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The Federal Aviation Administration’s (FAA) COVID-19 vaccine mandate for pilots violates federal regulations and places pilots and passengers at risk, according to a letter from the California-based Advocates for Citizens’ Rights.

The letter, only recently made public, was hand-delivered in December 2021 to then-director of the FAA, U.S. Department of Transportation, U.S. Department of Justice (DOJ), and CEOs and legal counsel of major U.S. air carriers (American Airlines, Alaska Airlines, Delta Airlines, Southwest Airlines and United Airlines).

It includes data showing pilots across the aviation industry — including commercial, military and general aviation pilots — face increased health risks from the vaccines due to the unique nature of their profession.

The letter also states that a significant number of vaccine injuries and adverse effects involving pilots have been recorded, and in some instances have forced pilots to stop flying.

The letter claims:

  • Federal regulations that prohibit pilots who have received non-FDA-approved medical products, such as COVID vaccines, from flying are being violated.
  • Vaccinated pilots potentially are flying with abnormal health conditions that may be exacerbated by flying at high altitudes. These include heart damage and blood clotting, which could lead to stroke or cardiac arrest.
  • Some pilots have suffered death and serious injury following COVID vaccination.
  • The federal government is aware of the issues associated with the vaccines, based on complaints filed with government agencies.
  • The health risks to pilots from the vaccines may lead to a catastrophic event such as a plane crash, with multiple fatalities and significant legal and monetary liabilities for the government, insurers and airlines.

The letter was co-signed by a series of prominent figures, including:

In an interview with The Defender, Advocates for Citizens’ Rights attorney Leigh Taylor Dundas, lead signatory of the letter, said products authorized under Emergency Use Authorization (EUA) are not fully approved by the FDA, and under EUA rules cannot be mandated.

“Our government has a long history, even with approvals and releases of products … of getting it wrong,” Dundas said. “Witness thalidomide, DDT, all sorts of things like that.”

“As a former environmental attorney and now staunch defender of basic human rights and civil liberties … I get contacted a fair amount by concerned individuals from all walks of life,” Dundas said.

“I was aware from things I had been hearing at conferences … that the inoculation was presenting severe and sometimes fatal issues to those who took it.”

Dundas said:

“I became aware that certain military personnel who were high-ranking surgeons within the U.S. armed forces were not just anecdotally becoming aware that pilots were having severe incidents of injury, but also that statistically that was being borne out by way of the database.

“At the same time, I was becoming aware of similar incidents in the civilian pilot population. So the combination of the two made me sort of pull the string and try to determine if not only was the vaccination causing an increase generally of disease and fatalities among those who took it, but if perhaps [these adverse reactions were] due to the unique combination of pilots being at altitude for long periods of time.”

Dundas said it appeared from the anecdotal, subjective data she was hearing and raw statistical data coming out of the DOD databases that these military doctors had access to — that the pilots were uniquely likely to be suffering ill effects from the vaccines.

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Significant health risks for pilots

The letter, along with the accompanying documentation, references numerous instances of adverse reactions sustained by pilots and other health risks they face as a result of the COVID vaccines.

The letter quotes flight surgeon and aerospace medicine specialist Dr. Theresa Long and cardiologist Dr. Peter McCullough, a cardiology consultant for the FAA.

Long and McCullough, who signed the letter, said:

  • “The risk of ‘post-vaccination myocarditis [is] not trivial.’
  • “The ‘aviation population is comprised of individuals with demographics that the [U.S. Centers for Disease Control and Prevention (CDC)] and FDA established (on June 25, 2021) was at greatest risk for developing post-vaccination induced myocarditis.’”

Cody Flint, also a signatory of the letter, described his experience. Flint, based in Cleveland, Mississippi, is an agricultural pilot with 10,000 hours of flight time. He testified at a Nov. 2, 2021 U.S. Senate hearing on COVID vaccine injuries about the adverse effects he sustained.

Portions of Flint’s testimony were quoted in the letter, including:

“I have been very healthy my whole life, with no underlying conditions.

