Please take a few minutes to register a comment BEFORE APRIL 10 about the modernization of flight schools, the focus of a 471-page industry report recently put out by the FAA. The impact of flight school airplane noise & pollution is of great concern to the neighborhoods of Clairemont and other surrounding communities near Montgomery-Gibbs Executive Airport. Thank you for your time & support. 

Noticed in the publication General Aviation News...

FAA Releases Report on Pilot Training Modernization With Only a 10-Day Comment Period — General Aviation News
The unusually short comment period means that action is required now to make sure your voice is heard.

- This 471-page industry report from the FAA is about flight schools like those at Montgomery-Gibbs Executive Airport (MYF) in San Diego.

Part 141 schools (flight schools) do most of the circuit training (touch-and-goes, pattern work) that creates the repeated low-altitude noise and 100LL lead pollution our community already experiences. The FAA's report proposes big changes to how these schools are certified, overseen, and what counts as “training time.”

- Potential upside for noise and pollution: The report strongly pushes for much greater use of flight simulators, advanced training devices (FSTDs), and even extended-reality (XR/VR) systems. It wants to give schools more credit for simulator time toward required hours and allow high-performing schools to reduce total flight time through “performance-based” and “competency-based” rules. It explicitly notes that shifting training (including pattern/circuit maneuvers) to simulators would cut actual aircraft flights, emissions, and noise over communities.

- Potential downside/risk: Making training faster, cheaper, and easier to scale could attract more students overall. If more people train at MYF, total flight operations (and circuit work) could still rise even if each student flies fewer hours. The report focuses on efficiency and industry growth, NOT on airport-specific limits or community noise.

-No direct mention of noise, lead pollution, or MYF-specific rules. The report does not propose changes to airport operations, traffic patterns, or noise abatement. It removes some outdated airport-related requirements from Part 141 and shifts oversight to school-level Safety Management Systems (SMS) and Quality Management Systems (QMS). This is where communities can push back—by insisting that any new rules require schools to address local noise/pollution impacts inside those SMS plans.

- The 10-day comment period is a red flag. Industry had months to shape the report; residents near airports like MYF had almost no notice. This is the rare moment the FAA is formally asking for input before it starts writing actual rules.

How neighbors should respond (sample language and strategy)
Act fast—deadline is April 10, 2026. Submit comments online at https://www.regulations.gov/commenton/FAA-2024-2531-0280 Reference the report by its comment ID (FAA-2024-2531-0293). You do not need to read all 471 pages; reference the executive summary and Recommendation 6 (simulators/technology) and Recommendation 7 (modernizing the training appendices).

Suggested key points for comments (copy/adapt):
- Support expanded simulator and XR credits, especially for traffic-pattern, circuit, and ground-reference maneuvers. Urge the FAA to maximize these credits so Part 141 schools minimize repetitive low-altitude flights over residential neighborhoods and schools.
- Require that every Part 141 school’s mandatory Safety Management System (SMS) and Quality Management System (QMS) explicitly address noise abatement, lead emissions, and community impacts. Flight schools should be required to incorporate FAA noise-abatement procedures (e.g., AC 91-36), track complaints, and demonstrate reductions in pattern work over populated areas.
- Any reduced-hour or performance-based approvals must include an environmental review so training volume does not increase overall noise/pollution at busy GA airports like MYF.
- Extend the comment period at least 30–60 days so communities near Part 141 schools can review the full report and provide input.
- Do not approve changes that would make circuit training easier or more scalable without binding local noise and safety protections.

Also email or call your City Council member, the San Diego Airports Advisory Committee, and your congressional representatives (ask them to request an extension from the FAA for a longer public comment time period). 

Bottom line for our communities
This is not a done deal that automatically adds more flights. It is an industry wishlist that the FAA is now reviewing. The simulator-heavy direction could actually help reduce the circuit training burden if the final rules prioritize it and require schools to prove they are cutting real-world flights over residential areas. But without community voices in the docket, the FAA will only hear from the flight schools. Forward this summary, the article link, and the direct comment link to neighbors today—April 10 is only days away. Collective comments from residents near MYF can help shape the rules so that “modernization” protects, rather than further erodes, your quiet and safety.

AGAIN, HERE ARE DIRECTIONS TO REGISTER YOUR COMMENT. PLEASE DO SO BEFORE APR.10!!

-Go to Regulations.gov
-Search for docket ID: FAA-2024-2531 (or go directly to the comment page)

-Select the rule/proposed rule/final rule category  for “what is your question about?”

-You can choose the anonymous input button. Or, if you don't mind your name/address being public record, feel free to insert your personal information.

-Feel free to copy and paste the comment below. Personalize it or use your own comment, if you have the time to write your own full comment. 

EXAMPLE COMMENT:
I  support expanded simulator and XR credits, especially for traffic-pattern, circuit, and ground-reference maneuvers. I urge the FAA to maximize these credits so Part 141 schools minimize repetitive low-altitude flights over residential neighborhoods and schools.  I also urge the FAA to make it a REQUIREMENT that each and every Part 141 school’s mandatory Safety Management System (SMS) and Quality Management System (QMS) explicitly address noise abatement, lead emissions, and impacts on surrounding residential communities. Flight schools should be required to incorporate FAA noise-abatement procedures (e.g., AC 91-36), track complaints, and demonstrate reductions in pattern work over populated areas.  Any reduced-hour or performance-based approvals must include an environmental review so training volume does not increase overall noise/pollution at busy general aviation airports like Montgomery-Gibbs Executive Airport. I ask that the FAA extend the comment period at least 60-90 days. Communities near Part 141 schools should have the opportunity to review this whole 471-page report and provide input.  A 10-day comment period is not a long enough time period to get feedback. I implore that the FAA not approve any changes that would make circuit training easier or more scalable without binding local noise and safety protections.

Thank you for your continued support of this petition & for registering your comment at Regulations.gov. Please share with neighbors and friends. Together, let's bring balance back to our San Diego skies...