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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 its
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 youre flying a part
103 compliant aircraft youre probably
not safe. Yes thats 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 wouldnt
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 yall do what you want
and we will see what we will see next year.
BB
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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.
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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.
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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.
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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.
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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.
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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.
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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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