If “Legal” Is the Reason, Then We’re Asking Legal
After more than a year of attempting to secure meaningful, policy-level engagement with FAA aeromedical leadership, Pilots for HIMS Reform has taken the question directly to the FAA’s Chief Counsel.
For more than a year, Pilots for HIMS Reform has attempted to do something that should not be extraordinary:
Sit down with the Federal Aviation Administration and talk.
That effort traces back to EAA AirVenture Oshkosh in 2025, when Federal Air Surgeon Dr. Susan Northrup publicly indicated that she was willing to meet with Pilots for HIMS Reform.
Over the year that followed, P4HR repeatedly attempted to turn that willingness into an actual stakeholder meeting.
Not about one pilot. Not about one medical certificate. Not about one lawsuit, appeal, Special Issuance, or pending case.
We have asked to discuss the HIMS system itself: how it operates, where pilots are getting trapped, where transparency is lacking, how due process can be strengthened, and how the FAA, pilots, physicians, treatment professionals, labor organizations, airlines, and other stakeholders might work together toward a better system.
At Oshkosh 2026, P4HR again raised the unanswered meeting request directly with Dr. Northrup. That was followed by a formal written meeting request on July 29, 2026, and another follow-up on August 16, 2026.
Still no acknowledgment. Still no meeting.
We Are Asking FAA Legal Directly
On August 17, 2026, P4HR leadership formally elevated the issue to FAA Chief Counsel William “Liam” McKenna.
Because legal considerations have repeatedly been raised in connection with the FAA’s unwillingness or reluctance to engage with P4HR, we believe the fairest and most direct course is to ask FAA Legal itself.
Has the FAA Office of the Chief Counsel advised Dr. Northrup, the Office of Aerospace Medicine, or other FAA personnel not to meet or substantively engage with Pilots for HIMS Reform?
If the answer is yes, we are asking the FAA to identify the legal, regulatory, ethical, or procedural concern preventing that engagement.
If the answer is no, another question naturally follows:
Why are we still not talking?
P4HR is not asking Chief Counsel to disclose privileged attorney-client communications, nor are we seeking access to internal FAA legal deliberations.
We are asking the agency to clarify its institutional position.
This Is Not About Anyone’s Individual Case
We have been especially careful to eliminate what could otherwise become an easy reason for avoiding the discussion.
The requested stakeholder meeting would not address any individual pilot’s pending medical certification matter, Special Issuance determination, NTSB appeal, litigation, enforcement proceeding, or other adjudicative matter.
Those issues can remain entirely outside the room.
P4HR wants to talk about the system.
That includes questions such as:
- How long should HIMS monitoring continue?
- What objective standards govern progression through monitoring?
- What is the actual pathway to unrestricted medical certification?
- What standards are being used to continue restrictions?
- What meaningful independent review should exist?
- What due-process protections should pilots receive?
- How can aeromedical decision-making become more transparent and consistent?
- How should affected pilots participate in shaping policies that may govern years — or decades — of their professional lives?
- What regulatory reforms are necessary?
- How can the FAA participate constructively in P4HR’s forthcoming Part 11 rulemaking effort?
These are public-policy questions.
They deserve public-policy engagement.
Does the FAA Have to Meet With Us?
Precision Matters
P4HR is not claiming that the Constitution gives an organization an absolute right to compel a particular federal official to attend a private meeting.
That is not our position.
But that does not mean federal agencies operate within a system where affected stakeholders are expected simply to speak into a void.
The Administrative Procedure Act recognizes participation by interested persons. Under 5 U.S.C. § 555(b), subject to the orderly conduct of public business, an interested person may appear before an agency or its responsible employees concerning issues, requests, controversies, proceedings, and other agency functions.
Federal law also gives interested persons the right to petition agencies for the issuance, amendment, or repeal of rules.
For the FAA, that process is implemented through 14 C.F.R. Part 11.
P4HR is actively preparing to use that process.
DOT Rules Contemplate Engagement With Interested Members of the Public
Federal transportation regulations provide mechanisms through which agency personnel can engage interested members of the public while protecting transparency and the integrity of formal proceedings.
That matters.
If a genuine legal or procedural concern exists with the particular meeting P4HR requested, we are willing to address it.
- Have agency counsel present.
- Limit the discussion to prospective policy.
- Memorialize the meeting.
- Place appropriate information in a public docket.
- Hold a listening session.
- Conduct a written question-and-answer process.
- Make the meeting public if necessary.
There are options.
