Comments to FAA-2001-11133 -- 4/27/02
I am a longtime pilot of light aircraft such as are covered by the proposal. I have flown and written detailed pilot reports on more of these aircraft than any other journalist. I am also a FAA Commercial pilot with Instrument, Multi-engine, and CFI ratings. For 35 years I have been flying numerous general aviation aircraft models and I have owned two Cessnas.
I support the new rule in that it will enfranchise a group of aircraft and pilots that now must turn to other alternatives. I believe it may draw in more new pilots and should make the entire segment safer through uniform standards and professionally-built aircraft.
However, I believe the rule -- despite its "umbrella" approach -- does not accurately serve a large segment of current aircraft. These aircraft include powered parachutes, trikes, and the sizable percentage of so-called ultralight aircraft that tend to fly more slowly (than the proposed 87 & 115 knot ranges). Most of these aircraft also have a gross weight well under the 1,232 pound limit in the proposal. They comprise the majority of 3ultralight2 aircraft.
Lumping together such disparate aircraft serves no useful purpose except to integrate all pilots under uniform rules.
The safety record of the existing light aircraft community has been quite good; the number of accidents and fatalities is not significantly higher than more regulated forms of flying. Instructors in this realm of flight are specialists that know the characteristics of their machines much better than conventional aircraft CFIs. I fly both (and am a CFI) and the two machines are NOT the same.
Therefore, I advise and support the construction of two tiers of aircraft and pilots. One should follow the current proposal with its allowance for faster, heavier aircraft.
The other should make use of existing methods and procedures created by organizations like USUA, EAA, and ASC. Making participation mandatory in these programs -- or other programs devised by other groups but along similar lines -- will preserve the goals of the current proposal without subjecting those pilots and aircraft to more onerous regulation.
The lower tier of aircraft and pilots should continue to follow the operational rules of Part 103 which should ensure that these less regulated pilots stay generally clear of other airspace. Using the same medical requirements as listed in the proposal also makes sense.
Taking the two tiered approach is not only more elegant but serves the spirit of the Sport Pilot proposal while allowing for the greatest freedom of pilots who operate largely outside of other airspace. It will preserve and environment where designers can create new aircraft more easily. It will cause less dislocation and cost for pilots and aircraft presently operating under the exemption to Part 103, yet it provides a way for those pilots to move up to the higher tier of Sport Pilot when and if they elect to do so.
Please consider the two tiered approach and go forward with the rest of Sport Pilot as described in the NPRM.
Sincerely,
Dan Johnson,
Aviation Writer
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