New FAA Interpretation Threatens BizAv; Civilian Rescue Teams and Feds Feud

Jessie Naor (00:00)

Alright, good morning and welcome to the VIP seat. Today is October 10th and our top stories in aviation this week include a new rule for mechanics that could be devastating to the industry and the feud between federal regulators and civilian rescuers in the aftermath of Helene. Your hosts today include yours truly,

and our guest Delray. Delray Dobbins, thank you for joining us today.

Delray Dobbins (00:21)

Jessie, thanks so much for having me. I'm looking forward to this.

Jessie Naor (00:24)

Gonna be fun. All right, folks, sit back, buckle up, and let's take off.

Alright Delray, so before we roll into our first story today, a lot of folks know you from your Rolls Royce and Pratt & Whitney days, but I heard that you have an announcement to make this morning.

Delray Dobbins (00:46)

I do, Jessie. I was

a lot of people know me from the Pratt & Whitney. I did Global Strategy for the ESP program for the last six years. Starting today, I've taken a new role with Engine Assurance Plan based out of Dallas as a director of Global Strategy. And for those of you that may not be familiar with Engine Assurance Plan, they are a pay-per-hour program provider that specifically focuses on out-of-production aircraft and engines.

Jessie Naor (01:04)

.

Delray Dobbins (01:13)

When COVID came along, a lot of those aircraft that were long in the tooth that were probably close to getting parted out suddenly got a new lease on life. And so our niche is focusing all of our experience and resources on keeping older aircraft flying through a cost effective value pay per hour program, including our own lease engine

Jessie Naor (01:36)

That's fantastic. Well, mean, yeah, definitely keeping those assets alive longer and is used as long as we can. That's a great mission and certainly a challenge. So one that I'm sure you'll meet.

Delray Dobbins (01:46)

Absolutely.

Jessie Naor (01:48)

All right, so our first story we've got

Textron, a few years ago, actually back in 2021, their Bell helicopter division had announced an eVTOL concept. It was supposed to be a hybrid propulsion, Safran was working on the engines, Nexus was the name of the concept aircraft. So this week they have announced they're actually gonna be doing test flights starting next year, which is exciting, but I'm slightly disappointed because it's not gonna be a hybrid anymore, and I really

understand.

They've taken Bell kind of out of the marketing when I thought, you know, Bell was really just such a great thing to embrace because it's got such a great history of being a helicopter company. You know, was it a mistake. Obviously, I Textron's going to be successful, but what's your take on it?

Delray Dobbins (02:31)

Well, mean, Textron has a history of bringing great products to

You know, they're about to launch their Citation Ascend as our next generation XLS line. So it does beg a few questions when you have a company under your umbrella like Bell that has a great history of bringing rotorcraft to market and vertical takeoff and landing.

being almost an expert in that space, why would you not leverage that branding for this next evolution of vertical takeoff aircraft? Great question.

don't know the answer but it sure and you know what maybe when they decided to change their minds and show up at NBAA here in a few weeks maybe it will become

maybe they'll show us something that's why but yeah it's it certainly begs the question

Jessie Naor (03:21)

Yeah, and I was, know, we've watched this whole eVTOL space, you know, start to open up, start to begin commercialization. And my thought originally, and maybe it's just because the world that I come from, but

I thought if anyone's going to do this well, it's going to be someone who has the background. So coming from a helicopter operation, a very strong, diverse fleet operator or builder like Textron or Embraer, I feel like they're going to have kind of the best chance at a good product going to market. So I'm excited to see it and I'm curious, but I definitely am also disappointed that it's not a hybrid because it's like no one seems to be pursuing hybrid propulsion in a world where battery...

just isn't that great yet.

Delray Dobbins (04:01)

Maybe, maybe the, maybe Textron has found the magic solution for the battery technology. mean, most of the trade show articles and industry articles in the last five years have all focused on the limiting factor is battery technology. I mean, you look at Joby. Embraer did several conceptual videos a couple of years ago at CJI Miami with Michael Amalfitano And they know they were looking heavily into that space.

So yeah, I take your point. The company that's going to be the most likely successful in that space is going to have to have a lot of well-funded backing. And most likely, that's going to be a Textron or an Embraer or a Bell. Joby startup, I'm optimistic for them. But it's still early.

Jessie Naor (04:36)

Yeah.

It's very early. So, well, we'll keep our eyes out. I do think, you know, if anyone, if anyone has the chance, and I'm a big lover of the Bell product, I think a helicopter company or a company that owns a helicopter company has got some definite competitive advantages over the newcomers to the space. But we shall see.