“I received my first dose of the Pfizer COVID vaccine on Feb. 1 [2021]. Within 30 minutes, I developed a severe stabbing headache, which later became a burning sensation in the back of my neck.

“Two days after vaccination, I got in my airplane to do a job that would only take a few hours. Immediately after taking off, I knew that something was not right with me. I was starting to develop tunnel vision, and my headache was getting worse.

“Approximately two hours into flying, I pulled my airplane up to turn around and felt an extreme burst of pressure in my ears. Instantly, I was nearly blacked out, dizzy, disoriented, nauseous and shaking uncontrollably. By the grace of God, I was able to land my plane without incident – although I do not remember doing this.

“My initial diagnosis of vertigo and severe panic attacks – although I’ve never had a history of either of these – was later replaced with left and right peri-lymphatic fistulas, Eustachian tube dysfunction and elevated intracranial pressure due to brain swelling.

“My condition continued to decline, and my doctors told me that only an adverse reaction to the vaccine or a major head trauma could have caused this much spontaneous damage.

“I’ve had six spinal taps over eight months to monitor my intracranial pressure, and two surgeries, eight weeks apart, to repair the fistulas. I have missed nearly an entire year of my life … I don’t know if I’ll ever be able to fly again.

“…the FDA, CDC, and NIH [National Institutes of Health] refuse to acknowledge that real lives are being absolutely destroyed by this vaccine.”

The letter also refers to the case of American Airlines pilot Wilburn Wolfe, who suffered a major seizure following his COVID vaccination. Wolfe died, though not while he was on duty.

It also cites the case of a Canadian flight in December 2021 that was forced to divert back to the airport shortly after takeoff because the pilot, who was recently vaccinated, passed out.

In other testimony from the November 2021 Senate proceedings, Long said the U.S. military was aware of the risks to its pilots, but chose to proceed with its vaccine mandate for service members.

Long said:

“Last May [2021], I attended the Senior Preventative Leadership Program for the Army. When we were given an opportunity to ask the senior leaders questions, I simply asked: ‘So we skipped two years of Phase 2 trials, and three years of Phase 3 trials? We only lost 12 active-duty soldiers to COVID — yet we’re going to risk the health of the entire fighting force, on a vaccine we only had two months of safety data on?’

“The response was: ‘You’re damn right, Colonel. And you’re going to get every soldier you can to take the vaccine so I can get enough data points to determine if the vaccine is safe.’”

Long said numerous soldiers told her about “threats and intimidation” they faced to get the vaccines that were still under the EUA. She said the Army Public Health Command was “not tracking, tracing or monitoring adverse events.”

Additional testimony from Long, cited in the letter, concerned military pilots she treated for vaccine injuries:

“I saw five patients in clinic, two of which presented with chest pain, days to weeks after vaccination, and were subsequently diagnosed with pericarditis …

“The third pilot had been vaccinated and felt like he was drunk, chronically fatigued within 24 hours after vaccination, [stating] he drank a lot of coffee to ‘try and wake himself up’, and continued to fly, until he realized the problem wasn’t going away.

“After I reported to my command my concerns that — in one morning — I’d had to ground 3 out of 3 pilots due to vaccine injuries, the next day my patients were canceled, my charts were pulled for review and I was told that I would not be seeing acute patients anymore, just healthy pilots there for their flight physical.”

The letter referenced 10 reports from the Vaccine Adverse Event Reporting System (VAERS) involving pilots who sustained severe injuries and side effects following the COVID vaccine. According to the letter, these 10 examples are a mere sample of the total number of injuries reported by pilots.

These injuries and symptoms included:

  • Heart attacks
  • Atrial fibrillation
  • Pericarditis
  • Brain swelling
  • Elevated intracranial pressure affecting the spinal cord and brain stem
  • Sub-arachnoid hemorrhages (brain bleeding)
  • Blindness

Statements from the VAERS reports include descriptions of vaccine injuries reported by pilots.

One report (VAERS ID: 1026783-1) stated:

“The physician determined … I had an allergic reaction to the Pfizer COVID vaccine [that] severely increased the pressure in my spinal cord and brain stem. That pressure causes my vision problems and ultimately ruptured my left inner ear, breaking off several crystals in the process. I cannot fly with this condition.”

