If you saw Marion's speach on NBC the night before last you know raising the age is a done deal, it's just when and the fine print surrounding it as in grandfathering and implementation.
Be that as it may the effort now has to be mitigating the effects on as many of us as we can, which is the tone I heard out of Pratter's speach. FWIW my advice on your NPRM comments need to focus on grandfathering, grandfathering, grandfathering. It wouldn't hurt to focus on on delayed implementation too, just to F*&% the numbnuts who brought this about; especially the nonmember numbnuts. Trying to make a safety argument against it isn't going to cut it, because the evidence to substantiate what we all know hasn't been developed yet. My letters to my congresspeople said just supoena the training records of 60 year olds moving to the back seat and compare to newhires. End of argument, but they don't listen to me and they won't listen to you.
Now don't flame me I know a bunch of you 60 and up guys operate just fine, even better than some sub 60 guys, but you're not the norm.