Mike Marron's Response To The NPRM

I am extremely grateful that the Sport Pilot NPRM presents many wonderful new opportunities such as: basic training leading to a more advanced pilot certifications, industry consensus aircraft certification standards enabling ultralight manufacturers to market ready-to-fly aircraft, and of course the driver's license medical -- the "crown jewel" of the entire proposal.

Unfortunately, the ultralight community has not enthusiastically embraced the Sport Pilot and Light Sport Aircraft proposal and the fact deeply concerns me.

As an EAA Ultralight Flight Instructor (UFI), FAA A&P mechanic, CFII, and single and multi-engine aircraft "single-pilot IFR" Commercial Pilot, I am convinced that certain aspects of the proposal must be changed, or deleted in their entirety, or else the Sport Pilot and Light Sport Aircraft program may actually end up destroying the magnificent sport of ultralight aviation!

I am convinced that the NPRM is much too complex and needs to be greatly simplified in order to be successfully and enthusiastically supported by the ultralight community. The comment period for the Sport Pilot NPRM absolutely must be extended to allow more time to study this enormous document and all of its potentially devastating ramifications to the presently thriving ultralight community.

In my view, below are just a few of the many changes that need to be made to the proposal:

• Delete the "make and model" training and logbook endorsement and require only "category and class" training and endorsements.
• Delete the requirement of "5 hours of pilot-in-command" time in each "make and model" in order to instruct in light-sport aircraft.
• elete the provision that restricts a student sport pilot from operating a light-sport aircraft that exceeds a cruise speed of 87 knots.
• Delete the requirement that a weightshift aircraft instructor must receive spin training.
• Delete the 10,000 foot altitude restriction.
• Delete the requirement that an experimental aircraft equipped with an "engine-driven electrical system" must be equipped with a mode-C transponder in order to operate outside of controlled airspace under the so-called "mode-C veil."
• Delete the stipulation in the NPRM which states that a sport pilot who is an aircraft salesperson may not demonstrate an aircraft in flight to a prospective buyer.
• Amend FAR 61.31 to allow ultralight pilots to receive basic and advanced training that will expand their privileges to those enjoyed by pilots certificated under FAR Part 61.
• Amend FAR 91.191 to allow an ultralight to receive an experimental airworthiness certificate without requiring that the ultralight aircraft be placed in the experimental-exhibition category, and without requiring the aircraft to be built under the "51-percent" (amateur-built) rule.
• Amend FAR 21.191 to allow all experimental two-seat ultralights to be used for compensated flight instruction indefinitely.
• Amend the Sport Pilot NPRM to allow sport pilots to tow hang gliders after training and a logbook endorsement.
• Amend the Sport Pilot NPRM to allow night-flying privileges in a weightshift aircraft after flying a 50 nautical mile cross-country trip at night, not 100 nautical miles at night.
• Amend the Sport Pilot NPRM to allow light-sport aircraft equipped with strobe lights to operate in early morning and late afternoon "twilight" hours.
• Allow the sport pilot to obtain the privilege of operating in Class B, C, or D airspace after S/he receives additional instruction in each type of airspace.
• Allow sport pilots to fly light-sport aircraft equipped with retractable gear, controllable pitch propeller, or two engines after receiving appropriate training and endorsements.
• Provide sport pilot instructors with on-site examiner training courses, at FAA expense, without requiring sport pilot examiner candidates to travel to Oklahoma City.
• Delay the implementation of the Sport Pilot NPRM until after a sufficient number of FAA Safety Inspectors are checked out in ultralights and qualify these safety inspectors as the first FAA Sport Pilot Examiners.

In addition to the changes listed above, before we jump on the Sport Pilot/Light Sport Aircraft bandwagon, we simply need more time to study all applicable Sport Pilot/Light Sport Aircraft FAA written exams, practical test standards, advisory circulars, pilot textbooks, etc.

Realistic costs and procedures used to implement the 16 and 80-hour maintenance schools, Designated Pilot and Airworthiness Examiners, liability insurance, industry consensus standards, etc. must also be carefully analyzed and/or revised before any permanent rules and regulations are adopted.

In the meantime, the present ultralight two-seat training exemption should be made into a SFAR (Special Federal Aviation Regulation) and a new FAA certificate for ultralight pilots should be created, that is issued by an FAA-recognized ultralight organization, and that allows an ultralight pilot to legally carry a passenger.

Sincerely,

Michael J. Marron
Clearwater, FL
727-443-6951
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