The more I look at this situation I think I am understanding it differently. I think as long as you pass a Falant, or any of the other substitute tests annually or bi-annually for a 1st class med you are good to go. I think the problem is the FAA used to issue a letter of evidence (LOE) or statement of demontrated ability (SODA) based on the tower light gun test or passing a FALANT and this waived you from ever having to pass another color vision test? Is this how it is/was? I can pass a FALANT annually if that is all that is required and it appears that it is according to the FAA link I posted a few threads back. I hope so. I have received two same day med certs based on passing a FALANT with out the AME ever sending anything to the FAA. My doc who is also a Navy Flight Surgeon and designated FAA examiner has told me more than once that the FALANT is the law even on the civilian side. Docs like to use the plates because of cost. A Falant machine costs about $6K compared to a $150.00 book. I have also read on one of those pilot med sites a report about color vision and he said anyone who can pass a plate test will pass a FALANT but not always the other way around. Lends credibility to docs using the more stringent test. It guarantees perfect color vision if you pass it where as the FALANT only apparently guarantees acceptable but possibly flawed color vision.