Pietenpol-List: NPRM comments part I

[matronics]

Original Posted By: "Christian Bobka"
comments to docket no. FAA-2001-11133Dear Sir:I am a supporter of the Light-Sport Aircraft NPRM. However, I feel changesare necessary to make the proposed rule viable. The discussion on page 5373column 2 of the NPRM addresses the fact that the recreational pilotcertificate and the primary aircraft category failed to address the needs ofsport and recreational aviation "for various reasons". I wish the "variousreasons" had been addressed in more detail as they would indicate what thisLight-Sport Aircraft NPRM (referred to as "the NPRM" from this point on)would need to contain in order for the proposed rule to be successful. Icontend that, simply put, a sport or recreational pilot should be able toget in, on, under, or over his aircraft, just as he does his small boat orhis sports car and go for a spin: take your friend, minimal rules,reasonable performance of the vehicles, lots of common sense and courtesy,low cost, go get a hamburger, with minimum paperwork. Freedom.The NPRM strongly addresses the Ultralight type of aircraft while greatlyoverlooking the more common type of certified aircraft that many sportpilots would like to fly. I have reviewed the list of currentlycertificated aircraft that would qualify for a sport pilot to operate and Ifind the list is rather sparse. Many of the most obvious aircraft, thosethat have trained generations of pilots or are merely updates of earlierversions of lower horsepower aircraft from an era two generations ago whenthe typical pilot weighed a scant 140 lbs and radios and an arm savingelectric engine starter where more the exception than the rule, are missingfrom the list. Most are missing because they are too heavy under theproposed rule. An example is the Aeronca Champ. The Champ Model 7AC wouldqualify for flight by a sport pilot. But if you take two typical 200 pound18 year old cornfed midwestern males and put them in this aircraft, it wouldbe too heavy to fly. However, put them in the virtually identical buthigher horsepower, arm saving electric engine starter equipped and slightlyfaster Champ Model 7EC and they can go out and have a good time, with muchgreater safety. Unfortunately, the Champ Model 7EC is too heavy under theproposed rule and would not be able to be flown by a sport pilot. Thisforces either disinterest in the sport pilot certificate, dooming it tofailure, or operation of an aircraft outside of its envelope and ultimatelyresulting in a dangerous situation. Page 5373, column 2 of the NPRM,recognizes that this safety related weight growth issue exists for part 103aircraft and is a main reason for this NPRM. Why can't the FAA recognizethat this issue relates to larger aircraft with standard certification aswell? Additional aircraft that I am shocked to see that do not qualify arethe Cessna 140, 150, and 152, the Ercoupe, the later Luscombes, and mostseaplanes. In additon, some aircraft that were certified for 3 occupants ofthe size of people that existed 60 years ago, such as the Piper J5, are nolonger realistically 3 occupant aircraft. They should be allowed ifoccuppied only by two people. Simply put, for the proposed rule to succeed,I recommend the definition in Section 1.1 of the FARs of a light-sportaircraft should be extended to but limited to a maximum weight of 1625pounds on wheeled landing gear with an allowance for the weight of seaplanegear (more on this below). This is more realistic.________________________________________________________________________________

[matronics]

Original Posted By: owner-pietenpol-list-server(at)matronics.com
Gene,did you just sit back and do nothing?Chris-----Original Message-----