Delray Dobbins (05:08)

Well, I think you've probably written in a few Bell products over the years, haven't you?

Jessie Naor (05:14)

I do. I am a self-professed Bell 407 enthusiast and you can't convince me that there's any better helicopter out there.

Delray Dobbins (05:22)

Awesome.

Jessie Naor (05:23)

So another news this morning, I found the tweets quite interesting between Elon Musk and Pete Buttigieg. And man, I just mentioned Elon Musk on this show last week. I just like, he's always in the news, in our news for some reason. But he's highlighting that there is some frustration right now in Western North Carolina and Tennessee and the Helene aftermath.

Delray Dobbins (05:36)

Ha

Jessie Naor (05:44)

Everyone has seen on the news how helicopter companies and private jet operators have just gone en masse to support efforts down there. But that has also created some frustration on the FAA side and some others because they've had 30 near misses in the last week. But at the same time, a lot of locals have been complaining and my dad is a local, so this is

area that I kind of know what's going on right now.

that honestly the government wasn't really there after the first week of the disaster response. So because those civilian missions came in and helped them, they really saved a lot of lives. And now people are complaining, well, the government's blocking us from continuing our work. So it's a tricky situation. I get the safety aspect of it, but Delray, if you were in charge, how would you manage this chaos?

Delray Dobbins (06:33)

Well, this is what happened with Helene and it's a little bit unprecedented because there was so much damage so far inland. And so when a hurricane comes, it's normal for the utilities and the certain agencies to prep closer to the coastline.

But this is not the first natural

by any means. And so the government and FEMA should be used to, after decades of general aviation, arriving in force, how can we help? This should not be a surprise to the government or FEMA. And so they really, I fault them a little bit for not being able to streamline.

Here's all the resources. Clearly, by the people in need, you need these resources. Figure out a way to embrace the resources instead of threatening to arrest a pilot for flying his helicopter into this area. OK, yeah. One of my favorite phrases is, don't tell me no, just tell me how.

And because the alternative is telling me no, that's right up there with, that's the way we've always done it, which is one of the worst answers ever.

Jessie Naor (07:34)

That's a good one. Yeah.

Yeah. Right. Yeah, and a lot of the complaints right now is that, you know, they've put in a prior permission request for Asheville Airport, which was one of the biggest that were affected, that has to go through FEMA.

Delray Dobbins (07:44)

So don't tell me no, tell me how. Don't threaten to arrest the guy. Just say, hey, do here, do this, follow this process for safety. But don't turn away people who show up with private aircraft who want to take time out of their life to help.

Jessie Naor (08:09)

but the time to get a FEMA approval to actually get it to the airport is taking forever. So a lot of these operations that were really nimble and moving fast and helping are now constrained. And Elon's tweet to, or he didn't tweet it to Pete Buttigieg, but he did tweet, you know, he was concerned that it was going to slow down the distribution of Starlink because there are communities that still don't have cell service. So they can't even coordinate with the locals on the ground because they can't reach them. So.

It's this really weird moment where it's like, there's an obvious need to help and the regulators want to also ensure safety, but it doesn't, it's not really conducive to actually making a difference. So I don't know. I'm like, let 'em go. That's what airspace is for. That's why we have rules that we have. That's why we have air traffic control. See and avoid if you're taking the risk out there to fly VFR as a helicopter operator, you you should take that on.

Delray Dobbins (09:03)

Well, go back to technology. Most aircraft running around, I know the aircraft I fly, I have ADS-B in. I can see almost everything around me. so the safety, technology allowed a higher degree of safety than we had 10 years ago in these natural disaster spaces.

Jessie Naor (09:22)

Right. Let the aircraft do what they're supposed to do. Now, there was also a pretty strong warning for the drone operators, you know, don't operate drones in these spaces. That one I'll give you. You know, they don't have the same safety technology and abilities. They do offer some serious visual support and help. But as someone who's been in helicopters and seen a drone come up along the way, like, makes me a little uncomfortable.

Delray Dobbins (09:37)

They don't.

Yeah, that's not cool.

Jessie Naor (09:48)

Yeah, no. So lots of regs if people are considering going down there to help pay attention to the TFRs that are changing all the time. Again, there's a lot of PPRs now at all these different airports. And I'm sure we're going to see the same thing now with Milton coming through. It's cool to see people come together. And I think it's like we've never seen before just the combination of technology and the internet. We spoke about it a little bit last week in the podcast, but definitely.

