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Sport Pilot Comments Page 1

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Wed July 25th, 2007 8:18 pm (PST)

My one-seater and I will pass, thank you. If I had a PPL then yeah sure but there are more than a few things that rub me the wrong way with Sport and FAA. First Sport is killing ultralighting and it isn't right. My wife made the observation the other night that people will not have a way to learn how to fly ultralights after the rules go into effect. Not to go off on a tangent but seems to me FAA has been promoting unsafe flying with Part 103 with its regulation limiting fuel capacity for ultralight flight. They have requirements for GA (general aviation) to always have at least a half hour of fuel reserve for Visual Flight Rules how is it they can tell ultralight pilots they are not allowed to have a safety margin of fuel for our daylight operations. They are promoting unsafe flying practices...if I allowed to fly and I will take it a step further, as an American I have a right to exercise my freedom to go where I want in this country and if 500agl or 4500agl is where I want to be I have the RIGHT to go there. FAA doesn't own the sky and it’s about time we showed them they don't. They have been promoting unsafe flying practices with their suggestions that recreational vehicles should be thus and such. The prevailing joke they have is if you’re flying a part 103 compliant aircraft you’re probably not safe. Yes that’s true. Thanks to their regs.. But for 30yrs not one ultralight manufacture has provided a Part 103 compliant aircraft. Ok, I am getting carried away but for the most part how has? Not since the 277 was discontinued anyway.

But back to the discussion at hand… Sport will allow you to use your newly registered recreational vehicle… Opps I mean monoplane to pass your certification process and win your pilots license. However, time comes for your biannual review process to keep your certification the deal is off; now you will have to fly in an aircraft your completely unfamiliar with have never flown. How in the heck are you going to pass that test? How about when someone stalls one on base to final and kills himself and the inspector/instructor? That sure will put a damper on things I am betting. Seems to me we got another double standard. If I can win my license flying my own, why can't I keep it by repeating proficiency in my single? What are you going to do start taking lessons just so you can pass your proficiency? Does that sound stupid or what? More like a way to get you out of your aircraft it sounds to me. Then there is the part about people who don't know my aircraft inspecting it. No, thanks.

The 2place boys are crying and they are pointing out that I better get inspected. Yeah, misery loves company. They are the ones that got this mess started in the first place.. I got it on pretty good authority ISC was selling BFI certifications like hot cakes. Thousands had them and none of them taught a soul to fly. Gee, do you think FAA would sit back and just let that go on? Don't think so. Damn if the USUA didn't figure that we all deserved to fly 2place if we wanted too. Not that they gave their certifications away, they didn't but they had the wrong attitude. Anybody who didn't have 2 students in 2 years should have had their cert pulled and they wouldn’t do it. Said they didn't have the authority. Thanks guys, you got us in this mess just as much as ASC. With authority comes responsibility, and you didn't exercise it in my opinion.

I guess I probably spouted off more than most wanted to hear, but just the same I been feeling like getting this off my chest for a while. So ya’ll do what you want and we will see what we will see next year.

BB




DÉJÀ VU

Earlier, we had mentioned our involvement in ultralight vehicle manufacturing and the new FAA regulations concerning light aircraft. The sport of ultralighting is a grassroots American creation. A flatland hang glider enthusiast named John Moody tired of long trips to launching sites in the hills, only to find wind conditions had adversely changed. He fixed a small engine to his glider and he and the ultralight sport took off.

Hang glider pilots, whose unregulated craft were either home designed or kit built, were a small cadre, well schooled in the art of minimum vehicle flying. However, motor-power opened up the sport and as new kits or self designs incorporating engines offered a previously unavailable low-cost opportunity to see America from the sky, participant numbers exploded. One kit manufacturer sold over two thousand craft in one year, many more than any of the conventional single engine aircraft manufacturers. Recognizing the change in this popular sport, the FAA produced a controlling regulation that limited this layperson activity to single occupant vehicles, weighing no more than 254 lbs., and having a level speed of 63 miles mph.

