Pietenpol-List: NPRM comments part III
Posted: Mon May 06, 2002 8:47 pm
Original Posted By: "Christian Bobka"
Just about the most fun one can have flying is in a seaplane. Seaplanefloat gear weighes a lot when compared to the typical wheeled landing gear.Fortunately, the floats tend to "fly" their own weight due to theiraerodynamic qualities. This has consistently been shown over and over bythe FAA when it certifies aircraft for use on floats by always allowing ahigher gross weight for the float version of an aircraft even though thebasic structure is unmodified. Unfortunately, the NPRM ignores this. Infact, of all the aircraft certified for floats, it only allows the Piper J3Cand the early and rare Taylorcraft A model to be flown by a sport pilot.One of the best certified aircraft for a sport pilot to fly is an Aeronca50-C Chief, one of which I own. The aircraft is certified on wheels with agross wieght of 1150 pounds. On floats, the aircraft, now designated anAeronca S-50-C Chief, is certified with a gross weight of 1252 pounds. Tooheavy under the proposed rule, yet THE most basic of seaplanes, with only a50 horsepower engine (as compared to the J3C's 65 horsepower engine). Thereis no reason for the seaplane version of this aircraft to be ineligible fora sport pilot to fly. It is the very essence of the proposed rule, but yetthe rule denies its use by a sport pilot. I recommend that the wheelequipped gross weight of an aircraft be the criterion for the judgingwhether an aircraft qualifies for use by a sport pilot. If the aircraft hasthe wheels removed and floats installed, then the aircraft still qualifiesfor a sport pilot to operate, even thought it may weigh more.The NPRM discusses the requirement that either a valid driver's license or acurrent FAA medical be required to have sport pilot priveleges (exceptinggliders and balloons). Your own evidence on page 5384, columns 2 and 3 inthe NPRM states that .13% of glider and lighter-than-air accidents and .21%of all other General Aviation accidents involved medical causal factors.You are taking the GA data and making a bold presumption that the worse .21%rate will apply to all sport and recreational flying. I dispute this. Isee no reason why self-certification cannot be an option for all sport pilotoperations, even if on a wait and see basis to observe if the sport pilotdata parallels the up until now pure recreational flying: thelighter-than-air and glider operations which currently enjoyself-certification with the low .13% rate. If data collected on futuresport and recreational flying operations turns out to show that a morerigorous medical certification is necessary, then so be it. I recommendthat medical self-certification for all sport pilot operations be allowedunder the new rule.________________________________________________________________________________
Just about the most fun one can have flying is in a seaplane. Seaplanefloat gear weighes a lot when compared to the typical wheeled landing gear.Fortunately, the floats tend to "fly" their own weight due to theiraerodynamic qualities. This has consistently been shown over and over bythe FAA when it certifies aircraft for use on floats by always allowing ahigher gross weight for the float version of an aircraft even though thebasic structure is unmodified. Unfortunately, the NPRM ignores this. Infact, of all the aircraft certified for floats, it only allows the Piper J3Cand the early and rare Taylorcraft A model to be flown by a sport pilot.One of the best certified aircraft for a sport pilot to fly is an Aeronca50-C Chief, one of which I own. The aircraft is certified on wheels with agross wieght of 1150 pounds. On floats, the aircraft, now designated anAeronca S-50-C Chief, is certified with a gross weight of 1252 pounds. Tooheavy under the proposed rule, yet THE most basic of seaplanes, with only a50 horsepower engine (as compared to the J3C's 65 horsepower engine). Thereis no reason for the seaplane version of this aircraft to be ineligible fora sport pilot to fly. It is the very essence of the proposed rule, but yetthe rule denies its use by a sport pilot. I recommend that the wheelequipped gross weight of an aircraft be the criterion for the judgingwhether an aircraft qualifies for use by a sport pilot. If the aircraft hasthe wheels removed and floats installed, then the aircraft still qualifiesfor a sport pilot to operate, even thought it may weigh more.The NPRM discusses the requirement that either a valid driver's license or acurrent FAA medical be required to have sport pilot priveleges (exceptinggliders and balloons). Your own evidence on page 5384, columns 2 and 3 inthe NPRM states that .13% of glider and lighter-than-air accidents and .21%of all other General Aviation accidents involved medical causal factors.You are taking the GA data and making a bold presumption that the worse .21%rate will apply to all sport and recreational flying. I dispute this. Isee no reason why self-certification cannot be an option for all sport pilotoperations, even if on a wait and see basis to observe if the sport pilotdata parallels the up until now pure recreational flying: thelighter-than-air and glider operations which currently enjoyself-certification with the low .13% rate. If data collected on futuresport and recreational flying operations turns out to show that a morerigorous medical certification is necessary, then so be it. I recommendthat medical self-certification for all sport pilot operations be allowedunder the new rule.________________________________________________________________________________