Our industry has saved lives the last couple of weeks and they'll continue to do so.

All right, so I was listening to a podcast last night that went in depth to this and I sent it to you, Delray, but I think, and I'll post it in the show notes too so people can listen to it later if they really want a deep dive on this, but we have a new FAA interpretation for mechanics that is really gonna be threatening the industry in a serious, serious way. And I've

some people talk about it, but I don't think it's getting enough news at this point. But Delray, do you wanna go ahead and give us a...

What's going on? Why is it a big issue? And what should we be doing about it?

Delray Dobbins (10:51)

Yeah, so this is

upended the aviation maintenance side of the house. So as I understand it, the manager of the FSDO, Flight Safety District's office in Little Rock.

gentleman by the name of Mr. Moss, requested an interpretation from the FAA lawyers regarding how a certificated A&P mechanic supervises the work of another non-certificated person doing maintenance. It doesn't matter what the maintenance is, but the FAA 43.13d basically says that a certificated mechanic can supervise another person

Jessie Naor (11:15)

you okay?

Delray Dobbins (11:34)

who's not certificated to do maintenance work, up to the point that the certificated mechanic is licensed to do. So it's almost like a force multiplier here. And there's a key phrase in that FAA regulation that says the supervision to take place is necessary to the extent to make sure the work is done correctly. That's been the standard for 60 years.

And this affects, there's so many MR&O facilities around the country that do internship programs using this certificated mechanic, supervising non-certificated mechanics. It's how a lot of people become A&P mechanics.

the interpretation came back about two years later. I'm not sure quite sure why it took two years, but okay, we'll let that one go. The ruling said,

Jessie Naor (12:19)

Okay.

Delray Dobbins (12:27)

that the certificated mechanic has to be present. And this cannot be via Zoom or Teams. It can't be via video. You've got to be present in the space. OK, so we got a 60-year regulation here. And now they're weighing in on the presence of new

Jessie Naor (12:38)

We're at phone call.

Delray Dobbins (12:46)

No, you can't use technology to be present, which I find interesting because doctors can do surgeries remotely using robotics.

If that's not safety of life, I don't know what is. But you can't use it for the purpose of doing aircraft maintenance. Where the real rub becomes is they didn't stop there. They went further and said, not only can you not remote in via Zoom, you must be present 100 % of the time while the non-certificated mechanic is doing the work. So let's think about this.

Jessie Naor (13:20)

So let's see.

Delray Dobbins (13:23)

You take a fuel control off of a, I don't know, fuel control off of a PT6 off a King Air. Maybe it takes an hour and a half to remove the fuel

Maybe it takes five hours to install and rig the fuel control. Following this latest interpretation, the certificated mechanic has to sit there 100 % of the time where you're doing the removal.

heat give you off. mean, the removal is not the critical phase. And so the 60-year regulation that's been a force multiplier and let a certificated mechanic supervise multiple interns, this has the ability to really cripple the future pipeline of A&P mechanics. There was a industry.

Jessie Naor (13:50)

Right. Well, even crippling shops today.

Delray Dobbins (14:13)

Well, you know, probably one of the words that has driven the most fatigue in this

is the word supply chain. We've heard that word so much in the last five years. And I think I don't think it's interpreted in the right way. Because when people say the word supply chain, I see the look on people's faces, and they think engines and fuel controls and parts and tires and brakes. The implications is much broader than just the hardware.

It's the talent. It's the people. It's the labor force. And so the supply chain, the shortage and the labor force was predicted in a industry article back in 2017 that said we would need something like 48,000 mechanics by 2027. The shortage starts in 2022, and it peaks in 2027. That was per an article in 2017. But now there was a bit of reprieve because COVID occurred in early 2020.

and everything kind of dropped off.

So the initial impact wasn't felt in 2022, but now we are. So that's the background, is that this interpretation is now going to be used as guidance for all the FSDOs around the country. And we already have a massive shortage of aircraft mechanics. This is going to exacerbate that.

Jessie Naor (15:35)

I was listening to, so Mike Busch, who is just a really, really well-known A&P expert, he had fantastic comments

this. And I think one of the things that he was saying is that this is, an FAA interpretation is not supposed to be rulemaking, but this is such a drastic,

change that it really should be rulemaking and go through a notice of proposal, give industry time to comment. So what they're wondering is maybe this was just some huge disconnect between the maintenance people who know how the system works and the FAA's legal office who actually wrote this interpretation. But if this is really going to be the FAA's stance, a lot of the hollering needs to happen. A lot of communications need to happen.