Initially, no regulatory consideration was given to the training of this new class of pilots. Of course one could learn to fly ultralights with an FAA certified instructor in a general aviation aircraft, but cost aside, that would parallel taking an auto driving course to understand how to operate on a motorcycle. For many new ultralight pilots, their first (and possibly last) escape from earth was as a self-trained solo pilot.

At the prodding of ultralight organizations, like the US Ultralight Association (morphed from an earlier hang glider association), the FAA allowed a waver to its initial FAR103 ultralight regulations. This provided for expanding ultralight training activities into two place aircraft, when these were used for instructional purposes, and for organizations like the USUA, USHGA, ASC, and later EAA to develop and supervise FAA acceptable training and registration programs for ultralight pilots, instructors and aircraft. These very successful programs produced thousands of trained and tested ultralight pilots and ultralight instructors.




THE INFANT GROWS OUT OF ITS CLOTHES

As the nature of ultralighting expanded, the original F103 ultralight regulation started to pinch. Items like the five-gallon fuel limit were not initially a burden to the liberated hang glider pilot who had previously expected traveling no more flying distance than to the bottom of the hill. Nor were wheels, floats, brakes, or a windshield considered an essential part of the early foot launched hang glider converted craft. However designers, liberated from the cost burden and extended delays of standard aircraft certification, quickly added enhancements like wheels, brakes, windshields, doors, multiple engines, floats, amphibious hulls, skis, partially metal covered or composite (rather than all fabric skinned) wings, fuselage, and control surfaces, electric start fuel injected engines, electric trim, pitch adjustable propellers, electronic instruments, GPS mapping, and rocket deployed safety parachutes, to name a few. Ultralight vehicles flew coast to coast, crossed the Great Lakes, and circumnavigated the United States. While no accurate figures are available, estimates run to the tens of thousands of currently active Ultralighters. Ultralighting was very available, very affordable, educational, inspirational, enjoyable, and a self created American activity. Nowhere else in the world had the free spirit of aviation creativity been so released.




WEAR WHAT YOU GOT

The original limits placed on single place ultralight vehicles by the FAA were never expanded. Design enhancements bumped into the 254 lb. limit, so if you wanted to replace the overtaxed single cylinder engine in your design with a two-piston version, maybe you had to forget brakes. Taking off with five gallons of fuel in most aviation circles would be like taking off out of gas. Particularly, when where you were jaunting to, like an unimproved farm field, didn't have fuel service. Flyers that added accouterments in violation of the ultralight weight stipulations, sparked the term "fat ultralight", for what are actually considered by regulation to be illegally operated aircraft, a criminal offense. Most present day ultralights, if not starting out above the 254 lb weight limit, moved into that class as the user added items to improve the safety, utility, performance, or enjoyment of the activity. Keep in mind that dead weight is the enemy of aircraft performance. Ultralight pilots carry enough fuel to get there and back with some reserve. Nobody would put a 30-gallon tank in an ultralight vehicle if the regulations allowed such. Nobody would put in a padded armchair for creature comfort. Unnecessary weight additions are a no-no.




MAYBE RELIEF IS POSSIBLE

In the decades since US Ultralighting invented itself and since the FAA imposed its initial limitations, ultralight organizations like the USUA have petitioned the FAA to make changes in items like the fuel allowance, speed, and weight of the ultralight vehicles. These requests first made in 1988 reflect the evolution of the industry and improvements in vehicle performance, durability, and safety. The FAA has continually denied granting these requests. The USUA also petitioned the FAA to allow the use of two-place vehicles for other than training. Four eyes could be better that two, two hearts better than one, particularly in the "no medical exam" ultralight environment. In response to this continuing pressure, in 1993 the FAA formed an Aviation Rule Making Advisory Committee (ARAC) to review the FAA part 103 defining ultralight activities. Representatives of the FAA, ultralight associations, general aviation, and Transport of Canada worked in the slow moving bureaucratic environment seriously for several years to formulate a recommendation to allow the development of a regulatory structure to accommodate the reality of vast numbers of "fat ultralights", and to expand the two place instructional environment. In spite of the many-hour and multi-year effort, these recommendations never made it through the rule-making phase.