What becomes increasingly difficult to understand is how the answer can simply be:
We Have Offered the FAA an Alternative
Our letter to Chief Counsel McKenna does not merely criticize.
It asks for a solution.
If FAA Legal believes the requested meeting cannot lawfully or appropriately take place in its present form, we have asked Chief Counsel to identify another mechanism for meaningful engagement.
That could include:
- a docketed stakeholder meeting;
- a public listening session;
- participation by agency counsel;
- a meeting expressly restricted to prospective policy;
- a written exchange;
- a publicly memorialized meeting; or
- another process FAA Legal considers appropriate.
Tell us what the rules are, and we will work within them.
But silence is not a process.
P4HR Would Rather Work With the FAA Than Around It
That remains our position.
Pilots for HIMS Reform did not come into existence because its leadership wanted a permanent fight with the Federal Aviation Administration.
We exist because pilots and their families kept telling us stories that demanded attention.
Our membership continues to grow.
The experiences being reported to us continue to accumulate.
And the fundamental questions surrounding HIMS — transparency, proportionality, medical standards, due process, independent review, monitoring duration, and a genuine pathway forward — are not disappearing.
P4HR intends to pursue those questions through every appropriate avenue available to us.
- Stakeholder engagement.
- Formal rulemaking.
- Legislative reform.
- Congressional and governmental oversight.
- And, where necessary, judicial review.
We would much rather undertake that work with the FAA than around it.
But meaningful collaboration requires two parties willing to communicate.
The Question Is Now With FAA Chief Counsel
Our request to Chief Counsel McKenna is straightforward.
P4HR has asked the Office of the Chief Counsel to:
- Confirm whether FAA Legal has advised Dr. Northrup or the Office of Aerospace Medicine not to meet or substantively engage with P4HR.
- If so, identify the legal, regulatory, ethical, or procedural basis for that position to the extent it can be disclosed.
- If no such prohibition exists, assist in facilitating an appropriate stakeholder meeting.
- If the meeting cannot occur in the form proposed, identify an alternative mechanism through which meaningful policy-level engagement can take place.
The letter was sent on behalf of Pilots for HIMS Reform.
Now we will see whether the FAA answers.
Read the Record for Yourself
Transparency matters. Below is the history of P4HR’s effort to obtain a meeting alongside the complete public version of our August 17 letter to FAA Chief Counsel William “Liam” McKenna.
More Than a Year Seeking Engagement
From Oshkosh 2025 through the formal 2026 request and subsequent escalation.
How We Got Here
This did not begin with an unanswered email last week. P4HR has been attempting to obtain meaningful policy-level engagement with FAA aeromedical leadership for more than a year.
Federal Air Surgeon Dr. Susan Northrup publicly indicated that she was willing to meet directly with Pilots for HIMS Reform.
P4HR continued attempting to turn that stated willingness into an actual policy-level stakeholder meeting with FAA aeromedical leadership.
After approximately a year without the requested meeting, P4HR again raised the matter directly with Dr. Northrup.
P4HR formally submitted its request for a stakeholder meeting with FAA aeromedical leadership.
With no acknowledgment or substantive response to the formal request, P4HR followed up again.
Because legal considerations had repeatedly been referenced in connection with FAA engagement, P4HR took the question directly to FAA Chief Counsel William “Liam” McKenna.
Letter to FAA Chief Counsel William “Liam” McKenna
P4HR asks FAA Legal directly whether it has advised aeromedical leadership not to engage with the organization.
We Will Keep Showing Our Work
P4HR has made a deliberate decision to conduct this reform effort as openly as circumstances permit.
When we write to the FAA on matters of broad public policy, we want pilots to see what we wrote.
When the FAA responds, where legally and ethically appropriate, we want pilots to see that too.
And when it does not respond, the record should reflect that as well.
This is not about manufacturing confrontation.
It is about accountability.
Why This Matters
Pilots subject to a federal medical certification system have an enormous amount at stake:
- their careers;
- their livelihoods;
- their medical privacy;
- their families; and
- their ability to continue exercising the privileges of certificates they worked years to earn.
They deserve a system capable not only of regulating them, but of hearing them.
The FAA Has the Question. We Look Forward to the Answer.
P4HR remains prepared to meet, listen, provide evidence, discuss solutions, and work constructively with the agency.
And if “Legal” has been the reason that conversation cannot occur, then we have now asked Legal directly.
We look forward to the answer.
Read the Record
We believe pilots should be able to review the underlying correspondence for themselves.