And I know people are worried like, why are there unlicensed people working on airplanes? But there's no other way to learn. That's the process. It takes 30 months of an apprenticeship to

your license. So if you have no opportunity to sit there and learn and do every day, and at the end of the day, the A &P that's signing off the work, they still have to inspect it. They still have to make sure the work was done, their license is at risk. It is not like we're sending people out to go do tire changes and you know.

Delray Dobbins (16:34)

Yes.

Jessie Naor (16:50)

signing them off through a zoom camera. You know, like that's just not what the intent of all this is. So a lot of nuance. But certainly, I mean, they need to fix this like yesterday. Like everyone is just screaming right now because of this.

Delray Dobbins (17:06)

Yeah, the implications are draconian.

when you look at the existing rule that's been there for 60 years, a couple of things come to mind. One is, are they going to rewrite 43.13 in light of this new interpretation? Because right now, the interpretation conflicts with overboarding at 4313D. So something's got to give, because now the interpretation does not clearly align with the regulation. The second thing is, I

Jessie Naor (17:31)

Okay.

Delray Dobbins (17:34)

The industry's been working this way for years. Nobody should be worried about an uncertificated mechanic working on their airplane in a proper shop. There's also an FAA regulation that says when you're performing a task, the printed

to do that task has to be in your work area. So it's not like you're just doing something from memory. You're reading a task card, you're reading a procedure, and you've still got the guy across the hanger to go get him if you need him.

Jessie Naor (18:01)

Right.

Yeah. And at the same time too, I noticed that Delta just became the first airline approved to use drones to do an inspection. So even though the letter says that you can't replace the mechanic with a technology tool, well then why is Delta getting this exemption all of a sudden and you've just destroyed every other part of the industry? That doesn't really jive.

Delray Dobbins (18:24)

Yeah, no. I think what you're hinting at there is that the FAA was just inconsistent.

Jessie Naor (18:27)

Thank you.

I'm hoping so. I'm hoping that it was just the original interpretation of a 60 year old rule was this and rulemaking needs to happen. But we'll have to see. I know the alphabet groups are on it, but if anyone out there is listening, bring it up with your with your representatives because I mean, at Grandview we had an apprenticeship program. You that was how we got A&Ps through the door. It was a great opportunity for them to learn the industry and.

Delray Dobbins (18:32)

you

Jessie Naor (18:57)

We were never going to assign them a task that they weren't able to do. You know, this was simple things like doing the non-critical parts of the job so the mechanic can go over and type things up and do other things while they're doing things that aren't safety related so they can learn, you know.

Delray Dobbins (19:11)

Yeah. And this really touches on something else, is that the

for our industry, for aviation technicians, we already know there's a shortage. This interpretation is going to dramatically affect the shortage even further. You'll notice I'm at Purdue University. I'm a Purdue graduate. came out here in 92 with my A&P and my commercial instrument license.

Purdue Aviation had a career fair today. And so the nice folks down at EJM had a booth up here, inviting me to come up and hang out with them and talk to students about why they should look at not just the airlines for a career, but look at business aviation. So I'm going hang out with students all day talking to them about business aviation. And as part of the NBAA maintenance committee, who I'm on with Andy Keel from EJM, we've been around a certain part 147 schools and we've talked to students.

And I hear things that really alarm me in that the demand for students with technical expertise has never been higher. And I hear stories of like 60 people will start students in an A&P class, only 30 graduate.

because they're getting poached and defected into other industries like marine, HVAC. All the trades you learn as an aircraft mechanic have an appeal to other industries. When you learn avionics, engine mechanics, hydraulics, electrical, you learn how to blueprints and schematics.

Jessie Naor (20:20)

Well.

Delray Dobbins (20:40)

all these other industries are coming at our students that are looking at aviation may already be in an A&P school. And then they realize, I don't have to finish A&P school and I can go make $75,000 a year or even $100 in anoth- HVAC.

Jessie Naor (20:41)

.

Delray Dobbins (20:56)

As an industry, we have to stop what we're doing. We have to stop our regular jobs, and we have to go to places like Purdue or Tarrant County College in Fort Worth or Western Michigan or Embry-Riddle and go talk to them about you had an

in aviation in general. We need to go further that interest in aviation and try to mitigate the technically minded people who have skills. We want them to stay in our industry and come into aviation and hopefully even business aviation.

