Comment from Vladislav Prostakov

I am writing this comment as an individual airman from the perspective of an Airline Transport Pilot and Certificated Flight Instructor in support of the proposed rule, but with some additions that are required in my opinion. I agree that the existing regulatory references to the National Weather Service no longer accurately describe how aviation weather reports should be provided and how they may be efficiently used in daily operations, especially during real day-to-day operations at satellite airports. I support the FAA’s effort to replace single approved weather resource, clarify terminology, and allow the Administrator to approve reliable alternate sources of aviation weather information. The aviation system is changing rapidly, and all of users of National Aerospace System, many airports, weather providers and community in general would benefit from more flexible, reliable, and timely weather information. My main concern is not with the direction of the rule, but with implementation. The proposed rule uses broad language such as “source approved by the Administrator.” That flexibility is useful, but without clear public guidance, it may create confusion among pilots, instructors, dispatchers, check airmen, inspectors, and practical test applicants. In aviation training, unclear regulatory language often becomes a safety issue because different people interpret it differently. In training, I see this issue often. Many pilots already struggle to understand the difference between official NWS weather reports and forecasts, advisory products, graphical weather, any EFB weather apps, model-based products, or even airport camera information. These are all useful tools, but they are not all the same, and they may not all be legally acceptable for the same operational use and decisions making. I believe that the FAA should adopt the proposed rule while pairing the final rule with specific implementation guidance that clarifies misunderstandings, helps properly teach this area from the legal side of the question, and makes the system easier to use improving safety. Please review the recommendation below which may help provide clarification: - Add language to the document that directs readers to where ‘source approved by the Administrator’ can be found. Additionally, it would be useful to publish a centralized list of approved weather-report sources, which should include already existing official NWS resources, contract weather observers, approved third-party sources, approved analyzed-weather systems, and any limitations applicable to each source. Pilots, instructors, and their students do not need to know every technical detail, but they do need confidence in which sources are officially approved and which ones can legally and officially be used during training, checkrides, daily flying, and, of course, for what types of operations. - Publish clear approval criteria for third-party weather sources. If third-party or analyzed weather sources may be approved, the FAA should publish minimum approval criteria. At a minimum, those criteria should address latency, accuracy, calibration, reliability, uptime, outage reporting, data quality control, human oversight or augmentation when applicable, data integrity, etc. Additionally, the FAA should publish procedures for removing or suspending approval when a source does not perform as expected - Create a monitoring and feedback process. The monitoring process should collect reports of discrepancies, latency issues, operational confusion, incorrect source use, and misunderstandings by pilots, dispatchers, or ATC - Update other applicable training and legal resources, such as the AIM, handbooks, ACSs, and other training and inspector guidance to include explanations of the differences between weather reports, forecasts, approved sources, and analyzed weather. From a CFI perspective, the rule will be difficult to teach consistently unless the FAA updates related training references. Practical test applicants should not be forced to guess what a DPE, instructor, or inspector means by ‘approved weather sources.’ The training materials should use the same terminology as the final rule. I’m questioning not the goal of the rule but how to make sure the final system is clear enough for everyday use. Weather decisions are already one of the most challenging parts of aviation, especially for students, instrument pilots, and pilots operating in marginal conditions. The more sources we allow, the more important it becomes to explain which sources are approved, what they can be used for, and where their limitations are. I respectfully recommend that the FAA adopt the proposed rule with additional guidance, public source lists, clear approval criteria, training updates, practical examples, and a feedback process. These steps would preserve the flexibility of the proposed rule while improving safety, consistency, and pilot understanding.