by Paul Cianciolo, FAA Safety Briefing
Attorney, Airworthiness Law Branch
Paul Greer is no stranger to aviation. Living close to the now closed Zahn’s Airport on Long Island — once the busiest general aviation airfield in the U.S. — and John F. Kennedy International Airport, sparked his desire to fly at a young age.
“I was one of those kids who soloed at 16 and got his pilot certificate at 17,” explains Greer. “It really was a different time. I took my first lessons in a J-3 Cub at Zahn’s. Taking off on a warm spring day with the door open, the sound of 65 horses pulling you skyward, and the smell of avgas everywhere was something I’ll never forget.”
Paul worked as a short order cook making $2 an hour to pay for his flying lessons. After high school as a West Point cadet, he pursued his passion at the Academy’s flying club.
“As plebes we couldn’t leave post except to participate in off post club activities,” he notes. “I remember taking a few of my ‘beanhead’ (an endearing term for newly admitted cadets) friends with me to Stewart Airfield and flying down to Zahn’s to visit with my parents, and go to Jones Beach. I wasn’t sure if that was truly legal, but we never got caught!” And no, that’s not his current legal test for actions he is asked to review.
After his time with the Army and earning his law degree, Paul was hired by an aviation consulting firm and did work for the FAA as well as corporate clients. “I had worked with a number of regulatory attorneys in the FAA’s Office of the Chief Counsel, and I thought it would be an interesting place to work, as it combined both my interests in aviation and law.” So he applied. Paul has been an attorney with the FAA for 18 years now.
As part of the agency’s regulatory division in the Office of the Chief Counsel, Paul provides legal advice to FAA personnel regarding the drafting, form, and legality of regulations, orders, exemptions, and airspace actions. He also interprets the FAA’s regulations, which are available online at http://bit.ly/2bc4IdC.
“Basically, if a regulation affects the GA community in any way, we’ll see it in our office.”
One of the biggest challenges his office faces is finding the regulatory “sweet spot.” Finding that regulatory mix where you have just enough regulation to ensure that people don’t get hurt, yet ensuring that the regulations don’t stifle innovation or keep citizens from readily exercising their freedom to fly can be a difficult task.”
“One of the things people may not realize is that my office not only helps other FAA offices ensure that legally sufficient regulatory proposals see their way into the Code of Federal Regulations, but we also review significant FAA policy and guidance,” he notes. “As you read our proposals, regulations, and guidance you’d be surprised, and perhaps even grateful, at the contributions my office has made.”
To become more familiar with the agency’s rulemaking and exemption procedures, Paul suggests pilots look at 14 CFR part 11. In addition to rules that can be waived under 14 CFR section 91.905, any person can request an exemption from FAA regulations — but pay special attention to section 11.81, and review how the FAA has treated similar requests by searching the exemption database at http://aes.faa.gov.
From a legal standpoint, Paul has some parting advice: don’t be afraid to ask questions.
“Just be sure you get an answer from a reputable source. Not everything you read in aviation blogs is true, regardless of what their authors may say. There’s a tremendous amount of information available from the FAA, and someone else has very likely asked the same question you have.” If in doubt, start at faa.gov.
Paul Cianciolo is an assistant editor and the social media lead for FAA Safety Briefing. He is a U.S. Air Force veteran, and a rated aircrew member and public affairs officer with the Civil Air Patrol.
This article was originally published in the November/December 2016 issue of FAA Safety Briefing magazine.