GODBOLD, Senior Circuit Judge:
Pinney appeals from the National Transportation Safety Board's (NTSB) order affirming the Federal Aviation Administration's (FAA) revocation of his airman certificates. This court has jurisdiction pursuant to 49 U.S.C.App. § 1486(a)(1988). The FAA revoked Pinney's certificates pursuant to 14 C.F.R. § 61.15,
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