Document rOaBM6VmB3wp79Mvzadk8dma

'United *tams *mate WASHINGTON, DC 20510 July 24, 2025 The Honorable Sean Duffy Secretary United States Department of Transportation 1200 New Jersey Avenue, S.E. Washington, D.C. 20590 Dear Secretary Duffy, We write regarding significant concerns with extended minimum crew operations (eMCO) to enable single-pilot flights in commercial aviation. The Federal Aviation Administration (FAA) is charged with ensuring aviation safety as its top priority. Single-pilot operations jeopardize safety procedures, undermine established best practices, and risk putting pilots and passengers in unmanageable situations. We believe FAA should counter single-pilot proposals and help maintain U.S. leadership in aviation safety by vigorously opposing reduced crew efforts at the International Civil Aviation Organization (ICAO). Despite ongoing challenges, the U.S. has long represented the gold standard in international aviation safety. The FAA should continue to promote sound safety standards as new technology develops and presents challenges to existing procedures. While technology will play a critical role in shaping the future of aviation innovation, including improved safety measures, policymakers have a duty to ensure that any changes are rigorously evaluated and incorporated into evidence-backed safety frameworks. The presence of two rested, well-trained, and qualified pilots on the flight deck remains a key pillar of aviation safety. U.S. policy for the composition of flight crew in commercial operations is clear that "No certificate holder may operate an airplane with less than the minimum flight crew" and that "The minimum pilot crew is two pilots."' This policy reflects current research and evidence. NASA and FAA joint studies have observed "significant increases in workload for single pilot operations, compared to two-crew", in addition to decreases in pilots' subjective perception of safety and performance.' It also reflects common sense and the testimonies and experiences of countless pilots. Under eMCO, a single pilot on the flight deck would be responsible for all cruise operations while a second pilot rests in a separate facility. eMCO is intended to push the permissible boundaries of Europe's maximum pilot flight limitations. The European Union Aviation Safety Agency (EASA) is pursuing a regulatory pathway to enable this new operation with the goal of full-time single pilot operation by the end of the decade. EASA's position could stress Code of Federal Regulations. 14 CFR 121.385 Composition of flight crew. https:Pwww.ecfr.gov!current/title14/chapter-1 subchapter-G 'part-121isubpart-M "section-121.385 2 NASA Technical Reports Server. (September 17, 2017). An Assessment of Reduced Crew and Single Pilot Operations in Commercial Transport Aircraft Operations. NASA Technical Reports Server. https:i ntrs.nasa.govicitations 20170009542 OST-2025-1200 Page 01992 Sierra Club v. Dept. of Transp. - 3:25-cv-06221 SC_EVERSPLIT0027873 Page 2 international aviation safety norms, but the L.S. has opportunities to defend its core safety interests. The Aircraft Certification, Safety, and Accountability Act directs the FAA to exercise leadership at ICAO and with international organizations on human factors, increased levels of automation in the cockpit, and the "extent to which cockpit automation introduces novel risks."' Additionally, the U.S.-EU Aviation Safety Agreement provides for regular consultation of aN iation safety proposals or changes and "early-warning discussions of draft regulations."' The FAA should heed this direction, oppose eMCO and related reduced crew efforts at ICAO, and directly engage with European counterparts to ensure that pilot and aircraft standards meet the highest aviation safety bar both domestically and globally. Redundancy, including the protection afforded by two well-trained and qualified pilots on the flight deck, is a key guardrail for the maintenance and promotion of effective global aviation safety standards. Technological advances can capture the imagination and sound compelling in theory, but as pilots recognize, safety standards exist for emergencies and there is no replacement for human talent and judgement. The presence of two pilots is vital not only for the overwhelming majority of occasions on which everything works fine on flights, but for the rare instances when challenges and potential tragedies develop. U.S. inaction on single-pilot issues in international fora could allow global aviation safety standards to wither and place downstream pressure on U.S. safety regulations, manufactures, and air carriers. We urge you to take a strong stand at ICAO and with EASA on maintaining global aircraft design and flight deck redundancy with a minimum of two pilots on the flight deck in FAR 121 operations. We respectfully request a response outlining DOT's position on this critical safety issue and the Department's plan for addressing these concerns at ICAO and with EASA. Sincerely. Tim Sheehy United States Senator Tamm )uckworth United States Senator Public Law 116-260. Section 119 (e) (3). https:, 'www.congress.gov.1116/plaws/pub1260/PLAW-116publ260.pdf Agreement between the United States of America and the European Union on Cooperation in the Regulation of Civil Aviation Safety and its Annexes. Article 3(c)(4) and (c)(5). https:/ Www.faa.govisitesffaa.gov/files/US_EU_safety_agreement.pdfhttps:, 'www.faa.gov'sites/faa.gov.ifiIes/ US_EU_safety_agreement.pdf OST-2025-1200 Page 01993 Sierra Club v. Dept. of Transp. - 3:25-cv-06221 SC_EVERSPLIT0027874 Page 3 Join Hickerilooper United States Senator Jeanne Shaheen United States Senator 1A14 Q. Jeffr . erkley -- United States Senator Patty United ates Senator Kirsten Gill ibrand United States Senator Margaret Wood Hassan United States Senator Ted Budd United States Senator Amy Kit 4 uchar United States Senator Sheldon Whitehouse United States Senator uben Gallego United States Senator Chris Van Hollen United States Senator Ja k eed United States Senator Lisa Murkowski United States Senator .Ikc_WRose United States Senator OST-2025-1200 Page 01994 Sierra Club v. Dept. of Transp. - 3:25-cv-06221 SC_EVERSPLIT0027875 Aary eters United States Senator Catherine Cortez Masto United States Senator /( Tim Kaine United States Senator Ron Wyden United States Senator Roger Marshall, M.D. United States Senator *ad ni K. Ernst tilted States Senator Bernard Sanders United States Senator Page 4 ON Steve Daines United States Senator Martin einrich United States Senator Cory A. Booker United States Senator Elizabeth Warren United States Senator Andy Kim United States Senator Tina Smith SgL United States Senator Richard Blumenthal United States Senator OST-2025-1200 Page 01995 Sierra Club v. Dept. of Transp. - 3:25-cv-06221 SC_EVERSPLIT0027876 Page 5 Raphael Warnock United States Senator Elissa Slotkin United States Senator 7'amt7Zaldwin United States Senator dam B. Schiff United States Senator United States Senator e,i4;44, Susan M. Collins United States Senator )11441/42;tir Shelley Moore Capito United States Senator Edward J. ark United States Senator elly United States Senator Alex Padilla United States Senator Maria Cantwell United States Senator ssoff nited States Senator Dan Sullivan United States Senato Bernie Moreno United States Senator OST-2025-1200 Page 01996 Sierra Club v. Dept. of Transp. - 3:25-cv-06221 SC_EVERSPLIT0027877 Christopher A. Coons United States Senator Page 6 OST-2025-1200 Page 01997 Sierra Club v. Dept. of Transp. - 3:25-cv-06221 SC_EVERSPLIT0027878