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The following observations and comments were authored by J. Reid Howell

Advantages of the Proposed Sport Pilot Certificate

To Instructors & dealers over Part 103 training exemption:

1) Provides an Airmen's Certificate to the student, granting the privilege of legally operating the aircraft chosen by the student.

2) Can offer a legal product for sale to the student.

3) More durable, lower maintenance trainer can be operated.

4) Provides for a training aircraft capable of flying in conditions generally considered adverse to UL operations, increasing daily hours available for training, thereby decreasing the frustration to the student resulting from "bad flying conditions".

5) All aircraft are insurable and may be financed - instructor or flight school investment in trainer is protected.

6) Provides a new market base for those who wish to fly legally.

7) Use of certified trainers instills confidence in the new student with little to no increased cost.

8) Training cost for powered fixed wing is less than Recreational or Private Pilot programs conducted in GA aircraft: SP ~$500 to $1500, Recreational Pilot ~ $1800 to $3500, PPSEL ~$3000 to $4500 (note that the cost to obtain a Sport Pilot certificate is similar to participation in ultralight airmen training programs).

9) Eliminates the "lack of perceived safety" by the public associated with the "unlicensed ultralight pilots".

10) Training aircraft may be used for recreational solo and passenger carrying operations, not limited to "For Instructional Use Only".

11) Improved airport accessibility with registered aircraft and certificated pilots.

12) Aircraft may be rented to students and customers, and may be leased to the instructor or flight school.

13) Improves safety by ensuring student completion of the training program since student must obtain a certificate to operate legally (students cannot legally leave instructor behind after just gaining the confidence to land).

14) No costly biennial renewal of "ultralight training exemptions".

15) Eliminates potential for false airmen qualifications via Examiner checks (no "pencil whipping").

16) Flight time applies to other Part 61 ratings.

To airmen over Part 103 operations:

1) Sport Pilot certificate provides for operation of either or both single and two seat aircraft up to 1200# gross takeoff weight with not more than a 39KCAS stalling speed, including operation of those aircraft defined in FAR Part 103 and those aircraft certificated in the Experimental, Primary, and Standard categories.

2) May fly over congested areas in appropriately certificated aircraft.

3) Not limited to 5 gallons of fuel.

4) No longer at the bottom rung of the right of way rules.

5) May operate certificated aircraft.

6) Not limited to only single seat vehicles of less than 254 pounds empty weight.

7) Flight time applies to other Part 61 ratings.

8) Provides a simple means by which to operate legally, those single and two seat aircraft that fall outside the scope of Part 103 (“fat ultralights” = illegal airplanes).

To airmen wishing to operate this category of aircraft over other Part 61 certificates:

1) Training appropriate to the aircraft class and operating privileges sought, by instructors specific to the category. No unnecessary cost or inapplicable training burden.

2) No 3rd class airmen medical certificate required for this category (airmen must proclaim themselves medically fit prior to each operation but may not do so if they have known conditions that would preclude them from obtaining a 3rd class airmen medical certificate).

Disadvantages of the proposed Sport Pilot Certificate

To Sport Pilots over Part 103 operations:

1) Requires flight training as appropriate to the aircraft class and operating privileges sought, and proof of knowledge of FAR Parts 61 & 91 as applicable to the aircraft class and operating privileges sought (is this really a disadvantage?).

2) Aircraft that are not eligible for operation under FAR Part 103 must be registered and certificated as appropriate in the Experimental, Primary, or Standard category (is this really a disadvantage?).

To a Sport Pilot wishing to operate this category of aircraft over other Part 61 certificates:

1) May not operate in class A, B, C, or D airspace without prior ATC authorization.

2) Limited to day VFR operations for sport and recreation.

3) Requires logbook endorsements to gain privileges for some operations.

4) Requires class ratings for some aircraft.

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