Another pilot stated (VAERS ID: 1743012-1):

“Symptoms began almost immediately [post-vaccination] as constant dizziness, body aches, overall weakness. Two months later I woke up with chest pain and difficulty breathing … I was diagnosed with inflammation of the heart cavity and pulmonary arteries … I was later diagnosed with vasculitis, specifically aortitis.

“I was completely healthy prior to the vaccination and there is not a single member of my family with any of the listed conditions … [I am] awaiting a medical evaluation … to determine if I’m allowed to remain on flying status and in the military.”

Another report (VAERS ID: 1768479-1) submitted by a pilot described the following:

“[The] morning following injection, I experienced extreme dizziness and brain discomfort. Dizziness was bad enough to make walking difficult and even created motion sickness … heights of about 10 feet give bad vertigo.

“I am a pilot and aircraft mechanic and this creates an issue working on jets … brain fog is also long-lasting still [sic] and makes mental clarity difficult, which was never an issue until the day after the shot.

“My heart has created irregular heart rhythms, I have physical stress and tire easily and my muscles will shake and twitch after minimal effort … my cognitive skills seem to have diminished from the lasting brain fog.”

Another pilot reported (VAERS ID: 1358033-1): “2 days after second shot, blood clot in left arm. Hit while walking in my home. Could not lift my arm. 5 days later heart attack. Pilot with EKG yearly. Last EKG less than one month from [sic] my heart attack on April 29, 2021.”

And one pilot reported (VAERS ID: 1376453-1): “Severe vertigo experienced for four days and counting … as a professional helicopter pilot, I cannot perform my job with these symptoms.”

In one report (VAERS ID: 1702509-1), submitted by a doctor, a pilot who was also a triathlete experienced pericarditis, chest pressure and irregular heartbeat after vaccination, with pain that “radiated to [the] jaw and neck,” “pressure in the chest” and difficulty walking, despite no prior heart problems.

Another report (VAERS ID: 1245452-1) submitted by a doctor described how a 37-year-old pilot who received the Moderna vaccine, and who had no prior medical history of heart conditions, sustained atrial fibrillation and a decrease in thyroid hormones, leading to him being kept off duty.

In one case (VAERS ID: 1388581-1), a doctor who is also a commercial airline pilot reported “subarachnoid hemorrhage” and “associated nausea, vomiting and photophobia.” According to the VAERS report, the doctor “remains off work pending FAA evaluation.”

This sampling of reports from VAERS is likely only the tip of the iceberg, according to Dundas, who said:

“It’s known that there’s a 1% reporting rate to VAERS, that there’s 99% underreporting. So if you looked at what was already in there, within a few months of this [vaccine] being rolled out and mandated to the pilots, you rapidly did the math … and realized that we are absolutely destroying the health of our pilots.”

The military’s own database, Defense Medical Epidemiological Database, found similar instances of injuries, Dundas said:

“When you looked at the data that these high-ranking U.S. military doctors were seeing, what you rapidly realized is that in all of the years prior to 2021, for the five years preceding that point in time, the total cumulative number of incidents of disease and injury in this database were 1.7 million every single year.

“Then, in January 2021, the U.S. military decided to essentially mandate that their service members take the vaccine, and it was fortuitous that they did it in January; [this] made for a very clean cut in terms of analyzing the data set.

“Within the first nine months [of 2021], the total number of incidents of disease and injury in the U.S. armed forces jumped from a very stable baseline of 1.7 million per year … to almost 22 million … and the year wasn’t even over. That was just the first three quarters of 2021.

“[These were] injuries where military pilots were walking off of flight vehicles, clutching their chests, complaining of chest pain. The military refused to take that seriously and ordered the doctors who would normally be sending these soldiers for cardiac MRIs and EKGs to basically write it off as anxiety or some such [condition].”

Josh Yoder, a pilot with a major commercial airline, Army combat veteran and former flight medic, co-founded the U.S. Freedom Flyers (USFF), an organization opposing vaccine mandates for pilots.

