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Below you will find my comments to the feds on the "Sport Pilot Program". I am sure others of you have other views and comments and I would ask that you please take the time to make them to the DOT so that your thoughts will be counted. Let me first say that the Sport Pilot Proposal is a major step in the right direction to promote safe additional aviation activity and in all cases it should go forward with only small clarifications. As with all written instruments there are some small areas that I will bring to your attention that I would ask that you kindly consider some clarifications, which I will propose to remove some of the ambiguity in the current proposal. In section VI. Section by Section Analysis of the Proposal 1.1 Definition of a "Light Sport Aircraft" The definition criteria by themselves are fine, many will want higher everything and in time we may find areas that may need some small adjustment. The problem, as I see it, is that the Proposal has a good clear definition for a "Light Sport Aircraft" but it does not address how existing aircraft, and for that mater, future aircraft will be determined to be compliant with the definition. Will the pilot's word be acceptable or will we need certification by the manufacture? If so what about homebuilts and aircraft with out a proper manufacture currently, such as the Ercoupe. In the case of the Ercoupe, Univair holds the Type Certificate but they may not have a manufacture's engineering expertise or capability to determine by appropriate flight test and documentation the compliance of a given aircraft with the "Light Sport Aircraft" rules or definition. They may also have no interest in the work required as they may see no practical way to recover the cost of such testing and certification of compliance to the rules established in the "Light Sport Aircraft" final rules. I would suggest that as you have found the sign off by rated personal as appropriate for the stipulation of a "Sport Pilot's" skills and the granting of approval to expanded authority to use his privileges then a similar program may work just as well by permitting individuals with an FAA Airframe and Powerplant Mechanics certificate to make such a determination and to make a simple entry into the aircraft's log book stipulating that the aircraft has been found to be compliant with the "Light Sport Aircraft" requirements. These individuals are highly trained people who have demonstrated their ability to the FAA and who have a great deal to lose if they are found to have stretched the rules as they would be open to the loss of their lively hood if found to be seriously at fault. This solution would add little or no cost and would use existing infrastructure until large numbers of new production aircraft are available to replace the existing aircraft. It is very important to the General Aviation industry to have this fine new program get off to a strong start and I am sure that this clarification will greatly improve the probability that the "Sport Pilot Program" will be well received by the current General Aviation industry and it will permit people to get involved several years earlier as it will take some time for new aircraft built to fit these new rules to become available in meaningful quantities. In the same area of definitions it would be appropriate to clarify how the 1,232 pounds maximum takeoff weight is to be applied. We all know what it means, simply that a Sport Pilot may not takeoff in an aircraft that starts the takeoff at a weight above 1,232 pounds and this is fine and simple. Where we have a need for a clarification is in how this limit will be interpreted. Is it the "Maximum Gross Takeoff Weight" from the Type Data Certificate or is it a simple limit to be determined at that takeoff? To use an example, in the case of the Ercoupe 415-C it has a certificated "Maximum Gross Takeoff Weight" of 1,260 pounds as found in the Type Data Certificate. However it can easily be limited by the pilot to the "Light Sport Aircraft" limit of 1,232 pounds with little loss in utility. We have good president for this in many certificated aircraft they are certificated in two categories at the same time at a lower maximum gross weight and some times a restricted Center of Gravity limit they are qualified in the Utility Category and at a higher gross weight and with an expanded C.G. envelope they are certificated in the Normal category. It is simply up to the pilot to know the limitation and to operate the aircraft within the limits if they wish to use the Utility Category capability. In the same way if we leave the "Light Sport Aircraft" maximum takeoff weight as a simple limitation to be observed by the pilot at the time of any takeoff then we have achieved the desired result and we may make the process of including many existing aircraft in the current pool of aircraft that may be used by Sport Pilots until the industry can supply new aircraft that will be more attractive to pilots. These aircraft are currently certificated and maintained to the higher standard of Normal Category aircraft assuring safe aircraft in the beginning and they are currently available so that the program can get rolling from day one instead of having to wait for industry to develop and produce in quantity new compliant aircraft. With this simple clarification many current aircraft will be usable now, yes some will be effectively one seat aircraft with the 1,232 pound limit but as they are all Normal Category aircraft they can be used with currently certificate flight instructors at their higher maximum weight during training just as they would be today for dual instruction and when restricted to the "Light Sport Aircraft" maximum weight limit they may well be functionally single seat aircraft. A good example of this would be the Cessna 150/152 which is well proved to be a safe and effective training aircraft and it would be just fine with one person in it for operation by a properly trained "Sport Pilot". As background information, I am a Commercial Pilot and an Airframe and Powerplant mechanic and look forward to the positive effects of this proposal. Thank you for your consideration of the above. Best regards, Vern Hendershott ==^================================================================ This email was sent to: [EMAIL PROTECTED] EASY UNSUBSCRIBE click here: http://topica.com/u/?aVxiLm.aVzvvT Or send an email to: [EMAIL PROTECTED] T O P I C A -- Register now to manage your mail! http://www.topica.com/partner/tag02/register ==^================================================================
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