Jessie Naor (21:26)

I mean, do you think the pipeline is big enough in the first place? know, are we not only engaging them at the college level, but you know, how do we engage younger people?

who didn't even think that aviation was an option in the first place.

Delray Dobbins (21:41)

You know, you get into the high school and some of the STEM activities and efforts. All of that is good. We need more. You just need more. The Northern Cal Business Association is doing a presence at San Jose State with their aviation program. And so what's interesting here at Purdue, I saw a lot of business aviation businesses here having a table. EJM is here.

JSX is here, Gulfstream is here, FlexJet's here. I mean there's a lot of businesses here coming out from corporate aviation that I don't think were coming to shows like this 10, 20 years ago. And we want them here, we need them here to keep them in aviation.

Jessie Naor (22:26)

Yeah, well, and one of the things that I mean, I'm a lot more familiar with the pilot recruiting side, because to be honest, we didn't go to the

The maintenance folks either, but we probably should have been. But is there also the same issue with corporate aviation versus the airlines? I'm sure everyone's competing over resources. So are you seeing mechanics go more the airline route or are they more interested in business aviation? Do we offer something different?

Delray Dobbins (22:51)

You know, that's an interesting question, Jessie. I've known pilots over the year that kind of jump from corporate to airline. Airline's a little bit more cyclical. Then again, they would argue the pilot side of corporate aviation is also cyclical. I've seen the pilots jump back and forth. I haven't really noticed the technicians jumping back and forth.

I usually the technicians I know in my circle of industry friends usually once they're on one side of the fence they seem seem to stay there.

Jessie Naor (23:15)

for the next few weeks. Thank

Yeah, I would think especially in corporate aviation, working with a private owner, it just seems like a much more laid back, not laid back necessarily, but just probably better lifestyle than necessarily working for the airlines. Work on your terms, work the shifts you want to work and different world. But that's good to hear that at least business aviation has got a little bit of pull in one labor area because I'll tell you on the pilot side.

you know, the salaries have just become completely non-competitive. You know, we can't pay people $450,000 a year to fly a Phenom 300. You know, it's just like the economics just don't work.

Delray Dobbins (23:59)

I've talked to several flight departments in the last three to six months and comments of we had to increase pay 20%, 25%, not just for the pilots, but also for the mechanics, just to keep them up where they need to be to keep the right talent, just to reduce the risk of them going somewhere else. And so that's.

uncomfortable from a finance bottom line margin perspective, but you've got to do what you've got to do to keep the people you've already invested in.

Jessie Naor (24:29)

I'm also wondering if this interpretation holds up, if this FAA interpretation saying that, you know, it basically destroys apprenticeships. I mean, let's be honest, like that's just gone. If that happens, does this become like the 1500 hour rule for pilots? You know, is there now this gap between the person fresh out of school versus the person with experience and we can no longer bridge that

Delray Dobbins (24:38)

It does.

Jessie Naor (24:53)

that gap anymore. think mechanics, like we have apprenticeship programs where we can do that. This could totally upend that and do the same thing to mechanics that did to pilots.

Delray Dobbins (25:03)

Well, and if this holds up, the 48,000 technicians that were forecasted to be short by 2027, you throw this rule into the equation, what does that 48,000 become? Does it double? It's going to be worse, significantly worse, because the 48,000 shortage in technicians was based with an apprenticeship program fully in place, unthreatened.

Jessie Naor (25:25)

how many, if you, and you may not know the number off the top of your head, I mean, I know as a 135 operator doing our own work, we would have, you know, maybe three or four apprentices to every three to four mechanics that we had. I mean, what is it like in the general shop? Like how many apprentices are out there that now have to be supervised? You know, how does the ratio work?

Delray Dobbins (25:47)

You know what? I don't know. I've reached out to a couple of my friends at the MRO shops because I was kind of curious, what's the volume of apprenticeships that they do? And I haven't heard back yet. I don't want to guess on an answer on that one. But I know a lot of the MRO shops, just like you were talking about, do internships. And so if it's literally one to one, one employee has to 100 % supervise one intern, I

Jessie Naor (26:06)

Mm-hmm.

Delray Dobbins (26:16)

the implications to your labor force have got to be just, I can't even think of the right word, bad, really bad.