In an interview with The Defender, Yoder said vaccine injuries among airline crews are “extremely common” and are being “actively covered up” by airline companies and the FAA.

Yoder told The Defender:

“U.S. Freedom Flyers receives almost daily communication from airline pilots who are flying with symptoms such as chest pain and neurological conditions post-vaccination. Most of them are afraid to come forward and seek medical attention for fear of losing their flight medicals.

“USFF has documented cases of blood clots, strokes, cardiac arrest, unconsciousness and sudden death among airline professionals which have been medically linked to the COVID-19 vaccinations.”

FAA ‘betting the farm’ a major catastrophe won’t occur

Dundas told The Defender the FAA is aware of these risks associated with the vaccines but is sweeping the problem under the rug.

She said the agency may be hoping “redundancy” in the cockpits of commercial airliners — meaning that two pilots are jointly in charge of flying the aircraft — will be enough to stave off a potential disaster.

“Where that analysis breaks down is during takeoff or landing,” Dundas said, “because during takeoff and landing, you’re not on autopilot. You’ve got both pilots fully engaged, but one of the pilots actively has his hands on the joystick and the controls.”

She added:

“If you’re 300 feet or 1,000 feet above, coming in for a landing … you’ve now got a massive gross muscle unit seizure as [the pilot’s] hand is on the yoke, that’s going to dip a wing and you’re going to have an entire plane full of people cartwheeling down the runway … probably with a mass fatality event at the end of the line.

“Even if you’re betting the farm, as I believe the FAA right now is, because they don’t have a choice, the water is already under the bridge on pilot redundancy. All it takes is bad timing for one of these events to occur on takeoff or landing. And you’ve got an unrecoverable airplane, [a] fatal crash, which the Department of Justice frowns upon.”

Yoder, also addressing this risk, said:

“Pilot redundancy is a critical component to aviation safety. The topic of adverse vaccine reaction and pilot redundancy is a complex one that requires in-depth analysis which the FAA has never studied.

“Critical phases of flight such as take-off or landing pose the greatest risk to passengers, should that be the moment a pilot experiences known side effects of these inoculations, such as blood clots, stroke, cardiac arrest or sudden death, which could lead to an unrecoverable event.”

FAA, airline industry violating federal regulations

In addition to numerous documented instances of pilots sustaining significant injuries and side effects — or even dying — as a result of the COVID vaccines, the letter also indicates the vaccination itself, let alone the vaccine mandates, may be in violation of federal regulations.

Specifically, the letter accuses the FAA, and the aviation industry, of:

“ … putting both pilots and the general public at risk of death and/or serious injury by operating in contravention of Title 14 of the Code of Federal Regulations, §61.53, and related guidance which together operate to disallow medical clearance of pilots who have injected or ingested non-FDA approved products — like the COVID-19 inoculation.”

The letter goes on to clarify this clause in the federal regulations prohibits aviation medical examiners from issuing medical clearances to pilots who use non-approved medical treatments, such as those that are being administered under an EUA instead of full FDA approval, and new medications fully approved by the FDA less than 12 months prior, stating that the FDA:

“ … generally requires at least one year of post-marketing experience with a new drug before consideration for aeromedical certification purposes.

“This observation period allows time for uncommon, but aeromedically significant, adverse effects to manifest themselves…”

The letter further quotes the federal regulations as stipulating:

“[N]o person who holds a medical certificate issued under part 67 of this chapter may act as pilot in command, or in any other capacity as a required pilot flight crewmember, while that person … [is] receiving treatment for a medical condition that results in the person being unable to meet the requirements for the medical certificate necessary for the pilot operation.”

As stated in the letter:

“[P]ut simply, any pilot flying right now who has been vaccinated in the United States has almost certainly NOT [emphasis original] received an FDA-approved vaccine …

“And even were such pilots to have received an FDA-approved vaccine, under relevant federal regulations, the pilots should still not be flying for 12 more months …

“The reason for this cannot be overstated: history and common sense evince that significant time must elapse post-FDA approval to ensure that new medical products do not end up causing adverse effects (as did Thalidomide and glyphosate).

