deferrals to FAA Aerospace Medicine, and extended processing times.

LanguageEnglish

CategoryLetters

FormatPDF

Pages12

Reading Time4 min

AccessFree to download

Background and purpose

Notice and Form 8500-8 revisions

Deficiencies and impacts on applicants

October 15, 2019 BY ELECTRONIC DOCKET ONLY Nicole Harrison Federal Aviation Administration, AAM-120 800 Independence Ave. SW Washington, DC 20591 Re: Docket Number 2019-0599, Agency Information Collection Activities: Requests for Comments; Clearance of Renewed Approval of Information Collection: Medical Standards and Certification To Whom It May Concern: The Aircraft Owners and Pilots Association (AOPA) submits the following comments regarding the notice and request for comments about the FAA’s intention to request Office of Management and Budget approval to “renew” an information collection involving information applicants must provide on an application for an FAA medical certificate. Our members collectively operate over 85% of all general aviation aircraft in the United States and represent two-thirds of all pilots, making AOPA the largest civil aviation organization in the world. More than 66,000 members of AOPA also participate in our Pilot Protection Services, which includes additional medical certification assistance as well as the AOPA Legal Services Plan. Our comments are as follows, and all text in italics is text from the Form 8500-8 and accompanying instructions: First, the Federal Register notification indicates this Docket Number to be a “Renewed Approval of Information Collection.” This is erroneous, as the FAA has materially revised Form 8500-8 since it was last approved by the Office of Management and Budget. The revisions significantly expanded the information collected by Form 8500-8 and, inappropriately, the purported scope and impact of the 14 CFR Part 67 regulations underlying the Form 8500-8. The FAA also did not provide screenshots of the online Form 8500-8 and drop down menus with docket materials [through Regulations.gov](through Regulations.gov) or the Federal Register. The FAA’s revisions added approximately 856 words to Form 8500-8 by including twenty new “additional instruction” text boxes which define words contrary to their plain meaning and provide confusing and misleading examples to be referenced by airmen which list conditions that are not listed as disqualifying conditions in Part 67 of the Federal Aviation Regulations. The June 22, 2015 and September 16, 2015 Notice and Request for Comments in the Federal Register concerning Form 8500-8 were both silent as to these changes. The revisions also contradict the recommendations contained in the Government Accountability Office’s April 2014 Report to Congressional Committees, number GAO-14-330, titled “FAA Should Improve Usability of its Online Application System and Clarity of the Pilot’s Medical Form”. Second, the FAA has failed with respect to the Form 8500-8 information collection on all counts. There are consistent issues highlighted in thousands of calls AOPA has received from its members related to medical application questions and deferrals by AMEs to the Office of Aerospace Medicine for a final determination, as discussed more detail below Disturbingly, (a) the scope of the information collection is not necessary for the FAA’s performance required under Federal Aviation Regulations addressing medical certification, (b) the estimated average burden per response of 1.5 hours is grossly inaccurate by an order of magnitude,(c) the FAA has been apprised of ways to enhance the quality, utility and clarity of the information collection since before 2014 but has failed to make improvements, and (d) the burden could be minimized without reducing the quality of the collected information by following recommendations from a 2014 GAO report discussed below and properly soliciting industry comments. Clarity of Form 8500-8 and consistency with the Federal Aviation Regulations applicable to medical certification are desperately needed to enhance the quality, utility and clarity of medical information collection, as well as to minimize burdens on applicants and the FAA. The FAA appears to have materially changed its criteria for medica

FAQs

What is AOPA commenting on regarding FAA medical certification?

AOPA submits comments on the FAA’s request for comments and renewal approval related to information applicants must provide for an FAA medical certificate, tied to Docket 2019-0599.

Why does AOPA say the “renewed approval” notice is erroneous?

AOPA argues the FAA materially revised Form 8500-8 since the last OMB approval, expanding collected information and changing how it addresses the scope and impact of 14 CFR Part 67 regulations.

What operational problems does AOPA associate with the Form 8500-8 changes?

AOPA reports applicant confusion and alleges enforcement actions in some cases, AMEs defer certificate decisions to FAA, and processing times increase for applications deferred to the Office of Aerospace Medicine.

Sep 19, 2026

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