Jessie Naor (26:23)

Yeah, I mean, we talk about things taking a long time in the shop today. Imagine what it's like when we've just lost half our workforce. So hopefully this gets addressed quickly. Very stressful, stressing news for many people. And it also puts people in limbo right now because once an FAA interpretation is out, I mean, it's the law of the land, so to speak. Now I've heard some online rumors that maybe these things won't hold up in court, but.

Delray Dobbins (26:39)

It does.

Jessie Naor (26:48)

you know, if there's an interpretation and you're not doing it today based on the interpretation, your feet are going to be on the fire. You could end up with some serious trouble. So I mean, I don't know what folks are going to be doing while this kind of gets worked out, if it gets worked out in the first place.

Delray Dobbins (27:03)

Well, I know Mike Busch, is not his first go around with the FAA. But I'm sure other AOPA and other industry groups that represent the industry will be up in arms and over it. Because I don't see how it can stand.

Jessie Naor (27:20)

No, I mean this is the most serious threat to business aviation right now. mean, you know, everyone needs to come together and work on this immediately.

All right, to wrap us up today, just a good news story. Well, good news, bad news. So, husband and wife are flying a King Air this week from Las Vegas to Monterey. Unfortunately, the husband became incapacitated, but the wife successfully landed the aircraft in Bakersfield. So, very excited to hear that she was able to do that successfully. She did run off the runway, but you know, it's

first time probably landing a King Air, so.

We'll give her that one. But that was great to hear. It's good news. And just a reminder that anytime you have a passenger in your plane, maybe give them some of the basics. You probably do that when you're flying your friends around, right, Delray?

Delray Dobbins (28:07)

Absolutely. And the interesting one,

the aircraft was not

The passenger lived because she successfully got the aircraft down on the ground. Doesn't matter it went off the runway. She walked away. But it illustrates your point. Anytime you're to have, if you've got a spouse or someone riding with you, to give them the basics of what if. And several associations, like the Citation Jet Pilots Group,

the Epic Owners Group, a lot of those annual events, they promote courses and kind of a...

quick hit orientation for the spouses, what if. The other thing is the Garmin Autoland. This is where technology is coming in as a huge safety factor. The Garmin Autoland system that's in a lot of the newer aircraft, especially single pilot certified IFR aircraft, which are complex aircraft. go up high. That's a huge, that's almost as good as ADS-B in, being able to see all the traffic around you when you're flying around Dallas, Fort

Jessie Naor (28:48)

.

Right.

Delray Dobbins (29:13)

So relatively good outcome, wonderful that she was able to put it down. And I applaud the just the associations like Citation Jet pilots that promote a little bit of training for the other person in the cockpit. Can't do enough of that.

Jessie Naor (29:21)

Thanks.

Yeah, no, that's a great idea. And I too, was cool because the, I guess not cool,

keep saying cool because I'm an aviation nerd, but the US Customs and Border Protection, they brought a Super King Air 350ER to fly alongside her to help keep her along the glide path down to the runway, which I thought, I always wondered to myself,

Delray Dobbins (29:35)

you

Jessie Naor (29:45)

okay, what happens in those situations? is just like AT.

They find an ATC person who's got some familiarity, but it sounds like what they did was call the local CBP folks that had a similar type aircraft, talked her through it, guided her through it. I mean, that has to be a huge relief and sure was a terrifying situation for her to at least have, you know, someone to be there on the wing side. But at least she was able to get out and protect herself. Certainly a harrowing story.

Delray Dobbins (30:12)

Yep, definitely. It emphasizes just the in the interest of safety, always having a second person who has some idea of how to get it down.

Jessie Naor (30:25)

Yeah, and that's always been my thing. know, if you can't afford a second pilot in the cockpit, especially as a 135 or, you know, a private 91 operator, you really shouldn't be flying. Just don't do it. It's the cheapest piece of equipment. It's an expensive piece of equipment, but it's the cheapest in terms of safety. Having a second person there, second set of eyes, incapacitations are quite rare. I think I don't know what the number is, but it does happen.

Delray Dobbins (30:41)

They are.

Jessie Naor (30:52)

And we always need to be prepared and vigilant.

Delray Dobbins (30:54)

Yep, definitely. just, you can't put enough effort into safety.

Jessie Naor (31:00)

with that we're going to wrap up the pod today. Thank you for joining us. The VIP seat is the fastest way to get news on what's happening in your industry. Don't forget to subscribe to our weekly email digest and click wherever you get your podcasts. Comments and suggestions on what we should cover next are always welcome. So we'll see you next time on the VIP seat.