“This is particularly true when the individuals who are receiving such new, experimental medical products are spending significant amounts of time at high altitude, and are in control of large vehicles carrying hundreds of other passengers, who could all die or be severely injured should the operator suffer an adverse health event.”

As previously reported by The Defender, and as outlined in the letter, none of the COVID vaccines currently available and being administered in the U.S. have received full FDA approval.

“We’ve got the FAA, a federal regulatory body, that is charged with protecting the safety of the flying public, as well as pilot safety, ignoring their own rule and the guidance on it,” Dundas said.

“Here, we’ve got an inoculation that is wholly unapproved, at least in the U.S., and yet we’ve got major carriers … who are not just ignoring this rule, but mandating their pilots to take this. And we’re seeing hellacious, horrifying results,” she added.

Dundas said the letter clearly warns the government and airlines of the legal and financial liabilities they would face should an airline disaster occur that is traced back to an adverse vaccine-related event suffered by a pilot — especially as it would be on the record that these entities have been made aware of such a risk.

As legal precedent, she cited a $2.5 billion fine levied by the DOJ in January 2021 against Boeing for “fraud conspiracy” involving safety issues with the 737 Max airplane, stemming from Boeing’s concealment from regulators of potential safety issues involving that model of aircraft.

The settlement included payments to the families of passengers who were killed in crashes involving the 737 Max.

Dundas likened the vaccine injury data involving pilots to the internal 1977 Ford Motor Company “smoking gun” memo that revealed the company was aware of safety issues with the Pinto model of automobiles but considered it more cost-effective to pay off future victims than to issue a recall and rectify the problem.

“Essentially what I was doing with the way I crafted the letter was … I was putting all the players in the industry, the regulator, the airline companies and the insurers for the companies, on notice that you probably have a problem here based on the numbers [of adverse vaccine events affecting pilots] that we are seeing,” Dundas said.

The letter provides an estimate of the likely amount of compensation that would result from a hypothetical accident if it could be traced back to an issue the airlines and regulators were aware of: $2 million to $3 million per person.

This amount, according to Dundas, would be “separate from punitive [actions], from fines assessed by the DOJ.”

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Did letter cause FAA director to resign?

In February, then-FAA director Steve Dickson suddenly announced his resignation, effective March 2022, claiming it was “time to go home” to his family.

Dickson, however, had previously faced controversy. For instance, during his confirmation as FAA director, allegations arose that during his previous tenure overseeing the pilots of Delta Air Lines, a Delta pilot was grounded in 2016 after she raised concerns regarding the airline’s approach to managing safety risk.

According to Yoder, the real reasons for his resignation may have had less to do with a desire to spend more time with his family and more to do with the hand-delivered letter he received in December 2021.

“Dickson’s resignation came on the heels of the tremendous pressure being applied to the agency via Leigh Dundas’ FAA letter, along with back-channel communication and media attention from [the] U.S. Freedom Flyers,” Yoder said.

Dickson’s promotion of unapproved experimental vaccines for pilots, which violates the FAA’s own guidance, caused a dangerous situation for not only pilots but also the flying public, Yoder said.

“Documented cases of pilots experiencing severe adverse reactions in flight accrue daily, thanks to an inept response from the FAA,” he said. “Internal reports from FAA employees reveal a scandal-ridden agency which needs to be destroyed and rebuilt from the ground up.”

“The FAA’s primary charter is safety and they have failed miserably by approving experimental vaccines for pilots with zero long-term safety studies.”

According to Yoder, the FAA, even following Dickson’s resignation, does not appear to have taken concrete actions in response to the letter.

“Rather than being proactive, the FAA and the airlines have chosen to ignore a prominent passenger safety issue,” Yoder said.

“Historically, it’s taken a fatal crash or series of near misses to execute change within the agency. Fundamental change to safety policy within the FAA is typically written in blood,” he said.

According to Dundas, a recent spate of widespread flight cancellations and protracted delays in late 2021 and up to the present — frequently blamed by airlines on such factors as poor weather — are in fact connected to pilot action in relation to the vaccine mandates, for two reasons: opposition to the mandates, and an abundance of caution by pilots who call in sick at the first sign of any symptoms of illness:

“I think it’s twofold, and I think you’re seeing two things and they’re very logical,” Dundas said, noting that pilots, along with certain other transportation employees, are technically not allowed to go on strike without first exhausting their collective bargaining remedies. That’s the federal law that’s been in existence for decades.