IF AT FIRST YOU DON'T SUCCEED, EXPAND THE GROUP

Giving up on the ARAC attempt, the next idea was to approach a recognized standards group and charge them with developing regulations for the manufacture and operation of non-FAR103 compliant ultralight vehicles and operators. The ASTM organization became the one to organize and implement this task.

I attended the first organizational meeting for this activity at the ASTM headquarters in Philadelphia. The invited group was made up of ultralight users, manufacturers, designers, ultralight organizations, and others associated with user and regulatory areas of aircraft activities. In this initial meeting, the members searched for a basis to form the envisioned structure. Some participants suggested adopting portions of existing FAA regulations for light aircraft. Others thought that foreign regulations for European or Canadian "Microlight" designs would be appropriate. Experts on engines, wings, hardware, safety, and the like wanted to assure that these particular areas of interest got attention in any upcoming regulations. One significant manufacturer opinioned that since the current two place ultralights and kit built aircraft were doing fine and experience no rash of in-flight failures or other operational problems, any burdensome detailed manufacturing and testing regulations would be addressing a situation that didn't exist. Others were reluctant to forfeit their chance to build the regulations.

It was decided that because of the significant differences in fixed wing, powered parachute, and lighter than air vehicles, multiple working groups would be formed to develop their separate manufacturing and testing regulations for these individual areas. Nothing was said yet about any new training program for future users or retraining of present users.




IT'S JUST A JOB

During the ASTM organizational session, I had the opportunity to lunch with two monitoring representatives of the ASTM and FAA. I pressed the point that there were no apparent design, quality, safety, or training problems with the current products being offered by ultralight manufacturers. That current producers were shallow pocket operations. That uncertified-design amateur-built non-FAA-inspected planes and pilots were not falling from the sky. That there was no need to burden producers and users with a new set of resource stealing regulatory documentation, procedures, and testing. They acknowledged there was no problems with the products being currently offered, but said detailed control had to be applied to existing and new products, so that new producers could be qualified on a common basis. Maybe they were already thinking of foreign products. Also, and probably more significantly, they said they worked for regulatory agencies and if the result was to be accepted by their organizations, it would have to read and be organized like a conventional regulatory document. And so it would be. The ASTM Committee soon went on a limited countrywide tour, accepting inputs from a variety of interested parties. The Internet also provided opportunity for suggestions, examination of progress, and ASTM member voting.

Somewhere along the line, the direction, at least in the fixed wing area, shifted from redefining a new role for the two-place ultralight, to defining a new vehicle for a new pilot class. It might be concluded overregulation, hassle, expense, cost of product and other factors had over the years produced the continually declining private pilot base. An attempt by the FAA to reverse this trend with the offering of a simplified Recreational Pilot License failed, because of such discouraging limitations as being allowed to fly no more that 50 miles from your base airport. Ultralight pilots, without any medical testing, could range to the limits of the country.




WHATS GOOD FOR THE BIG BOYS WILL BE FINE FOR YOU

The Experimental Aircraft Association (which has a better relationship with the FAA than the US Ultralight Association), with its core of certified pilots flying real airplanes, took an increasing part in the ASTM activity. An EAA vice president is chairman of the ASTM International Light Sport Aircraft Committee. The ASTM agenda moved from addressing two-place ultralight concerns, to the possibility of halting the continuing shrink in the number of licensed pilots. As the pilot population aged, the more limited finances and medical problems of this group were taking its toll. Heavy control and regulation of training and flying discourage potential new participants. With single-engine general-aviation new-aircraft prices currently starting out just below $200K, the opportunity to define a simplified airplane class and new pilot licensing requirements became the captain steering the course. When the smoke cleared, any possible recognition of the viability of "fat ultralights" as such was eliminated, the very successful training program for ultralight pilots by uncertified instructors was dismembered, and a specification for a class of aircraft not even being manufactured in the US was offered as the new "Light Sport" direction.


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