Thanks again for your thoughts on this issue, Jerry. I am hoping not 
to belabor this topic, but my DPE specializes in Sport Pilot 
training. The following is a copy of an email exchange between him 
and the FAA Sport Pilot Branch manager with regard to how the 
Ercoupe restriction is removed (I am not sure were the "415B" 
reference comes from):

--------------------------------------------------------------------

From: <[EMAIL PROTECTED]>
To: "Jon Thornburgh" <[EMAIL PROTECTED]>
Cc: <[EMAIL PROTECTED]>; <[EMAIL PROTECTED]>
Sent: Thursday, June 28, 2007 6:01 AM
Subject: Re: Ercoupe Limitation


QUESTION:  Regarding my question about the removal of the "Ercoupe 
415B Without Rudder Pedals" limitation on a private pilot 
certificate, I was  wondering what area of operations and tasks and 
certification procedures must be accomplished to get the limitation 
removed.  I'm suspecting that just a shorten practical test to a DPE 
of those tasks requiring the use of rudders (forward slip and cross 
wind takeoff/landing) would be sufficient to get the limitation 
removed.  As far as required documentation, I suspect a fully 
endorsed and completed FAA Form 8710 application would be 
satisfactory.  However, I don't see any specific reference in the 
Pilot Examiner's Handbook (8710.3D) regarding this procedure, so I 
wanted to check with you to be sure I did it correctly.

ANSWER:  Ref. § 61.45(b)(2); § 61.63(c); and FAA Order 8700.1, Volume
2, page 27-2, paragraph 3.I.(2)(a); and the Private Pilot Airplane 
(Single Engine Land) PTS, FAA-S-8081-14A;  There is no specific 
guidance in FAA Order 8700.1 or in FAA Order 8710.3D that addresses 
the procedures, area of operations, and tasks that must be 
accomplished to get the "Ercoupe 415B Without Rudder Pedals" 
limitation removed.  Therefore, in reviewing the Private Pilot 
Airplane PTS, the applicant would be required to accomplish the 
following procedures, area of operations, and tasks to get 
the "Ercoupe 415B Without Rudder Pedals" limitation removed:

    As per § 61.39(a)(7), must have completed and signed FAA Form 
8710-1 application.

    As per § 61.63(c)—

•       Must have an endorsement in his or her logbook or training 
record from an authorized instructor and that endorsement must 
attest that the applicant has been found competent in the 
aeronautical knowledge areas appropriate to the pilot certificate 
for the aircraft class rating sought.  Those aeronautical knowledge 
areas at the private pilot certification level would be: Safe and 
efficient operation of aircraft; Principles of aerodynamics; and 
Stall awareness, spin entry, spins, and     spin recovery techniques.
•       Must have an endorsement in his or her logbook or training 
record from an authorized instructor, and that endorsement must 
attest that the applicant has been found proficient in the areas of 
operation appropriate to the pilot certificate for the aircraft 
class rating sought.  Those areas of operation at the private pilot 
certification level would be:  Preflight procedures; Airport and 
seaplane base operations; Takeoffs, landings, and go-arounds; 
Performance maneuvers; Ground reference maneuvers; Slow flight and 
stalls; Basic instrument maneuvers; and Emergency operations.
•       Must pass the required practical test that is appropriate to 
the pilot certificate for the aircraft class rating sought; As per 
the Private Pilot Airplane (Single Engine Land) PTS, FAA-S-8081-14A, 
the following areas of operations and tasks must be accomplished on 
the practical test--

      II. Preflight Procedures
         A. Preflight Inspection (ASEL and ASES)
         D. Taxiing (ASEL)
         F. Before Takeoff Check (ASEL and ASES)
      III. Airport and Seaplane Base Operations
         B. Traffic Patterns (ASEL and ASES)
      IV. Takeoffs, Landings, and Go-Arounds
         A. Normal and Crosswind Takeoff and Climb (ASEL and ASES)
         B. Normal and Crosswind Approach and Landing (ASEL and ASES)
         C. Soft-Field Takeoff and Climb (ASEL)
         D. Soft-Field Approach and Landing (ASEL)
         E. Short-Field Takeoff and Maximum Performance Climb (ASEL 
and
         ASES)
         F. Short-Field Approach and Landing (ASEL and ASES)
         L. Go-Around/Rejected Landing (ASEL and ASES)
      V. Performance Maneuver
         Steep Turns (ASEL and ASES).
      VI. Ground Reference Maneuvers
         A. Rectangular Course (ASEL and ASES)
         B. S-Turns (ASEL and ASES)
         C. Turns Around a Point (ASEL and ASES)
      IX. Basic Instrument Maneuvers
         A. Straight-And-Level Flight (ASEL and ASES).
         B. Constant Airspeed Climbs (ASEL and ASES)
         C. Constant Airspeed Descents (ASEL and ASES)
         D. Turns To Headings (ASEL and ASES)
         E. Recovery From Unusual Flight Attitudes (ASEL and ASES)
      X. Emergency Operations.
         A. Emergency Approach and Landing (Simulated) (ASEL and 
ASES).

Larry W. Clymer
Aviation Safety Inspector (Operations)
Manager, Light-Sport Aviation Branch AFS-610
Ph: 405-954-6399


--- In [email protected], "Jerry Eichenberger" 
<[EMAIL PROTECTED]> wrote:
>
> This is NOT the product of any research, only my personal opinion.
> 
> Because sport pilot certificates, unlike private, commercial, ATP 
and CFI
> certificates have no ratings, that's why there is no limitation.
> 
> As previously said, it's because of the way SP works.  It takes a 
period of
> training and a second CFI ride, and filling out and filing an 8110 
to get
> privileges in other classes of aircraft (such as sea plane, powered
> parachute, lighter than air, glider, etc) than the one in which 
the SP
> originally trained and passed his flight test.
> 
> Jerry E.


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