“But this is a cat of a different color,” Dundas said. “You are mandating, against other federal law … an inoculation that you’re not allowed to mandate, and it’s likely unconstitutional.”

“So you have a lot of sectors in transportation that are really not happy saying get the jab, get the jab or your job is going goodbye,” she said.

Dundas added:

“What you saw … were segments of these transportation sectors saying, ‘you know what, we operate heavy machinery and we are required as well by rule and law in many cases to not operate these large pieces of equipment if we are remotely under the weather.’

“So, I think you saw a convergence of two variables. I think you saw pilots who were unhappy at being made to work in unsafe working conditions … in conjunction with a pilot population that was getting now not just the first shot, but the second shot and/or the third shot and a cumulative consequence and concatenation of adverse health events.

“[T]hey [the pilots] are, in many cases, highly educated, caring human beings, [who] wake up in the morning and go, ‘You know what, I’m not 100%, I’m not fit to fly, I’m going to call out sick because I don’t want to take other people down with me if I’m about to have a stroke.’”

Dundas said a recent flight of hers from Salt Lake City was delayed for almost a full day following an adverse event affecting one of the flight attendants scheduled to work on that flight.

Dundas also cited conversations with pilots who told her “they wanted no part of the mandate.”

According to Dundas, the reasons for their opposition were described in the following terms:

“[W]e see our colleagues dying and or stroking out or having cardiovascular events that they are not recovering from.

“And so, we quit rather than sacrifice our health or possibly our lives. And now we’re flying charters [private aviation] where [COVID vaccination] is not a mandate, it’s not required.”

Letter calls on FAA, airlines to take immediate action

The letter from Advocates for Citizens’ Rights calls for immediate action by federal authorities and air carriers, including:

  • Medically flagging all vaccinated pilots.
  • Adaptation, on the part of the FAA, of a screening program requiring all vaccinated pilots to undergo medical recertification, including D-Dimer, Troponin, and EKG tests, as well as cardiac MRIs, with medical clearance issued to vaccinated pilots only if they present “a clean bill of health on ALL [emphasis added] tests.”
  • Medically decertifying and grounding any pilot who fails one or more of the aforementioned tests, or who otherwise displays symptoms of possible blood clotting issues or myocarditis; re-testing these pilots at six-week intervals until they return to a medically acceptable condition.
  • Allowing commercial aircraft to be operated only by pilots who can show a clean medical examination undertaken a minimum of five days after each COVID vaccination and booster shot, stating that “the current FAA wait time of two (2) days is insufficient to detect a significant number of blood clotting and myocarditis cases (which are manifesting more than 47 hours post-inoculation).”
  • Immediate investigation, on the part of the FAA, of all commercial air carriers and all insurance companies providing coverage to commercial airlines, regarding the application of federal do-not-fly regulations.
  • Creation, by the FAA, of “a database to track pilot adverse events in a manner similar to VAERS,” stating the likelihood that “medical adverse events post-vaccination in pilot populations are occurring at greater rates than have been tracked or monitored in either civilian or military populations …”

“[A]ny in-house counsel, any CEO, any insurance company number-cruncher, any airline regulator who reads this [letter] is going to be nothing if not clear about the fact that … there is a problem brewing,” Dundas said.

“Right now, they have completely abandoned their duty to both the pilot population and the American flying population by allowing carriers to mandate a non-FDA-approved medical intervention, in violation of their own regulations and guidance,” she added.

Yoder expressed his unease with the current level of safety of air travel as a result of the vaccine mandate for pilots, stating that passengers are taking a risk by flying.

“Every time a passenger flies with a fully vaccinated crew, they are accepting a predictable risk that their pilots have been injected with an inoculation which has known side effects of blood clots, strokes, myocarditis, all of which can lead to cardiac arrest, incapacitation and sudden death,” he said.