Ps were a group of pilots who petitioned D for exemptions to the “Age Sixty Rule.” Since 1958, D has held fast to enforcing the Rule against commercial pilots. Under the Federal Aviation Act D is charged with promoting safety in the skies by prescribing minimum standards in such areas as aircraft design, aircraft inspection, and pilot qualifications. D has been delegated the responsibility to carry out the Act so as to reduce or eliminate the possibility or recurrence of accidents in air transportation. D defends its Rule to no longer allow 60-year-old pilots to fly commercial airplanes in that available medical studies show that sudden incapacitation due to heart attacks or strokes becomes more frequent as men approach age sixty and present medical knowledge is such that it is impossible to predict with accuracy those individuals most likely to suffer attacks. D does have the power to grant exemptions to the Rule. D even stated publicly that exemptions were to be summarily denied unless a viable means to address the relevant health issues were presented. Ps applied for exemptions. Ps claiming that there was now a comprehensive and realistic protocol to evaluate the medical/neuropsychological status of pilots seeking to continue their services in airline operations after the age of sixty. D listened and then held that Ps’ protocol did not meet D’s standards. Ps applied for review. D solicited comments and D once again denied Ps request.